MEMORANDUM February 11, Phillip Fielder, P.E., Permits and Engineering Group Manager, Air Quality Division

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1 OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM February 11, 2010 TO: THROUGH: THROUGH: THROUGH: FROM: SUBJECT: Phillip Fielder, P.E., Permits and Engineering Group Manager, Air Quality Division Kendal Stegmann, Senior Environmental Manager, Compliance and Enforcement Phil Martin, P.E., Engineering Section Peer Review David Schutz, P.E., New Source Permits Section Evaluation of Permit Application No TVR (M-3) W-W Trailer Manufacturers, Inc. Livestock Trailer Manufacturing Operation Sec. 9 T5S R5E Madill, Marshall County, Oklahoma From Junction of US-70 and SH-199, Two Miles North Latitude o, Longitude o SECTION I. INTRODUCTION W-W Trailer Manufacturer, Inc. (W-W) has requested a significant modification of their current Part 70 operating permit for a horse trailer manufacturing operation at Madill (SIC 3715). The facility is currently operating under Permit No TVR (M-2) issued April 29, The permit modification application requested the following change: - Some of the coatings have been re-formulated by the manufacturers and no longer meet the supercoating specifications. The facility wishes to revise the permit to determine compliance with VOC concentration limits on a monthly average. Trailer manufacturing consists primarily of cutting and shaping steel plate and structural steel stock. Steel parts are cut, then welded into sub-assembly units. Sub-assembly units are then welded together to form the trailers. The trailers, when assembled, are washed and then coated with a primer and a topcoat in a large spray booth. The facility includes a paint touch-up booth for correction of problems with the main coating operations.

2 PERMIT MEMORANDUM TVR (M-3) 2 Paint is applied by spray guns and dried in four heated booths. The anticipated spray transfer efficiency is 50%. The painting areas are equipped with water curtains and fiberglass filters with a (conservative) expected capture efficiency of 70%. Operations are conducted in a building which is feet tall, approximately 800 feet long by approximately 400 feet wide. The facility emits more than 100 TPY of a criteria pollutant 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. EQUIPMENT EUG 1 Priming and Painting Operations Emission Point EU Name/Model Construction Date Heat Capacity, MMBTUH 1 Water-Wash Primer Booth 9/ Water-Wash Paint Booth 9/ Drying Booth 9/ Water-Wash Primer Booth 9/ Water-Wash Paint Booth 9/ Drying Booth 9/ Water-Wash Primer Booth 9/ Water-Wash Paint Booth 9/ Drying Booth 9/ Water-Wash Primer Booth 9/ Water-Wash Paint Booth 9/ Drying Booth 9/ Touch-up Booth 9/ Touch-up Booth 9/ EUG 3 Hydrocarbon Tanks Emission Point EU Name/Model Capacity, Gallons Construction Date T-1 Solvent Tank T-2 Thinner/Reducer Tank 1, T-3 Gasoline Tank 3, T-4 Diesel Tank 1, SECTION III. AIR EMISSIONS Air emissions result from process operations and from operations involving solvent evaporation (priming, topcoat application, and spray gun cleaning).

3 PERMIT MEMORANDUM TVR (M-3) 3 EUG 1: Priming and Painting Operations: Paint, primer, and solvent VOC emissions were based on mass balances for Supercoatings (generic specifications for coating materials derived from maximum concentrations listed on MSDSs), while PM emissions from painting and priming assume 50% transfer efficiency and 70% control efficiency of wet filters. Worst-case hourly emissions were derived assuming a 1,920 hours per year operating schedule (40-hour work week for 48 weeks per year). Supercoating compositions are listed in the following table. Component Supercoat 1: Paints Less than 4.4 lb/gal VOC lb/gal Supercoating Compositions Supercoat 2: Paints Supercoat more than 4.4 Primers lb/gal lb/gal VOC lb/gal Supercoat Thinner lb/gal Gun Cleaner lb/gal Wash Cleaners lb/gal Glue & Hardener lb/gal TOTAL VOC TOTAL SOLIDS Butyl cellosolve Ethyl benzene Ethylene glycol butyl ether acetate Formaldehyde Guaiacol alkyl phenol Nickel o-cresol Toluene Xylene Supercoating Usages Raw Material Hourly Usage, Annual Usage, Gallons Gallons Supercoat 1: Paints Less than 4.4 lb/gal VOC ,850 Supercoat 2: Paints more than 4.4 lb/gal VOC 0.7 1,425 Supercoat Primers ,523 Supercoat Thinner ,680 Gun Cleaner ,801 Wash Cleaners ,702 Glue & Hardener Natural gas combustion emissions factors for the paint booth heaters were taken from AP-42 (7/98), Section 1.4.

4 PERMIT MEMORANDUM TVR (M-3) 4 Unit ID Heat Capacity, MMBTUH 2, 5, 8, per heater 3, 6, 9, per heater EUG 1 Painting and Priming Emission EU Point Name/Model Painting & 1-14 Priming Combustion Units Pollutant Emission Emissions Per Heater Factor, lb/mmbtu lb/hr TPY NOx CO VOC PM NOx CO VOC PM NOx CO VOC PM 10 lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY EUG 3: Hydrocarbon Tanks. Storage tank emissions were estimated using the EPA program, TANKS4.09. EUG 3 Hydrocarbon Tanks Emission Point EU Name/Model VOC lb/hr TPY T Gallon Solvent Tank T-2 1,500 Gallon Thinner/Reducer Tank T-3 3,000 Gallon Gasoline Tank T-4 1,500 Gallon Diesel Tank TOTALS SUMMARY OF CRITERIA POLLUTANT EMISSIONS BY OPERATION Emission PM 10 NOx VOC CO Unit lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY Paint/Primer Plant-Wide Fug ** ** * * HC Tanks TOTAL * included in paint/primer emissions ** expected to be negligible

5 PERMIT MEMORANDUM TVR (M-3) 5 SIGNIFICANT DISCHARGE POINTS Discharge Height Diameter Flow Rate Temperature Emission Unit Point Feet Inches ACFM F 1 Water-Wash Primer Booth , Water-Wash Paint Booth , Drying Booth , Water-Wash Primer Booth , Water-Wash Paint Booth , Drying Booth , Water-Wash Primer Booth , Water-Wash Paint Booth , Drying Booth , Water-Wash Primer Booth , Water-Wash Paint Booth , Drying Booth , Touch-up Booth , Touch-up Booth , SECTION IV. INSIGNIFICANT ACTIVITIES 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. - Space heaters, boilers, process heaters and emergency flares less than or equal to 5 MMBTUH heat input (commercial natural gas). Facility comfort space heaters and paint dryers are in this category. - * Emissions from fuel storage/dispensing equipment operated solely for facility-owned vehicles if fuel throughput is not more than 2,175 gallons per day, averaged over a 30-day period. The gasoline tank is in this category. - * 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. The solvent and thinner tanks are in this category. - Alkaline/phosphate washers and associated burners. The facility includes washing tanks.

6 PERMIT MEMORANDUM TVR (M-3) 6 - 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). - Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including hazardous waste satellite (accumulation) areas. The facility includes a chemical/paint/solvent storage area. - 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. - * Activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant. This last category includes weld grinding and floorboard cutting shops. SECTION V. BEST AVAILABLE CONTROL TECHNOLOGY The facility was required by Consent Order No to conduct a BACT analysis. This would have been part of a facility construction permit, but no construction permit was obtained. BACT was not re-evaluated between issuance of the original permit and this permit. Best Available Control Technology (BACT) is determined on a case-by-case basis taking into account energy, economic, and environmental impacts. Major-source BACT is required only for VOC emissions which will exceed 100 TPY. BACT has been determined to be a combination of low-emitting activities: low-solvent coatings used in conjunction with application methods which minimize paint usage: high-volume lowpressure spray guns. A combination of techniques can achieve results equal to the most effective add-on control methods. The EPA publication Control of Volatile Organic Emissions From Existing Stationary Sources, Volume VI: Surface Coating of Miscellaneous Metal Parts and Products (EPA-450/ ) lists six available emissions control technologies for this industry and efficiencies for each technology: Water-borne (spray, dip, or flow coat) 60-90% Water-borne (electrodeposition) 90-95% Higher-solids (spray) 50-80% Powder (spray) 95-98% Carbon adsorption 90% Incineration 90% +

7 PERMIT MEMORANDUM TVR (M-3) 7 VOC emissions from spray painting can be controlled by either add-on controls or by minimizing waste (overspray). Add-on controls fall into two categories: destruction and recovery. Recovery systems are condensation and carbon adsorption, while destructive systems are thermal or catalytic oxidizers. Regenerative catalytic oxidizers (RCOs) are not technically feasible since the discharges will contain finite amounts of metal-based PM which will poison the catalyst, rendering the RCO ineffective. Carbon adsorption is doubtful from a technical perspective and is expected to cost 30% more than RTO. An RTO is expected to have extremely high costs, thus those controls may be rejected on an economic basis since the facility will not violate any ambient air quality standard. The permit will limit the VOC content of liquid coatings and the chemical constituents of those liquids, and will require that the operator be able to demonstrate that the spray guns are operating properly to minimize overspray. SECTION 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) [Not Applicable] This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal Regulations. 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 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 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 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

8 PERMIT MEMORANDUM TVR (M-3) 8 Emission limitations for all the sources are taken from the permit application and previous permit. OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable] Except as provided in OAC 252: (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: , 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: (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) [Applicable] Subchapter 19 specifies PM emissions limitations based on heat input capacity. For equipment with a capacity of 10 MMBTUH or less, the applicable standard is 0.60 lb/mmbtu. AP-42 (7/98), Section 1.4, shows PM emissions at 7.6 lb/million cubic feet, or lb/mmbtu. This emission rate is in compliance with Subchapter 19. Subchapter 19 also limits emissions of particulate matter from processes based on their process weight rate. Based on a process weight rate of 10 TPH (one trailer per paint booth), facility PM emissions would be limited to lb/hr (19.22 lb/hr x 8 booths). Total PM emissions have been estimated at lb/hr. This emission rate is in compliance with Subchapter 19. OAC 252: (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 on the paint booths to ensure compliance with this rule. OAC 252: (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.

9 PERMIT MEMORANDUM TVR (M-3) 9 OAC 252: (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 gaseous fuel with sulfur content less than 343 ppmv to ensure compliance with Subchapter 31. OAC 252: (Nitrogen Oxides) [Not Applicable] Subchapter 33 affects new fuel-burning equipment with a rated heat input of 50 MMBTUH or more. The paint booth heaters have a total capacity below the 50 MMBTUH de minimis level. OAC 252: (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: (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. This rule affects the gasoline tank but not the other tanks. The thinner and solvent tanks contain organic liquids with vapor pressures which are below the 1.5 psia threshold. Part 5 limits the VOC content of coatings used in coating lines and operations. The primers to be used will be limited to 4.8 lb/gal VOC. The paints to be used have a maximum VOC content of 4.78 lb/gal, which is in compliance with the most stringent limitations of this part for paints. 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. Part 7 also requires all reciprocating compressors to be equipped with packing glands that are properly installed and maintained in good working order. OAC 252: (Toxic Air Contaminants (TAC)) [Applicable] Part 5 of OAC 252: 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.

10 PERMIT MEMORANDUM TVR (M-3) 10 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 Reduction not eligible 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: Feed & Grain Facility not in source category OAC 252: Nonattainment Areas not in a subject area OAC 252: Landfills not type of source category SECTION VII. 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] 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, The several tanks are smaller than the 19,813-gallon de minimis level. 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.

11 PERMIT MEMORANDUM TVR (M-3) 11 NESHAP, 40 CFR Part 63 [Applicable] Subpart MMMM, Surface Coating of Miscellaneous Metal Parts and Products. This subpart was finalized on January 2, This facility is considered an existing source and had a compliance date of January 2, 2007, however, the facility achieved area source status just prior to the compliance date. Subpart MMMM affects only major sources of HAPs. Subpart HHHHHH, Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources. This subpart was promulgated on January 9, 2008, and affects stripping using methylene chloride; auto body painting; and spray painting using lead, nickel, chromium, manganese, or cadmium compounds. The facility does not conduct paint stripping and the only metallic pigments listed in any coating MSDS is nickel at 0.01 lb/gal. The operator must certify compliance with the rule, or non-use of target HAPs, by March 11, Once certification is successfully performed, Subpart HHHHHH will become not applicable. Subpart XXXXXX, Area Source Standards for Nine Metal Fabrication and Finishing Source Categories. This subpart was promulgated on July 23, 2008, and affects dry abrasive blasting operations, machining operations, dry grinding and dry polishing, spray painting, and welding operations. Processes containing MFHAP (metal finishing hazardous air pollutants) above the following concentrations are affected: manganese, 1.0%; or cadmium, chromium, lead, or nickel, 0.1%. Grinding using hand-held devices is excluded. The facility has until July 25, 2011, to achieve compliance with Subpart XXXXXX. The facility is committing to avoiding coating materials and welding electrodes whose HAP concentrations exceed the applicability thresholds of Subpart XXXXXX. 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 100 TPY. The only active controls at this facility are the dry filters on the paint booths. Potential PM emissions would be 21 TPY, which is less than the 100 TPY threshold. 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:

12 PERMIT MEMORANDUM TVR (M-3) 12 Stratospheric Ozone Protection, 40 CFR Part 82 [Subpart A and F 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, This facility does not utilize any Class I & II substances. SECTION VIII. COMPLIANCE Inspection The facility was inspected on August 31, 2007, by Berry Mantooth of the Compliance Section. No violations were noted from the full compliance evaluation. Tier Classification and Public Review This application has been determined to be a Tier II based on the request for a significant modification to a major source operating permit. The applicant published the Notice of Filing a Tier II Application in the Madill Record on January 14, 2010, a newspaper of general circulation in Marshall County. The notice said that the application was available for public review at the Madill Public Library or at the AQD office. A draft of this permit will also be made available for public review for a period of thirty days as will be stated in another published announcement. The facility is located within 50 miles of the Oklahoma border with Texas; the state of Texas will be notified of the draft permit. Information on all permit actions is available for review by the public in the Air Quality section of the DEQ Web page:

13 PERMIT MEMORANDUM TVR (M-3) 13 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. Fees Paid Part 70 operating permit significant modification fee of $1,000. SECTION IX. SUMMARY The facilty was constructed as described in the permit application. There are no active Air Quality compliance or enforcement issues that would affect the issuance of this permit. Issuance is recommended, contingent on public and EPA review.

14 PART 70 PERMIT AIR QUALITY DIVISION STATE OF OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY 707 N. ROBINSON STREET, SUITE 4100 P.O. BOX 1677 OKLAHOMA CITY, OKLAHOMA Permit No TVR (M-3) W-W Trailers Manufacturers, Inc., having complied with the requirements of the law, is hereby granted permission to operate a trailer manufacturing operation at Sec. 9-T5S-R5E, Marshall County, Oklahoma, subject to standard conditions dated July 21, 2008, and specific conditions, both attached. This permit shall expire on September 11, 2011, except as authorized under Section VIII of the Standard Conditions. Division Director Air Quality Division Date DEQ Form # Revised 10/20/06

15 W-W Trailer Manufacturers, Inc. Attn: Ms. Lori Watkins P.O. Box 807 Madill, OK SUBJECT: Permit Application No TVR (M-3) Madill Livestock Trailer Manufacturing Operation Sec. 9 T5S R5E Madill, Marshall County, Oklahoma Dear Ms. Watkins: Enclosed is the permit authorizing operation of the referenced operation. Please note that this permit is issued subject to standard and specific conditions, which are attached. These conditions must be carefully followed since they define the limits of the permit and will be confirmed by periodic inspections. Also note that you are required to annually submit an emissions inventory for this facility. An emissions inventory must be completed on approved AQD forms and submitted (hardcopy or electronically) by April 1 st of every year. Any questions concerning the form or submittal process should be referred to the Emissions Inventory Staff at Thank you for your cooperation in this matter. If we may be of further service, please contact our office at (405) Sincerely, David S. Schutz, P.E. AIR QUALITY DIVISION Enclosures

16 PERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONS W-W Trailer Manufacturers, Inc Madill Plant Permit No TVR (M-3) The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on March 21, 2006, with supplemental information received May 18, 2006; February 5, 2008; and October 23, The Evaluation Memorandum dated February 11, 2010, 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, based on 12-month rolling totals for annual limitations and monthly averages for hourly limitations: [OAC 252: (a)] EUG 1 Painting and Priming Emission VOC PM EU Name/Model 10 Point lb/hr TPY lb/hr TPY 1-14 Painting & Priming a. NOx and CO emissions are considered insignificant (less than 5 TPY). b. Coatings shall be applied using HVLP, electrostatic, or equivalent application methods with 60% or higher transfer efficiency. [OAC 252: (a)] c. Paint spraying equipment shall be cleaned with VOCs being drained into a closed container. [OAC 252: (a)] d. Particulate emissions from paint booth overspray shall be controlled by water curtains with efficiency of at least 70%. The filters or alternative device with the same or better control efficiency shall be maintained and operated in accordance with manufacturer's specifications. [OAC 252: (a)] e. Emissions of Hazardous Air Pollutants shall not exceed 9.9 TPY of any one HAP nor 24.9 TPY of all HAPs, 12-month rolling totals. Compliance with these limits shall be demonstrated by monthly mass balance calculations using the amounts of each HAPladen material used and HAP concentrations of the material. [OAC 252: (a)] f. Coating materials as applied shall not exceed the following VOC lb/gal limitations, excluding water and exempt solvents. [OAC 252: (a)]

17 SPECIFIC CONDITIONS PERMIT NO TVR (M-3) 2 Component Supercoat 1: Paints Less than 4.4 lb/gal VOC lb/gal Supercoat 2: Paints more than 4.4 lb/gal VOC lb/gal Supercoat Primers lb/gal Supercoat Thinner lb/gal Gun Cleaner lb/gal Wash Cleaners lb/gal Glue & Hardener lb/gal TOTAL VOC TOTAL SOLIDS g. Each coating material used at the facility shall be classified as one of the above categories: Supercoating 1, Supercoating 2, Primers, thinner, gun cleaners, wash cleaners, and glue & hardeners. Compliance with lb/gallon VOC limitations shall be determined for each month for each type of coating as VOC emissions from all materials in a category divided by the sum of volumes of all materials in a category. Water and exempt solvents shall be excluded from the VOC content of each coating material. VOC emissions from the clean-up of applicators shall be included in VOC emissions from coating applications. h. Coating material usages shall not exceed the following limitations: Raw Material 12-Month Rolling Usage Limitation, Gallons Supercoat 1: Paints Less than 4.4 lb/gal VOC 52,850 Supercoat 2: Paints more than 4.4 lb/gal VOC 1,425 Supercoat Primers 20,523 Supercoat Thinner 11,680 Gun Cleaner 1,801 Wash Cleaners 10,702 Glue & Hardener 301 i. Coating materials as applied shall not exceed the following VOC emissions, lb VOC per gallon of coating excluding the volume of water and any exempt organic compounds. [OAC 252: (a)] i. Alkyd primers: 4.8. ii. Vinyls: 6.0. iii. NC lacquers: 6.4. iv. Acrylics: 6.0. v. Epoxies: 4.8. vi. Maintenance finishes: 4.8. vii. Custom product finishes: 6.5.

18 SPECIFIC CONDITIONS PERMIT NO TVR (M-3) 3 EUG 3 Hydrocarbon Tanks: Emissions from the equipment listed below are estimated based on existing equipment items and are insignificant. Emission Point EU Name/Model Capacity, Gallons Construction Date T-1 Solvent Tank T-2 Thinner/Reducer Tank 1, T-3 Gasoline Tank 3, T-4 Diesel Tank 1, The permittee shall be authorized to operate the facility continuously (24 hours per day, every day of the year). [OAC 252: (a)] 3. The fuel-burning equipment shall be fired with pipeline grade natural gas or other gaseous fuel with a sulfur content less than 343 ppmv. Compliance can be shown by the following methods: for pipeline grade natural gas, a current gas company bill; for other gaseous fuel, a current lab analysis, stain-tube analysis, gas contract, tariff sheet, or other approved methods. Compliance shall be demonstrated at least once annually. [OAC 252:100-31] 4. The following records shall be maintained on-site to verify insignificant activities. [OAC 252: (a)(3)(b)] a. Amounts of drums washed for reclamation (monthly and annual totals). b. Types of materials stored in Tanks T-1, T-2, and T-4. c. Throughput of gasoline through Tank T-3 (monthly and annual totals). 5. Coating materials and welding materials shall not exceed the following thresholds. A Material Safety Data Sheet or other documentation of composition of those materials shall be kept on-site: [OAC 252:100-43] a. Cadmium: 0.1% b. Chromium: 0.1% c. Lead: 0.1% d. Manganese: 1.0% e. Nickel:0.1%

19 SPECIFIC CONDITIONS PERMIT NO TVR (M-3) 4 6. 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: (a)(3)(B)] a. Usage of materials listed in Specific Condition Number 1 by type and volume/quantity (monthly and 12-month rolling totals). b. A material safety data sheet (MSDS) or other vendor specification which documents the VOC content and HAP composition of each product. c. Average VOC composition of each coating material category, determined as total VOC emissions from coating materials used divided by volume of coating materials used in each month (monthly). d. Amount of collected cleaning solvent or wastes for disposal (monthly and 12-month rolling total). e. For the fuel(s) burned, the appropriate document(s) as described in Specific Condition No. 3. f. Calculations of HAP emissions (monthly and 12-month rolling totals). 7. No later than 30 days after each anniversary date of the issuance of the initial Part 70 operating permit (September 17, 2001), 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)] 8. 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)] a. OAC 252: Alternative Emissions Reduction b. OAC 252: Mobile Sources c. OAC 252: Cotton Gins d. OAC 252: Grain Elevators e. OAC 252: Nitrogen Oxides f. OAC 252: Carbon Monoxide g. OAC 252: Landfills

20 SPECIFIC CONDITIONS PERMIT NO TVR (M-3) 5 h. OAC 252: Nonattainment Areas i. 40 CFR Part 60 New Source Performance Standards j. 40 CFR Part 61 NESHAP k. 40 CFR Part 64 Compliance Assurance Monitoring l. 40 CFR Part 72 Acid Rain 9. This permit supersedes all previous permits for this facility, which are now considered null and void.

21 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 ] 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)]

22 MAJOR SOURCE STANDARD CONDITIONS July 21, 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 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: (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 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: (f), OAC 252: (a)(3)(C)(iv), OAC 252: (c)(1), OAC 252: (e), and OAC 252: (f)]

23 MAJOR SOURCE STANDARD CONDITIONS July 21, 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 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: (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: (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: (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 (PM 10 ). 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: (c)(1) and OAC 252:100, Appendix Q]

24 MAJOR SOURCE STANDARD CONDITIONS July 21, 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: (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: (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: (f) and OAC 252: (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: (e)(8)(B) and OAC 252: (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: (c)(6)]

25 MAJOR SOURCE STANDARD CONDITIONS July 21, 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: (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: (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: , OAC 252: , and OAC 252: (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: (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: (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: (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: (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: (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: (a)(6)]