OKLAHOMA DEPARTMENT OF ENVIRONMENTAL · PDF fileDW-National Standard, Stillwater LLC. Wire ......

DRAFT DRAFT

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM January 11, 2011

TO: Phillip Fielder, P.E., Permits and Engineering Group Manager

THROUGH: Kendal Stegmann, Enforcement and Compliance Manager

THROUGH: Phil Martin, P.E., Engineering Section

THROUGH: Peer Review

FROM: Ellis Fischer, P.E., New Source Permits Section

SUBJECT: Evaluation of Permit Application No. 2006-313-TVR

DW-National Standard, Stillwater LLC.

Wire Manufacturing Operation

SE ¼ of Sec 35, T20N, R2E

Lat: 36.15886° N Long: 97.05179° W

3602 N. Perkins Road

Stillwater, Payne County, Oklahoma

Latitude: 36.161o Longitude -97.052

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SECTION I. INTRODUCTION

DW - National Standard, Stillwater LLC, operates a wire manufacturing operation in the

northern part of Stillwater (SIC 3315). Operations commenced at the facility in 1975. The

facility was issued an initial Title V Permit No. 2001-211 TV on June 24, 2002. The facility is

currently operating under Permit No. 2001-211-TV (M-1) issued February 26, 2007.

The facility has requested a renewal of their Title V operating permit. The facility emits more

than 100 TPY of NOx, CO, and VOC, and is subject to Title V permitting requirements.

Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) in the following

outline. The facility only has one operating scenario.

SECTION II. PROCESS DESCRIPTION

Wire is produced for a variety of end-uses, including vehicle tire components, welding wire,

spring wires, etc. The desired end use determines the diameter, metallurgy, and surface

treatment.

Wire production is accomplished by pulling metal rod through dies, reducing the diameter at

each die. The metal is heated to soften it and enhance ductility. Following diameter reduction,

PERMIT MEMORANDUM 2006-313-TVR 2 DRAFT

the metal is heated in molten lead baths to anneal it, then washed in a series of baths which

include acids, and finally a surface treatment (organic for some wires, inorganic for others) is

applied. The finished product is wound up on spools and stored in an on-site warehouse prior to

shipment.

The Stillwater facility receives steel rod direct from steel mills. The steel rod is first cleaned in

the Clean and Coat house (C & C) pickling line. Steel Rod may also be coated with a Borax

(Na2O 2B2O3) solution or a Zinc Phosphate (ZnPO4) solution prior to wire drawing operations.

The wire is then dried in electric ovens and rolled on spools.

After drawing to a finer diameter, the wire receives heat-treatment, washing, acid and/or caustic

bipolar wash, copper plating, and an organic coating. Line 39 involves lead coating, caustic

wash, sulfuric acid (33%), washing, Sulfuric acid (1%), copper plating, and washing again. The

wire is then dried to insure the organic coating adheres properly to the wire. An organic coating

(Cumar) is applied to the wire for final treatment of finished product (Bead Wire). The 29 Line

and 39 Line both use an electric oven. Operations on the 29 Line are almost identical with the

difference being one less sulfuric acid bath and the use of anti-corit as the organic coating for the

treatment of the finished product (Weld Wire). Line 29 also has the potential for lead coating,

but does not currently perform the process.

The wire is treated for removal of scale and other surface deposits by “pickling” in Hydrochloric

Acid (HCl) solutions. Four tanks are utilized. Pickling is a batch process of soaking coils of

steel rod in progressively weaker acid bath solutions. There is an additional tank used for

rinsing. There are also tanks used for Zinc Phosphate coating which have no air emissions. Acid

fumes from each acid and rinse tank are controlled by a packed bed wet scrubber with a 95%

efficiency for HCl emissions control. Spent HCl is stored in tanks and collected by an

independent company as a beneficial reuse product.

SECTION III. EQUIPMENT

In previous permits, some emission points were duplicated or inconsistent between the Permit

Memorandum and Specific Conditions. To be consistent with previously-established facility

hood/point notations, emission unit and/or point identification has changed. New ID numbers

are noted below. All emission points are located within the main facility building, with the

exception of the generators, lime silo, tanks and emission points within the Clean and Coat

house, a separate structure to the west of the main building. Clean and Coat house emission

points are designated by 90-series emission units/points.

Additionally, some equipment has been moved, removed, or permanently disconnected.

Equipment as currently configured is reflected in the tables below.

Organic Coating: Coatings containing VOCs are applied at various points in the line processes,

depending on the end-use of produced wire or required lubrication prior to successive process

steps. The coatings are contained in large vats, through which the wire is drawn. Currently,

organic coatings include Cumar, Anti-Corit, and Magnus.


EUG 1 – Coating Operations (Organic Wire Coating)

EU ID New EU ID EU Name/Model Construction Date

EP-28

EP-33

EP-37a

EP-59

EP-65

Organic Coating 1975 / 1983

Combustion Units: National Standard has two elongated vats that contain lead in molten form.

Each vat is heated by a single elongated natural gas burner. Boiler No. 1 has been disconnected

and is no longer functional. National Standard has electric dryers on the wire lines, but the

previously listed natural gas-fired Baker Dryer has been removed. Boilers 4 and 5 were

previously listed as insignificant, but since these boilers have a heat capacity greater than 5

MMBtu/hr, they have been included with the combustion units.

EUG 2 – Combustion Units

EU

ID

Point

ID

New

Point ID EU Name/Model Construction

Date

Heat

Capacity

MMBTUH

39-1 EP-26 EP-41 Line 39 Lead Furnace 1975 4.0

29-1 EP-33 EP-51 Line 29 Lead Furnace 1983 4.0

M-4 EP-49 EP-43 Boiler No. 2 1976 8.369

M-5 EP-50 EP-44 Boiler No. 3 1976 8.369

M-14 EP-80 EP-99a Boiler No. 4 2007 8.369

M-15 EP-80 EP-99b Boiler No. 5 2007 6.9

Lead Pots: Wire is drawn in a conveyor-like fashion through molten lead to coat. Although the

Line 29 lead pot is currently not in use, the facility maintains its listing in the permit for

operational flexibility. Each lead pot has two emission points.

EUG 3 – Lead Process Units

EU

ID

Point

ID

New

Point

ID

EU Name/Model Construction Date

39-1 EP-27

EP-28

EP-39

EP-40 Line 39 Lead Pot 1975 / 1999

29-1 EP-34

EP-35

EP-49

EP-50 Line 29 Lead Pot 1983 / 2000

Acid Process and Storage: Process lines previously using hydrochloric acid (HCl) are now using

sulfuric acid. HCl is currently used only in the C & C house. Line HCl tanks have been deleted

from the following table and EUG 4 has been corrected to reflect the changes.


EUG 4 – Acid Process and Storage Units

EU

ID

Point

ID EU Name/Model

Capacity,

Gallons Construction Date

PT-1

EP-99

HCl Pickling Tank -- 1977

PT-2 HCl Pickling Tank -- 1977



RT-5 Rinse Tank --

SC-6 HCl Scrubber -- 1975

T-1 EP-81 Virgin HCl Tank 8,500 1986

T-2 EP-82 Spent Acid Tank 4,000 1986

T-3 EP-83 Spent Acid Tank 4,000

Insignificant PM Sources: Previously, EUG 5 listed eight (8) wall exhaust fans as particulate

emissions sources (identified as emission units M-6 through M-13). The facility has several wall

and ceiling exhaust fans and vents. These fans and vents provide work area ventilation, but there

are no published emission factors for the activities and negligible emissions are expected from

these points.

Miscellaneous Insignificant Sources: Two emergency generators (EP-71 and EP-90) are limited

to 500 hours per year operation. The third generator (EP-73), located in the Waste Water

Treatment building, is smaller than 50 hp and, therefore, qualifies as insignificant with no hourly

restrictions. Combustion emissions from these sources are included with annual emissions.

Emissions from the lime silo are limited to particulate matter and are also included with annual

emissions.

EUG 6 – Miscellaneous Insignificant Activities

EU ID Point ID EU Name/Model Capacity Construction Date

71 EP-71 Emergency Generator 365 KW (460 HP) 1975

73 EP-73 WWT Generator (< 50 HP) 15 KW (30 HP) 1992

90 EP-90 C & C Emergency Generator 74.9 KW (100 HP) 2006

Fuel Storage Tanks: The facility has three storage tanks located to the north of the main building

that store fuel for facility vehicles and generators. The propane tank is pressurized and,

therefore, not a source of emissions. Calculated emissions indicate insignificant VOC emissions

from all tanks. The fuel tanks are listed in EUG 7 with their contents.

EUG 7 – Fuel Storage Tanks

EU ID Point ID Contents Capacity (gallons)

84 EP-84 Propane 1,000

85 EP-85 Diesel 750

86 EP-86 Gasoline 300


SECTION IV. AIR EMISSIONS

Emission Factors and Sources

Stack

ID

New

Stack

ID

Operation Emission

Type Factor Reference Emission Factors/Limits

25 81 Virgin HCl tank HCl, Cl2 TANKS3.1 TANKS3.1

26 41 Line 39 lead furnace

(4.0 MMBTUH)

combustion

gases

AP-42 (7/98)

Section 1.4

NOx: 0.098 lb/MMBTU

CO:0.0824 lb/MMBTU

VOC:0.00539 lb/MMBTU

PM10: 0.00745 lb/MMBTU

SO2: 0.00059 lb/MMBTU

27 39 Line 39 lead pot Pb / PM10

stack test results

plus 40% safety

factor

PM10: 1.58 lb/hr

Pb: 0.041 lb/hr

28 40 Line 39 lead pot

Pb / PM10 +

organic coating

vapors

stack test results

plus 40% safety

factor

PM10: 1.74 lb/hr

Pb: 0.007 lb/hr

29 35 Line 39 water rinse steam -- --

30 36 Line 39 plater steam -- --

31 37 Line 39 water rinse steam -- --

32 38 Line 39 bipolar steam -- --

33 51 Line 29 lead furnace

(4.0 MMBTUH)

combustion

gases + organic

coating vapors

AP-42 (7/98)

Section 1.4

NOx: 0.098 lb/MMBTU

CO: 0.0824 lb/MMBTU

VOC: 0.00539 lb/MMBTU




stack test results

plus 40% safety

factor

PM10: 3.58 lb/hr

Pb: 0.18 lb/hr


stack test results

plus 40% safety

factor

PM10: 3.58 lb/hr

Pb: 0.18 lb/hr

36 53 Line 29 Bipolar stack steam -- --

37 54 Line 29 Bipolar stack steam -- --

39 56 Line 29 plater steam -- --

40 61 Line 29 wash steam -- --




44 65 Line 29 dip tank VOC -- --

45 55 Line 29 H2SO4 dip steam -- --

49 43 Boiler No. 2

(8.369 MMBTUH)

combustion

gases

AP-42 (7/98)

Section 1.4

NOx: 0.098 lb/MMBTU

CO: 0.0824 lb/MMBTU




50 44 Boiler No. 3

(8.369 MMBTUH)

combustion

gases

AP-42 (7/98)

Section 1.4

NOx: 0.098 lb/MMBTU

CO: 0.0824 lb/MMBTU



Stack

ID

New

Stack

ID

Operation Emission

Type Factor Reference Emission Factors/Limits



50 99a Boiler No. 4

(8.369 MMBTUH)

combustion

gases

AP-42 (7/98)

Section 1.4

NOx: 0.098 lb/MMBTU

CO: 0.0824 lb/MMBTU




50 99b Boiler No. 5

(6.9 MMBTUH)

combustion

gases

AP-42 (7/98)

Section 1.4

NOx: 0.098 lb/MMBTU

CO: 0.0824 lb/MMBTU




51 82 Spent acid tank HCl, Cl2 TANKS3.1 TANKS3.1

83 Spent acid tank HCl, Cl2 TANKS3.1 TANKS3.1

60 71 Emergency Generator

(460 HP)

diesel

combustion

AP-42 (7/00)

Table 3.3-1

NOx: 0.031 lb/hp-hr

CO: 0.00668 lb/hp-hr

VOC: 0.00251 lb/hp-hr

PM10: 0.0022 lb/hp-hr

SO2: 0.00205 lb/hp-hr

60 73 Small Generator

(30 HP)

natural gas

combustion

AP-42 (7/00)

Table 3.2-3

NOx: 2.21 lb/MMBtu

CO: 3.72 lb/MMBtu

VOC: 0.0296 lb/MMBtu

PM10: 0.00991 lb/MMbtu

SO2: 0.000588 lb/MMbtu

60 90 Emergency Generator

(100 HP)

natural gas

combustion

AP-42 (7/00)

Table 3.2-3

NOx: 2.21 lb/MMBtu

CO: 3.72 lb/MMBtu

VOC: 0.0296 lb/MMBtu

PM10: 0.00991 lb/MMbtu

SO2: 0.000588 lb/MMbtu

-- 98 Rust Prevention &

Rinse steam -- --

99 99 HCl Pickling and Rinse

Tanks HCl, Cl2, PM10

stack test results

plus 40% safety

factor

PM10: 1.646 lb/hr

HCl: 0.644 lb/hr

Cl2: 0.287 lb/hr

-- 85 Diesel Tank VOC TANKS 4.0.9d --

-- 86 Gasoline Tank VOC TANKS 4.0.9d --

An organic coating material is authorized with the following specifications. A maximum usage

of 60,000 gallons per year is permitted.

Coating Specifications

Parameter C A S Number Limitation, lb/gal

Density -- 9.0

Total VOC -- 6.5


Stack Parameters

Previous

Discharge

Point

New

Discharge

Point

Emission Unit Height

Feet

Diameter

Inches

Flow

Rate

ACFM

Temp., oF

26 41 Line 39 lead furnace 36 10 1,150 200

27 39 Line 39 lead pot 43 26 8,000 170

28 40 Line 39 lead pot 43 26 8,000 170

30 36 Line 39 plater 40 20 8,000 70

33 51 Line 29 lead furnace 37 12 1,150 200

34 49 Line 29 lead pot 41 30 8,000 170

35 50 Line 29 lead pot 41 30 8,000 170

36 53 Line 29 Bipolar stack 40 15 5,000 70

37 54 Line 29 Bipolar stack 40 15 5,000 70

39 56 Line 29 plater 39 1.3 8,000 70

37a Cumar stack 10 12 1,300 70

37 Rinse stack 45 30 8,000 70

98 Rust Prevention and Rinse 45 58 44,000 65

49 43 Boiler No. 2 23 16 2,600 270

50 44 Boiler No. 3 23 16 2,600 270

71 71 Emergency generator 6 6 1,780 600

99 99 Pickling tank scrubber 45 58 44,000 65

POTENTIAL EMISSIONS EUG 1: Three organic coatings are currently applied to wires. The composition of coating

containing the most VOCs has been assumed for all coatings to reflect the worst-case scenario of

VOC emissions. Emissions from these operations are based on mass balances assuming 100

percent evaporation of coating solvents. Anticipated potential VOC emissions from organic

coatings are based on maximum VOC content and requested annual usage limitation.

EUG 1: Coating Operations

Point

ID

New Point

ID Description

VOC

Content

Lb/gal

Hourly

Usage

Gallons

Annual

Usage

Gallons

VOC

lb/hr TPY

EP-26

EP-33

EP-37a

EP-59

EP-65

Organic Coating 6.5 6.85 60,000 44.52 195.00

EUG 2: Emissions from external combustion sources (boilers and lead burners) were calculated

using factors from AP-42 (7/98), Section 1.4.

EUG 2: Combustion Units

Point

ID

New

Point ID Description

PM10 SO2 NOx CO VOC

lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY

EP-26 EP-41 Line 39 Lead

Furnace 0.03 0.13 0.00 0.01 0.39 1.72 0.33 1.44 0.02 0.09

EP-33 EP-51 Line 29 Lead

Furnace 0.03 0.13 0.00 0.01 0.39 1.72 0.33 1.44 0.02 0.09

EP-49 EP-43 Boiler No. 2 0.06 0.27 0.01 0.02 0.82 3.59 0.69 3.02 0.05 0.20


Point

ID

New

Point ID Description

PM10 SO2 NOx CO VOC


EP-50 EP-44 Boiler No. 3 0.06 0.27 0.01 0.02 0.82 3.59 0.69 3.02 0.05 0.20

EP-80 EP-99a Boiler No. 4 0.06 0.27 0.01 0.02 0.82 3.59 0.69 3.02 0.05 0.20

EP-81 EP-99b Boiler No. 5 0.05 0.23 0.00 0.02 0.68 2.96 0.57 2.49 0.04 0.16

TOTALS 0.29 1.30 0.03 0.10 3.92 17.17 3.30 14.43 0.23 0.94

EUG 3: According to AP-42, lead pots generate lead vapor and emissions of particulate matter.

Particulates are produced from fluxes used with most types of molten metal to prevent the

formation of a “skin” on the surface of the liquid metal. National Standard uses a carbon-based

flux, which is the likely source of particulates from the lead pots. Lead is one of the heaviest

metals and would only be an airborne pollutant in its vaporized form. Any solidified lead

particles would settle out of the air as dust near the source.

Given the scarcity of published emission factors for the other operations such as molten lead

baths or acid pickling, emissions were derived from stack testing with a 40% safety factor added

to allow for increased operations in the future. This calculation strategy assumed a linear

relationship between process rate and emissions provided other variables such as packed bed wet

scrubber efficiency remain constant.

EUG 3: Lead Process Units

Point

ID

New Point

ID Description

Pb PM10

lb/hr TPY lb/hr TPY

EP-27 EP-39 Line 39 Lead Pot 0.041 0.180 1.580 6.920




TOTALS 0.41 1.79 10.48 45.90

EUG 4: Pickling with hydrochloric acid was previously performed in the main building on one

of the wire process lines, but vats and processing has been moved to the Clean and Coat House.

Fumes from all vats are directed to the HCl scrubber and emissions are derived from scrubber

stack testing. TANKS 3.1 was used in previous permits to estimate emissions from virgin and

spent HCl tanks. Since this program no longer estimates emissions for HCl, emission estimates

have been carried forward.

EUG 4: Acid Process and Storage Units

Point

ID

New

Point

ID

Description

PM10 HCl Cl2

lb/hr TPY lb/hr TPY lb/hr TPY

PT-1 HCl Pickling Tank

1.646 7.210 0.644 2.820 0.287 1.257




RT-5 HCl Rinse Tank

99 SC-6 HCl Scrubber

EP-25 EP-81 Virgin HCl Tank -- -- 0.117 0.512 -- --

EP-82 Spent HCl Tank -- -- 0.00 0.02 -- --


Point

ID

New

Point

ID

Description

PM10 HCl Cl2


EP-83 Spent HCl Tank -- -- 0.00 0.02 -- --

TOTALS 1.65 7.21 0.76 3.37 0.29 1.26

EUG 6: Emissions from the 460-hp diesel-fueled generator was calculated using factors from

AP-42 (7/00), Table 3.3-1. Emissions from the 30-hp and 100-hp natural gas-fired generators

were calculated using factors from AP-42 (7/00), Table 3.2-3.

EUG 6: Miscellaneous Insignificant Activities

Point

ID Description

PM10 SO2 NOx VOC CO


EP-71 Emergency

Generator 0.36 0.09 0.34 0.09 5.16 1.29 0.41 0.10 1.11 0.28

EP-73 WWT

Generator 0.10 0.10 0.10 0.10 0.17 0.74 0.00 0.01 0.28 1.24

EP-90

C&C

Emergency

Generator

0.10 0.10 0.10 0.10 0.56 0.14 0.01 0.00 0.95 0.24

TOTALS 0.56 0.29 0.54 0.29 5.89 2.17 0.42 0.11 2.34 1.76

EUG 7: TANKS 4.0.9d indicates negligible VOC emissions from fuel storage tanks, assuming

worst-case gasoline usage of one turnover per month (12 turnovers per year).

EUG 7: Insignificant Fuel Storage Tanks

Point ID Description VOC Emissions

(TPY)

EP-85 Diesel Storage Tank <0.001

EP-86 Gasoline Storage Tank 0.11

TOTAL EMISSIONS

EUG Description PM10 SO2 NOx CO VOC


1 Coating -- -- -- -- -- -- -- -- 44.52 195.00

2 Combustion 0.29 1.30 0.03 0.10 3.92 17.17 3.30 14.43 0.23 0.94

3 Lead Process 10.48 45.90 -- -- -- -- -- -- -- --

4 Acid Process 1.65 7.21 -- -- -- -- -- -- -- --

6 Insig. Act. 0.56 0.29 0.54 0.29 5.89 2.17 0.42 0.11 2.34 1.76

7 Fuel Storage -- -- -- -- -- -- -- -- -- 0.11

TOTALS 12.98 54.70 0.57 0.39 9.81 19.34 3.72 14.54 47.09 197.81

Note: Although PM emissions are shown as PM10 because of the nature of the process, it is

assumed that all PM10 is PM2.5.


HAP EMISSIONS

HAP CAS Number Emissions

lb/hr TPY

Chlorine * 7782505 0.29 1.26

HCl * 7647010 0.76 3.37

Lead * 7439921 0.41 1.79

* HAP. Total HAPs = 6.42 TPY.

SECTION V. INSIGNIFICANT AND TRIVIAL ACTIVITIES

Insignificant

The insignificant activities identified and justified in the application and listed in OAC 252:100-

8, Appendix I, are listed below. Recordkeeping for activities indicated with “*” is listed in the

Specific Conditions.

- * Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel

which are either used exclusively for emergency power generation or for peaking power

service not exceeding 500 hours per year. The two emergency generators are in this

category.

- Alkaline/phosphate washers and associated burners. The facility includes several alkaline

and phosphate wash tanks.

- Hazardous waste and hazardous materials drum staging areas. The facility includes a drum

storage room.

- Sanitary sewage collection and treatment facilities other than incinerators and Publicly

Owned Treatment Works (POTW). Stacks or vents for sanitary sewer plumbing traps are

also included (i.e., lift station). This includes the lime silo, since lime is used exclusively in

the wastewater treatment process.

- * Activities having the potential to emit no more than 5 TPY (actual) of any criteria

pollutant.

Trivial

Trivial activities at the facility include a deaerator associated with boilers, process water

filtration systems and demineralizers (waste water treatment facility), demineralized water tanks

and demineralizer vents, lime and lime storage (waste water treatment), welding for maintenance

purposes, and surface coating for maintenance purposes. Two PMP cyclone-type vacuums are

used for housekeeping purposes around the wire drawing machines, but TCLP testing indicates

non-hazardous waste only. There are no recordkeeping requirements for these activities.

SECTION VI. AIR QUALITY IMPACTS

Lead is subject to an NAAQS limitation of 0.15 ug/m3, rolling 3-month quarter average. Air

modeling was conducted with the ISCST3 refined model. A 100-meter receptor grid was

established around the plant fenceline, and one year pre-processed meteorological data was

utilized. Maximum lead impacts were shown at 0.029 ug/m3 calendar quarter, which is in


compliance with the NAAQS limitation of 0.15 ug/m3, rolling 3-month average.

SECTION VII. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable]

Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]

Subchapter 3 enumerates the primary and secondary ambient air quality standards and the

significant deterioration increments. At this time, all of Oklahoma is in attainment of these

standards.

OAC 252:100-4 (New Source Performance Standards) [Not Applicable]

Federal regulations in 40 CFR Part 60 are incorporated by reference as they existed on

September 1, 2005, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16),

Subpart B, Subpart C, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, Subpart

BBBB, Subpart DDDD, Subpart HHHH and Appendix G. NSPS requirements are addressed in

the “Federal Regulations” section.

OAC 252:100-5 (Registration, Emission Inventory, and Annual Fees) [Applicable]

The owner or operator of any facility that is a source of air emissions shall submit a complete

emission inventory annually on forms obtained from the Air Quality Division. This facility has

submitted the required emission inventories and has paid the applicable fees.

OAC 252:100-8 (Major Source/Part 70 Permits) [Applicable]

Part 5 includes the general administrative requirements for Part 70 permits. Any planned

changes in the operation of the facility which result in emissions not authorized in the permit and

which exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior

notification to AQD and may require a permit modification. Insignificant activities mean

individual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual

calendar year emissions do not exceed the following limits:

5 TPY of any one criteria pollutant

2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of

any threshold less than 10 TPY for single HAP that the EPA may establish by rule

Emissions limitations have been established for each emission unit based on information from

the permit application.

OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable]

Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess

emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following

working day of the first occurrence of excess emissions in each excess emission event. No later

than thirty (30) calendar days after the start of any excess emission event, the owner or operator


of an air contaminant source from which excess emissions have occurred shall submit a report

for each excess emission event describing the extent of the event and the actions taken by the

owner or operator of the facility in response to this event. Request for affirmative defense, as

described in OAC 252:100-9-8, shall be included in the excess emission event report. Additional

reporting may be required in the case of ongoing emission events and in the case of excess

emissions reporting required by 40 CFR Parts 60, 61, or 63.

OAC 252:100-13 (Open Burning) [Applicable]

Open burning of refuse and other combustible material is prohibited except as authorized in the

specific examples and under the conditions listed in this subchapter.

OAC 252:100-19 (Particulate Matter) [Applicable]

Subchapter 19 specifies PM emissions limitations based on heat input capacity. All fuel-burning

units at this facility have maximum heat input values less than the Appendix C threshold of 10

MMBtu. The Appendix D allowable PM emission rate for these units is 0.60 lb/MMBtu. Total

PM emission from combustion processes indicate that the facility is not likely to violate this

limit.

Subchapter 19 also limits emissions of particulate matter from processes based on their process

weight rate. The limitation is given by the formula E = 4.1 * P0.67

for process rates less than 30

TPH, and E = 55 * P0.11

– 40 for process rates above 30 TPH.

Point

ID Process Unit

Process Rate

TPH

Anticipated PM

Emission Rate

lb/hr

Allowable PM

Emission Rate

lb/hr

EP-39 Line 39 Lead Furnace 11.67 1.580 21.3

EP-40 Line 39 Lead Furnace 11.67 1.740 21.3

EP-49 Line 29 Lead Pot 11.25 3.580 20.8

EP-50 Line 29 Lead Pot 11.25 3.580 20.8

EP-99 HCl Scrubber 10.63 0.823 20.0



OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]

No discharge of greater than 20% opacity is allowed except for short-term occurrences which

consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed

three such periods in any consecutive 24 hours. In no case shall the average of any six-minute

period exceed 60% opacity. The permit will require maintenance of air pollution controls to

ensure compliance with this rule.

OAC 252:100-29 (Fugitive Dust) [Applicable]

Subchapter 29 prohibits the handling, transportation, or disposition of any substance likely to

become airborne or wind-borne without taking “reasonable precautions” to minimize emissions

of fugitive dust. No person shall cause or permit the discharge of any visible fugitive dust

emissions beyond the property line on which the emissions originate in such a manner as to

damage or to interfere with the use of adjacent properties, or cause air quality standards to be

exceeded, or to interfere with the maintenance of air quality standards. Under normal


circumstances, this facility will not cause a problem in this area, therefore it is not necessary for

specific precautions to be taken.

OAC 252:100-31 (Sulfur Compounds) [Applicable]

Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1,

1972). For gaseous fuels the limit is 0.2 lb/MMBTU heat input averaged over 3 hours. For fuel

gas having a gross calorific value of 1,000 BTU/SCF, this limit corresponds to fuel sulfur

content of 1,203 ppmv. The permit requires the use of commercial pipeline-grade natural gas to

ensure compliance with Subchapter 31.

OAC 252:100-33 (Nitrogen Oxides) [Not Applicable]

Subchapter 33 affects new fuel-burning equipment with a rated heat input of 50 MMBTUH or

more. The heaters on a prior Line 58 lead tank is the only unit larger than this threshold.

Subchapter 33 limits NOx emissions to 0.2 lb/MMBTU from gas-fired equipment. Stack testing

showed NOx emissions of 0.016 lb/MMBTU. However, the prior line 58 was decommissioned

in July 2008 and is in process of being removed from facility. Therefore, this subchapter is not

applicable.

OAC 252:100-35 (Carbon Monoxide) [Not Applicable]

None of the following affected processes are part of this project: gray iron cupola, blast furnace,

basic oxygen furnace, petroleum catalytic cracking unit or petroleum catalytic reforming unit.

OAC 252:100-37 (Volatile Organic Compounds) [Applicable]

Part 3 requires new storage tanks (constructed after December 28, 1974) with a capacity between

400 and 40,000 gallons holding a VOC with a true vapor pressure greater than 1.5 psia to be

operated with a submerged fill pipe. The material dip tanks are process operations rather than

storage tanks, and the storage tanks contain only HCl or H2SO4, which are not an organic

materials. The propane tank is pressurized. The diesel storage tank has a vapor pressure less

than 1.5 psia. The gasoline storage tank has a capacity less than 400 gallons.

Part 5 limits the VOC content of coatings used in coating lines for parts and products. National

Standard uses three product coatings finishes that as applied contain VOCs of less than 6.5 pounds

of VOC per gallon of coating limit.

Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize

emissions. Temperature and available air must be sufficient to provide essentially complete

combustion. The permit will require compliance.

OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Not Applicable]

Part 5 of OAC 252:100-41 was superceded by this subchapter. Any work practice, material

substitution, or control equipment required by the Department prior to June 11, 2004, to control a

TAC, shall be retained unless a modification is approved by the Director. Since no Area of

Concern (AOC) has been designated anywhere in the state, there are no specific requirements for

this facility at this time.

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable]

This subchapter provides general requirements for testing, monitoring and recordkeeping and

applies to any testing, monitoring or recordkeeping activity conducted at any stationary source.


To determine compliance with emissions limitations or standards, the Air Quality Director may

require the owner or operator of any source in the state of Oklahoma to install, maintain and

operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant

source. All required testing must be conducted by methods approved by the Air Quality Director

and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol

shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests.

Emissions and other data required to demonstrate compliance with any federal or state emission

limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained,

and submitted as required by this subchapter, an applicable rule, or permit requirement. Data

from any required testing or monitoring not conducted in accordance with the provisions of this

subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive

use, of any credible evidence or information relevant to whether a source would have been in

compliance with applicable requirements if the appropriate performance or compliance test or

procedure had been performed.

The following Oklahoma Air Pollution Control Rules are not applicable to this facility:

OAC 252:100-11 Alternative Emissions Reduction not requested

OAC 252:100-15 Mobile Sources not in source category

OAC 252:100-17 Incinerators not type of emission unit

OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Grain Elevators not in source category

OAC 252:100-39 Nonattainment Areas not in area category

OAC 252:100-47 Municipal Solid Waste Landfills not in source category

SECTION VIII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable]

The facility has emissions which are below the 250 TPY threshold for PSD, and it is not among

the industries defined as “major sources” by PSD at a potential emission level of 100 TPY.

NSPS, 40 CFR Part 60 [Not Applicable]

Subparts D and Da (Steam Generating Units) affect units with heat input capacities of 250

MMBTUH or more. No unit has a heat input larger than 117 MMBTUH.

Subpart Db (Commercial-Industrial-Institutional Steam Generating Units) affects boilers with a

rated heat input of 100 MMBTUH or more which commenced construction, reconstruction, or

modification after June 19, 1984. The Line 58 Lead Furnace was constructed in 1975, prior to

the effective date of Subpart Db. However, Line 58 was decommissioned in July 2008 and is in

process of being removed from facility. Therefore, there is no equipment at this time subject to

this Subpart.

Subpart Dc (Small Industrial-Commercial-Institutional Steam Generating Units) affects boilers

and heat transfer medium heaters which commenced construction, reconstruction, or

modification after June 9, 1989. All of the existing combustion units at this facility were

constructed prior to that date; the new units are smaller than the threshold of applicability of 10

MMBTUH.

Subpart Kb (Volatile Organic Liquids Storage Vessels) affects volatile organic materials storage


tanks with a capacity above 19,813 gallons which commenced construction, reconstruction, or

modification after July 23, 1984. The tanks at the facility are smaller than the 19,813-gallon de

minimis level.

Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion

Engines) affects compression ignition (CI) internal combustion engines (ICE) based on power and

displacement ratings, depending on date of construction, beginning with those constructed after

July 11, 2005. The CI ICE at this facility was constructed in 1975.

Subpart JJJJ (Standards of Performance for Stationary Spark Ignition Internal Combustion

Engines) affects owners and operators that commence construction after June 12, 2006, of

emergency generators rated greater than 25 hp and manufactured after January 1, 2009, and of

other generators rated less than 500 hp that were manufactured after July 1, 2008. The natural gas

generators at this facility were constructed and manufactured prior to the effective date of this

subpart.

The following subparts affect surface coating, but not this facility:

Subpart EE: Metal Furniture

Subpart MM: Automobiles and Light-Duty Trucks

Subpart QQ: Graphic Arts (Rotogravure)

Subpart RR: Pressure-Sensitive Tape and Labels

Subpart SS: Surface Coating of Large Appliances. No large appliances are coated at this

facility.

Subpart TT: Metal Coil Surface Coating. No metal coils are coated at this facility.

Subpart WW: Beverage Cans

Subpart FFF: Flexible Vinyl and Urethane

NESHAP, 40 CFR Part 61 [Not Applicable]

None of the eight pollutants subject to NESHAP will be emitted: arsenic, asbestos, benzene,

beryllium, coke oven emissions, mercury, radionuclides, or vinyl chloride.

NESHAP, 40 CFR Part 63 [Not Applicable]

Subpart CCC (Steel Pickling – HCl Process Facilities and Hydrochloric Acid Regeneration

Plants) affects new and existing steel picking facilities using hydrochloric acid that contains 6%

or more by weight HCl and is at a temperature of 100oF or hotter which are located at major

sources of HAP emissions. This facility is an “area” source of HAPs.

Subpart MMMM (Surface Coating of Miscellaneous Metal Parts and Products). This subpart

affects all coating operations and storage containers and mixing vessels for coatings, thinners,

cleaners, and wastes. The final rule became effective January 2, 2007. This subpart requires

existing sources to limit HAP emissions from general use coatings to 2.60 lb/gallon of solids,

high performance coatings to 27.54 lb/gallon of solids, magnet wire coatings to 1.00 lb/gallon of

solids, and rubber-to-metal coatings to 37.70 lb/gallon of solids. This facility is an “area” source

of HAPs, therefore is not subject to this Subpart.

Subpart SSSS (Surface Coating of Metal Coil) affects facilities that perform metal coil surface

coating operations and are major sources of HAPs. This facility is an “area” source of HAPs.

Subpart ZZZZ (Reciprocating Internal Combustion Engines (RICE)) affects RICE with a site

rating greater than 500 brake horsepower that are located at a major source of HAP emissions.


The engines at this facility are all rated less than 500 hp and the facility is not a major source of

HAPs.

Subpart HHHHH (Miscellaneous Coating Manufacturing) affects facilities that manufacture

coatings at major sources of HAPs. This facility does not manufacture coatings and is an “area”

source of HAPs.

Subpart CCCCCC (Gasoline Dispensing Facilities) affects GDF with a monthly throughput less

than 10,000 gallons. This facility maintains throughput records and management practices as

required by this Subpart.

Subpart HHHHHH (Paint Stripping and Miscellaneous Surface Coating Operations at Area

Sources) establishes requirements to demonstrate initial and continuous compliance with the

emission standards involved in: (a) Paint stripping operations that involve the use of chemical

strippers that contain methylene chloride (MeCl), Chemical Abstract Service number 75092, in

paint removal processes; (b) Autobody refinishing operations that encompass motor vehicle and

mobile equipment spray-applied surface coating operations; (c) Spray application of coatings

containing compounds of chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), or cadmium

(Cd), collectively referred to as the target HAP to any part or product made of metal or plastic, or

combinations of metal and plastic that are not motor vehicles or mobile equipment. This facility

does not perform any of the operations listed in this Subpart.

Subpart WWWWWW (Plating and Polishing Operations) affects area sources that perform

plating or polishing operations involving a metal listed in this Subpart. This facility does not use

any of the metals listed in this Subpart.

Subpart XXXXXX: (Nine Metal Fabrication and Finishing Source Categories) affects area

sources that are primarily engaged in the operations in one of the nine source categories listed

below:

(1) Electrical and Electronic Equipment Finishing Operations;

(2) Fabricated Metal Products;

(3) Fabricated Plate Work (Boiler Shops);

(4) Fabricated Structural Metal Manufacturing;

(5) Heating Equipment, except Electric;

(6) Industrial Machinery and Equipment Finishing Operations;

(7) Iron and Steel Forging;

(8) Primary Metal Products Manufacturing; and

(9) Valves and Pipe Fittings.

This facility is not among any of the nine source categories listed in this subpart.

Subpart BBBBBBB (Area Sources: Chemical Preparations Industry) affects area sources that

performs chemical preparations on products containing a target HAP. This facility does not use

preparations or substrates containing any target HAP.

Compliance Assurance Monitoring, 40 CFR Part 64 [Not Applicable]

Compliance Assurance Monitoring, as published in the Federal Register on October 22, 1997,

applies to any pollutant specific emission unit at a major source, that is required to obtain a Title

V permit, if it meets all the following criteria:

It is subject to an emission limit or standard for an applicable regulated air pollutant.


It uses a control device to achieve compliance with the applicable emission limit or

standard.

It has potential emissions, prior to the control device, of the applicable regulated air

pollutant of the major source thresholds.

A CAM plan is not required.

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable]

This facility does not store any regulated substance above the applicable threshold limits. More

information on this federal program is available at the web site: http://www.epa.gov/ceppo/.

Stratospheric Ozone Protection, 40 CFR Part 82 [Subparts A and F are Applicable]

These standards require phase out of Class I & II substances, reductions of emissions of Class I

& II substances to the lowest achievable level in all use sectors, and banning use of nonessential

products containing ozone-depleting substances (Subparts A & C); control servicing of motor

vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations

which meet phase out requirements and which maximize the substitution of safe alternatives to

Class I and Class II substances (Subpart D); require warning labels on products made with or

containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon

disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds

under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons

(Subpart H).

Subpart A identifies ozone-depleting substances and divides them into two classes. Class I

controlled substances are divided into seven groups; the chemicals typically used by the

manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform

(Class I, Group V). A complete phase-out of production of Class I substances is required by

January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are

hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs.

Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances,

scheduled in phases starting by 2002, is required by January 1, 2030.

Subpart F requires that any persons servicing, maintaining, or repairing appliances except for

motor vehicle air conditioners; persons disposing of appliances, including motor vehicle air

conditioners; refrigerant reclaimers, appliance owners, and manufacturers of appliances and

recycling and recovery equipment comply with the standards for recycling and emissions

reduction.

Conditions are included in the standard conditions of the permit to address the requirements

specified at §82.156 for persons opening appliances for maintenance, service, repair, or disposal;

§82.158 for equipment used during the maintenance, service, repair, or disposal of appliances;

§82.161 for certification by an approved technician certification program of persons performing

maintenance, service, repair, or disposal of appliances; §82.166 for recordkeeping; § 82.158 for

leak repair requirements; and §82.166 for refrigerant purchase records for appliances normally

containing 50 or more pounds of refrigerant.

http://www.epa.gov/ceppo/


SECTION IX. COMPLIANCE

Inspection

A Full Compliance Evaluation (FCE) was conducted on February 8, 2008 by Berry Mantooth of

DEQ. Several violations were noted. A FCE of the facility was conducted on June 18, 2010 by

Keely Dolan of DEQ. Several violations were identified.

An initial compliance inspection for the operating permit was conducted at 1:00 PM on May 9,

2007. Ellis Fischer of Air Quality, accompanied by Brian McGuire (Corporate EH&S Manager)

and Mike Gravett (Continuous Improvement Manager), of National Standard, conducted the

inspection. The facility was physically as described in the permit application and supplemental

material. Operating records were complete and are kept at the National Standard office in

Stillwater, Oklahoma. On November 23, 2010 the facility was revisited by Ellis Fischer of Air

Quality, accompanied by Greg Donahoo of National Standard.

Tier Classification and Public Review

This application has been determined to be a Tier II based on the operating application emission

calculations. The applicant has submitted an affidavit that they are not seeking a permit for land

use or for any operations upon land owned by others without their knowledge. The affidavit

certifies that the applicant owns the land. Information on all permit actions is available for review

by the public in the Air Quality section of the DEQ Web page: www.deq.state.ok.us/.

The applicant published the “Notice of Filing a Tier II Application” in the Stillwater NewsPress,

a daily newspaper printed in the City of Stillwater, Payne County, Oklahoma, on March 1, 2007.

The notice stated that the application was available for public review at the 3602 North Perkins

Road, Stillwater, Oklahoma 74075 (location of National Standard’s facility) or at the DEQ Air

Quality Office in Oklahoma City. A copy of the draft permit will be made available to the

public.

Information on all permit actions is available for review by the public in the Air Quality section

of the DEQ Web page:http://www.deq.state.ok.us.

The applicant has submitted an affidavit that they are not seeking a permit for land use or for any

operation upon land owned by others without their knowledge. The affidavit certifies that the

applicant owns the property.

Applicant has requested that public review and EPA review run concurrently.

Stack Testing

Stack testing was conducted at the facility on January 14, 1998; September 20-21, 2000; October

12-13, 2000; and March 14, 2002. Results of the testing are tabulated following. Compliance

was demonstrated for all points tested.

http://www.deq.state.ok.us/


Emission Unit Points Emissions Limitations Test Results

Line 29 EP-33 PM10: 7.16 lb/hr

Lead: 0.36 lb/hr

PM10: 0.85 lb/hr

lead: 0.13 lb/hr

Line 39 EP-26 DRE: 90% DRE: 99.4%

Line 39 North Lead

Pots EP-27

PM10: 1.58 lb/hr

Lead: 0.041 lb/hr

PM10: 1.13 lb/hr

lead: 0.03 lb/hr

Line 39 South Lead

Pots EP-28

PM10: 1.74 lb/hr

Lead: 0.007 lb/hr

PM10: 1.24 lb/hr

lead: 0.005 lb/hr

Line 39 Scrubber EP-38 HCl: 0.137 lb/hr

Cl2: 0.143 lb/hr

HCl: 0.026 lb/hr

Cl2: 0.001 lb/hr

In 2009, the HCl tanks and scrubber were removed from Line 39 and placed in the Clean and

Coat house. In March, 2009, stack testing was performed on the scrubber stack for HCl and Cl2.

Test results indicated one skewed run due to a mechanical problem. The problem was addressed

and testing was repeated in August, 2009. Results of tests on the scrubber are listed in the table

below. Prior notifications of testing and all test results were provided to the DEQ in accordance

with regulations.

Date Unit [Discharge Point] Emissions Limitations Test Results

3-25-09

Scrubber Stack [99]

HCl: 0.644 lb/hr

Cl2: 0.287 lb/hr

PM10: 1.646 lb/hr

HCl: 0.16 lb/hr

3-26-09 HCl: 0.60 lb/hr

PM10: 1.57 lb/hr

8-19-09 HCl: 0.31 lb/hr

Cl2: 0.014 lb/hr

Fees Paid

Title V operating permit renewal application fee of $1,000.

SECTION X. SUMMARY

The facility was constructed as described in the permit application. There are active Air Quality

compliance or enforcement issues that would not affect the issuance of this permit. Issuance of

this permit does not waive any violations discovered in Full Compliance Evaluations conducted

under prior operating permits issued to the facility. Issuance of the operating permit is

recommended, contingent on public and EPA review.

DEQ Form #100-890 Revised 10/20/06

DRAFT

PART 70 PERMIT


STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2006-313-TVR

National Standard, Inc.

having complied with the requirements of the law, is hereby granted permission to operate

all the air emission sources within their boundaries at 3602 N. Perkins Road, Stillwater,

Payne County Oklahoma, subject to Standard Conditions dated July 21, 2009 and Specific

Conditions, both attached.

This permit shall expire on June 24, 2012, except as authorized under Section VIII of the

Standard Conditions.

_________________________________

Director, Air Quality Division Date

DRAFT

National Standard, Inc.

Attn: Mr. Greg Donahoo

3602 N. Perkins Road

Stillwater, OK 74075

SUBJECT: Permit Application No. 2006-313-TVR

Wire Manufacturing Operation

Stillwater, Payne County, Oklahoma

Dear Mr. Donahoo:

Air Quality Division has completed the initial review of your operating permit application

referenced above. This application has been determined to be a Tier II. In accordance with 27A

O.S. § 2-14-302 and OAC 252:4-7-13(c) the draft permit is now ready for public review. The

requirements for public review of the draft permit include the following steps, which you must

accomplish:

1. Publish at least one legal notice (one day) in at least one newspaper of general circulation

within the county where the facility is located. (Instructions enclosed).

2. Provide for public review (for a period of 30 days following the date of the newspaper

announcement) a copy of the draft permit at a convenient location within the county of the

facility.

3. Send AQD a written affidavit of publication for the notice from Item #1 above together with

any additional comments or requested changes which you may have for the permit

application within 20 days of publication.

After public review, a Proposed Permit will be submitted for EPA review. Contingent on public

and EPA review, the permit will be issued as a Title V operating permit. The permit review time

is hereby tolled pending the receipt of the affidavit of publication. Thank you for your

cooperation. If you have any questions, please refer to the permit number above and contact the

permit writer at (405) 702-4100, or at [email protected] or at (405) 702-4194.

Sincerely,

Phillip Fielder, P.E.

Permits and Engineering Group Manager


Enclosures

mailto:[email protected]

DEQ FORM # 100-822 REVISED NOVEMBER 28, 2007

APPLICANT RESPONSIBILITIES Permit applicants are required to give public notice that a Tier II or Tier III draft permit has been

prepared by DEQ. The notice must be published in one newspaper local to the site or facility.

Upon publication, a signed affidavit of publication must be obtained from the newspaper and sent

to AQD. Note that if either the applicant or the public requests a public meeting, this must be

arranged through the Customer Services Division of the DEQ.

REQUIRED CONTENT (27A O.S. § 2-14-302 and OAC 252:4-7-13(c))

1. A statement that a Tier II or Tier III draft permit has been prepared by DEQ;

2. Name and address of the applicant;

3. Name, address, driving directions, legal description and county of the site or facility;

4. The type of permit or permit action being sought;

5. A description of activities to be regulated, including an estimate of emissions from the

facility;

6. Location(s) where the application and draft permit may be reviewed (a location in the county

where the site/facility is located must be included);

7. Name, address, and telephone number of the applicant and DEQ contacts;

8. Any additional information required by DEQ rules or deemed relevant by applicant;

9. A 30-day opportunity to request a formal public meeting on the draft permit.

SAMPLE NOTICE on page 2.

NOTICE OF DRAFT PERMIT

TIER II or TIER III AIR QUALITY PERMIT APPLICATION

DEQ FORM # 100-822 REVISED NOVEMBER 28, 2007

SAMPLE NOTICE (Italicized print is to be filled in by the applicant.):

In addition to the public comment opportunity offered under this notice, this draft permit is

subject to U.S. Environmental Protection Agency (EPA) review, EPA objection, and petition to

EPA, as provided by 40 CFR § 70.8. [For Construction Permits, add: The requirements of the

construction permit will be incorporated into the Title V permit through the administrative

amendment process. Therefore, no additional opportunity to provide comments or EPA review,

EPA objection, and petitions to EPA will be available to the public when requirements from the

construction permit are incorporated into the Title V permit.]

DEQ NOTICE OF TIER …II or III… DRAFT PERMIT

A Tier …II or III… application for an air quality …type of permit or permit action being

sought (e.g., Construction Permit for a Major Facility)… has been filed with the Oklahoma

Department of Environmental Quality (DEQ) by applicant, …name and address.

The applicant requests approval to …brief description of purpose of application… at the

…site/facility name … …[proposed to be] located at …physical address (if any), driving

directions, and legal description including county…..

In response to the application, DEQ has prepared a draft permit [modification] (Permit

Number: …xx-xxx-x…), which may be reviewed at …locations (one must be in the county

where the site/facility is located)… or at the Air Quality Division's main office (see address

below). The draft permit is also available for review in the Air Quality Section of DEQ's

Web Page: http://www.deq.state.ok.us/

This draft permit would authorize the facility to emit the following regulated pollutants:

(list each pollutant and amounts in tons per year (TPY))

The public comment period ends 30 days after the date of publication of this notice. Any

person may submit written comments concerning the draft permit to the Air Quality

Division contact listed below. [Modifications only, add: Only those issues relevant to the

proposed modification(s) are open for comment.] A public meeting on the draft permit

[modification] may also be requested in writing at the same address. Note that all public

meetings are to be arranged and conducted by DEQ/CSD staff.

If the Administrator (EPA) does not object to the proposed permit, the public has 60 days

following the Administrator’s 45 day review period to petition the Administrator to make

such an objection as provided in 40 CFR 70.8(d) and in OAC 252:100-8-8(j). Information

on all permit actions and applicable review time lines is available in the Air Quality section

of the DEQ Web page: http://www.deq.state.ok.us/.

For additional information, contact …names, addresses and telephone numbers of contact

persons for the applicant, or contact DEQ at: Chief Engineer, Permits Section, Air Quality

Division, 707 N. Robinson, Suite 4100, P.O. Box 1677, Oklahoma City, OK, 73101-1677.

Phone No. (405) 702-4100.

http://www.deq.state.ok.us/

DRAFT DRAFT DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

National Standard, Inc

Stillwater Plant Permit No. 2006-313-TVR

The permittee is authorized to operate in conformity with the specifications submitted to Air

Quality on October 2, 2001, with supplemental information received December 26, 2001, April

26, 2002, December 29, 2006, October 27, 2010, and at various other times as requested. The

Evaluation Memorandum dated January 11, 2011, explains the derivation of applicable permit

requirements and estimates of emissions; however, it does not contain limitations or permit

requirements. Continuing operations under this permit constitutes acceptance of, and consent to

the conditions contained herein:

1. Applicable emissions limitations for the facility are based on 12-month rolling totals for

annual limitations and monthly averages for hourly limitations: [OAC 252:100-8-6(a)]

EUG 1: Coating Operations

Point

ID Description

VOC

lb/hr TPY

EP-37a

EP-59

EP-65

Organic Coatings 44.52 195.00

EUG 2: Combustion Units Point

ID Description

PM10 SO2 NOx CO VOC lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY

EP-41 Line 39 Lead

Furnace 0.03 0.13 0.00 0.01 0.39 1.72 0.33 1.44 0.02 0.09

EP-51 Line 29 Lead

Furnace 0.03 0.13 0.00 0.01 0.39 1.72 0.33 1.44 0.02 0.09

EP-43 Boiler No. 2 0.06 0.27 0.01 0.02 0.82 3.59 0.69 3.02 0.05 0.20

EP-44 Boiler No. 3 0.06 0.27 0.01 0.02 0.82 3.59 0.69 3.02 0.05 0.20

EP-99a Boiler No. 4 0.06 0.27 0.01 0.02 0.82 3.59 0.69 3.02 0.05 0.20

EP-99b Boiler No. 5 0.05 0.23 0.00 0.02 0.68 2.96 0.57 2.49 0.04 0.16



EUG 3: Lead Process Units

Point ID Description Pb PM10

lb/hr TPY lb/hr TPY

EP-39 Line 39 Lead Pot 0.041 0.180 1.580 6.920

EP-40 Line 39 Lead Pot 0.007 0.031 1.740 7.621

EP-49 Line 29 Lead Pot 0.180 0.788 3.580 15.680

EP-50 Line 29 Lead Pot 0.180 0.788 3.580 15.680



SPECIFIC CONDITIONS 2006-313-TVR 2

DRAFT DRAFT DRAFT

A. The permittee shall conduct Method 22 visual observations of emissions from all of the

above stacks in EUG 3 at least once per week. In no case shall the observation period be

less than six minutes in duration. If visible emissions are observed for six minutes in

duration for any observation period and such emissions are not the result of a

malfunction, then the permittee shall conduct, for the identified points, within 24 hours, a

visual observation of emissions, in accordance with 40 CFR Part 60, Appendix A,

Method 9.

B. If a Method 9 observation exceeds 20% opacity the permittee shall conduct at least two

additional Method 9 observations within the next 24-hours.

EUG 4: Acid Process and Storage Units

Point

ID Description

PM10 HCl Cl2


EP-81 Virgin HCl Tank -- -- 0.117 0.512 -- --

EP-82 Spent Acid Tank -- -- 0.00 0.02 -- --

EP-83 Spent Acid Tank -- -- 0.00 0.02 -- --

EP-99

HCl Pickling Tanks

PT-1, PT-2, PT-3,

PT-4, RT-5 and

Wet Scrubber

1.646 7.210 0.644 2.820 0.287 1.257



A. All air discharges from the HCl pickling operations of EP-99 shall be processed by a

packed bed scrubber or equivalent (95% control efficiency) controls for emissions of

HCl. A minimum liquor flow of 3 GPM shall be maintained, and a minimum pH of 5.0

of inlet scrubber liquor shall be maintained.

B. Scrubber liquor pH shall be tested at least once per day, and records of results shall be

kept.

EUG 6: Miscellaneous Insignificant Activities: The following operations are considered

insignificant since emissions are less than 5 TPY.

EU

ID

Point

ID EU Name/Model Capacity

Construction

Date

71 EP-71 Emergency Generator 365 KW (460 HP) 1975

73 EP-73 WWT Generator 15 KW (30 HP) 1992

90 EP-90 C&C Emergency Gen. 74.9 KW (100 HP) 2006

A. EP-71 generator shall not exceed 500 hours per year of operation.

B. EP-90 generator shall not exceed 500 hours per year of operation.

EUG 7: Insignificant Fuel Storage Tanks: The following storage tanks are considered

insignificant since emissions are less than 5 TPY.

EU ID Point ID Contents Capacity (gallons)

85 EP-85 Diesel 750

86 EP-86 Gasoline 300


DRAFT DRAFT DRAFT

2. Plant-wide raw material usage shall not exceed the following limits: [OAC 252:100-8-6(a)]

Raw Material Annual Usage Limit

Organic Wire Coating 60,000 gallons

The organic wire coating shall comply with OAC 252:100-37 limits.

3. The permittee shall be authorized to operate the facility continuously (24 hours per day,

every day of the year). [OAC 252:100-8-6(a)]

4. The fuel-burning equipment shall be fueled with commercial pipeline-grade natural gas.

5. The solvent vapors from the 29 Line and 39 Line may be vented to the lead furnaces burner

of the respective lines. [OAC 252:100-8-6(a)]

6. The following records shall be maintained on-site to verify insignificant activities.

[OAC 252:100-8-6(a)(3)(b)]

A. Hours of operation of the emergency generator (monthly and 12-month rolling totals).

7. The following records shall be maintained on-site. All such records shall be made available

to regulatory personnel upon request. These records shall be maintained for a period of at

least five years after the time they are made. [OAC 252:100-8-6(a)]

A. Usage of materials listed in Specific Condition Number 2 by type and quantity

(monthly and 12-month rolling total).

B. A material safety data sheet (MSDS) which documents the VOC content and

chemical composition of each product.

C. Emissions of organic solvents from coating operations (monthly and 12-month rolling

totals).

D. 40 CFR Part 60, Appendix A, Method 9.

E. Method 22 visual observations of emissions from all of the above stacks in EUG 3 at

least once per week.

F. Liquor flow and liquor pH to each packed bed wet scrubber (daily).

8. No later than 30 days after each anniversary date of the issuance of the initial Title V

operating permit (June 24, 2002), the permittee shall submit to Air Quality Division of DEQ,

with a copy to the US EPA, Region 6, a certification of compliance with the terms and

conditions of this permit. [OAC 252:100-8-6 (c)(5)(A) & (D)]

9. The Permit Shield (Standard Conditions, Section VI) is extended to the following

requirements that have been determined to be inapplicable to this facility.

[OAC 252:100-8-6(d)(2)]

A. OAC 252:100-11 Alternative Emissions Reduction

B. OAC 252:100-15 Mobile Sources

C. OAC 252:100-23 Cotton Gins

D. OAC 252:100-24 Grain Elevators

E. OAC 252:100-35 Carbon Monoxide


DRAFT DRAFT DRAFT

F. OAC 252:100-47 Landfills

G. OAC 252:100-39 Nonattainment Areas

H. 40 CFR Part 60 New Source Performance Standards

I. 40 CFR Part 61 NESHAP (as promulgated on 7/1/00)

J. 40 CFR Part 64 Compliance Assurance Monitoring

K. 40 CFR Part 72 Acid Rain

10. Within 180 days of issuance of this permit (or Start up of operations), and at other such times

as directed by Air Quality, the permittee shall conduct performance testing on Point EP-99

(HCl pickling operation wet scrubber) as follows and furnish a written report to Air Quality.

Testing shall be conducted while a process unit is being operated at least 90% of permitted

hourly capacity. A sampling protocol and notification of testing date(s) shall be submitted at

least 30 days in advance of commencement of testing. The following USEPA methods shall

be used for testing of emissions, unless otherwise approved by Air Quality:[OAC 252:100-43]

Method 1: Sample and Velocity Traverses for Stationary Sources.

Method 2: Determination of Stack Gas Velocity and Volumetric Flow Rate.

Method 3: Gas Analysis for Carbon Dioxide, Excess Air, and Dry Molecular

Weight.

Method 4: Moisture in Stack Gases.

Method 5: PM Emissions from Stationary Sources

Method 26 or 26A: Hydrogen Halide and Halogen Emissions from Stationary Sources.

11. This permit supersedes all previous Air Quality permits for this facility, which are now null

and void.

MAJOR SOURCE AIR QUALITY PERMIT

STANDARD CONDITIONS

(July 21, 2009)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with the federal

Clean Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act

and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma

Department of Environmental Quality (DEQ). The permit does not relieve the holder of the

obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or

ordinances. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance

shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement

action, permit termination, revocation and reissuance, or modification, or for denial of a permit

renewal application. All terms and conditions are enforceable by the DEQ, by the

Environmental Protection Agency (EPA), and by citizens under section 304 of the Federal Clean

Air Act (excluding state-only requirements). This permit is valid for operations only at the

specific location listed.

[40 C.F.R. §70.6(b), OAC 252:100-8-1.3 and OAC 252:100-8-6(a)(7)(A) and (b)(1)]

D. It shall not be a defense for a 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

conditions of the permit. However, nothing in this paragraph shall be construed as precluding

consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for

noncompliance if the health, safety, or environmental impacts of halting or reducing operations

would be more serious than the impacts of continuing operations. [OAC 252:100-8-6(a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from an emergency and/or posing an imminent and substantial

danger to public health, safety, or the environment shall be reported in accordance with Section

XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported

consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

[OAC 252:100-8-6(a)(3)(C)(iv)]

C. Every written report submitted under this section shall be certified as required by Section III

(Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 2

A. The permittee shall keep records as specified in this permit. These records, including

monitoring data and necessary support information, shall be retained on-site or at a nearby field

office for a period of at least five years from the date of the monitoring sample, measurement,

report, or application, and shall be made available for inspection by regulatory personnel upon

request. Support information includes all original strip-chart recordings for continuous

monitoring instrumentation, and copies of all reports required by this permit. Where appropriate,

the permit may specify that records may be maintained in computerized form.

[OAC 252:100-8-6 (a)(3)(B)(ii), OAC 252:100-8-6(c)(1), and OAC 252:100-8-6(c)(2)(B)]

B. Records of required monitoring shall include:

(1) the date, place and time of sampling or measurement;

(2) the date or dates analyses were performed;

(3) the company or entity which performed the analyses;

(4) the analytical techniques or methods used;

(5) the results of such analyses; and

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

[OAC 252:100-8-6(a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the

original Part 70 operating permit or alternative date as specifically identified in a subsequent Part

70 operating permit, the permittee shall submit to AQD a report of the results of any required

monitoring. All instances of deviations from permit requirements since the previous report shall

be clearly identified in the report. Submission of these periodic reports will satisfy any reporting

requirement of Paragraph E below that is duplicative of the periodic reports, if so noted on the

submitted report. [OAC 252:100-8-6(a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or

operator shall comply with the provisions of Section II (Reporting Of Deviations From Permit

Terms) of these standard conditions. [OAC 252:100-8-6(a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this

permit, monitoring and reporting may be required under the provisions of OAC 252:100-43,

Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean

Air Act or Oklahoma Clean Air Act. [OAC 252:100-43]

F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report,

Excess Emission Report, and Annual Emission Inventory submitted in accordance with this

permit shall be certified by a responsible official. This certification shall be signed by a

responsible official, and shall contain the following language: “I certify, based on information

and belief formed after reasonable inquiry, the statements and information in the document are

true, accurate, and complete.”

[OAC 252:100-8-5(f), OAC 252:100-8-6(a)(3)(C)(iv), OAC 252:100-8-6(c)(1), OAC

252:100-9-7(e), and OAC 252:100-5-2.1(f)]

G. Any owner or operator subject to the provisions of New Source Performance Standards


(“NSPS”) under 40 CFR Part 60 or National Emission Standards for Hazardous Air Pollutants

(“NESHAPs”) under 40 CFR Parts 61 and 63 shall maintain a file of all measurements and other

information required by the applicable general provisions and subpart(s). These records shall be

maintained in a permanent file suitable for inspection, shall be retained for a period of at least

five years as required by Paragraph A of this Section, and shall include records of the occurrence

and duration of any start-up, shutdown, or malfunction in the operation of an affected facility,

any malfunction of the air pollution control equipment; and any periods during which a

continuous monitoring system or monitoring device is inoperative.

[40 C.F.R. §§60.7 and 63.10, 40 CFR Parts 61, Subpart A, and OAC 252:100, Appendix Q]

H. The permittee of a facility that is operating subject to a schedule of compliance shall submit

to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for

achieving the activities, milestones or compliance required in the schedule of compliance and the

dates when such activities, milestones or compliance was achieved. The progress reports shall

also contain an explanation of why any dates in the schedule of compliance were not or will not

be met, and any preventive or corrective measures adopted. [OAC 252:100-8-6(c)(4)]

I. All testing must be conducted under the direction of qualified personnel by methods

approved by the Division Director. All tests shall be made and the results calculated in

accordance with standard test procedures. The use of alternative test procedures must be

approved by EPA. When a portable analyzer is used to measure emissions it shall be setup,

calibrated, and operated in accordance with the manufacturer’s instructions and in accordance

with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document

or an equivalent method approved by Air Quality.

[OAC 252:100-8-6(a)(3)(A)(iv), and OAC 252:100-43]

J. The reporting of total particulate matter emissions as required in Part 7 of OAC 252:100-8

(Permits for Part 70 Sources), OAC 252:100-19 (Control of Emission of Particulate Matter), and

OAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing

or calculation procedures, modified to include back-half condensables, for the concentration of

particulate matter less than 10 microns in diameter (PM10). NSPS may allow reporting of only

particulate matter emissions caught in the filter (obtained using Reference Method 5).

K. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required

by 40 C.F.R. Part 60, 61, and 63, for all equipment constructed or operated under this permit

subject to such standards. [OAC 252:100-8-6(c)(1) and OAC 252:100, Appendix Q]

SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70

operating permit or alternative date as specifically identified in a subsequent Part 70 operating

permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a

certification of compliance with the terms and conditions of this permit and of any other

applicable requirements which have become effective since the issuance of this permit.

[OAC 252:100-8-6(c)(5)(A), and (D)]

B. The compliance certification shall describe the operating permit term or condition that is the


basis of the certification; the current compliance status; whether compliance was continuous or

intermittent; the methods used for determining compliance, currently and over the reporting

period. The compliance certification shall also include such other facts as the permitting

authority may require to determine the compliance status of the source.

[OAC 252:100-8-6(c)(5)(C)(i)-(v)]

C. The compliance certification shall contain a certification by a responsible official as to the

results of the required monitoring. This certification shall be signed by a responsible official,

and shall contain the following language: “I certify, based on information and belief formed

after reasonable inquiry, the statements and information in the document are true, accurate, and

complete.” [OAC 252:100-8-5(f) and OAC 252:100-8-6(c)(1)]

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions

units or stationary sources that are not in compliance with all applicable requirements. This

schedule shall include a schedule of remedial measures, including an enforceable sequence of

actions with milestones, leading to compliance with any applicable requirements for which the

emissions unit or stationary source is in noncompliance. This compliance schedule shall

resemble and be at least as stringent as that contained in any judicial consent decree or

administrative order to which the emissions unit or stationary source is subject. Any such

schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the

applicable requirements on which it is based, except that a compliance plan shall not be required

for any noncompliance condition which is corrected within 24 hours of discovery.

[OAC 252:100-8-5(e)(8)(B) and OAC 252:100-8-6(c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the

permit term and that are applicable to the facility. Compliance with all new requirements shall

be certified in the next annual certification. [OAC 252:100-8-6(c)(6)]

SECTION VI. 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, but

excluding terms and conditions for which the permit shield is expressly prohibited under OAC

252:100-8) shall be deemed compliance with the applicable requirements identified and included

in this permit. [OAC 252:100-8-6(d)(1)]

B. Those requirements that are applicable are listed in the Standard Conditions and the Specific

Conditions of this permit. Those requirements that the applicant requested be determined as not

applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6(d)(2)]

SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees


based on emissions inventories. The methods used to calculate emissions for inventory purposes

shall be based on the best available information accepted by AQD.

[OAC 252:100-5-2.1, OAC 252:100-5-2.2, and OAC 252:100-8-6(a)(8)]

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date

of issuance. [OAC 252:100-8-6(a)(2)(A)]

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely

and complete renewal application has been submitted at least 180 days before the date of

expiration. [OAC 252:100-8-7.1(d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and

become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction

is not commenced within 18 months after the date the permit or authorization was issued, or if

work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit shall apply for a permit to operate (or modified

operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application

of any provision of this permit to any circumstance, is held invalid, the application of such

provision to other circumstances, and the remainder of this permit, shall not be affected thereby.

[OAC 252:100-8-6 (a)(6)]

SECTION X. PROPERTY RIGHTS

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

[OAC 252:100-8-6(a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon

which the equipment is located and does not release the permittee from any liability for damage

to persons or property caused by or resulting from the maintenance or operation of the equipment

for which the permit is issued. [OAC 252:100-8-6(c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty

(60) days of the request unless the DEQ specifies another time period, any information that the

DEQ may request to determine whether cause exists for modifying, reopening, revoking,

reissuing, terminating the permit or to determine compliance with the permit. Upon request, the

permittee shall also furnish to the DEQ copies of records required to be kept by the permit.

[OAC 252:100-8-6(a)(7)(E)]


B. The permittee may make a claim of confidentiality for any information or records submitted

pursuant to 27A O.S. § 2-5-105(18). Confidential information shall be clearly labeled as such

and shall be separable from the main body of the document such as in an attachment.

[OAC 252:100-8-6(a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and

shall be made in writing within thirty (30) days after such sale or transfer.

[Oklahoma Clean Air Act, 27A O.S. § 2-5-112(G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause.

Except as provided for minor permit modifications, the filing of a request by the permittee for a

permit modification, revocation and reissuance, termination, notification of planned changes, or

anticipated noncompliance does not stay any permit condition.

[OAC 252:100-8-6(a)(7)(C) and OAC 252:100-8-7.2(b)]

B. The DEQ will reopen and revise or revoke this permit prior to the expiration date in the

following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source

category three or more years prior to the expiration date of this permit. No such

reopening is required if the effective date of the requirement is later than the expiration

date of this permit.

(2) The DEQ or the EPA determines that this permit contains a material mistake or that the

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

(3) The DEQ or the EPA determines that inaccurate information was used in establishing the

emission standards, limitations, or other conditions of this permit. The DEQ may revoke

and not reissue this permit if it determines that the permittee has submitted false or

misleading information to the DEQ.

(4) DEQ determines that the permit should be amended under the discretionary reopening

provisions of OAC 252:100-8-7.3(b).

C. The permit may be reopened for cause by EPA, pursuant to the provisions of OAC 100-8-

7.3(d). [OAC 100-8-7.3(d)]

D. The permittee shall notify AQD before making changes other than those described in Section

XVIII (Operational Flexibility), those qualifying for administrative permit amendments, or those

defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII). The

notification should include any changes which may alter the status of a “grandfathered source,”

as defined under AQD rules. Such changes may require a permit modification.

[OAC 252:100-8-7.2(b) and OAC 252:100-5-1.1]

E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that

are not specifically approved by this permit are prohibited. [OAC 252:100-8-6(c)(6)]


SECTION XIII. INSPECTION & ENTRY

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

permittee shall allow authorized regulatory officials to perform the following (subject to the

permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(18)

for confidential information submitted to or obtained by the DEQ under this section):

(1) enter upon the permittee's premises during reasonable/normal working hours where a

source is located or emissions-related activity is conducted, or where records must be

kept under the conditions of the permit;

(2) have access to and copy, at reasonable times, any records that must be kept under the

conditions of the permit;

(3) inspect, at reasonable times and using reasonable safety practices, any facilities,

equipment (including monitoring and air pollution control equipment), practices, or

operations regulated or required under the permit; and

(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times

substances or parameters for the purpose of assuring compliance with the permit.

[OAC 252:100-8-6(c)(2)]

SECTION XIV. EMERGENCIES

A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later

than 4:30 p.m. on the next working day after the permittee first becomes aware of the

exceedance. This notice shall contain a description of the emergency, the probable cause of the

exceedance, any steps taken to mitigate emissions, and corrective actions taken.

[OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (IV)]

B. Any exceedance that poses an imminent and substantial danger to public health, safety, or the

environment shall be reported to AQD as soon as is practicable; but under no circumstance shall

notification be more than 24 hours after the exceedance. [OAC 252:100-8-6(a)(3)(C)(iii)(II)]

C. An "emergency" means any situation arising from sudden and reasonably unforeseeable

events beyond the control of the source, including acts of God, which situation requires

immediate corrective action to restore normal operation, and that causes the source to exceed a

technology-based emission limitation under this permit, due to unavoidable increases in

emissions attributable to the emergency. An emergency shall not include noncompliance to the

extent caused by improperly designed equipment, lack of preventive maintenance, careless or

improper operation, or operator error. [OAC 252:100-8-2]

D. The affirmative defense of emergency shall be demonstrated through properly signed,

contemporaneous operating logs or other relevant evidence that: [OAC 252:100-8-6 (e)(2)]

(1) an emergency occurred and the permittee can identify the cause or causes of the

emergency;

(2) the permitted facility was at the time being properly operated;

(3) during the period of the emergency the permittee took all reasonable steps to minimize


levels of emissions that exceeded the emission standards or other requirements in this

permit.

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an

emergency shall have the burden of proof. [OAC 252:100-8-6(e)(3)]

F. Every written report or document submitted under this section shall be certified as required

by Section III (Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop

and register with the appropriate agency a risk management plan by June 20, 1999, or the

applicable effective date. [OAC 252:100-8-6(a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate individual emissions units that are either on the list in Appendix I to OAC Title 252,

Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below.

Any activity to which a State or Federal applicable requirement applies is not insignificant even

if it meets the criteria below or is included on the insignificant activities list.

(1) 5 tons per year of any one criteria pollutant.

(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an

aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year

for single HAP that the EPA may establish by rule.

[OAC 252:100-8-2 and OAC 252:100, Appendix I]

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate any individual or combination of air emissions units that are considered inconsequential

and are on the list in Appendix J. Any activity to which a State or Federal applicable

requirement applies is not trivial even if included on the trivial activities list.

[OAC 252:100-8-2 and OAC 252:100, Appendix J]

SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the

need for any permit revision or any notification to the DEQ (unless specified otherwise in the

permit). When an operating scenario is changed, the permittee shall record in a log at the facility

the scenario under which it is operating. [OAC 252:100-8-6(a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:


(1) result in no net emissions increases,

(2) are not modifications under any provision of Title I of the federal Clean Air Act, and

(3) do not cause any hourly or annual permitted emission rate of any existing emissions unit

to be exceeded;

provided that the facility provides the EPA and the DEQ with written notification as required

below in advance of the proposed changes, which shall be a minimum of seven (7) days, or

twenty four (24) hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the

DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such

change, the written notification required above shall include a brief description of the change

within the permitted facility, the date on which the change will occur, any change in emissions,

and any permit term or condition that is no longer applicable as a result of the change. The

permit shield provided by this permit does not apply to any change made pursuant to this

paragraph. [OAC 252:100-8-6(f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility

unless elsewhere covered by a more restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized

in the specific examples and under the conditions listed in the Open Burning Subchapter.

[OAC 252:100-13]

(2) No particulate emissions from any fuel-burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(3) For all emissions units not subject to an opacity limit promulgated under 40 C.F.R., Part

60, NSPS, no discharge of greater than 20% opacity is allowed except for:

[OAC 252:100-25]

(a) Short-term occurrences which consist of not more than one six-minute period in any

consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours.

In no case shall the average of any six-minute period exceed 60% opacity;

(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7;

(c) An emission, where the presence of uncombined water is the only reason for failure

to meet the requirements of OAC 252:100-25-3(a); or

(d) Smoke generated due to a malfunction in a facility, when the source of the fuel

producing the smoke is not under the direct and immediate control of the facility and

the immediate constriction of the fuel flow at the facility would produce a hazard to

life and/or property.

(4) No visible fugitive dust emissions shall be discharged beyond the property line on which

the emissions originate in such a manner as to damage or to interfere with the use of

adjacent properties, or cause air quality standards to be exceeded, or interfere with the

maintenance of air quality standards. [OAC 252:100-29]


(5) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2

lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur

dioxide. [OAC 252:100-31]

(6) Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and

with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia

or greater under actual conditions shall be equipped with a permanent submerged fill pipe

or with a vapor-recovery system. [OAC 252:100-37-15(b)]

(7) All fuel-burning equipment shall at all times be properly operated and maintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of

ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an order for production or importation of certain

class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the

requirements of §82.4;

(2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain

class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping

requirements at §82.13; and

(3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,

HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane

(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an

ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air

conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term

“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the

vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the

air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger

buses using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions

reduction except as provided for MVACs in Subpart B: [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, service, repair, or disposal must comply

with the required practices pursuant to § 82.156;

(2) Equipment used during the maintenance, service, repair, or disposal of appliances must

comply with the standards for recycling and recovery equipment pursuant to § 82.158;

(3) Persons performing maintenance, service, repair, or disposal of appliances must be

certified by an approved technician certification program pursuant to § 82.161;

(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply


with record-keeping requirements pursuant to § 82.166;

(5) Persons owning commercial or industrial process refrigeration equipment must comply

with leak repair requirements pursuant to § 82.158; and

(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant

must keep records of refrigerant purchased and added to such appliances pursuant to §

82.166.

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is

not inconsistent with Federal requirements, to provide for incorporation of requirements

established through construction permitting into the Source’s Title V permit without causing

redundant review. Requirements from construction permits may be incorporated into the Title V

permit through the administrative amendment process set forth in OAC 252:100-8-7.2(a) only if

the following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the

procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice

to the public that this permit is subject to EPA review, EPA objection, and petition to

EPA, as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit

will be incorporated into the Title V permit through the administrative amendment

process; that the public will not receive another opportunity to provide comments when

the requirements are incorporated into the Title V permit; and that EPA review, EPA

objection, and petitions to EPA will not be available to the public when requirements

from the construction permit are incorporated into the Title V permit.

(2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR §

70.8(a)(1).

(3) A copy of the draft construction permit is sent to any affected State, as provided by 40

C.F.R. § 70.8(b).

(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period

as provided by 40 C.F.R.§ 70.8(a) and (c).

(5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day

comment period of any EPA objection to the construction permit. The DEQ shall not

issue the permit until EPA’s objections are resolved to the satisfaction of EPA.

(6) The DEQ complies with 40 C.F.R. § 70.8(d).

(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8(a).

(8) The DEQ shall not issue the proposed construction permit until any affected State and

EPA have had an opportunity to review the proposed permit, as provided by these

permit conditions.

(9) Any requirements of the construction permit may be reopened for cause after

incorporation into the Title V permit by the administrative amendment process, by

DEQ as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40

C.F.R. § 70.7(f) and (g).

(10) The DEQ shall not issue the administrative permit amendment if performance tests fail

to demonstrate that the source is operating in substantial compliance with all permit

requirements.


B. To the extent that these conditions are not followed, the Title V permit must go through the

Title V review process.

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing

shall preclude the use, including the exclusive use, of any credible evidence or information,

relevant to whether a source would have been in compliance with applicable requirements if the

appropriate performance or compliance test or procedure had been performed.

[OAC 252:100-43-6]

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