DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION. MEMORANDUM November 18, 2010

Transcription

1 DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM November 18, 2010 TO: THROUGH: THROUGH: THROUGH: FROM: SUBJECT: Phillip Fielder, P.E., Permits and Engineering Group Manager Kendal Stegmann, Enforcement and Compliance Manager Phil Martin, P.E., New Source Permits Section Peer Review Ellis Fischer, P.E., New Source Permits Section Evaluation of Permit Application No TVR Athenian Marble Corporation Cultured Marble Fabrication Facility (SIC 3088) 7724 West Melrose Lane Bethany, Oklahoma I. INTRODUCTION Athenian Marble Corporation (Athenian) has requested an operating permit for their existing cultured marble fabrication facility (SIC 3088). The applicant has been manufacturing cultured marble since Athenian manufactures cabinet tops, sinks, bathtubs, and other miscellaneous products for use in the residential home building industry. Units are manufactured utilizing either a cultured marble process or a solid surface process. Hazardous air pollutants (HAPs) are generated and released from both the cultured marble fabrication process and solid surface fabrication process. The primary HAPs generated from the facility are styrene and methyl methacrylate (MMA) which are generated from the gelcoats and resins used in the fabrication processes. Particulate matter (PM) is generated and collected in both the cultured marble finishing process and solid surface finishing process. The facility currently operating under Permit No TV, issued March 13, 2006, which is based on the facility operation time of 10 hours/day and 365 days/year (3,650 hours/year). Due to an increase in business, the applicant requests an operating permit that reflects operating at maximum capacity based on continuous operations (8,760 hrs/yr) and emitting their maximum potential to emit (PTE) VOCs and HAPs. This permit will be processed as a Tier II application with issuance of a Title V major source operating permit contingent on public and EPA review.

2 PERMIT MEMORANDUM No TVR DRAFT 2 II. PROCESS DESCRIPTION The cultured marble fabrication process occurs in the building located at 7724 West Melrose. The units fabricated in the process are finished and stored for delivery at the building located at 400 North Thompkins. The solid surface fabrication process occurs in the building located at 400 North Thompkins Street. The units fabricated in the process are finished and stored for delivery in the building at 400 North Thompkins Street. Cultured Marble Fabrication and Finish Process The cultured marble units are fabricated in a building approximately 19,000 square feet in size. Upon fabrication, the cultured marble units are transported to the cultured marble finish building which is approximately 15,000 square feet in size. The following is a description of this process. Cultured Marble Fabrication 1. The process begins by removing the fabricated units from their molds. These units were fabricated on the previous workday. 2. The fabricated units are transported to the cultured marble finish building at 400 North Thompkins. 3. The empty molds are placed on storage racks and moved onto processing tables as needed. Once on the processing table, the molds are cleaned, waxed, and prepared for a new unit. 4. The prepared empty molds are then moved into the gelcoat booth (one mold at a time), where a layer of gelcoat is sprayed into the empty mold. 5. The mold is then removed from the gelcoat booth and placed on a casting table. 6. The marble casting material is prepared in the mixing room with an auto-caster mixer. Marble casting material is made up of resins, catalyst, pigments, and fillers. The mixing process is totally enclosed. 7. The marble cast material is poured into a portable container and transported to the casting table. 8. The marble cast material is hand scooped into the mold until the mold is filled. 9. Once the mold is full and stabilized, it is transported to a storage rack, where it cures overnight. The minimum curing time for a fabricated unit is 8 hours. Some units require up to twelve hours to cure depending on size of unit and quantity of marble cast material in the mold. 10. Molds, hand scoops, and other such equipment are cleaned either in the open wash basin in the mixing room or in the acetone wash basin also located in the mixing room. Cultured Marble Finishing 11. Once cultured marble units are fabricated and received for finishing, they are sanded, ground, and buffed.

3 PERMIT MEMORANDUM No TVR DRAFT PM emissions from the AEM (Abrasive Engineering & Manufacturing is the manufacturer) Sander are collected in a steel drum. The process is totally enclosed, so no PM escapes. 13. Additional PM is generated from grinding and sanding which occurs prior to shipment of the part. The PM is swept up and disposed of in a covered container so that no appreciable PM escapes. However, some PM escapes the building when doors are open, and from through traffic. 14. The cultured marble units are finished and stored for delivery. Solid Surface Fabrication and Finish Process The solid surface process has been consolidated with the cultured marble finish process in the building located at 400 North Thompkins street. The following is a description of this process. Solid Surface Fabrication 1. The process begins by removing the fabricated units from their molds. These units were fabricated the previous workday. 2. The molds are cleaned and waxed and placed on an empty stationary table. No gelcoat application occurs in this process. 3. The solid surface casting material is prepared in the mixers. The solid surface casting material is made up of resins, catalyst, pigments, and fillers. 4. Overhead cranes move the solid surface cast material over the mold, where it is poured into the mold. 5. Once the mold is full, the unit is left on the stationary table overnight to cure. The minimum curing time for a fabricated unit is 8 hours. Some units require up to twelve hours curing time depending on size of unit and quantity of marble cast material in the mold. 6. Molds and other such equipment are cleaned at the mold location. Solid Surface Finishing 7. Once solid surface units are fabricated and received for finishing, they are sanded and ground. 8. PM emissions from the AEM Sander are collected in a steel drum. The process is totally enclosed, so no PM escapes. 9. Additional PM is generated from grinding and sanding which occurs prior to shipment of the part. The PM is swept up and disposed of in a covered container so that no appreciable PM escapes. However, some PM escapes the building when doors are open, and from through traffic. 10. The solid surface units are finished and stored for delivery.

4 PERMIT MEMORANDUM No TVR DRAFT 4 III. EQUIPMENT The process operations occur in two buildings located in close proximity to each other. The physical addresses of each building is listed below: Cultured Marble Fabrication Cultured Marble Finishing 7724 West Melrose 400 North Thompkins 7724 West Melrose The cultured marble fabrication building consists of: offices and showroom, a mold preparation area, one gelcoat spray booth, three equipment cleaning areas, spray guns, molds, storage racks, processing tables, casting tables, auto-caster (mixer), sand tank, two 25,000 pound resin tanks, and an electric air compressor. 400 North Thompkins The cultured marble finish area building consists of: two AEM sanders, storage racks, molds, an electric air compressor, and two dust collection systems for the AEM sanders. In addition to mold preparation area, two mixers, stationary table, buckets and brushes. EU ID Point ID Cultured Marble Fabrication EU Name/Model Construction/ Modification Date EUG 1 M-1 Gelcoat Spray Booth 1973 Clear gelcoat spray gun (E-Z Rider Gelcoat System ATG 3500) 1996 White gelcoat spray gun (Binks Century Gun) 2001 EUG 2 M-2 2 Stainless steel resin storage tanks with 25,000 lb/each with vapor pressure less than 1.0 psia 1973 Gruber Autocaster #150100RC 2001 Open transfer containers 2001 Open molds 1973 AEM Sander 2001 Torit Downflo II Dust Collector 2001 EU ID Point ID Solid Surface Fabrication EU Name/Model EUG 3 S-1 Vacuum Blender #1 by Amerek 1993 Vacuum Blender #2 by Amerek 1997 Open transfer containers 1993 Open molds 1993 AEM Sander 2001 Torit Downflo II Dust Collector 2001 Construction/ Modification Date

5 PERMIT MEMORANDUM No TVR DRAFT 5 Gelcoat Spray Gun Equipment Make Number Fluid Output Transfer Of Model Model No. Coating Oz/Min Efficiency Units 10psi DeVilbiss 1 GTI-546P General Purpose 16 85% DeVilbiss 1 JGA-635G General Purpose 16 85% The high volume, low pressure (HVLP) spray guns have a spraying efficiency in excess of 85% due to coating large, flat surfaces. The spray guns have a maximum application rate of 7.5 gallons/hour each. IV. EMISSIONS General Description Emissions from the fiberglass fabrication process consist of Hazardous Air Pollutants (HAP) (mainly styrene) that are also Volatile Organic Compounds (VOC) and are considered organic HAP. HAP emissions originate from several points located within the building but are primarily generated in the spraying booths during gel coating and resin application. As required in , (a)(1) and (b), and (a)(1), to calculate organic HAP emission factors for specific open molding process streams, a facility must use the equations in Table 1 of Subpart WWWW, which is reproduced on the following pages. The emission factors calculated using Table 1 of Subpart WWWW are in pounds of organic HAP emitted per ton of resin or gel coat used and are based on the resin/gel coat organic HAP content. HAP emission estimates from the use of resins and gel coats were then calculated using the required NESHAP, Subpart WWWW, emission factors that were calculated using the equations in Table 1 of Subpart WWWW. Potential emissions from use of the resins and gel coats are based on the emission factors for the resin/gel coats with the highest organic HAP content and the maximum estimated material usage. Emissions from the use of the liquid organic peroxide catalyst MEKP have been calculated, using the report prepared by Dr. Robert Haberlein of Engineering Environmental on behalf of the Composites Fabricators Association (CFA) Emission Factors for Liquid Organic Peroxide Catalyst Used in Open Molding of Composites. All other VOC/HAP emissions from other processes are based on the maximum VOC/HAP content of the material and material usage. All of these VOCs/HAPs are assumed to be emitted to the atmosphere. A small amount of particulate matter will result from overspray of the material. The particulate emissions were calculated with 85% transfer efficiency and 75% collection efficiency. The following is a list of emission points for Athenian. PM is generated and collected in the finishing processes for both cultured marble and solid marble production and is considered

6 PERMIT MEMORANDUM No TVR DRAFT 6 insignificant. Emissions from storage tanks, heaters, and other miscellaneous equipment are insignificant. M-1 Cultured Marble Fabrication Building Gelcoat Booth. M-2 Cultured Marble Fabrication Building mixing room, mold set-up, and hand lay-up. S-1 Located in cultured marble finish building. CMF Cultured Marble Finishing Building SSF Located in cultured marble finish building M-1 Emissions from Gelcoat Booth Maximum capacity for this emission source will be based on the most conservative MACT material composition limits and calculations. The material used in the calculations is clear, white, and colored gelcoat with the maximum HAP composition limit allowed in WWWW Table 3. Gelcoats containing styrene and MMA are the only material used in the gelcoat booth and thus the only air pollutants emitted. Maximum capacity is based on an extrapolation of 2 factors. The first factor for determining maximum capacity is based on a ratio of actual hours worked vs. potential maximum hours worked 8760/2080 equals 4.2. The second factor for determining maximum capacity is based on additional floor space and equipment that will allow for an increase in production of approximately 50%. The maximum capacity ratio multiplier is 1.5. Maximum capacity emissions are calculated using 2004 actual emissions with maximum material compositions allowed in WWWW Table 3. These emissions are multiplied by the maximum capacity ratios of 4.2 (maximum hours) and 1.5 (additional floor space) using emissions formulas provided in WWWW Table 1. M-2 Emissions from Mixing Room, Hand Lay-up, and Mold Set-up Area source emissions occur from the marble-caste material after mixing and during hand lay-up and curing. In addition, area source emissions also occur from cleaners and waxes used during mold preparation. The marble caste material is made-up of resins, pigments, catalyst, and fillers. All ingredients are transferred through enclosed systems into the auto-caster, where they are mixed in a closed system. After mixing, the auto caste material is poured into open containers that are moved to the mold area where the mixture is hand scooped or layed-up into molds. The full molds are allowed to cure in the area. The majority of emissions occur during hand lay-up and curing. In addition, to hand lay-up practices, mold preparation or set-up also occurs in the area. Prior to use, molds are removed from storage, where they are cleaned, and waxed for use. The cleaners and waxes also contain HAP chemicals styrene and MMA. The maximum capacity determination of emissions will be based on the most conservative MACT material composition limits (listed in WWWW Table 3).

7 PERMIT MEMORANDUM No TVR DRAFT 7 Dry materials or fillers are transferred into the auto caster via an enclosed chute. The process is totally enclosed, eliminating PM. Hand scoops and other equipment used are cleaned in the mixing room wash basin with non- HAP containing chemicals. The wash basin has a hood with a mechanical exhaust fan. In addition, certain parts are cleaned with acetone which is the only chemical used for cleaning parts. Acetone is not subject to either the EPA or Oklahoma Air Pollution Rules. S-1 Emissions from Solid Surface Manufacturing Area source emissions occur from the solid surface marble-caste material after mixing and during hand lay-up and curing. In addition, area source emissions also occur from cleaners and waxes used during mold preparation. The solid surface marble caste material is made-up of resins, pigments, catalyst, and fillers. All ingredients are poured into the mixer, where they are blended together. The mixer is closed during blending. After blending, the material is poured into open containers that are moved to the mold area where the mixture is hand scooped or layed-up into molds. The full molds are allowed to cure on the lay-up table. The majority of emissions occur during hand lay-up and curing. The maximum capacity determination of emissions will be based on the most conservative MACT material composition limits listed in WWWW Table 3. Particle Matter Emission Control Equipment The AEM sander generates particulate matter (PM). The Torit Downflo II Dust Collector (baghouse) is used for the collection of airborne dust and PM from the AEM sander. Basically, the contaminated air enters the baghouse through the top inlet area and passes down and through the filter elements. Dust is collected on the outside surface of the filter elements. The clean, filtered air flows through the center of the filter elements into the clean air plenum, where it exits through the clean air outlet. Filter elements are cleaned automatically and sequentially. The result is that only one row (2 filter cartridges) may be off-line for cleaning at any given time. During the filter-cleaning purge, the solid-state timer energizes a solenoid valve, causing the corresponding diaphragm valve to send a pulse of compressed air through the filter, removing the collected contaminants from the outside surfaces of the filter. The dust falls into the hopper and then into the dust storage container. The dust barrel is changed when it gets approximately 2/3 full and disposed of with the industrial trash. The filters operate at % efficiency (manufacturer s information). Any dust that escapes falls to the processing floor where it is swept up and disposed of in industrial trash. PM emissions are estimated at 0.14 TPY. Therefore, they are negligible and are not included in emission tables. Sanding and grinding operations also generate PM. Products undergo a light sanding to finish the surface. PM generated by this process fall onto the floor, where at the end of each workday they are swept up and disposed of in the industrial trash. Some dust or PM does escape through open doors, walk-through or vertical traffic.

8 PERMIT MEMORANDUM No TVR DRAFT 8 The photohelic gage reading for cultured marble building is ¾ 5 ½. The photohelic gage reading for solid surface building is ¾ 5 ½. The facility uses filters to control PM emissions from the gelcoat booth. The filters are 2 standard roll and pad fiberglass media. The primary purpose is to collect any solids emitted in the gelcoat process. The filters are changed on average every two weeks or 80 hours of production time. The laboratory efficiency rating of the filters is 75%. PM emissions from spraying operations are estimated at 0.77 TPY. Therefore, they are negligible and are not included in emission tables. Emissions and Tables a. Hazardous Air Pollutants The gelcoats and resins contain styrene and methyl methacrylate (MMA) which are hazardous air pollutants. b. Criteria Pollutants and HAPs Emissions from the cultured marble and solid surface fabrication process consist of HAPs (mainly styrene) and VOCs. Styrene emissions originate from the cultured marble fabrication (M-1 and M- 2) and solid surface fabrication (S-1) buildings during resin and gelcoat application and open air curing. EPA rescinded Chapter 4.4 of AP-42, effective 3/18/98, because the emission factors significantly under predicted styrene emissions for most polyester resin operations. Effective October 24, 2005, Section of Subpart WWWW applies to an owner or operator of a reinforced plastic composites production facility that is located at a major source of HAP emissions. Reinforced plastic composites production is limited to operations in which reinforced and/or nonreinforced plastic composites or plastic molding compounds are manufactured using thermoset resins and/or gel coats that contain styrene to produce plastic composites. The resins and gel coats may also contain materials designed to enhance the chemical, physical, and/or thermal properties of the product. Reinforced plastic composites production also includes cleaning, mixing, HAP-containing materials storage, and repair operations associated with the production of plastic composites. Athenian Marble is an existing facility and is subject to Table 1, 3, and 5 of this subpart. The facility will track emissions using a 12-month rolling total and comply with the HAP content of resin and gelcoat materials along with the required work procedures. Maximum styrene and methyl methacrylate (MMA) emissions from gelcoats and resins are calculated using the upper limits for HAP content and emission factors specified by Subpart WWWW. Styrene, MMA, and other HAP ingredient quantities are shown on the MSDS submitted by applicant. There are no non-hap VOCs. c. Other Emissions The catalyst contains several toxics other than styrene, but they are usually completely consumed in the resin reaction. Waxes, paste, and other miscellaneous materials contain HAP ingredients and are calculated by assuming 100% vaporization of those HAP ingredients.

9 PERMIT MEMORANDUM No TVR DRAFT 9 d. PM Emissions Particulate emissions from sanding, and grinding operations are considered de minimis and are not listed below. However, particle matter control equipment requirements will be specified in the specific conditions. e. VOC emissions VOC is as defined in Subchapter 37 and excludes acetone. Materials with a vapor pressure of less than 0.01 psia are not considered to be emitted to the atmosphere. f. Limitations 1. The applicant has requested that limitations be established in this permit that allows for continuous operations (8,760 hr/yr) and at a 50% increase in material usage. 2. The HAP content in the materials used will be below the threshold percentages for HAP content for the application method specified in WWWW Table Actual emissions will be calculated using WWWW Table Combined actual annual HAP emissions will be below the TPY total emissions limitation based on a 12-month rolling total. 5. The emission factors used to calculate the HAP emission limits were based on the application methods designated in WWWW Table Other material usage results in a de minimis amount of emissions (<5 TPY actual each). Records of these activities and their associated emissions must be kept to ensure that they do not exceed 5 TPY.

10 PERMIT MEMORANDUM NO TVR Page 10 DRAFT Table 1 to Subpart WWWW Equations to Calculate Organic HAP Emission Factors Specific Open Molding and Centrifugal Casting Process Streams 1 If your operation type is a new or existing And you use With Use this organic HAP Emission Factor (EF) Equation for materials with less than 33 % organic HAP (19 % organic HAP for nonatomized gel Use this organic HAP Emission Factor (EF) Equation for materials with 33 % or more organic HAP (19 % organic HAP for nonatomized gel coat) 2 3 coat) Open molding operations a. Manual resin application i. Nonvapor-suppressed resin. EF = %HAP EF = ((0.286 %HAP) ) ii. Vapor-suppressed resin. EF = %HAP 2000 (1 (0.5 VSE factor)) EF = ((0.286 %HAP) ) 2000 (1 (0.5 VSE factor)). iii. Vacuum bagging/closed mold curing with roll-out. EF = % HAP EF = ((0.286 %HAP) ) b. Atomized mechanical resin application c. Nonatomized mechanical resin application d. Atomized mechanical resin application with robotic or automated spray control 5 iv. Vacuum bagging/closed mold curing with out roll-out. EF = (0.126 % HAP EF = ((0.286 %HAP) ) i. Nonvapor-suppressed resin. EF = %HAP EF = ((0.714 %HAP) 0.18) ii. Vapor-suppressed resin. EF = %HAP 2000 (1 (0.45 VSEfactor)). EF = ((0.714 %HAP) 0.18) 2000 (1 (0.45 VSE factor)). iii. Vacuum bagging/closed mold curing with roll-out. EF = %HAP EF = ((0.714 %HAP) 0.18) iv. Vacuum bagging/closed mold curing with out roll -out. EF = %HAP EF = ((0.714 %HAP) 0.18) i. Nonvapor-suppressed resin. ii. Vapor-suppressed resin. EF = %HAP 2000 (1 (0.45 VSEfactor)). EF = %HAP EF = ((0.157 %HAP) ) EF = ((0.157 %HAP) ) 2000 (1 (0.45 VSE factor)). iii. Closed mold curing EF = %HAP 2000 with roll-out iv. Vacuum bagging/closed EF = %HAP 2000 mold curing with out roll out. Nonvapor-suppressed resin. EF = %HAP EF = ((0.157 %HAP) ) EF = ((0.157 %HAP) ) EF = 0.77 ((0.714 %HAP) 0.18) 2000.

11 PERMIT MEMORANDUM NO TVR Page 11 DRAFT Table 1 to Subpart WWWW Equations to Calculate Organic HAP Emission Factors Specific Open Molding and Centrifugal Casting Process Streams (Cont.) If your operation type is a new or existing 2. Centralfugal casting operations. 7 8 And you use With Use this organic HAP Emission Factor (EF) Equation for materials with less than 33 % organic HAP (19 % organic HAP for nonatomized gel coat) Use this organic HAP Emission Factor (EF) Equation for materials with 33 % or more organic HAP (19 % organic HAP for nonatomized gel coat) e. Filiment application 6 i. Nonvapor-suppressed resin EF = %HAP 2000 EF = (( %HAP) ) 2000 ii. Vapor-suppressed resin EF = 0.12 %HAP 2000 EF = (( %HAP) ) f. Atomized spray gel coat application Nonvapor-suppressed gel coat EF = %HAP 2000 EF = (( %HAP) 0.195) 2000 g. Nonatomized spray gel coat application Nonvapor-suppressed gel coat EF = %HAP 2000 EF = (( %HAP) ) 2000 h. Atomized spray gel coat application using robotic or automated spray Nonvapor-suppressed gel coat EF = % HAP EF = (( %HAP) 0.195) a. Heated air blown through molds b. Vented molds, but air vented through the molds is not heated Nonvapor-suppressed resin EF = (%HAP) 2000 EF = (%HAP) 2000 Nonvapor-suppressed resin EF = (%HAP) 2000 EF = (%HAP) 2000 Footnotes to Table 1 1 The equations in this table are intended for use in calculating emission factors to demonstrate compliance with the emission limits in Subpart WWWW. These equations may not be the most appropriate method to calculate emission estimates for other purposes. However, this does not preclude a facility from using the equations in this table to calculate emission factors for purposes other than rule compliance if these equations are the most accurate available. To obtain the organic HAP emissions factor value for an operation with an add-on control device multiply the EF above by the add-on control factor calculated using Equation 1 of The organic HAP emissions factors have units of lbs of organic HAP per ton of resin or gel coat applied %HAP means total weight percent of organic HAP (styrene, methyl methacrylate, and any other organic HAP) in the resin or gel coat prior to the addition of fillers, catalyst, and promoters. Input the percent HAP as a decimal, i.e. 33 %HAP should be input as 0.33, not 33. The VSE factor means the percent reduction in organic HAP emissions expressed as a decimal measured by the VSE test method of appendix A to this subpart. This equation is based on a organic HAP emissions factor equation developed for mechanical atomized controlled spray. It may only be used for automated or robotic spray systems with atomized spray. All spray operations using hand held spray guns must use the appropriate mechanical atomized or mechanical nonatomized organic HAP emissions factor equation. Automated or robotic spray systems using nonatomized spray should use the appropriate nonatomized mechanical resin application equation. Applies only to filament application using an open resin bath. If resin is applied manually or with a spray gun, use the appropriate manual or mechanical application organic HAP emissions factor equation. These equations are for centrifugal casting operations where the mold is vented during spinning. Centrifugal casting operations where the mold is completely sealed after resin injection are considered to be closed molding operations. If a centrifugal casting operation uses mechanical or manual resin application techniques to apply resin to an open centrifugal casting mold, use the appropriate open molding equation with covered cure and no rollout to determine an emission factor for operations prior to the closing of the centrifugal casting mold. If the closed centrifugal casting mold is vented during spinning, use the appropriate centrifugal casting equation to calculate an emission factor for the portion of the process where spinning and cure occur. If a centrifugal casting operation uses mechanical or manual resin application techniques to apply resin to an open centrifugal casting mold, and the mold is then closed and is not vented, treat the entire operation as open molding with covered cure and no rollout to determine emission factors.

12 PERMIT MEMORANDUM NO TVR DRAFT 12 OPERATIONAL TYPE/USE WITH WWWW EMISSION FACTORS Gelcoats and Resins Material Description Application Process Description HAP CAS# WWWW Table 3 Max %HAP Content WWW Table 3 Maximum Emission Factors (EF) Clear Gelcoat Open Mold/Clear Production Gelcoat Methyl Methacrylate (MMA) White Gelcoat Open Mold/White Production Gelcoat Styrene Almond Gelcoat Open Mold/Pigmented Production Gelcoat Styrene Black Gelcoat Open Mold/Pigmented Production Gelcoat Styrene Biscuit Gelcoat Open Mold/Pigmented Production Gelcoat Styrene Resin Open Mold/non-CR/HS/Manual Application Styrene Resin Open Mold/non-CR/HS/Manual Application Styrene Resin Silmar Open Mold/non-CR/HS/Manual Application Styrene Resin Freeman Open Mold/CR/HS/Manual Application Styrene Material Description Catalysts, Wax, Paste, Miscellaneous Materials Application Process Description HAP HAP CAS# HAP Content % by Weight Emission Factors based on MSDS Norox MEKP-9 Catalyst/Used with Resin in Mixer Methyl Ethyl Ketone Peroxides (MEKP) Not Measurable Dimethyl Phthalate Methyl Ethyl Ketone (MEK) Arkema MEKPDDM-9 Catalyst Used with Resin MEKP MEK TR-210 Wax Used to clean old wax buildup from molds in cultured marble Toluene Xylene Cumene ,2,4- trimethylbenzene Partall Paste #2 Used to coat tub mold hats in cultured marble Xylene Gruber Seaming Used in solid surface to glue pieced together at seams MMA

13 PERMIT MEMORANDUM NO TVR DRAFT 13 EMISSION LIMITS Material Description HAP Material Usage 2004 based on 2080 hr/yr Gelcoats and Resins Ratio to increase Material Usage based on 8760 hr/yr Ratio for Production Increase Maximum Material Usage based on 8760 hr/yr (TPY) WWW Table 3 Maximum Emission Factors (EF) (lb/ton) Clear Gelcoat Styrene White Gelcoat Styrene Almond Gelcoat Styrene Black Gelcoat Styrene Biscuit Gelcoat Styrene Resin Styrene Resin Styrene Resin Silmar Styrene Resin Freeman Styrene TOTAL Gelcoat & Resin HAPs Material Description Material Usage 2004 Catalysts, Wax, Paste, Miscellaneous Materials Ratio to increase Ratio for Material Usage based Production on 8760 hr/yr Increase Maximum Material Usage based on 8760 hr/yr (TPY) Emission Factors based on MSDS Norox MEKP-9 MEKP Not Measurable 0.05 Dimethyl Phthalate MEK Arkema MEKPDDM-9 MEKP MEK TR-210 Wax Toluene Xylene Cumene ,2,4-trimethylbenzene Partall Paste #2 Xylene Gruber Seaming MMA TOTAL Catalyst, Wax, Paste & Miscellaneous Materials HAPs 6.33 TOTAL HAP EMISSION LIMITS Emission Limits (TPY) Emission Limits (TPY)

14 PERMIT MEMORANDUM NO TVR DRAFT 14 SUMMATION OF PROCESS EMISSIONS Emission Point CAS HAP Emissions Chemical Unit ID Number Y/N (TPY) EUG 1 M-1 Styrene Y MMA Y 0.00 MEKP Y 0.05 EUG 2 M-2 Styrene Y Dimethyl Phthalate Y 0.05 Methyl Ethyl Ketone Y 0.10 Toluene Y 2.82 Xylene Y 0.18 Cumene Y ,2,4-Trimethylbenzene 0.35 MEKP Y 0.05 EUG 3 S-1 Styrene Y 7.50 MMA Y 2.63 Total HAPs HAP EMISSION SUMMARY Chemical CAS Number Emissions (TPY) Styrene MMA MEKP Dimethyl Phthalate Methyl Ethyl Ketone Toluene Xylene Cumene ,2,4 Trimethylbenzene 0.35 Total Emissions V. INSIGNIFICANT ACTIVITIES 1. Space heaters, boilers, process heaters, and emergency flares less than equal to 5 MMBTU/hr heat input (commercial natural gas). 2. *Storage tanks with less than or equal to 10,000 gallons capacity that store volatile organic liquids with true vapor pressure less than or equal to 1.0 psia at maximum storage temperature. 3. Hazardous waste and hazardous materials drum staging areas. 4. Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including hazardous waste satellite (accumulation) areas.

15 PERMIT MEMORANDUM NO TVR DRAFT *Activities having the potential to emit no more than 5 TPY of any criteria pollutant. * Appropriate records of hours, quantity, or capacity must be kept on the activity to verify its significance. 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 regulated pollutants. Emission inventories have been submitted and fees paid for the past years. 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 mean individual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual calendar year emissions do not exceed the following limits: 5 TPY of any one criteria pollutant 2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for a HAP that the EPA may establish by rule OAC 252:100-9 (Excess Emissions 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

16 PERMIT MEMORANDUM NO TVR DRAFT 16 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 (PM)) [Not Applicable] This subchapter specifies a PM emissions limitation of 0.6 lbs/mmbtu from fuel-burning equipment with a rated heat input of 10 MMBtu/hr or less. AP-42, Table (7/98), lists the total PM emissions for natural gas to be 7.6 lbs/mmft 3 or about lbs/mmbtu. The permit requires the use of natural gas for all fuel-burning equipment to ensure compliance with Subchapter 19. This subchapter also limits emissions of particulate matter from industrial processes based on their process weight rates. The emission rate in pounds per hour (E) is not to exceed the rate calculated using the process weight rate in tons per hour (P). For process rates up to 60,000 lb/hr, the formula in appendix G is (E = 4.10*P (0.67) ). Facility operations produce only insignificant particle matter emissions. 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. Particulate emissions from overspray of the coating operations are controlled by filters. The permit will require maintenance of the dry filters or equivalent systems to achieve and maintain compliance with this limitation. A properly functioning manometer will be required to indicate when booth filters need to be changed. 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 originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. Particle matter emissions are generated from sanding the finished product. Athenian has limited sanding activities. This activity is conducted in a hooded area and particulate emissions are controlled by a baghouse filtration system. Sand is routinely cleaned up from around and within the hooded area. Emission estimates indicate that an insignificant amount of particulate matter emissions dissipate during sanding and drift as fugitive emissions. Under normal operating conditions, this facility will not cause a problem in regards to fugitive dust emissions (estimated at 0.14 TPY); therefore it is not necessary to require specific precautions to be taken.

17 PERMIT MEMORANDUM NO TVR DRAFT 17 OAC 252: (Volatile Organic Compounds) [Part 5 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 no storage tanks with a capacity greater than 400 gallons. Part 5 limits the VOC content of alkyd primer, epoxy, and maintenance finish coatings to 4.8 lbs/gallon, vinyl and acrylic coatings to 6.0 lbs/gallon, lacquers to 6.4 lbs/gallon, and custom product finishes to 6.5 lbs/gallon less water. The permit requires all coatings to comply with the solvent limitations including solvents used to cleanup any article, machine, or equipment used in applying coatings. Part 5 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 solvent usage not incorporated into the coatings as they are applied has been averaged over coating usage and all coatings still comply with the VOC limitations. Part 7 addresses fuel-burning equipment. Insignificant sources of VOC include: LP gas space heaters, central natural gas heating in the office area, fuel storage and dispensing, use of propane forklifts. 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. 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

18 PERMIT MEMORANDUM NO TVR DRAFT 18 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: Sulfur Compounds not type of emission unit OAC 252: Nitrogen Oxides exempted by size of combustion units OAC 252: Carbon Monoxide not type of emission unit OAC 252: Nonattainment Areas not in area category OAC 252: Landfills not in source category VII. FEDERAL REGULATIONS PSD, 40 CFR Part 52 [Not Applicable] Total potential emissions for NO X and CO are greater than the major source threshold of 250 TPY. Any future increases of emissions must be evaluated for PSD if they exceed a significance level (100 TPY CO, 40 TPY NO X, 40 TPY SO 2, 40 TPY VOC, 15 TPY PM 10, 10 TPY H 2 S). NSPS, 40 CFR Part 60 [Not Applicable] Subparts K, Ka, Kb, VOL Storage Vessels. There are no tanks which exceed the lowest size threshold (19,813 gallons) of these subparts. The following subparts affect surface coating, but not this facility: Subpart EE: Metal Furniture Subpart MM: Automobiles and Light-Duty Trucks Subpart QQ: Graphic Arts (Rotogravure) Subpart RR: Pressure-Sensitive Tape and Labels Subpart SS: Surface Coating of Large Appliances. No large appliances are coated at this facility. Subpart TT: Metal Coil Surface Coating. No metal coils are coated at this facility. Subpart WW: Beverage Cans Subpart FFF: Flexible Vinyl and Urethane NESHAP, 40 CFR Part 61 [Not Applicable] There are no emissions of any of the regulated pollutants: arsenic, asbestos, beryllium, benzene, coke oven emissions, mercury, radionuclides, or vinyl chloride except for trace amounts of benzene. Subpart J (Equipment Leaks of Benzene) concerns only process streams which contain more than 10% benzene by weight. Benzene is present only in trace amounts in any stream at this facility. All process streams at this facility are below this threshold. NESHAP, 40 CFR Part 63 [Applicable] Section of Subpart B requires that any facility not included in a listed source category (or for which a standard has not been promulgated under Section 112c of the CAA prior to May 15, 2002) that constructs or reconstructs a major source of HAPs after June 29, 1998, is subject to a case-by-case MACT determination. Athenian Marble is an existing facility.

19 PERMIT MEMORANDUM NO TVR DRAFT 19 Subpart WWWW, Reinforced Plastics Composites Production. Section of Subpart WWWW applies to an owner or operator of a reinforced plastic composites production facility that is located at a major source of HAP emissions. Reinforced plastic composites production is limited to operations in which reinforced and/or nonreinforced plastic composites or plastic molding compounds are manufactured using thermoset resins and/or gel coats that contain styrene to produce plastic composites. The resins and gel coats may also contain materials designed to enhance the chemical, physical, and/or thermal properties of the product. Reinforced plastic composites production also includes cleaning, mixing, HAP-containing materials storage, and repair operations associated with the production of plastic composites. Athenian Marble is an existing facility and is subject to Table 1, 3, and 5 of this subpart. The estimated maximum capacity for HAP emissions is below 100 TPY and not subject to BACT. The facility will track emissions using a 12-month rolling total and comply with the HAP content of resin and gelcoat materials along with the required work procedures. Maximum capacity will be calculated using the upper limits for HAP content specified by Subpart WWWW. For existing facilities emitting less than 100 TPY of organic HAP, the proposed emission limits shown below will apply to the listed operations on a 12-month rolling average: Open Molding - Corrosion-Resistant (CR)/High Strength (HS) lb HAP/ton Mechanical resin application 112 Manual resin application 123 Open Molding Non-CR/HS lb HAP/ton Mechanical resin application 87 Manual resin application 87 Open Molding Tooling lb HAP/ton Mechanical resin application 254 Manual resin application 157 Open Molding Low-Flame Spread/Low Smoke Products lb HAP/ton Mechanical resin application 270 Manual resin application 238 Open Molding Shrinkage Controlled Resins lb HAP/ton Mechanical resin application 354 Manual resin application 180 Open Molding Gel Coat lb HAP/ton Tooling gel coating 437 White/off white pigmented gel coating 267 All other pigmented gel coating 377 CR/HS or high performance gel coat 605 Fire retardant gel coat 854 Clear production gel coat 522 The MACT standard also requires the following work practices for existing sources emitting less than 100 TPY of organic HAP: Cleaning operations shall not use cleaning solvents that contain HAP. Keep containers that store HAP materials closed or covered except during the addition or removal of materials.

20 PERMIT MEMORANDUM NO TVR DRAFT 20 No other MACT standards are scheduled for promulgation that may affect this facility. Air Quality reserves the right to reopen this permit if any standard becomes applicable. CAM, 40 CFR Part 64 [Not Applicable] Compliance Assurance Monitoring (CAM), 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 of the criteria on the following page: 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 for the source to be classified as a major source. None of the emission units located at this source use a control device to achieve compliance with the applicable emission limits or standards for any regulated air pollutant. The gelcoat booth system uses particulate filters but does not have potential emissions greater than 100 TPY prior to the control device. 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: 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.