DRAFT. MEMORANDUM May 18, Kendal Stegmann, Sr. Environmental Manager, Compliance and Enforcement

Transcription

1 DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM May 18, 2009 TO: THROUGH: THROUGH: THROUGH: FROM: SUBJECT: Phillip Fielder, Permits and Engr. Group Mgr. Kendal Stegmann, Sr. Environmental Manager, Compliance and Enforcement Phil Martin, P.E., Engineering Section Peer Review, David Pollard, DEQ Regional Office at Tulsa Herb Neumann, DEQ Regional Office at Tulsa Evaluation of Permit Application No TVR Tracker Marine, LLC Tracker Miami Plant, Boat Manufacturing Facility 3807 Tahoe Way, Miami, Ottawa County, OK Sec 12, T28N, R22E ( N, W) Driving directions: From the intersection of OK 10 and US 69 in Miami, north approximately 3.5 miles on US 69, approximately ¼ mile west on E 65 (Newman) Road to Tahoe. The office is on the south side of Plant III, the large building at the northwest corner of the property. I. INTRODUCTION The Tracker Marine boat manufacturing facility (SIC Code 3732) began emission-related activities in March 2003 and currently operates under Part 70 Operating Permit No TV (M-2), issued August 2, Applicant now applies for a renewal of its Part 70 permit. Minor changes in stack configuration and in emission factors are addressed at appropriate points in this Memorandum. The facility now performs start-up tests on each stern-drive engine installed on their boats. Treatment of this new emission point is included in this memorandum and reflected in the renewal permit. II. PROCESS DESCRIPTION Many boat-manufacturing companies have occupied this property, with some estimates that activities might date as far back as the 1950s. As mentioned above, Tracker began its operation of the facility in The facility contains numerous structures on approximately 50 acres. A plat of the facility identifies buildings called Plant I, Plant II, Plant III, Small Parts, and Tooling. There are other smaller buildings, including office space and storage space. Manufacturing is currently taking place in Plant III, Small Parts, Tooling, and Plant II.

2 PERMIT MEMORANDUM TVR DRAFT 2 Plant III is somewhat T-shaped, and accommodates boat manufacturing processes such as hull and deck lay-up, setting stringers, installing plumbing, spraying polyurethane foam for flotation, upholstery, plumbing, wiring, and engine installation. Operational repairs and maintenance also take place in Plant III. Several small parts for the boats are manufactured in the Small Parts building and in Plant III. Finally, molds are constructed and repaired in the Tooling building. The boats being manufactured are called reinforced plastic composite boats by this facility and are also commonly referred to as fiberglass boats. The manufacturing process uses both fiberglass and polymerization of styrene, so the resulting material is also commonly known as fiberglass reinforced plastic, or FRP. The following description of the process is loosely modeled on the description found in 40 CFR 63 Subpart VVVV, the Boat Manufacturing MACT. FRP boats are manufactured by laying fiberglass reinforcements in a mold and saturating the mold with a polyester or vinyl ester plastic resin. The liquid resin is mixed with a cross-linking catalyst as it is applied, causing the resin to harden into a solid, creating a rigid plastic part strengthened by the fiberglass. There are open molding and closed molding processes used in FRP production, but the hulls and decks of boats are too large for current closed molding technology. While the facility has some processes similar to closed molding, it does not have any true closed molding. Decks and hulls are built in parallel production lines in the upright section of the T formed by Plant III. There are four stations for hull lay-up and 5 stations for deck lay-up. Molds of each section start at the bottom of the T and the boat is built up in layers on the mold, which essentially builds the boat from the outside to the inside of the finished product. The mold is first sprayed with a layer of gel coat, which is a pigmented polyester resin that hardens and becomes the smooth surface of the part. The inside of the hardened gel coat layer is coated with a skin coat of chopped fiberglass fibers and polyester or vinylester resin. Additional coats are applied until the desired thickness is achieved; with the minor difference that fiberglass is applied in layers, rather than as chopped fibers. The same type of flow coating gun is used throughout, with an attachment available to provide a flow of chopped fiberglass. Molds and small parts are constructed using the same basic process. The use of methyl ethyl ketone peroxide (MEKP) as a liquid catalyst allows the parts to be cured at room temperature. Resin and gel coat application equipment require solvent cleaning to flush uncured resin or gel coat after each use to prevent the material from catalyzing in the hoses or guns. The facility performs this cleaning with acetone, a solvent not regulated as a VOC by EPA or DEQ. As mentioned in the preceding paragraph, molds are constructed in the same manner as boat components. The resins and gel coats used for mold construction and for repair of damaged molds are special high-performance versions of the normal resins or gel coats. Because molds are reused, they must be cleaned and prepared for each new part to be manufactured on them. Because the wet resin would bond to the mold without a protective barrier, a mold release agent called mold wax is applied to the mold before the new part is started. Mold wax is a blend of solid waxes and liquid petroleum distillates, much like automotive car wax. It is applied, allowed to dry, and any dry residue is removed. As many coats are applied as necessary to achieve the desired characteristics allowing for easy removal of the manufactured part from the mold. More coats are needed for new

3 PERMIT MEMORANDUM TVR DRAFT 3 molds. Accumulated wax deposits are removed from the mold with a mold cleaner that is simply applied and wiped off. All components may require additional work before being assembled into a finished boat. For instance, excess material may need to be cut or ground off, holes may be drilled, routing may be required, or some finish sanding may be necessary. Additional wooden parts are needed in some boats for extra rigidity (stringers) or for space separation in some spots. This amounts to approximately one half sheet of plywood per boat. Particulate emissions from laminate grinding and woodworking operations are all passed through dust collection systems and HEPA filters before exhausting inside the building. Laminate grinding is performed in a room whose sidewalls are air exhausts, and whose ends are air screens, providing a negative pressure environment. The various woodworking pieces of equipment are fitted with vacuum exhausts near the work surface, all of which are manifolded together into a cyclone located outside the building. The cyclone exhaust is ducted into a HEPA filter that exhausts inside the workspace. When the hull and liner of some boats come off their respective fabrication lines, they are joined using a two-part reactive adhesive containing methyl methacrylate (MMA). Final steps taken to finish each boat include plumbing, electrical wiring, application of flotation foam, installation of carpeting, and installation of the engine. Flotation foam is a two-part polyurethane foam that is applied to provide buoyancy in the event the boat is swamped. The foam is usually mixed and poured, but can be sprayed. Carpeting is installed for appearance, to provide traction, and to absorb sound. It is typically applied using a contact adhesive. Various fabrics and carpets are measured, cut and trimmed for covering wood, FRP, and aluminum panels and for covering various other wood parts constructed in the woodshop. These upholstered parts are used for installation as luxury accessory packages installed on some boats. Most upholstery attachment to wood components is accomplished using staple guns. Any minor amount of gluing is done using a spray gun. Production resin is delivered by tank truck and is stored in four 5,000-gallon tanks, while tooling resins and all gel coats are delivered and stored in 55-gallon drums. Recent information from the American Composite Manufacturers Association (ACMA) indicates that certain non-hap VOCs may be contained in the resins used by boat manufacturers. Due to proprietary considerations, OSHA allows these constituents to be reported in generic concentration ranges, rather than in specific percentages. Because Tracker was unaware of these constituents, it has established a new category of recording to accurately report all emissions. This will be addressed further in Section IV (Emissions). Total VOC emissions will continue to be authorized at the level of 249 TPY, below the PSD threshold. The facility tests engines installed on their boats. Each engine is run for ten minutes. There are five models of direct injection engine and four models of carbureted engines. Direct injection models are rated at 425-hp, 320-hp, 220-hp and two at 300-hp each. The carbureted engines are rated at 250-hp, 220-hp, 190-hp and 135-hp. The facility maintains records of all engine testing and calculations of emission estimates.

4 PERMIT MEMORANDUM TVR DRAFT 4 III. EQUIPMENT The bulk of all emission activities relate to the lamination (or lay-up ) process by which boats and molds are manufactured. The original permit application created EUGs for each of four buildings or locations to represent the specific activities occurring in each. Because all of these activities are subject to a common set of rules and regulations, all activities and buildings are now contained in a single EUG to comply with EPA guidance. EUG 1 Lamination and Assembly This EUG contains numerous emission sources. Since the exact nature of these sources or emission units (EUs) is subject to change based on the boat models to be manufactured, and since the individual points are subject to a facility-wide standard, the points are not individually identified. They include resin application, gel coat application, assembly adhesive application, and carpet installation. For example, on December 23, 2008, Plant III Lamination contained eight gelcoat guns, seven flow coater guns, two base coat guns, two foam guns, and 16 carpet adhesive guns. Small Parts Lamination contained one gelcoat gun and one resin gun on December 23, Tooling Lamination contains high-performance gel coat and resin applications, and contained two gelcoat guns and two flow coater guns on December 23, Plant II Lamination contained six gelcoat guns, six flow coater guns, no base coat guns, two foam guns, five carpet adhesive guns, and closed molding equipment on December 23, EUG 2 Empty. Equipment and descriptions formerly contained in this EUG are now found in EUG 1. EUG 3 Empty. Equipment and descriptions formerly contained in this EUG are now found in EUG 1. EUG 4 Plant-wide This EUG is established to address those rules or regulations that apply to the entire facility, including such rules as open burning or fugitive dust. EUG 5 Empty. Equipment and descriptions formerly contained in this EUG are now found in EUG 1. EUG 6 Engine Testing As mentioned above, this EUG is established to consider the emissions involved in testing the various engines before shipping the finished product. Stack Parameters The following table describes Plant III, Small Parts, Tooling, and Plant II as-built stacks.

5 PERMIT MEMORANDUM TVR DRAFT 5 Diameter Height Exhaust velocity Building Point # Activity (in) (ft) (fpm) 1, 2, 3, 4, 13 Deck lamination ,490 5, 6, 7, 8 Hull lamination ,490 Plant III 9 Hull gel coat , Deck gel coat ,436 14, 15 Base coat ,435 Small Parts 1 Building exhaust ,400 Tooling 1 Building exhaust ,490 1, 2 Deck lamination ,436 3 Base coat ,490 Plant II 4 Deck lamination ,436 5 Gelcoating ,488 6 Hull lamination ,482 7 Hull lamination ,410 IV. EMISSIONS As noted in the previous discussion, particulate emissions are generally negligible, or at least qualify as Insignificant Activities. Products of combustion also qualify as Insignificant, leaving various sources of VOC as the only emissions to be considered in detail. The principal concern is styrene, followed by MMA, and then by several less important VOCs. Styrene Styrene emissions are primarily generated in Plant III and Plant II during gel coat and resin application and open air curing, but these same processes occur in both the Small Parts and Tooling buildings. Emissions estimates for the facility have been calculated using the latest version (June 11, 2008) of Technical Discussion of the Unified Emission Factors for Open Molding of Composites (UEF) prepared for the American Composites Manufacturers Association (ACMA) and accepted by the American National Standards Institute (ANSI). The emission factors provided by the UEF are given in pounds of styrene emitted per ton of resin or gel coat used. Each factor is based upon a complex of conditions, including styrene content of the resin or gel coat, application process, vapor suppressant additives, and any special pollution prevention techniques employed. Because the facility has requested a facility-wide emission limit so that they may vary the type and quantity of material used to reflect changing market needs, there is no reason to establish limits on any particular material. A secondary source of emissions centers on the resin storage tanks. Tank characteristics of 5,000 gallons, 8.5 diameter, 14 height, 12 average headspace height, maximum 120 fills per year, pure production resin vapor pressure of 5 mm Hg, and indoor temperature were input to Tanks 3.1, yielding annual emissions of 57 pounds per tank. Total styrene emissions of 0.11 TPY from these four tanks is negligible.

6 PERMIT MEMORANDUM TVR DRAFT 6 MMA The UEF evaluation for MMA is much simpler than it was for styrene. All considerations other than quantity disappear and emissions of MMA are calculated at 75% of the available monomer present in each gel coat. Other VOC There are two other primary sources of VOC; carpet adhesives and mold cleaners. Carpet adhesives contain various VOCs, including heptane and mineral spirits. Similarly, mold cleaners contain VOCs such as xylene (a HAP) and some non-hap petroleum hydrocarbons. Additionally, recent analysis of resins and gelcoats shows that they contain some VOC that is proprietary in nature and is not required to be reported in detail by OSHA. Principal among these is methyl styrene, for which the ACMA has provided guidelines to be used in conjunction with the UEF table. Currently, the guideline indicates that a factor equal to 55% of the styrene factor for the particular resin should be used. Thus, if the styrene emission factor for a specific concentration of styrene is represented by S, then the emission factor for an equivalent concentration of methyl styrene is 0.55 S. Comments The two most commonly used catalysts, MEKP and dimethyl phthalate (DMP) are generally completely consumed in the reaction. The facility chooses not to use DMP, a HAP, at this location. MEKP is received at the facility as a solution with some methyl ethyl ketone (MEK) that is released during use. MEKP is added in proportions of only 1% to 2% of the resin, and MEK is only a fraction of the MEKP. The facility has also provided estimates of aerosol emissions of resin as a particulate. This discussion is similar to the sort of analysis associated with overspray in a conventional surface coating operation. A conservatively high assumption of 10 lbs/hr of such aerosols, coupled with 24-hour operations five days per week and 50 weeks per year, yields emissions of 1.5 TPY. Note that this estimate is little more than a conservatively high guess, because no data exist to support or refute this calculation. The facility has requested annual VOC emission limits as follow. Material Annual emissions (TPY) Styrene 191 MMA 23 Other resin & gelcoat, carpet adhesive, & miscellaneous VOCs 35 Total VOC (all of the above) 249 Emission factors for the engines are taken from Exhaust Emission Factors for Nonroad Engine Modeling: Spark Ignition NR-10e, EPA420-R (12/05). NR-10e is one of a series of reports concerning aspects of nonroad engines. It describes and documents exhaust emission factors, crankcase estimates, and BSFC estimates used for SI engines. Table 9 covers Marine Engine Technology Class and Designations, classifying engines by various parameters; first by outboard or stern-drive inboard, second by cycle, third by fuel system, and fourth by after treatment. Designation as to Nonroad 2004 or Nonroad 2005 are then applied, yielding a total of

7 PERMIT MEMORANDUM TVR DRAFT 7 15 Technology Types. Table 10 then is a look-up table that gives emission factors based on horsepower and technology type. Emission factors (g/hp-hr) Pollutant Direct injection Carbureted NO X CO VOC PM Emissions resulting from the PM factor are significantly less than one TPY and will be considered negligible for this analysis. The following table lists the maximum number of each type of engine tested in any month during the ten months of data available. Engine type # tested Engine type # tested 425 hp Direct Inj hp Carb hp Direct Inj hp Carb hp Direct Inj hp Carb hp Direct Inj hp Carb 133 Assume that at least one 425 hp DI engine will be tested each month in the future and assume that the figures listed above could be achieved each month. This would yield engine testing at approximately 165% of the historical rate. Direct injection engines with aggregate 40,245 hp would be tested each month and carbureted engines with aggregate 90,395 hp would be tested each month. If each engine were to be tested for ten minutes, the following table represents emissions, using all of the data above. Pollutant Direct Injection Carbureted Factor (g/hp-hr) TPY Factor (g/hp-hr) TPY Total TPY NO X CO VOC V. INSIGNIFICANT ACTIVITIES The insignificant activities identified in the application are listed below. Appropriate recordkeeping of activities indicated below with an asterisk is identified in the Specific Conditions. 1. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBTU/hr heat input (commercial natural gas). None identified; may be used in the future. 2. *Emissions from fuel storage/dispensing equipment operated solely for facility owned vehicles if fuel throughput is not more than 2,175 gallons/day averaged over a 30-day

8 PERMIT MEMORANDUM TVR DRAFT 8 period. Fuel for vehicles is purchased off-site, but the facility may wish to buy in bulk at some time in the future. 3. *Storage tanks with less than or equal to 10,000-gallons capacity that store volatile organic liquids with a true vapor pressure less than or equal to 1.0 psia at maximum storage temperature. Four 5,000-gallon storage tanks contain production resin with 5 mm Hg vapor pressure. 4. Hazardous waste and hazardous materials drum staging areas. 5. *Surface coating and degreasing operations which do not exceed a combined total usage of more than 60 gallons/month of coatings, thinners, clean-up solvents, and degreasing solvents at any one emissions unit. 6. Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including hazardous waste satellite (accumulation) areas. 7. Hand wiping and spraying of solvents from containers with less than 1-liter capacity used for spot cleaning and/or degreasing in ozone attainment areas. 8. *Activities that have the potential to emit no more than 5 TPY (actual) of any criteria pollutant. Emissions from sanding and grinding of the boats and from wood shop activities are collected and exhausted into the interior of their respective buildings. These activities are considered to be Trivial and do not require recordkeeping. Other activities with actual emissions of less than 5 TPY may occur in the future. VI. OKLAHOMA AIR POLLUTION CONTROL RULES OAC 252:100-1 (General Provisions) Subchapter 1 includes definitions but there are no regulatory requirements. [Applicable] OAC 252:100-2 (Incorporation by Reference) [Applicable] This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal Regulations listed in OAC 252:100, Appendix Q. These requirements are addressed in the Federal Regulations section. 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 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable] Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission inventories annually, and pay annual operating fees based upon total annual emissions of

9 PERMIT MEMORANDUM TVR DRAFT 9 regulated pollutants. Emission inventories were submitted and fees paid for previous years as required. OAC 252:100-8 (Permits for Part 70 Sources) [Applicable] Part 5 includes the general administrative requirements for Part 70 permits. Any planned changes in the operation of the facility that result in emissions not authorized in the permit and that exceed the Insignificant Activities or Trivial Activities thresholds require prior notification to AQD and may require a permit modification. Insignificant activities refer to those individual emission units either listed in Appendix I 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 a HAP that the EPA may establish by rule Emission limitations and operational requirements necessary to assure compliance with all applicable requirements for all sources are taken from the existing operating permit or developed from the applicable requirement. OAC 252:100-9 (Excess Emissions Reporting Requirements) [Applicable] In the event of any release that results in excess emissions, the owner or operator of such facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10) working days after the immediate notice is given, the owner or operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. In addition, if the owner or operator wishes to be considered for the exemption established in 252: , a Demonstration of Cause must be submitted within 30 calendar days after the occurrence has ended. OAC 252: (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: (Particulate Matter (PM)) [Not Applicable] Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment, with emission limits based on maximum design heat input rating. Fuel-burning equipment is defined in OAC 252: as any internal combustion engine or gas turbine, or other combustion device used to convert the combustion of fuel into usable energy. This facility has no fuel-burning equipment. Section limits particulate emissions from new and existing directly fired fuel-burning units and emission points in an industrial process based on process weight rate, as specified in Appendix G. As noted, there are no fuel-burning units and the only other sources of particulate emissions are trivial sources with negligible emissions.

10 PERMIT MEMORANDUM TVR DRAFT 10 OAC 252: (Visible Emissions and Particulates) [Applicable] No discharge of greater than 20% opacity is allowed except for short-term occurrences that 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. There are no operations likely to cause visible emissions, so no special precautions are required. OAC 252: (Fugitive Dust) [Applicable] No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the emissions originated 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 operating conditions, this facility has negligible potential to violate this requirement; therefore it is not necessary to require specific precautions to be taken. OAC 252: (Sulfur Compounds) [Not Applicable] Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1, 1972). There are no production combustion devices. OAC 252: (Nitrogen Oxides) [Not Applicable] This subchapter limits new gas-fired fuel-burning equipment with rated heat input greater than or equal to 50 MMBTUH to emissions of 0.2 lbs of NO X per MMBTU, three-hour average. There are no production combustion devices of any size. OAC 252: (Carbon Monoxide) [Not Applicable] This subchapter affects gray iron cupolas, blast furnaces, basic oxygen furnaces, petroleum catalytic cracking units, and petroleum catalytic reforming units. There are no affected sources. OAC 252: (Volatile Organic Compounds) [Applicable] Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. There are four 5,000- gallon resin storage tanks with submerged fill pipes. Production resin has a vapor pressure of 5 mm Hg, well below the 1.5 psia ( 78 mm Hg) threshold. Part 5 limits the VOC content of coatings used in coating lines and operations. The gel coats contain pigments and might be considered to be coatings. The only VOC contained in the gel coats is a monomer that is catalyzed into a solid, with only a tiny fraction of the monomer actually emitted. Such emissions are well below any threshold set in this part. The resins are not surface coatings and are not subject to the solvent content limitations of Part 5. This part further requires all emissions of VOC from the cleanup of any article, machine, or equipment used in applying coatings to be included when determining compliance with the above stated solvent limitations and emission limits. All cleanup is done using acetone, which is not regulated as a VOC. Coating or painting for routine maintenance of the facility and equipment are not affected operations.

11 PERMIT MEMORANDUM TVR DRAFT 11 OAC 252: (Toxic Air Contaminants (TAC)) [Applicable] This subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in areas of concern (AOC). 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 AOC has been designated there are no specific requirements for this facility at this time. OAC 252: (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: Alternative Emissions Reduction not requested OAC 252: Mobile Sources not in source category OAC 252: Incinerators not type of emission unit OAC 252: Cotton Gins not type of emission unit OAC 252: Grain Elevators not in source category OAC 252: Nitrogen Dioxides not in source category OAC Carbon Monoxide not type of emission unit OAC 252: Nonattainment Areas not in area category OAC 252: MSWL not in source category VII. FEDERAL REGULATIONS PSD, 40 CFR Part 52 [Not Applicable] Total emissions are less than the major source threshold of 250 TPY of any single regulated pollutant and the facility is not one of the listed stationary sources with a threshold of 100 TPY.

12 PERMIT MEMORANDUM TVR DRAFT 12 NSPS, 40 CFR Part 60 [Not Applicable] Subparts K, Ka, Kb, VOL Storage Vessels. There are no tanks with capacity greater than the smallest threshold capacity listed in any of these subparts. NESHAP, 40 CFR Part 61 [Not Applicable] There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium, coke oven emissions, mercury, radionuclides or vinyl chloride. NESHAP, 40 CFR 63 [Subpart VVVV Applicable] Subpart VVVV (Boat Manufacturing) affects new and existing boat manufacturing facilities with resin and gelcoat operations, carpet and fabric adhesive operations, or aluminum recreational boat surface coating operations. This facility is a major source of HAPs and is required in the permit to comply with the requirements of the MACT. This discussion treats the facility as new for all purposes. There are work practice or good housekeeping standards as well as material content standards. Six boat manufacturing operations are listed in as affected sources under VVVV, four of which occur at this facility: (a) open molding resin and gel coat operations, (c) resin and gel coat mixing operations, (d) resin and gel coat application equipment cleaning operations, and (e) carpet and fabric adhesive operations. (a) sets a rolling 12-month limit on HAP emissions from open molding operations using production resin, pigmented gel coat, clear gel coat, tooling resin, and tooling gel coat. HAP emissions from open molding operations using production resin, pigmented gel coat, clear gel coat, tooling resin, and tooling gel coat are limited by the following formula. HAP limit = [46(M R ) + 159(M PG ) + 291(M CG ) + 54(M TR ) + 214(M TG )] where HAP limit = total allowable organic HAP in kilograms M R = mass of production resin M PG = mass of production gel coat M CG = mass of clear gel coat M TR = mass of tooling resin M TG = mass of tooling gel coat, with all masses (M) in megagrams, cumulative over a rolling 12-month period. Compliance with this formula can be demonstrated through the use of compliant materials. This method uses the weighted average HAP content (%) of all materials in a given category and compares it to a standard published in Table 2 of the subpart. There are several exemptions available, all of which require recordkeeping, including military and Coast Guard vessels, gel coats used for part or mold repair and touch up, and pure vinylester resin used for skin coats. There are three options for demonstrating compliance with the formula, including emissions averaging, compliant materials, and add-on controls. The facility uses compliant materials, meaning that all resins and gel coats must meet the organic HAP content requirements of Table 2 of the MACT. The table lists seven criteria, consisting of type of operations (e.g., tooling resin), application method (e.g., atomized {spray}), and sets a weighted-average organic HAP content for each. (c) requires that all resin and gel coat mixing containers with capacity greater than or equal to 208 liters (55 gallons) must have a cover with no visible gaps in place at all times, except when material or equipment is being added to or removed from the container. Visual

13 PERMIT MEMORANDUM TVR DRAFT 13 inspections of the covers and gaps are required at least monthly, and records of each such container, inspection results, and corrective actions must be maintained. (d) requires that solvents used for routine flushing of resin and gel coat application equipment must contain no more than 5% WT organic HAP. Containers storing the cleaning solvents must have covers with no visible gaps and the covers must be in place at all times except when items are being placed into or removed from the container. Inspections and records are identical to those in (c) preceding. Containers with capacity greater than 7.6 liters (2 gallons) cannot be filled to a height greater than ¾ of the diameter of the container, measured from the top. HAP content and container restrictions do not apply to those solvents used for removing cured resin or gel coat. (e) requires that carpet and fabric adhesives must contain no more than 5% W organic HAP. Subpart PPPP, Surface Coating of Plastic Parts and Products (signed August 29, 2003). This subpart specifically exempts boat manufacturing facilities that are subject to VVVV at 40 CFR (c)(11). Subpart WWWW, Reinforced Plastic Composites Production was issued April 21, This subpart specifically exempts boat manufacturing facilities that are subject to VVVV at 40 CFR (b). CAM, 40 CFR Part 64 [Not Applicable] This part applies to any pollutant-specific emission unit at a major source that is required to obtain an operating permit, for any application for an initial operating permit submitted after April 18, 1998, that addresses large emissions units, or any application that addresses large emissions units as a significant modification to an operating permit, or for any application for renewal of an operating permit, if it meets all of 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 100 TPY Compliance with NESHAP Subpart VVVV satisfies all requirements of Part 64. Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable] This facility will not process or store more than the threshold quantity of any regulated substance (Section 112r of the Clean Air Act 1990 Amendments). More information on this federal program is available on the web page: Stratospheric Ozone Protection, 40 CFR 82 [Not 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. This facility does not utilize any Class I & II substances.

14 PERMIT MEMORANDUM TVR DRAFT 14 VIII. COMPLIANCE Inspection David Youngman, DEQ ROAT environmental specialist, performed a full compliance evaluation of the facility on March 16, All equipment and records were presented and appeared to show compliance with all Specific Conditions of the current Part 70 permit. The following table shows some production and compliance data provided with the application. These data cover the entire period from first Tracker production in March 2003 through February 2009 and were supplied as an addendum to the application. The actual 12-month total at February 2009 and the highest 12-month total during the entire five years are shown. The facility had minimal activity at the time of the inspection because of decreased customer demand and annual turn around procedures. Material 12-month rolling total emissions (TPY) Feb 09 Highest Authorized Styrene MMA Carpet adhesive VOCs 2 9 Miscellaneous VOCs 9 16 Other resin & gelcoat VOCs 1 1 Total VOC Combined others Compliance with the MACT HAP limit is shown by a weighted average calculation, based on various factors supplied in the MACT and dependent on mass of material used in each named category. Because the standard varies as a function of the materials used, compliance is usually indicated by stating a comparison between actual HAP emissions and theoretical allowed emissions. The 12-month rolling ratio as of October 2008 is 80% and the highest ratio over the last five years was 84%. Ratios less than 100% demonstrate compliance. Tier Classification and Public Review This application has been determined to be a Tier II based on the request for a Part 70 operating permit renewal. The permittee 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 land. Notice of Application for a Title V Renewal permit was published in the Miami News-Record on February 10, The notice stated that the application was available for review at Tracker s office in Miami and at the AQD office in Oklahoma City. Another notice will be published in a newspaper of general circulation in Ottawa County upon availability of a Draft permit, stating the location at which the Draft will be available for public review and comment. This site is within 50 miles of the Oklahoma border with Kansas, Missouri, and Arkansas. Each state will be notified of the availability of the draft permit. Fee Paid Part 70 renewal permit application fee of $1,000.

15 PERMIT MEMORANDUM TVR DRAFT 15 IX. SUMMARY This facility was constructed as described in the application. There are no active Air Quality compliance or enforcement issues that would affect the issuance of this permit. Issuance of the renewal Part 70 operating permit is recommended, pending public comment and EPA review.

16 DRAFT PERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONS Tracker Marine LLC Tracker Miami Boat Manufacturing Plant Permit No TVR The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on January 2, The Evaluation Memorandum dated May 18, 2009, explains the derivation of applicable permit requirements and estimates of emissions; however, it does not contain operating limitations or permit requirements. Continuing operation under this permit constitutes acceptance of, and consent to, the conditions contained herein. 1. Points of emissions and limitations. [OAC 252: (a)(1)] EUG 1 Lamination and Assembly The facility has facility-wide emissions authorized under this permit, and individual equipment items do not have emission limits specifically attached. Specific locations engaged in these activities include Plant III, Small Parts Lamination, Tooling Lamination, and Plant II. EUG 2 This is an empty EUG. It formerly contained Small Parts Lamination activities. EUG 3 This is an empty EUG. It formerly contained Tooling Lamination activities. EUG 4 Plant-wide This EUG is established to address those rules or regulations that apply to the entire facility, including such rules as open burning or fugitive dust. EUG 5 This is an empty EUG. It formerly contained Plant II Lamination activities. The facility is authorized annual VOC emissions not to exceed 249 TPY, inclusive of HAPs styrene and methyl methacrylate (MMA). Limits authorized in the following table are 12-month rolling total limits. Styrene and MMA emissions are to be calculated based on the Unified Emission Factors for Open Molding of Composites or UEF (June 11, 2008) published for the American Composites Manufacturers Association. Other VOC emissions shall be calculated based on 100% emission of all VOCs contained in the products used, except for certain VOC now addressed by the UEF. These include methyl styrene, dimethyl phthalate stabilizer(s), reactive MMA in adhesives, and new factors for closed molding. VOC emissions from engine testing in EUG 6 shall be included in the facility-wide 249 TPY authorization.

17 SPECIFIC CONDITIONS TVR DRAFT 2 Material Annual emissions (TPY) Styrene 191 MMA 23 Carpet adhesive, mold wax & cleaner, & miscellaneous VOCs 35 EUG 6 Engine Testing Emissions for this EUG are authorized not to exceed 5 TPY of oxides of nitrogen (NO X ) and 50 TPY of carbon monoxide (CO). Compliance shall be demonstrated by calculating emissions using the horsepower of each engine tested, the length of time each is tested, and emission factors from Exhaust Emission Factors for Nonroad Engine Modeling: Spark Ignition NR-10e, EPA420-R (12/05). Calculations shall be performed monthly, and cumulated on a rolling-12-month basis. 2. The permittee shall be authorized to operate this facility continuously (24-hours per day, every day of the year). [OAC 252: (a)] 3. The facility is subject to the Boat Manufacturing MACT and the following listed provisions. [40 CFR 63 Subpart VVVV] Applicability Emission limits and compliance demonstrations 5715 What operating limits must I meet? Performance testing 5725 Monitoring Operating standards 5740 Carpet and fabric adhesive standards Aluminum boat standards 5758 How do I determine the organic HAP content of materials? Reporting and recordkeeping 5773 What parts of the General Provisions apply to me? 5776 Who implements and enforces this subpart? 5779 What definitions apply to this subpart? 4. The permittee shall maintain records of operations and emissions as listed below. These records shall be maintained on-site for at least five years after the date of recording and shall be provided to regulatory personnel upon request. [OAC 252:8-6 (a)(3)(b)] a) Material Safety Data Sheets (MSDSs) for all resins, gel coats, cleaning solvents, fabric and carpet adhesives, and any other materials used at the facility, showing the percentage by weight of all HAP and VOC. b) Calculations of facility-wide emissions of all VOC, and individually of styrene and MMA (monthly and 12-month rolling total). c) Data and calculations demonstrating compliance with the MACT VVVV HAP limit, as required by Specific Condition #3.

18 SPECIFIC CONDITIONS TVR DRAFT 3 d) Records of inspections and corrective actions taken for all resin and gel coat mixing containers and cleaning solvent containers, as required by SC #3. e) Engine test data, including horsepower of each engine, duration of test, engine type (direct injection or carbureted) and resulting calculations (monthly and 12-month rolling total). 5. Individual pieces of equipment are not permitted, because affected sources are operations of each type. The emissions authorized are facility-wide and allow flexibility in the type and size of each operation. New equipment may be added under the following conditions. [40 CFR et seq] a) Only equipment of a type subject to MACT VVVV is covered by this SC. Equipment subject to any other federal or state regulation or rule shall require permit modification. b) The Air Quality Division of DEQ (AQD) shall be notified in writing at least 30 days before the proposed installation of new equipment. If modification of the permit is required, the appropriate application and fees shall be submitted. c) A current tabulation of equipment shall be maintained and provided to AQD on each anniversary date (July 1) following the year in which the equipment is installed. 6. The following records shall be maintained on-site to verify Insignificant Activities. No recordkeeping is required for those operations that qualify as Trivial Activities. [OAC 252: (a)(3)(b)] a) Records of fuel storage/dispensing equipment operated solely for facility owned vehicles sufficient to demonstrate that fuel throughput is not more than 2,175 gallons/day averaged over a 30-day period. b) Vapor pressure of volatile organic liquids stored in tanks with capacity less than 10,000 gallons. c) Records sufficient to demonstrate that surface coating and degreasing operations do not exceed a combined total usage of more than 60 gallons/month of coatings, thinners, clean-up solvents, and degreasing solvents at any one emission unit. d) For activities claimed to have emissions less than 5 TPY (actual) of any criteria pollutant; the type of activity and the amount of emissions from that activity (cumulative annual). 7. 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: (d)(2)]

19 SPECIFIC CONDITIONS TVR DRAFT 4 OAC 252: Alternative Emissions Reduction not requested OAC 252: Mobile Sources not in source category OAC 252: Incinerators not type of emission unit OAC 252: Cotton Gins not type of emission unit OAC 252: Grain Elevators not in source category OAC 252: Nitrogen Dioxides not in source category OAC Carbon Monoxide not type of emission unit OAC 252: Nonattainment Areas not in area category OAC 252: MSWL not in source category 8. No later than 30 days after each anniversary date of the original Part 70 permit issuance (July 1, 2004), 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: (c)(5)(a) & (D)] 9. This permit supersedes all other Air Quality permits for this facility and they are now null and void.

20 MAJOR SOURCE AIR QUALITY PERMIT STANDARD CONDITIONS (December 22, 2008) 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 ] 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 ] 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: and OAC 252: (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: (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: (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: (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: (a)(3)(C)(iv)]

21 MAJOR SOURCE STANDARD CONDITIONS December 22, SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING 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: (a)(3)(b)(ii), OAC 252: (c)(1), and OAC 252: (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: (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, 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: (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: (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 document 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. However, an exceedance report that must be submitted within ten days of the exceedance under Section II (Reporting Of Deviations From Permit Terms) or Section XIV (Emergencies) may be submitted