PERMIT MEMORANDUM 2006-108-O 2

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM May 31, 2006

TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality Division

THROUGH: Grover Campbell, P.E., Existing Source Permits Section

THROUGH: Phil Martin, P.E., New Source Permits Section

THROUGH: Peer Review

FROM: David Schutz, P.E., New Source Permits Section

SUBJECT: Evaluation of Permit Application No. 2006-108-O

Mobile Products, Inc.

Equipment Manufacturing/Painting Operation

Section 21, T21N, R12W

201 W. Oklahoma Avenue

Fairview, Major County, Oklahoma

SECTION I. INTRODUCTION

Mobile Products, Inc. operates a heavy industrial equipment manufacturing operation in Fairview (SIC 3537). Operations commenced at the facility in 1968. The facility is currently operating under Permit No. 1998-274-TV issued September 9, 2001.

The operator has applied for a “synthetic minor” operating permit in lieu of the Title V operating permit renewal due to expire on September 9, 2006. The modified permit will have the following changes from the current operating permit:

a.  Emissions limitations for the coating operations will be revised. Instead of having maximum allowed coating usages and “Supercoating” generic specifications for coatings and solvents, the permit will be revised to incorporate a “solvent tracking system” for VOC and HAPs.

b.  VOC will be limited to 99 TPY, while total HAPs will be limited to 24.0 TPY aggregate and 9.0 TPY of each HAP.

c.  Emissions limitations will be established for all non-trivial activities.

The changes, as requested, will require relaxation of existing recordkeeping requirements. Under OAC 252:100-8-7.2(b), the modification to the permit meets the criteria as a “significant modification.” Tier II processing is required.

PERMIT MEMORANDUM 2006-108-O 11 11

SECTION II. FACILITY DESCRIPTION

The applicant manufactures several types of industrial equipment such as aerial lift booms, sweepers, back hoes, front end loaders, fork lifts, and small and mid-sized garden tractors. Therefore, several areas of the facility are used for general metal fabrication and coating.

Sheets of metal are received at the facility. The sheets are either sawed, punched, torch-cut (plasma or oxy-acetylene), or hydraulically sheared to size. Cut pieces are bent, drilled, and machined to final size and shaped before being welded together. After final assembly, the products may be washed, grit-blasted or shot-blasted, then primed and painted. Both coatings are allowed to air-dry.

Operations are conducted in a building which is 27 feet tall, 211 feet wide, and 300 feet long.

SECTION III. EQUIPMENT

EUG 1 – Paint Booth

Emission Point / EU Name/Model / Construction Date
11000 / Paint booth / 1968

EUG 2 – Fabrication and Assembly Areas

Emission Point / EU Name/Model / Construction Date
2 / Assembly operations: including torch cutting, machining and welding / 1968

EUG 3 – Surface Preparation Operation, Interior

Emission Point / EU Name/Model / Construction Date
3-A / Shot Blasting Booth / 1968
3-B / Grit Blasting Booth / 1968

EUG 4 – Gas-fired Heaters

Emission Point / EU Name/Model / Construction Date
4-A / 0.099 MMBTUH Heater / 1968
4-B / 0.099 MMBTUH Heater / 1968
4-C / 0.099 MMBTUH Heater / 1968
4-D / 0.099 MMBTUH Heater / 1968

SECTION IV. AIR EMISSIONS

Emissions were based on the following factors and data.

-  VOC and HAP emissions are shown at levels just below major source thresholds. A “solvent tracking system” will be implemented to ensure that VOC / HAP emissions do not exceed the stated levels. PM emissions from painting were estimated based on 5 lb/gal solids, 198,000 gallons of paint, 50% retention on product, and 95% control by dry filters, and painting 920 hours per year.

-  Welding emissions were based on AP-42 (1/95), Table 12.19-2.

Hourly Usage (lb) / Annual Usage (lb) / Emission Factor, lb/103 lb electrode / Emissions
lb/hr / TPY
5 / 4,750 / 24.1 PM / 0.121 / 0.057
0.524 chromium / 0.003 / 0.001
0.001 chromium VI / 0.001 / 0.001
0.001 cobalt / 0.001 / 0.001
0.346 manganese / 0.002 / 0.001
0.184 nickel / 0.001 / 0.001

-  Abrasive blasting emissions were based on AP-42 (9/97), Section 13.2.6.

Operation / Hourly Usage (lb) / Annual Usage (lb) / Emission Factor, lb/103 lb abrasive / Control Efficiency / Emissions
lb/hr / TPY
Shot and Grit Blasting / 12 / 10,500 / 3.12 / 99% / 0.01 / 0.01

-  Gas-fired heater emissions were based on AP-42 (7/00), Section 1.4:

Heater
Capacities / Emission Factor,
lb/MMBTU / Emissions
lb/hr / TPY
0.396 MMBTUH / NOx: 0.10 lb/MMBTU / 0.04 / 0.17
CO: 0.084 lb/MMBTU / 0.03 / 0.15
VOC: 0.0055 lb/MMBTU / 0.01 / 0.01
SO2: 0.0515 lb/MMBTU * / 0.02 / 0.09
PM: 0.0076 lb/MMBTU / 0.01 / 0.01

* Based on 343 ppmv sulfur in fuel, although pipeline-grade natural gas will be combusted.


FACILITY-WIDE EMISSIONS

Emission

Point / PM / VOC / NOx / CO
lb/hr / TPY / lb/hr / TPY / lb/hr / TPY / lb/hr / TPY
Coating Booth / 5.38 / 2.48 / 215.22 / 99.00 / --- / --- / --- / ---
Heaters / 0.01 / 0.01 / 0.01 / 0.01 / 0.04 / 0.17 / 0.03 / 0.15
Grit Blasting
/ 0.01 / 0.01 / --- / --- / --- / --- / --- / ---
Welding / 0.12 / 0.06 / --- / --- / --- / --- / --- / ---
TOTALS / 5.52 / 2.56 / 215.23 / 99.01 / 0.04 / 0.17 / 0.03 / 0.15

HAZARDOUS POLLUTANT EMISSIONS

Pollutant / Emissions
lb/hr / TPY
Chromium / 0.01 / 0.01
Cobalt / 0.01 / 0.01
Cumene / 19.57 / 9.00
Ethyl benzene / 19.57 / 9.00
Glycol ethers / 19.57 / 9.00
Manganese / 0.01 / 0.01
Nickel / 0.01 / 0.01
Styrene / 19.57 / 9.00
Toluene / 19.57 / 9.00
Xylene / 19.57 / 9.00

SIGNIFICANT DISCHARGE POINTS

Discharge
Point / Height
Feet / Diameter
Inches / Flow Rate
ACFM / Temperature
oF
Paint booth stack 1 / 12 / 36 / 8,000 / 70
Paint booth stack 2 / 12 / 36 / 8,000 / 70
Shot blasting / 20 / 48 / 38,100 / 70

SECTION V. OKLAHOMA AIR POLLUTION CONTROL RULES

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

Subchapter 1 includes definitions but there are no regulatory requirements.

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

Subchapter 3 enumerates the primary and secondary ambient air quality standards and the significant deterioration increments. At this time, all of Oklahoma is in attainment of these standards.

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

Federal regulations in 40 CFR Part 60 are incorporated by reference as they exist on July 1, 2002, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix G. NSPS standards are discussed in the “Federal Regulations” section.

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

The owner or operator of any facility that is a source of air emissions shall submit a complete emission inventory annually on forms obtained from the Air Quality Division. Emission inventory information has been submitted and fees paid for past years.

OAC 252:100-7 (Permits for Minor Facilities) [Applicable]

Subchapter 7 sets forth the permit application fees and the basic substantive requirements of permits for minor facilities. Since controlled criteria pollutant emissions are less than 100 TPY for each pollutant, and emissions of HAPs will not exceed 10 TPY for any one HAP or 25 TPY for any aggregate of HAPs, the facility is defined as a minor source. However, since the facility currently has a Title V operating permit, the “synthetic minor” operating permit must undergo Tier II review.

OAC 252:100-8 (Permits for Part 70 Sources) [Not 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. By issuance of this permit, the facility will cease to be a major source.

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

In the event of any release which results in excess emissions, the owner or operator of such facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10) working days after the immediate notice is given, the owner or operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility.


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

Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in this subchapter.

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

Subchapter 19 specifies PM emissions limitations for fuel-burning equipment based on heat input capacity. For heaters smaller than 10 MMBTUH, the applicable standard is 0.60 lb/MMBTU. AP-42 (7/98), Chapter 1.4, Table 1.4-1 lists natural gas TPM emissions to be 7.6 lb/million SCF or about 0.0076 lb/MMBTU which is in compliance with this subchapter. The permit will require the use of natural gas for all fuel-burning equipment.

Subchapter 19 specifies an allowable PM emission rate based on process weight rate. For a process rate of 10 TPH, the allowable PM emission rate is 17.2 lb/hr. The expected PM emission rates (5.38 lb/hr for painting, 0.01 for gritblasting, and 0.12 lb/hr for welding) are in compliance with Subchapter 19.

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

No discharge of greater than 20% opacity is allowed except for short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. The permit will require proper operation of the control equipment to ensure compliance with this subchapter.

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

Subchapter 29 prohibits the handling, transportation, or disposition of any substance likely to become airborne or windborne 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. The permit will require that sandblasting be conducted in enclosures to achieve compliance with Subchapter 29.

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

Part 3 lists a maximum ambient air concentration limit of 1,200 mg/m3 (1-hour average) for existing equipment. A typical heater burning natural gas with a sulfur concentration of 343 ppmv will produce a maximum ambient concentration of less than 22 mg/m3 which is in compliance. Compliance with the other averaging period standards (5-minute, 3-hour, 24-hour, and annual) is assured by the wide margin of compliance with the 1-hour standard.

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

Subchapter 33 affects new fuel-burning equipment with a rated heat input of 50 MMBTUH or more. The paint booth heaters have a total capacity below the 50 MMBTUH de minimis level.


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

None of the following affected processes are part of this project: gray iron cupola, blast furnace, basic oxygen furnace, petroleum catalytic cracking unit or petroleum catalytic reforming unit.

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

Part 3 affects 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. There are no storage tanks above 400 gallons at this facility.

Part 3 requires loading facilities with a throughput equal to or less than 40,000 gallons per day to be equipped with a system for submerged filling of tank trucks or trailers if the capacity of the vehicle is greater than 200 gallons. This facility does not have the physical equipment (loading arm and pump) to conduct this type of loading. Therefore, this requirement is not applicable.

Part 5 limits the VOC content of coatings used in coating lines. The alkyd (oil-based) primers are subject to a limitation of 4.8 lb/gal VOC. The maximum anticipated VOC content of primers is 4.7 lb/gal, which is in compliance with the applicable limitation. Thinner and cleaning solvent usage is counted in the VOC content for determining compliance. The topcoats are not among the categories of coatings which are subject to Part 5 (vinyls, NC lacquers, acrylics, epoxies, maintenance finishes, or custom product finishes).

Part 7 requires fuel-burning and refuse-burning equipment to be operated to minimize emissions of VOC. There is no fuel-burning equipment at this facility except for trivial space heaters.

Part 7 also requires effluent water separators which receive water containing more than 200 gallons per day of any VOC to be equipped with vapor control devices. There is no water effluent separator at this location.

OAC 252:100-41 (Hazardous Air Pollutants and Toxic Air Contaminants) [Applicable]

Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted by reference as they exist on September 1, 2004, with the exception of Subparts B, H, I, K, Q, R, T, W and Appendices D and E, all of which address radionuclides. In addition, General Provisions as found in 40 CFR Part 63, Subpart A, and the Maximum Achievable Control Technology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, J, L, M, N, O, Q, R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS, TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO, PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, DDDD, EEEE, FFFF, GGGG, HHHH, IIII, JJJJ, KKKK, MMMM, NNNN, OOOO, PPPP, QQQQ, RRRR, SSSS, TTTT, UUUU, VVVV, WWWW, XXXX, YYYY, ZZZZ, AAAAA, BBBBB, CCCCC, EEEEE, FFFFF, GGGGG, HHHHH, IIIII, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP, QQQQQ, RRRRR, SSSSS and TTTTT are hereby adopted by reference as they exist on September 1, 2004. These standards apply to both existing and new sources of HAPs. These requirements are covered in the “Federal Regulations” section.