p.1 

OAR Box 1413 

Prepped by Ollie Stewart 

Document Number: 

29) 11-1-29 

Docket Number: 

A-94-52 

Printed 7/9/2008 3:11:21 PM Sheet 29 of 114 
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T EXAS AIR CONTROL BOAR 

12124 PARK 33 CIRCLE. U'STl.V TEXAS ~«"5.'. 512"9ns-l»Ki D 

DICKVVHITTISCTON.rE 

CHMRMAX 

BOBC BAILED 

VICECHAIRMAS 

fTE\'E\ \ fl-AVV. PE 

EXECUTIXT DIRECTOR 

ICHN L 31 -:\ j&& 

\ 5 -i.SNEi.!. 's •-: : M- •*- *n 

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'• \A\_ \ .. •• •-

November 5, 1991 

Mr. Thomas D. Walczyk 

Plant Engineer 

COMPOSITE TECHNOLOGY 

1005 Blue Mound Road 

Fort Worth, Texas 76131 

Re: Permit No. 19424 

Fiberglass Production 

Facility 

Blue Mound, Tarrant County 

Account ID No. TA-0573-N 

Dear Mr. Walczyk: 

A permit for your new facility is enclosed. We appreciate your 

cooperation in sending us the information necessary to evaluata 

your proposal. 

The permit contains several general and special provisions that* 

define the level of operation and allowable emissions. In 

addition, the construction and operation of the facilities must 

be as represented in the application. 

Thank you for your cooperation and interest in air pollution 

control. 

Sincerely, 

\^JLMJHJrUA^JtfaJ JbatJZf 

Lawrence E. Pewitt, P.E. 

Director , Permits Program 

Enclosures 

cc: Mr. Melvin Lewis, Regional Director, Fort Worth 

Mr. Gene Rattan, Supervisor, Environmental Quality 

Section, Public Health Department, Fort Worth 

The Honorable A. R. Perkins, Mayor, City of Blue Mound 

Texans ivorkingfor clean air 
P.3 

GENERAL PROVISIONS 

19424 

1. Equivalency of Methods - It shall be the responsibility of the 

holder of this permit to demonstrate or otherwise justify the 

equivalency of emission control methods, sampling or other 

emission testing methods and monitoring methods proposed as 

alternatives to methods indicated in the provisions of this 

permit. Alternative methods shall be applied for in writing 

and shall be reviewed and approved by the Executive Director 

prior to their use in fulfilling any requirements of this 

permit. 

2. Sampling Requirements - If sampling of stacks or process vents 

is required, the holder of this permit must contact the 

Quality Assurance Division of the Texas Air Control Board 

(TACB) prior to sampling to obtain the proper data forms and 

procedures. The holder of this permit is also responsible for 

providing sampling facilities and conducting the sampling 

operations at his own expense. 

3. Appeal - This permit may be appealed pursuant to Rule 103.81 

of the Procedural Rules of the TACB and Section 382.032 of the 

Texas Clean Air Act. Failure to take such appeal constitutes 

acceptance by the applicant of all terms of the permit. 

4. Construction Progress - Start of construction, construction 

interruptions exceeding 45 days and completion of construction 

shall be reported to the appropriate regional office of the 

TACB not later than 10 working days after occurrence of the 

event. » 

5. Recordkeeping - Information and data concerning production, 

operating hours, sampling and monitoring data, if applicable, 

fuel type and fuel sulfur content, if applicable, shall be 

maintained in a file at the plant site and made available at 

the request of personnel from the TACB or any local air 

pollution control program having jurisdiction. The file shall 

be retained for at least two years following the date that the 

information or data is obtained. 

6. Maintenance of Emission Control - The facilities covered by 

this permit shall not be operated unless all air pollution 

emission capture equipment and abatement equipment are 

maintained in good working order and operating properly during 

normal facility operations. 

2_ 
P.4 

SPECIAL PROVISIONS 

19424 

EMI88I0M 8TANDARD8, FUEL SPECIFICATIONS AMD WORK PRACTICE* 

1. This permit covers only those sources of emissions listed in 

the attached table entitled "Emission Sources - Maximum 

Allowable Emission Rates," and those sources are limited to 

the emission limits and other conditions specified in that 

attached table. The annual rates are based on any consecutive 

12-month period. 

2. The temperature in the retention chamber of the thermal 

oxidizer shall be continuously monitored and recorded to 

ensure it is maintained at 1400*F or greater. 

3. In-stack concentration of volatile organic compounds (VOC) 

will be continuously measured as total hydrocarbon (THC) and 

reported as styrene. The THC measured in the thermal oxidizer 

stack shall not exceed 50 parts per million by volume (ppmv), 

averaged over a one-hour period. Any upset conditions that 

cause the 50 ppmv hourly average to be exceeded shall be 

reported to the TACB as required by TACB General Rules and 

shall be reviewed by the TACB on a case-by-case basis to 

determine whether the exceedance was beyond the control of the 

company. 

4. VOC emissions from the fiberglass production processes in the 

facility shall be captured at the source and routed to a 

thermal oxidizer capable of achieving at least 95 percent 

destruction efficiency. If the thermal oxidizer fails to meet 

the requirements of Special Provision No. 3 (above), all VOC 

producing fiberglass production will be terminated, * as 

follows: The mixing and Hetrolac coating operations shall be 

immediately shut down. No new liquid resins shall be added 

to the panel line or pultrusion line and the line shall be run 

only until the existing liquid resins are bound into the 

panel. In the event one portion of the collection systems 

malfunctions and is unable to collect and route the emissions 

to the oxidizer, the VOC producing processes associated with 

that portion of the collection system will be terminated until 

the VOCs can be properly routed to the thermal oxidizer. 

5. Supplemental fuel used in the thermal oxidizer shall be 

limited to pipeline quality sweet natural gas. 

6. Opacity of emissions from the thermal oxidizer stack must not 

exceed 5 percent averaged over a 6-minute period, except for 

those periods described in TACB Rule 111.111(a)(1)(E). 

3 
P.5 

SPECIAL PROVISIONS 

19424 

Page 2 

7. Thermal oxidizer operating instructions shall be established 

and must be posted on or near the thermal oxidizer. The 

thermal oxidizer shall be operated in accordance with these 

instructions. Thermal oxidizer operators must be trained 

prior to operating the thermal oxidizer and records of initial 

and recurring training must be kept. 

8. During all VOC emitting operations, all building doors where 

these operations take place will remain closed except for the 

ingress/egress of personnel, raw materials and finished 

products. A negative air flow indicating system shall be 

installed to indicate the direction of airflow to ensure air 

is flowing from the building into the enclosures for the 

mixing room, panel line and Hetrolac booths during all VOC 

producing operations. 

9. All VOC containing compounds outside of the enclosed areas 

under negative pressure shall be kept in closed containers at 

all times. 

10. All handling and cleanup of spills shall be done in such a 

way as to minimize any possible fugitive emissions. 

11. All cutting and grinding operations shall be controlled by a 

dust collection system. Particulates trapped in the dust 

collection systems/baghouses shall be bagged and disposed of 

in a manner that will prevent visible emissions. 

12. All exhaust filters in the spray booths will be inspected* on 

a regular schedule and replaced whenever a hole is detected 

or whenever the pressure drop, as measured by a manometer-or 

other suitable device, increases to a maximum of 0.5 inches 

of water. 

Fabric bags in the baghouse will be inspected weekly for holes 

and moisture/oil buildup and will be replaced as necessary. 

Pressure drops across the fabric bags shall be measured by a 

magnehelic gauge or other suitable device such that the 

reverse jet pulse cleaning system can be monitored for proper 

operation. If the pressure drop increases to a maximum of 3 

inches of water, the cleaning system shall be inspected and 

repaired. 

13. Permittee shall provide public notice pursuant to Section 

116.10 for all changes in operations, modifications and 

expansions for which a permit is required under Section 116.1 

or a permit amendment is required under Section 116.5 if the 

amendment (a) makes changes to the permit "maximum allowable 

emission rates" tables by increasing the maximum permit 

allowable emissions rate by any amount or adding to the table 

any nev air contaminant, or (b) changes any of the special 

permit conditions. Copies of all amendment requests to the 

TACB vill be mailed directly to the Mayor of Blue Mound. 
P.6 

r 

SPECIAL PROVISIONS 

19424 

Page 3 

14. The holder of this permit shall physically identify and mark 

in a conspicuous location al l equipment that has the potential 

of emitting air contaminants as follows: 

A. The facility identification numbers (FIN) as submitted 

to the Emissions Inventory Section of the TACB. 

B. The emission point numbers as listed on the Maximum 

Allowable Emission Rates table. 

8TACK SAMPLING 

15. Upon request of the TACB, the holder of this permit shall 

perform stack sampling and other testing as required t o 

establish the actual pattern and quantities of ai r 

contaminants being emitted into the atmosphere: from the 

facility . The testing required by this Special Provision for 

VOC shall be used to determine compliance with the pound per 

hour limit of the Maximum Allowable Emission Rates Table, THC 

concentration in the stack limitation in Special Provision No. 

3 and the VOC destruction efficiency specified in Special 

Provision No. 4. Sampling must be conducted in accordance 

with appropriate procedures of the TACB Samplinq Procedures 

Manual and in accordance vith EPA Reference Method 18 for VOC. 

The holder of this permit is responsible for providing 

sampling and testing facilitie s and conducting the sampling 

and testing operation at his expense. 

A. The TACB regional offic e in Fort Worth shall be contacted 

as soon as testing is scheduled but not less than 45 days 

prior to sampling to schedule a pretest meeting. 

The notice shall include: 

1. Date for pretest meeting. 

2. Date sampling will occur. 

3. ~ Name of firm conducting sampling. 

4. Type of sampling equipment to be used. 

5. Method or procedure to be used in sampling. 

The purpose of the pretest meeting is to review the 

necessary sampling and testing procedures, to provide 

the proper data forms for recording pertinent data and 

t o review the format procedures for submitting the test 

reports. 

A written proposed description of any deviation from 

sampling procedures specified in permit provisions or 

TACB or U.S. Environmental Protection Agency (EPA) 

sampling procedures shall be made available to the TACB 

prior to the pretest meeting. The Regional Director or 

the Director of the Quality Assurance Division shall 

approve or disapprove of any deviation from specified 

sampling procedures. 

• • ' - 5 
P.7 

SPECIAL PROVISIONS 

19424 

Page 4 

Requests to waive testing for any pollutant specified in 

B of this provision shall be submitted to the TACB 

Permits Program. Test waivers and alternate/equivalent 

procedure proposals for New Source Performance Standard 

testing which must have EPA approval shall be submitted 

to the TACB Quality Assurance Division in Austin. 

B. Air contaminants emitted from the thermal oxidizer stack 

to be tested for include, but are not limited to, styrene 

methyl methacrylate and toluene. 

C. Sampling ports and platforms shall be incorporated into 

the design of the thermal oxidizer stack according to 

the specifications set forth in the attachment entitled 

"Chapter 2, -Stack Sampling Facilities." Alternate 

sampling facility designs may be submitted for approval 

by the Executive Director of the TACB. 

D. Sampling shall occur within 90 days of the date of 

request by the TACB. Requests for additional time to 

perform stack sampling shall be submitted to the regional 

office. 

E. The thermal oxidizer shall be tested at maximum plant 

operating conditions during stack emission testing. 

Primary operating parameters that enable determination 

of VOC generation rate shall be monitored and recorded 

during the stack test. These parameters are to be 

determined at the pretest meeting. If the plant* is 

unable to operate at maximum rates during testing, then 

future production rates may be limited to the rates 

established during testing. Additional stack testing 

may be required when higher production rates are 

achieved. 

F. Sampling reports shall comply with the provisions of 

Chapter 14 of the TACB Sampling Procedures Manual* Pour 

copies of the sampling report shall be distributed as 

follows: 

One copy to the TACB Region 8 Office in Fort Worth. 

One copy to any appropriate local air pollution control 

program. 

One copy to the Quality Assurance Division, TACB,-Austin 

Office. 

One copy to the City of Blue Mound. 

G. At least two opacity readings will be taken during the 

testing. 

6 
P.8 

SPECIAL PROVISIONS 

19424 

Page 5 

16. The holder of this permit shall demonstrate that all hooding, 

ducting and collection-systems are effective in capturing 

emissions and routing them to the thermal oxidizer. The 

building ventilation system shall be operated at maximum 

during the tests. 

CONTINUOUS DEMONSTRATION OF COMPLIANCE 

17. The holder of this permit shall continuously monitor and 

record gas temperature in the retention chamber of the thermal 

oxidizer to demonstrate continuous compliance vith Special 

Provision No. 2. 

18. The holder of this permit shall install, calibrate and 

maintain a continuous emission monitoring system (CEMS) to 

measure and record THC in the thermal oxidizer stack. The 

monitoring shall be done in accordance vith current TACB 

Quality Assurances procedures. 

A. The THC CEMS shall meet the design and performance 

specifications, pass the field tests and meet the 

installation requirements, data analysis and reporting 

requirements (all appropriate procedures equivalent to 

40 CFR 60, Appendix B) specified by the TACB Quality 

Assurance Division. 

B. The system shall be zeroed and spanned daily vhile 

operating and corrective action taken when the 24-hour 

span drift exceeds two times the amounts specified ih 40 

CFR 60, Appendix B or as specified by the TACB Quality 

Assurance Division. 

C. The THC monitor shall use styrene as the reference gas. 

D. The THC concentrations shall be recorded in ppmv. 

RECORDKEEPING REQUIREMENTS 

19. A copy of this permit shall be kept at the plant site and be 

available at the request of personnel from the TACB, any air 

pollution control agency with appropriate jurisdiction or the 

City of Blue Mound. 

20. Records of emissions shall be maintained to demonstrate 

compliance with the limits of this permit. These records shall 

be accumulated monthly to give year-to-date totals for each 

compound and process and shall be retained for a minimum of 

24 months on a rolling two-year basis. They will be kept onsite and made available to representatives of the TACB or any 

other air pollution control agency having jurisdiction and 

shall contain as a minimum: 

7 
P.9 

SPECIAL PROVISIONS 

19424 

Page 6 

A. Material usage in pounds per hour for each fiberglass 

production and coplaner process. 

B. Thermal oxidizer stack VOC emissions, in pounds per hour, 

calculated using the output of the monitor required by 

SP 18 (above) and the estimated stack volumetric flow as 

determined by sampling. 

C. Daily hours of operation for the facility and for the 

panel line and pultrusion line. 

D. Material Safety Data Sheets (MSDS) for each compound 

stored or used. 

E. Purchase records for all compounds stored or used at the 

facility. 

F. Records of initial and recurring training for operators 

of the thermal oxidizer. 

G. Recorder strip charts containing the thermal oxidizer 

retention chamber temperature and THC stack concentration 

in ppmv. 

f 
P.10 

EMISSION SOURCES - MAXIMUM ALLOWABLE EMISSION RATES 

19424 

This table lists the maximum allowable emission rates and all sources of air 

contaminants on the applicant's property covered by this permit. The 

emission rates shown are those derived from information submitted as part of 

the application for permit and are the maximum rates allowed for these 

facilities. Any proposed increase in emission rates may require an 

(1) Emission point identification - either specific equipment designation or 

emission point number from plot plan. • 

(2) Specific point source name. For fugitive sources use area name or 

fugitive source name. 

(3) PM - particulate matter 

PMIO - particulate matter less than 10 microns 

VOC - volatil e organic compounds as defined in General Rule 101.1 

NOx - total oxides of nitrogen 

CO - carbon monoxide 

1-1-1- TCE - 1-1-1 tricloroethane 

F-22/F-12 - freon 22 and freon 12 mixture 

* Emission rates are based on and the facilitie s are limited by the 

following maximum operating schedule: 

Hrs/day 24 Days/weekjg Weeks/year 52 or Hrs/year 6000 

No VOC emitting production operations vil l be conducted betveen 7:00 

a.m. Saturday and 7:00 a.m. Monday. 

Revised. 

appiic ;ati( 

Emission 

point No. 

TOI 

V4 

VF 

Cl 

.3 

_>n toe 

m 

a mouiiication oi uie 

Source 

Name 12. 

Thermal Oxidizer 

Panel Baghouse 

Fabrication Baghouse 

Coplanar Vent 

Coplanar Vent 

isciiiues covered oy *cnis permi*c. 

AIR CONTAMINANTS DATA 

Air Contaminant 

Name (31 

VOC 

NOX 

" C O 

PM/PM10 

PM/PM10 

1-1-1 TCE 

F-22/F-12 

Emission Rates * 

lb/hr TPY 

9.79 

4.09 

6.51 

0.34 

0.20 

2.00 

3.53 

12.00 

12.28 

19.54 

1.03 

0.60 

1.80 

3.18 

1