OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITYPREP-24 PE-722 Inner Liner (PGI) Extruder 2011 PREP-25 PE-280 VMI Apex Extruders 1 & 2 2016 PREP-26 PE-280 VMI Apex Extruders 3 & 4 2017

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OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM January 2, 2019

TO: Phillip Fielder, P.E., Chief Engineer

THROUGH: Rick Groshong, Environmental Manager, Compliance and Enforcement

THROUGH: Phil Martin, P.E., Manager, Existing Source Permits Section

THROUGH: Ryan Buntyn, P.E., Existing Source Permits Section

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

SUBJECT: Evaluation of Permit Application No. 2018-0965-TVR3

Michelin North America, Inc

Ardmore Rubber Tire Manufacturing (FAC ID 1648)

Section 26 – T4S – R1E

Ardmore, Carter County, Oklahoma

Directions: At Northwest Corner from I-35 Exit 32

Latitude 34.18085o, Longitude 97.17195o

SECTION I. INTRODUCTION

Michelin North America (Michelin) has requested renewal of the Title V operating permit for

their Ardmore tire plant (SIC Code 3011). The facility is currently operating under Permit No.

2013-1159-TVR2 (M-1) issued May 16, 2017.

Michelin has requested the following changes from the current operating permit:

1. Tire building operations will be renamed from EUG “TBLDG” to “PREP.”

2. The White Sidewall (WSW) inspection grinder will be moved to EUG “WSW” from

EUG “PREP.”

3. Tread-end cementing operations currently in EUG “PREP” will be moved to a separate

EUG for operations subject to MACT Subpart XXXX.

4. The Tire Uniformity Optimizer (TUO) operations and WSW operations will be classified

as “insignificant activities.” The applicant has submitted calculations showing that

emissions from each operation are below 5 TPY prior to controls.

5. The boilers will be limited to natural gas fuel only to avoid liquid fuel requirements of

MACT Subpart DDDDD.

PERMIT MEMORANDUM 2018-0965-TVR3 2

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6. Three tanks have been removed from service and will be removed from the permit: Tank

A-2 (8,820 gallon solvent tank), Tank F-1 (420,000 gallon diesel fuel storage), and Tank

I-2 (8,820 gallon hydraulic oil bulk storage).

7. Two 30,000 gallon process oil tanks (B-1 and B-2), which were previously subject to

NSPS Subpart Kb at construction but have ceased to be due to vapor pressures below 0.5

psia, are being moved from EUG “TANKS-1” to EUG “TANKS” with other tanks not

subject to Subpart Kb.

8. The Mix Area Vacuum Cleaner, used for housekeeping, is being removed from the

permit.

9. The carbon black unloading systems do not use a baghouse, therefore, are not subject to

CAM. The operation consists only of a carbon black unloading system. The system is a

pneumatic system that uses the negative pressure created by the cyclonic system to pull

carbon black from the hopper delivery truck. The cyclonic system temporarily holds the

carbon black while the air valves are reversed. Once the valves are reversed, the carbon

black is pneumatically transferred to sealed silos. From the silos, the carbon black is

pneumatically transferred to sealed bins. The bins are stored on the carbon black storage

pad. As carbon black is needed at the mixer, a “Seald Bin” is moved by lift to the crane

hoist for hoisting to the 3rd floor of the mix area. The bin is moved into the building to the

mixer weigh-up and then transferred by gravity to the mix process. The cyclones and the

silos are contained in a separate building. There are no separate dust collectors in the

carbon black transfer system. Air is recirculated and discharged only at transport

decoupling. Filters are internal to the cyclone to prevent carbon black from being lost

when the air flow is reversed. The filters are part of the cyclone. Calculated annual PM

emissions are 1.24 TPY, making carbon black unloading an “insignificant activity” now.

Since the facility emits more than 100 TPY of a regulated pollutant, it is subject to Title V

permitting requirements. Emission units (EUs) have been arranged into Emission Unit Groups

(EUGs). The facility is subject to PSD requirements and also subject to the requirements of 40

CFR Part 63, Subparts XXXX, ZZZZ, and DDDDD.

SECTION II. FACILITY DESCRIPTION

The facility was initially constructed in 1970 and was modified in 1974, 1975, 1976, 1982, 1988,

1991, 1992, 1993, 1996, 1999, 2001, 2005, 2008, 2009, 2013, 2016, and 2017.

Tire production begins with mixing raw materials (natural and synthetic rubbers, carbon black,

and accelerators) in a large blender called a Banbury mixer. Mixed rubber of varying

compositions are produced in long sheets and stacked on pallets prior to movement to the various

rubber-using operations.


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The rubber "mixed stock" is used for making tire components in the Stock Preparation Area.

Primary components are rubber-coated fabric, rubber-coated wire, and solid rubber profiles for

treads, sidewalls, and miscellaneous components. Mixed stock passes through a series of two-roll

mills where the rubber stock is blended and warmed by running through the rollers; no external

heat is added. The rubber is processed to its final shape by passing through extruders or

"calenders," where fabric cord and rubber are pressed flat. Cement may be applied to the tread

ends to bond the ends together during the tire assembly process. As a result of process

improvement, it is no longer necessary to cement all tread ends.

Tire assembly involves putting together beads, the inner liner, ply materials, sidewalls, steel

belts, and tread. The assembled tire is referred to as a "green tire". “Green Tire Spray” is applied

to the green tire to aid in mold release. The green tires are "cured" with no-contact steam heat to

fuse the rubber components, imprint the tread pattern, and complete the vulcanizing process.

Cured tires proceed to the "TUO" (tire uniformity optimizer - RIS grinding) where very small

amounts of rubber may be ground off the tread and sidewalls.

In addition to the tire manufacturing processes, the plant includes a "bladder" manufacturing unit.

"Bladders" are inflatable rubber balloons, which are used during tire curing to press the green tire to

its mold from inside the green tire. Bladders are manufactured at the Ardmore plant both for use

within the plant and other tire manufacturing locations.

There are three boilers supporting the operations. Two of these predated the first permitting

regulation (October 1972), while the third was installed in 1975. Each boiler is rated at 60

MMBTUH and is designed to burn both liquid (either distillate or residual oils) and gas fuels. The

facility is now taking a limit that the boilers be fueled only with natural gas to avoid most standards

of NESHAP Subpart DDDDD.

Permit No. 2000-128-C (PSD)(M-1) authorized the facility to prepare a new type of rubber,

rubber using a silica blend, on existing units at the facility. The tires that contain this

silica/elastomer compound have a lower rolling resistance, good grip on cold road surfaces, and

better tread wear qualities. Since only a portion of the tire is tread rubber and only a portion of

that tread contains silica, the silica filler is never used at the process’s maximum capacity. The

project added units which receive and store silica. A facility-wide cap on raw materials usages was

established.


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SECTION III. EQUIPMENT

EUG PREP: Rubber Preparation

EU Point EU Name Construction Date

PREP-1 PE-216

PE-217

Metallic Tissue (wire calendar & warm-up

mill) 6/72

PREP-3

PE-218

PE-219

PE-220

PE-221

Sidewall Lines 2 & 3 10/70

PREP-7

PE-223

PE-224

PE-225

Fabric calender & warm-up mills 11/70

PREP-16

PE-232

PE-233

PE-234

Inner Line Calender Line warm-up mills and

calender 4/94

PREP-21 PE-280 Auto Apex Extruder 1997

PREP-23 PE-230 Sidewall Line No. 4 2003

PREP-24 PE-722 Inner Liner (PGI) Extruder 2011

PREP-25 PE-280 VMI Apex Extruders 1 & 2 2016

PREP-26 PE-280 VMI Apex Extruders 3 & 4 2017

PREP-27 PE-280* Sidewall Coex Extruder 2017

PREP-28 PE-277 Single Strand Bead Coil Extruders (4) 2002

EUG TRED12: Tire Building Operations Subject to MACT Subpart XXXX


TRED1

PE-226

PE-227

PE-228

No. 1 Tread Line with tread end cementing

(warm-up mill & extruder) 10/70

TRED2

PE-229

PE-230

PE-231

No. 2 Tread Line with tread end cementing

(warm-up mill & extruder) 2/73

EUG TRED3: Tread Line 3


TRED3-1

PE-271

PE-272

PE-274

No. 3 Tread End Line (subject to NSPS Subpart

BBB) 1/97


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EUG CUR: Tire Curing


CUR-1 EF * Curing presses 1970-2006

PTTCUR EF * Electric curing press 2017

* There are numerous identical exhaust fans serving general building ventilation: EF577, EF579,

F581, EF582, EF583, EF584, EF585, EF586, EF587, EF588, EF589, EF590, EF591, EF592,

EF593, EF594, EF606, EF607, EF608, EF609, EF610, EF611, EF612, EF613, EF614, EF596,

EF597, EF598, EF599, EF600, EF601, EF602, EF603, EF604, EF615, EF616, EF617, EF618,

EF619, EF620, EF621, EF622, EF623, EF624, EF625, EF626, EF627,EF628, EF629, and

EF630.

EUG MEMB: Membrane (Bladder) Manufacturing


MEMB-1

PE-253

PE-270

PE-269

Bladder Line 1/73 – 6/92

EUG TUO: Tire Uniformity Optimization Grinding (Insignificant Activities)


TUO-1

E-258

E-259

TUO Line Group “E” 6/72

TUO-2 TUO Line Group “G” 5/76

TUO-3 TUO Line Group “D” 10/71, 2017

TUO-4 TUO Line Group “H” 10/82

TUO-5 TUO Line Group “B” 3/75

TUO-6 TUO Line Group “C” 11/77

TUO-7 TUO Line Group “Y” 10/89

TUO-8 TUO Line Group “X” 9/91

EUG WSW: White Sidewall Grinding (Insignificant Activities)


WSW-1 E-M WSW Grinder Group “M” 12/2007

WSW-2 E-J WSW Grinder Group “J” 12/2007

WSW-3 E-256 WSW Grinder Group “F” 4/73

PREP-20 PE-257 WSW inspection and blem repair grinder 4/73

EUG B1: Boiler No. 1

EU Point EU Description Capacity Construction Date

B1 PE-245 Keeler Boiler, Model DS10-10 60 MMBTUH 5/72 (installed 1975)

The boilers will now burn only natural gas fuel. The liquid fuels have been removed from

the location.


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B2 PE-244 Keeler Boiler, Model DS10-10 60 MMBTUH 10/70



B3 PE-243 Keeler Boiler, Model DS10-10 60 MMBTUH 10/70

EUG GEN: Emergency Generator


GEN-1 GEN-1 Caterpillar D346 (S/N 39J336)

Gen set (S/N 300PH2014)

350 kW

(440 HP) 1971

EUG FIRE: Fire Pump Engines Subject to NSPS Subpart IIII


FIRE2 FIRE2 Clark Model JU6H-UFADX8

(North pump house) 305 HP 2016


(South pump house) 305 HP 2018





EUG TANKS: Storage Tanks Not Subject to NSPS


A Tank A-1 South solvent tank 8,820 gal. 1991

B Tank B-1 North process oil tank 30,000 gal. 1992


C Tank C-1 Vehicle gasoline tank 1,100 gal. 1974

C Tank C-2 Vehicle diesel tank 1,100 gal. 1974

D Tank D-1 South pump house diesel tank 350 gal. 1970

D Tank D-2 North pump house diesel tank 350 gal. 1970

E Tank E-1 Standby fuel tank 5,754 gal. 1991

G Tank G-1 South pump house diesel tank 350 gal. 1970

G Tank G-2 North pump house diesel tank 350 gal. 1970

H Tank H-1 Waste collection tank No. 1 8,820 gal. 1979



H Tank H-4 Waste oil skimmer 8,000 gal. 1978

I Tank I-1 Cooling water recovery 8,820 gal. 1981

K Tank K-1 Emergency generator fuel 551 gal. 1970

L Tank L-1 Membrane shop waste oil 2,220 gal. 1997

M Tank M-1 Propane 1,000 gal. 1998



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M Tank M-3 Propane 500 gal. 1996



B Tank B-3 South process oil tank 17,000 gal. 1992

EUG EVAP: Evaporative Losses


EVAP-1 PE-224 Marking inks 1970-present

EVAP-2 EF Maintenance parts cleaning 1970-present

EVAP-3 EF Tire protective coatings 1970-present

EUG CB-HAND: Bulk Carbon Black Unloading


CB-UNLD CB-UNLD Carbon Black Unloading 2005

EUG MIX-2: Rubber Mixing Operations


MIX-5 PE-209

PE-213 Mix Line 11 12/71

MIX2-16 NA* Mixing Line 13 and Silica Silo 12/00

MIX3-2

PE-206

PE-212

PE-203

Mixing Line 12 2/72

MIX3-3

PE-207

PE-208

PE-215

PE-214

Mixing Line 13 11/72

MIX-6

PE-210

PE-211

PE-214

Mix Line 14 2/77

* The silica silo operates with a closed system without a discharge point.

EUG TBLDG-3


TBLDG-23 EF Sidewall Line No. 4 2003

EUG GTS-2: New Green Tire (“Carcass”) Spray Operations


GTS2-6 E-101 GTS Sprayer 2005



GTS-2-9 E-104 GTS Sprayer 2008


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EUG IA-NEW: New Insignificant Activities


PE-275

PE-276

PE-275

PE-276 Chemical Weighing System 2002

PE-277 PE-277 Single Strand Bead Coil Extruders 2002

-- -- Balancing Operation 2005

-- -- WSW Grinders 2007

-- -- Warming Oven for scrap tire recovery 2007

-- -- Ash Furnace for sample testing 2008

-- -- Green Tire Sprayers for identification 2008

-- -- Auto Apexers (2) 2010 / 2011

-- -- Lab product testing equipment 2013

EUG EVAP-NEW: New Evaporative VOC Emissions


-- -- WSW Protective Spray (new automatic unit) 2007

SECTION IV. EMISSIONS

Emissions from the facility are limited by a plantwide cap described following. Air pollutants

will be emitted from gluing/cementing operations, from solid raw materials mixing and

handling, from rubber heating/molding operations, from green tire spraying, miscellaneous

operations, and the three boilers. Emissions from adhesive usage, green tire spraying, and

protective coatings are determined on a mass-balance basis. Emissions of powdered solids

were determined from stack testing at other facilities. Estimated emissions for the tanks are

based on TANKS3.1. Emissions from tire and bladder grinding were estimated from factors

supplied by the Rubber Manufacturer’s Association (RMA), as were emissions from

compounding and extruding conventional tire rubber. Emissions from compounding and

extruding silica rubber were based on stack testing by the RMA: compounding operations yield

0.122 pound of ethanol per pound of silane, while curing operations yield 0.049 pounds of

ethanol per pound of silane.

Emissions calculations were based on 42,250 tires per day. The sum of emissions shown for

individual emissions units will exceed the plantwide total, allowing production to swing

between EUGs, but the plantwide “cap” will provide the effective limitation.

Facility boilers will be limited to natural gas fuel. Emissions were calculated using factors for

AP-42 (7/98), Section 1.4 for gas fuel.

The Rubber Manufacturer's Association (RMA) has developed factors for VOC and HAP

emissions from rubber processing; these factors have been proposed, but not yet accepted, for

inclusion into AP-42. According to the applicant, whenever a range was specified, the high end

of the range was used in calculating VOC emissions.

Since emissions rates are limited by tire curing rates, total emissions are less than the sum of

the individual emission unit group limitations.


DRAFT

FACILITY EMISSIONS

EUG ID PM2.5/PM10 SO2 NOx VOC CO

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

PREP 0.01 0.01 -- -- -- -- 3.0 13.2 -- --

TRED1-2 0.01 0.01 -- -- -- -- 33.4 146.3 -- --

TRED3 0.01 0.01 -- -- -- -- 13.7 59.8 -- --

CUR -- -- -- -- -- -- 23.3 101.9 -- --

MEMB 0.2 0.7 -- -- -- -- 0.4 1.5 -- --

GTS-2 3.0 12.6 -- -- -- -- 0.4 1.4 -- --

TUO 6.0 26.4 -- -- -- -- 1.1 5.0 -- --

WSW 4.9 21.6 -- -- -- -- 0.9 4.0 -- --

B1 0.44 1.95 0.04 0.15 5.85 25.64 0.32 1.41 4.92 21.54

B2 0.44 1.95 0.04 0.15 5.85 25.64 0.32 1.41 4.92 21.54

B3 0.44 1.95 0.04 0.15 5.85 25.64 0.32 1.41 4.92 21.54

GEN 0.95 0.24 0.89 0.22 13.58 3.4 1.11 0.28 2.93 0.73

FIRE 0.44 0.12 2.48 0.62 14.60 3.65 0.24 0.06 0.66 0.17

TANKS -- -- -- -- -- -- 0.4 1.8 -- --

EVAP 0.1 0.6 -- -- -- -- 5.6 24.3 -- --

TANKS-1 -- -- -- -- -- -- 0.4 1.8 -- --

MIX-2 2.4 10.4 -- -- -- -- 32.9 144.0 -- --

TBLDG-3 -- -- -- -- -- -- 1.0 4.1 -- --

IA-NEW 1.2 5.1 -- -- -- -- 1.8 2.8 -- --

CB-HAND 0.22 1.0 -- -- -- -- -- -- -- --

Totals 20.76 84.64 3.49 1.29 45.73 83.97 120.6 516.47 18.35 65.52

Existing Totals 32.1 138.9 41.6 144.7 56.4 160.2 132.5 573.8 15.5 53.5

CHANGES -11.34 -54.26 -38.11 -143.41 -10.67 -76.23 -11.90 -57.33 2.85 12.02

Potential greenhouse gas emissions have been stated at 92,000 TPY CO2e.

HAZARDOUS AIR POLLUTANT EMISSIONS

HAP C A S

Number

Emissions

lb/hr TPY

1,1,1-Trichloroethane 71556 0.036 0.16

1,3-Butadiene 106990 0.021 0.09

2-Chloroacetophenone 532274 0.001 0.01

Acetophenone 98862 0.490 2.16

Acrylonitrile 107131 0.017 0.07

Aniline 62533 1.130 4.93

Benzene 71432 0.020 0.09

Biphenyl 92524 0.006 0.03

bis-(2-Ethylhexyl) phthalate 117817 0.112 0.49

Cadmium 7440439 0.025 0.11

Carbon disulfide 75150 1.790 7.86

Carbonyl sulfide 463581 0.100 0.44


DRAFT

HAP C A S

Number

Emissions

lb/hr TPY

Chromium (trivalent) 1308389 0.001 0.01

Cobalt 7440484 0.001 0.01

Cumene 98828 0.102 0.44

Dibenzofuran 132649 0.002 0.01

Hexachlorobutadiene 87883 0.003 0.01

Isophorone 78591 1.390 6.07

Methylene chloride 75092 3.450 15.10

Naphthalene 91203 0.081 0.35

n-Hexane 110543 1.200 5.04

Nickel 7440020 0.014 0.06

o-Toluidine 95534 0.001 0.01

Phenol 108952 0.063 0.28

Styrene 100425 0.310 1.34

Tetrachlorethylene 127184 0.260 1.14

Toluene 108883 2.200 9.45

Xylene 1330207 1.340 3.39

SECTION V. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified in the application are duplicated below.

Records are available to confirm the insignificance of the activities. Appropriate

recordkeeping of activities indicated below with “*” is specified in the Specific Conditions.

1. Space heaters, boilers, process heaters and emergency flares less than or equal to 5

MMBTUH heat input (commercial natural gas). The plant space heaters meet this

criterion.

2. * Emissions from storage tanks constructed with a capacity less than 39,894 gallons

which store VOC with a vapor pressure less than 1.5 psia at maximum storage

temperature. The diesel fuel and kerosene tanks are in this category.

3. 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 stations).

4. Hazardous waste and hazardous materials drum staging areas.

5. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria

pollutant. This includes the oil-water separators, propane storage tanks, chemical mixing

operation, the balancing operation, WSW Protective Sprayer, Warming Oven (electric)

for scrap tire recovery, Ash Furnace (electric) for rubber sample testing, the BJ Tuber,

the TUO and WSW grinders, and the lab product testing equipment.

The facility will conduct welding and sandblasting during maintenance activities. These are

among the “trivial activities” for the facility.


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SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES

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

Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-2 (Incorporation by Reference) [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. In addition, modeled emissions from the facility demonstrate that the facility

would not have a significant impact on air quality.

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

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

Emission limitations for all the sources are taken from the permit application and previous

permit.

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

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

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

following working day of the first occurrence of excess emissions in each excess emission

event. No later than thirty (30) calendar days after the start of any excess emission event, the

owner or operator of an air contaminant source from which excess emissions have occurred

shall submit a report for each excess emission event describing the extent of the event and

the actions taken by the owner or operator of the facility in response to this event. Request

for mitigation, as described in OAC 252:100-9-8, shall be included in the excess emission


DRAFT

event report. Additional reporting may be required in the case of ongoing emission events

and in the case of excess emissions reporting required by 40 CFR Parts 60, 61, or 63.

OAC 252:100-13 (Prohibition of 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 (PM)) [Applicable]

This subchapter specifies a particulate matter (PM) emissions limitation of 0.36 lb/MMBTU

from fuel-burning equipment with a rated heat input of 60 MMBTU/hr. AP-42 (7/98),

Section 1.4 lists the PM emissions for natural gas at 0.0076 lb/MMBTU. This emission rate is

in compliance with Subchapter 19.

Subchapter 19 also specifies limitations on PM emissions based on process weight rate. The

following table compares emissions limitations with emissions estimates. All points are in

compliance with Subchapter 19.

Emission Unit

Group

Process Weight Rate,

TPH

Subchapter 19 PM

Emission Limitation,

lb/hr

PM Emissions,

lb/hr

EUG MIX 24.3 34.8 4.0

EUG MIX2 23.5 34.0 5.0

EUG MEMB 0.23 1.5 0.2

EUG GTS 31.2 40.3 2.5

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. When burning natural gas there is very little

possibility of exceeding these standards.

OAC 252:100-29 (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. Solids handling operations are

conducted in enclosed operations, with most discharges vented to baghouses. Under normal

operating conditions, this facility will not cause a problem in this area, therefore it is not

necessary to require specific precautions to be taken.


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

Two of the boilers were installed prior to 1972, the effective date of Subchapter 31, while

the third was installed after 1972.

Part 2 limits the ambient air concentration of hydrogen sulfide (H2S) emissions from any

facility to 0.2 ppmv (24-hour average) at standard conditions which is equivalent to 283

ug/m3. Facilities combusting pipeline-grade natural gas will have negligible H2S emissions.

Part 5 limits sulfur dioxide emissions from new equipment (constructed after July 1, 1972).

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

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

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


OAC 252:100-33 (Nitrogen Oxides) [Applicable]

This subchapter limits new fuel-burning equipment with rated heat input greater than or

equal to 50 MMBTUH to emissions of 0.2 lb of NOx per MMBTU when using gas fuel. The

newest boiler is subject to these limitations. Using AP-42 (1/95, Section 1.4) factors, gas

fuel emissions have been estimated at 0.10 lb/MMBTU. These emission rates are in


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

This facility has none of the affected sources: 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 new (constructed after December 28, 1974) storage tanks with a capacity

between 400 and 40,000 gallons holding an organic liquid with a true vapor pressure greater

than 1.5 psia. The rubber solvent and diesel have vapor pressures below the 1.5 psia

threshold.

Part 5 limits the VOC content of paints and coatings. Organic materials used as rubber

additives are not regulated by Subchapter 37.

Part 7 requires fuel-burning and refuse-burning equipment to be operated to minimize

emissions of VOC. The equipment at this location is subject to this requirement.

Part 7 also affects effluent-water separators which receive more than 200 gallons per day of

VOC which have a vapor pressure of 1.5 psia or greater. The facility operates effluent water

separators for stormwater clean-up and process oil separation. These separators receive less

than 200 gallons per day of VOC and the organic materials have vapor pressures below 1.5

psia.


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OAC 252:100-42 (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 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable]

This subchapter provides general requirements for testing, monitoring and recordkeeping

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

source. To determine compliance with emissions limitations or standards, the Air Quality

Director may require the owner or operator of any source in the state of Oklahoma to install,

maintain and operate monitoring equipment or to conduct tests, including stack tests, of the

air contaminant source. All required testing must be conducted by methods approved by the

Air Quality Director and under the direction of qualified personnel. A notice-of-intent to

test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA

Reference Method stack tests. Emissions and other data required to demonstrate compliance

with any federal or state emission limit or standard, or any requirement set forth in a valid

permit shall be recorded, maintained, and submitted as required by this subchapter, an

applicable rule, or permit requirement. Data from any required testing or monitoring not

conducted in accordance with the provisions of this subchapter shall be considered invalid.

Nothing shall preclude the use, including the exclusive use, of any credible evidence or

information relevant to whether a source would have been in compliance with applicable

requirements if the appropriate performance or compliance test or procedure had been

performed. Monitoring and reporting of solvent usage has been established to ensure

compliance with the facility plant-wide VOC emissions limit.

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

OAC 252:100-8 Part 9 Major Sources Affecting

Nonattainment Areas not in area category

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

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

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

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

OAC 252:100-29-2 Fugitive Dust/Nonattainment Areas not in area category

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

OAC 252:100-47 Landfills not in source category


DRAFT

SECTION VII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Applicable]

The facility is a major source for PSD and has been issued a PSD permit in the past. Any

future increases must be evaluated in the context of PSD significance levels: 40 TPY NOx,

100 TPY CO, 40 TPY SO2, 15 TPY PM10, 10 TPY PM2.5, 40 TPY VOC, 10 TPY TRS, 0.6

TPY lead, or 75,000 TPY CO2e.

NSPS, 40 CFR Part 60 [Subparts BBB and IIII Are Applicable]

Subparts D and Da (Steam Generating Units) affect boilers with rated heat input capacities

of 250 MMBTUH or more. Each boiler has a capacity of 60 MMBTUH, which is smaller

than the de minimis level for these regulations.

Subpart Db (Steam Generating Units) affects boilers with a rated heat input above 100

MMBTUH. Again, the 60 MMBTUH boilers are smaller than the applicability level.

Subpart Dc (Steam Generating Units) affects boilers with a rated heat input between 10 and

100 MMBTUH with commenced construction, reconstruction, or modification after June 19,

1989. All boilers were constructed prior to this date.

Subpart Kb (VOL Storage Vessels) affects VOL storage vessels with capacities above

19,813 gallons and which were constructed after July 23, 1984. Tanks containing an organic

liquid with a vapor pressure below 0.5 psia are not subject to Subpart Kb.

Subpart VV (Equipment Leaks of VOC in the Synthetic Organic Chemical Manufacturing

Industry). The equipment is not in a SOCMI plant.

Subpart BBB (Rubber Tire Manufacturing) affects equipment that commence construction,

modification, or reconstruction after January 20, 1983: each undertread cementing

operation, each sidewall cementing operation, each tread end cementing operation, each

bead cementing operation, each green tire spraying operation, and various Michelin-specific

operations. Tire curing presses are not an affected operation. The tread end cementing

operation permitted under Permit No. 96-139-C is limited to 10 grams per tire of VOC

emissions, while the green tire spraying units installed under Permit Nos. 91-035-C and 96-

139-C (M-2) are limited to 1.2 grams per tire of VOCs. The new electric curing press, TUO,

and apexers are not among the affected processes.

Subpart IIII (Stationary Compression Ignition Internal Combustion Engines) affects

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

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

after July 11, 2005. For the purposes of this subpart, the date that construction commences

is the date the engine is ordered by the owner or operator. Engines FIRE1, FIRE2, FIRE3,

and FIRE4 are subject to Subpart IIII standards as an emergency fire pump engine

constructed after 2005. The emergency generator engine at this facility pre-dates Subpart IIII.

NESHAP, 40 CFR Part 61 [Not Applicable]

The project involves no emissions of any of the pollutants subject to regulation under 40

CFR 61 except benzene. Subpart J affects process streams with 10% or more by weight

benzene; Subpart BB affects transfer and loading of streams with 70% or more by weight

benzene; and Subpart FF affects benzene-contaminated waste water handling at petroleum

refineries and chemical plants. None of these subparts affects benzene emitted from rubber

decomposition during heating.


DRAFT

NESHAP, 40 CFR Part 63 [Subparts XXXX, ZZZZ, and DDDDD Are Applicable]

Subpart XXXX (Tire Production) was promulgated on July 9, 2002. The facility, as an

existing source, had until July 9, 2005, to achieve compliance with the standards. Subpart

XXXX affects tire production, tire cord production, puncture sealant application, and rubber

processing. Subpart XXXX specifies the following standards for the following operations:

- Tire Production is defined as the collection of all processes that use or process

cements and solvents, including but not limited to storage and mixing vessels;

transfer equipment; wastewater handling and treatment operations; tread and cement

operations; tire painting operations; ink and finishing operations; undertread cement

operations; process equipment cleaning materials; bead cementing operations; tire

building operations; green tire spray operations; extruding, to the extent solvent are

used; cement house operations; marking operations; calendar operations, to the

extent solvents are used; tire striping operations; tire repair operations; slab dip

operations; other tire building operations to the extent solvents are used; and balance

pad operations. HAP emissions are limited to either (1) 1,000 grams per megagram

total cements and solvents, or (2) 0.024 grams per megagram rubber used.

- Tire cord production operations (which are defined to include dipping operations,

drying ovens, heat-set ovens, bulk storage tanks, mixing facilities, general facility

vents, air pollution control devices, and warehouse storage vents). HAP emissions

are limited to either (1) 280 grams per megagram fabric processed, (2) 1,000 grams

per megagram total coatings used.

- Puncture sealant application equipment. HAP emissions are limited to (1) 86%

reduction of HAPs by add-on controls, or (2) 1,000 grams HAPs per megagram total

puncture sealants used. (Michelin no longer conducts this type of operation at the

Ardmore Plant.)

- Rubber processing equipment (defined as banburys and associated mixing processes

and rubber warming operations). There are no standards for these operations.

The facility is subject to Subpart XXXX and all requirements are incorporated into the

permit.

Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). Owners and operators

of new or reconstructed engines at area sources and of new or reconstructed engines with a

site rating equal to or less than 500 HP located at a major source (except new or

reconstructed 4-stroke lean-burn engines with a site rating greater than or equal to 250 HP

and less than or equal to 500 HP located at a major source) must meet the requirements of

Subpart ZZZZ by complying with either 40 CFR Part 60 Subpart IIII (for CI engines) or 40

CFR Part 60 Subpart JJJJ (for SI engines). Engines FIRE1, FIRE2, FIRE3, and FIRE4 are

subject to NSPS Subpart IIII. The other emergency engine at this facility pre-dates the new

standards.

On March 3, 2010, EPA finalized additional requirements for stationary CI RICE. A

summary of these requirements for the emergency generator engine located at this facility are

shown following. The fire pump engines comply with Subpart ZZZZ by complying with

NSPS Subpart IIII.


DRAFT

Engine Category Normal Operation @ 15% O2

Existing Emergency CI & Black Start

CI

Change oil and filter every 500 hours of operation

or annually, whichever one comes first;

Inspect air cleaner every 1,000 hours of operation

or annually, whichever one comes first; and

Inspect all hoses and belts every 500 hours of

operation or annually, whichever one comes first

and replace as necessary.

Sources have the option to utilize an oil analysis program in order to extend the specified oil

change requirements of this subpart. Initial compliance demonstrations must be conducted

within 180 days after the compliance date. Owners and operators of a non-operational

engine can conduct the performance test when the engine is started up again.

Other applicable requirements include:

1) The owner/operator must operate and maintain the stationary RICE and after-treatment

control device (if any) according to the manufacturer’s emission-related written

instructions or develop their own maintenance plan which must provide to the extent

practicable for the maintenance and operation of the engine in a manner consistent with

good air pollution control practice for minimizing emissions.

2) Existing emergency stationary RICE located at an area source of HAP emissions must

install a non-resettable hour meter if one is not already installed.

Existing stationary CI RICE must comply with the applicable emission limitations and

operating limitations no later than May 3, 2013. The permit will require the facility to

comply with all applicable requirements.

Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Industrial,

Commercial and Institutional Boilers and Process Heaters. The boilers meet the definition of

“units designed to burn gas-1 fuels.” Boilers in this category are required to conduct a tune-

up of the boiler or process heater annually as specified in § 63.7540(a)(10).

If your unit is . . .

You must meet the

following . . .

1. A new or existing boiler or process heater with a continuous oxygen

trim system that maintains an optimum air to fuel ratio, or a heat input

capacity of less than or equal to 5 million Btu per hour in any of the

following subcategories: unit designed to burn gas 1; unit designed to

burn gas 2 (other); or unit designed to burn light liquid, or a limited use

boiler or process heater

Conduct a tune-up of

the boiler or process

heater every 5 years as

specified in §63.7540.


DRAFT

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 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 carbon black handling systems which previously used baghouses have had different

unloading system installed and no longer use controls subject to CAM.

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

Toxic and flammable substances subject to this regulation not stored on-site in quantities

greater than the threshold quantities. More information on this federal program is available

on the web page: www.epa.gov/rmp.

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, 2030.

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

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

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

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

emissions reduction.


DRAFT

The standard conditions of the permit address the requirements specified at §82.156 for

persons opening appliances for maintenance, service, repair, or disposal; §82.158 for

equipment used during the maintenance, service, repair, or disposal of appliances; §82.161

for certification by an approved technician certification program of persons performing

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

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

normally containing 50 or more pounds of refrigerant.

SECTION VIII. COMPLIANCE

Inspection

The facility was inspected on June 1, 2016, by Mr. Rodney Pesch of the AQD Enforcement

Section. A final determination of the compliance status of the facility has not yet been made

at this time.

Tier Classification and Public Review

This application has been determined to be a Tier II based on the request for a renewal of a

major source operating permit.

Public review of the application and permit are required. The applicant published the

“Notice of Filing a Tier II Application” on October 5, 2018, in the The Ardmorite, a daily

newspaper printed in Carter County. The notice stated that the application was available for

public review at Ardmore Public Library or at the Air Quality Division’s main office. The

applicant will also publish a “Notice of Tier II Draft Permit” in The Daily Ardmorite. The

facility is located within 50 miles of the Oklahoma border with Texas; that state will be

notified of the draft permit. The “proposed” permit will be submitted to EPA for a 45-day

review period.

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

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

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

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

the applicant owns the real property.

Fee Paid

Part 70 permit renewal fee of $7,500.


DRAFT

SECTION IX. SUMMARY

The facility was constructed as described in the permit application. Ambient air quality

standards are not threatened at this site. There are no active Air Quality compliance and

enforcement issues concerning this facility. Issuance of the permit is recommended,

contingent on public and EPA review.

DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Michelin North America, Inc Permit No. 2018-0965-TVR3

Ardmore Rubber Tire Manufacturing Plant

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

Quality on July 24, 2018. The Evaluation Memorandum, dated January 2, 2019, explains the

derivation of applicable permit requirements and estimates of emissions; however, it does not

contain operating limitations or permit requirements. Continuing operations under this permit

constitutes acceptance of, and consent to, the conditions contained herein:

1. Points of emissions and emissions limitations for each point: [OAC 252:100-8-6(a)]

A. EUG PREP

EU Point EU Name PM2.5/PM10 VOC

lb/hr TPY lb/hr TPY

PREP-1 PE-216

PE-217

Metallic Tissue (wire calendar &

warm-up mill)

0.01 0.01 3.01 13.19

PREP-3

PE-218

PE-219

PE-220

PE-221

Sidewall Lines 2 & 3

PREP-7

PE-223

PE-224

PE-225

Fabric calender & warm-up mills

PREP-16

PE-232

PE-233

PE-234

Inner Line Calender Line warm-up

mills and calender

PREP-21 PE-280 Auto Apex Extruder

PREP-23 PE-230 Sidewall Line No. 4

PREP-24 PE-722 Inner Liner (PGI) Extruder

PREP-25 PE-280 VMI Apex Extruders 1 & 2

PREP-26 PE-280 VMI Apex Extruders 3 & 4

PREP-27 PE-280 Sidewall Coex Extruder

PREP-28 PE-277 Single Strand Bead Coil Extruders (4)

SPECIFIC CONDITIONS PERMIT NO. 2018-0965-TVR3 2

DRAFT

B. EUG TRED12: Existing Tread Extruding Operations Subject to MACT Subpart XXXX

EU Point EU Name PM2.5/PM10 VOC

lb/hr TPY lb/hr TPY

TRED1

PE-226

PE-227

PE-228

No. 1 Tread Line with tread end

cementing (warm-up mill & extruder)

0.01 0.01 33.40 146.3

TRED2

PE-229

PE-230

PE-231

No. 2 Tread Line with tread end

cementing (warm-up mill & extruder)

i. The above units are subject to 40 CFR Part 63, Subpart XXXX. [40 CFR 63.5981]

C. EUG TRED3: Tread Extruding Operations Subject to NSPS Subpart BBB and MACT

Subpart XXXX

EU ID# Point

ID# EU Name

PM10 / PM2.5 VOC

lb/hr lb/hr TPY TPY

TRED3-1

PE-271

PE-272

PE-274

No. 3 Tread end line 0.01 0.01 13.7 59.8

i. The No. 3 Tread End Cementing operation (Krupp-Treadline #3) is subject to 40

CFR Part 60, Subpart BBB and shall comply with all applicable requirements.

In accordance with NSPS Subpart BBB, VOC emissions from the tread end

cementing unit shall not exceed 10 grams per tire. [40 CFR 60.542(a)(3)]

ii. The above unit is subject to 40 CFR Part 63, Subpart XXXX. [40 CFR 63.5981]

D. EUG CUR: Tire Curing Operations

EU ID# Point

ID# EU Name

VOC

lb/hr TPY

CUR-1 EF Curing presses 23.3 101.9

PTTCUR EF Electric curing press

i. Tire mold lubricant is subject to 40 CFR Part 63, Subpart XXXX.


DRAFT

E. EUG MEMB: Existing Membrane Production Operations

EU ID# Point

ID# EU Name

PM2.5/PM10 VOC

lb/hr TPY lb/hr TPY

MEMB-1

PE-253

PE-270

PE-269

Bladder line 0.2 0.7 0.4 1.5

i. All grinding shall be vented to cyclones or equivalent devices with PM control

efficiencies of at least 90%.

ii. The bladder release agent is subject to 40 CFR Part 63, Subpart XXXX.

F. EUG TUO: Existing Tire Uniformity Optimization Emissions from the equipment

listed below are estimated based on existing equipment items and are insignificant.


TUO-1

E-258

E-259

TUO Line Group “E” 6/72

TUO-2 TUO Line Group “G” 5/76

TUO-3 TUO Line Group “D” 10/71, 2017

TUO-4 TUO Line Group “H” 10/82

TUO-5 TUO Line Group “B” 3/75

TUO-6 TUO Line Group “C” 11/77

TUO-7 TUO Line Group “Y” 10/89

TUO-8 TUO Line Group “X” 9/91

G. EUG WSW: White Sidewall Grinding Operations Emissions from the equipment

listed below are estimated based on existing equipment items and are insignificant.


WSW-1 E-M WSW Grinder Group “M” 12/2007

WSW-2 E-J WSW Grinder Group “J” 12/2007

WSW-3 E-256 WSW Grinder Group “F” 4/73

PREP-20 PE-257 WSW inspection and blem repair grinder 4/73

i. All tire grinding shall be vented to cyclones or equivalent devices with PM

control efficiencies of at least 90%. [OAC 252:100-8-6(a)]


DRAFT

H. EUG B1: Boiler B1



EUG B1, 60

MMBTUH 0.44 1.95 0.04 0.16 5.85 25.64 0.32 1.41 4.92 21.54

i. The unit shall be fueled with commercial natural gas only. Compliance can be

shown by the following methods: for commercial 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 method. Compliance shall be

demonstrated at least once per calendar year. [OAC 252:100-31]

ii. The above unit is subject to 40 CFR Part 63, Subpart DDDDD, and shall

comply with the tune-up standards of 63.7540(a)(10).

I. EUG B2: Boiler B2



EUG B2, 60

MMBTUH 0.44 1.95 0.04 0.16 5.85 25.64 0.32 1.41 4.92 21.54








J. EUG B3: Boiler B3



EUG B3, 60

MMBTUH 0.44 1.95 0.04 0.16 5.85 25.64 0.32 1.41 4.92 21.54









DRAFT

K. EUG GEN: Emergency Generator


GEN-1 GEN-1 Caterpillar D346 (S/N 39J336)

Gen set (S/N 300PH2014)

350 kW

(440 HP) 1971

i. The owner/operator shall comply with all applicable requirements of the NESHAP:

Reciprocating Internal Combustion Engines, Subpart ZZZZ, for each affected facility

including but not limited to: [40 CFR 63.6580 through 63.6675]

a. § 63.6580 What is the purpose of subpart ZZZZ?

b. § 63.6585 Am I subject to this subpart?

c. § 63.6590 What parts of my plant does this subpart cover?

d. § 63.6595 When do I have to comply with this subpart?

e. § 63.6603 What emission limitations, operating limitations, and other

requirements must I meet if I own or operate an existing stationary RICE

located at an area source of HAP emissions

f. § 63.6604 What fuel requirements must I meet if I own or operate a stationary

CI RICE?

g. § 63.6605 What are my general requirements for complying with this subpart?

h. § 63.6612 By what date must I conduct the initial performance tests or other

initial compliance demonstrations if I own or operate an existing stationary

RICE with a site rating of less than or equal to 500 brake HP located at a

major source of HAP emissions or an existing stationary RICE located at an

area source of HAP emissions?

i. § 63.6625 What are my monitoring, installation, operation, and maintenance

requirements?

j. § 63.6630 How do I demonstrate initial compliance with the emission

limitations, operating limitations, and other requirements?

k. § 63.6640 How do I demonstrate continuous compliance with the emission

limitations, operating limitations, and other requirements?

l. § 63.6645 What notifications must I submit and when?

m. § 63.6650 What reports must I submit and when?

n. § 63.6655 What records must I keep?

o. § 63.6660 In what form and how long must I keep my records?

p. § 63.6665 What parts of the General Provisions apply to me?

q. § 63.6670 Who implements and enforces this subpart?

r. § 63.6675 What definitions apply to this subpart?


DRAFT

L. EUG FIRE: Fire Pump Engines Subject to NSPS Subpart IIII












FIRE2 0.11 0.03 0.62 0.15 3.65 0.91 0.06 0.02 0.66 0.17

FIRE1 0.11 0.03 0.62 0.15 3.65 0.91 0.06 0.02 0.66 0.17

FIRE3 0.11 0.03 0.62 0.15 3.65 0.91 0.06 0.02 0.66 0.17

FIRE4 0.11 0.03 0.62 0.15 3.65 0.91 0.06 0.02 0.66 0.17

i. The facility shall comply with applicable provisions of 40 CFR Part 60, Subpart IIII:

a. §60.4200 Am I subject to this subpart?

b. §60.4201 What emission standards must I meet for non-emergency engines if I

am a stationary CI internal combustion engine manufacturer?

c. §60.4202 What emission standards must I meet for emergency engines if I am a

stationary CI internal combustion engine manufacturer?

d. §60.4203 How long must my engines meet the emission standards if I am a

manufacturer of stationary CI internal combustion engines?

e. §60.4204 What emission standards must I meet for non-emergency engines if I

am an owner or operator of a stationary CI internal combustion engine?

f. §60.4205 What emission standards must I meet for emergency engines if I am an

owner or operator of a stationary CI internal combustion engine?

g. §60.4206 How long must I meet the emission standards if I am an owner or

operator of a stationary CI internal combustion engine?

h. §60.4207 What fuel requirements must I meet if I am an owner or operator of a

stationary CI internal combustion engine subject to this subpart?

i. §60.4208 What is the deadline for importing or installing stationary CI ICE

produced in previous model years?

j. §60.4209 What are the monitoring requirements if I am an owner or operator of a

stationary CI internal combustion engine?

k. §60.4210 What are my compliance requirements if I am a stationary CI internal

combustion engine manufacturer?

l. §60.4211 What are my compliance requirements if I am an owner or operator of

a stationary CI internal combustion engine?

https://www.ecfr.gov/cgi-bin/text-idx?SID=cc65e3b9c8dde949b6d6d3ef0ea6abf7&mc=true&node=sp40.8.60.iiii&rgn=div6#se40.8.60_14200
























DRAFT

m. §60.4212 What test methods and other procedures must I use if I am an owner or

operator of a stationary CI internal combustion engine with a displacement of less

than 30 liters per cylinder?

n. §60.4213 What test methods and other procedures must I use if I am an owner or

operator of a stationary CI internal combustion engine with a displacement of

greater than or equal to 30 liters per cylinder?

o. §60.4214 What are my notification, reporting, and recordkeeping requirements if

I am an owner or operator of a stationary CI internal combustion engine?

p. §60.4215 What requirements must I meet for engines used in Guam, American

Samoa, or the Commonwealth of the Northern Mariana Islands?

q. §60.4216 What requirements must I meet for engines used in Alaska?

r. §60.4217 What emission standards must I meet if I am an owner or operator of a

stationary internal combustion engine using special fuels?

s. §60.4218 What parts of the General Provisions apply to me?

t. §60.4219 What definitions apply to this subpart?

M. EUG TANKS: Non-NSPS Tanks Emissions from the equipment listed below are estimated

based on existing equipment items and are insignificant.


A Tank A-1 South solvent tank 8,820 gal. 1991


B Tank B-2 Middle process oil tank 30,000 gal. 1991

C Tank C-1 Vehicle gasoline tank 1,100 gal. 1974

C Tank C-2 Vehicle diesel tank 1,100 gal. 1974

D Tank D-1 South pump house diesel tank 350 gal. 1970

D Tank D-2 North pump house diesel tank 350 gal. 1970

E Tank E-1 Standby fuel tank 5,754 gal. 1991

G Tank G-1 South pump house diesel tank 350 gal. 1970

G Tank G-2 North pump house diesel tank 350 gal. 1970




H Tank H-4 Waste oil skimmer 8,000 gal. 1978

I Tank I-1 Cooling water recovery 8,820 gal. 1981

L Tank L-1 Membrane shop waste oil 2,220 gal. 1997






M Tank M-6 Compressed gas storage -- 1998

B Tank B-3 South process oil tank 17,000 gal. 1992

















DRAFT

N. EUG EVAP: Existing Evaporative VOC Emissions

EU ID# Point

ID# EU Name

VOC PM2.5/PM10

lb/hr TPY lb/hr TPY

EVAP-1 PE-273 Marking inks

5.6 24.3 0.1 0.6 EVAP-3 EF Tire protective coatings

EVAP-2 EF Maintenance parts cleaning

i. The above units are subject to 40 CFR Part 63, Subpart XXXX.

O. EUG MIX-2: Modified Rubber Mixing Operations

EUG ID Point

ID Process Description

PM2.5/PM10 VOC

lb/hr TPY lb/hr TPY

MIX-5 PE-209

PE-213 Mix Line 11

2.4 10.4 32.9 144.0

MIX2-16 NA* Mixing Line 13 and Silica Silo

MIX3-2

PE-206

PE-212

PE-203

Mixing Line 12

MIX3-3

PE-207

PE-208

PE-215

PE-214

Mixing Line 13

MIX-6

PE-210

PE-211

PE-214

Mix Line 14

* The silica silo operates with a closed system without a discharge point.

i. The following operations shall utilize specified PM emissions controls or equivalent

devices with at least the required control efficiency.

Operation PM Emission Control

Device

Minimum Required

Efficiency

Mixing Line 11 baghouse 98%

Mixing area vacuum cleaner baghouse 98%

Mixing Line 14 pigment baghouse 98%

Mixing Line 14 carbon black baghouse 98.5%


DRAFT

P. EUG TBLDG-3: No. 4 Sidewall Line

EU ID# Point

ID# EU Name

VOC

lb/hr TPY

TBLDG-23 EF Sidewall Line No. 4 0.5 2.1

Q. EUG GTS-2: New Green Tire Spraying Operations

EU ID# Point

ID# EU Name

PM2.5/PM10 VOC

lb/hr TPY lb/hr TPY

GTS2 E-101 GTS Sprayer

3.0 12.6 0.4 1.4 GTS2 E-102 GTS Sprayer



i. All spraying shall be vented to cartridge filters or equivalent devices with PM control

efficiencies of at least 99%.

ii. The above operations are subject to 40 CFR Part 60, Subpart BBB, and shall comply

with all applicable standards.

iii. VOC emissions from the green tire spraying units shall not exceed 1.2 grams per tire

for inside carcass sprays. [40 CFR 60.542(a)(5)(i)]

iv. VOC emissions from the green tire spraying units shall not exceed 9.3 grams per tire

for outside carcass sprays. [40 CFR 60.542(a)(5)(ii)]

v. The owner or operator of each tread end cementing operation and each green tired

spraying operation using only water-based sprays (inside or outside) containing less

than 1.0% by weight VOC is not required to conduct a monthly performance test as

described in NSPS Subpart BBB. In lieu of conducting a monthly performance test,

the owner or operator of each tread end cementing operation and each green tire

spraying operation shall submit formulation data or the results of Method 24 analysis

annually to verify the VOC content of each tread end cement and each green tire

spray material. [40 CFR 60.542(a)(5)(ii)]


DRAFT

R. EUG IA-NEW: New Insignificant Activities Emissions from the equipment listed below are

estimated based on existing equipment items and are insignificant.


PE-275

PE-276

PE-275

PE-276 Chemical Weighing System 2002

PE-277 PE-277 Single Strand Bead Coil Extruder 2002

-- -- Balancing Operation 2005

-- -- WSW Grinders 2007

-- -- Warming Oven for scrap tire recovery 2007

-- -- Ash Furnace for sample testing 2008

-- -- Green Tire Sprayers for identification 2008

-- -- Auto Apexers (2) 2010 / 2011

-- -- Lab Product Testing Equipment 2013

i. All discharges from the chemical weighing system shall be processed by fabric filters

and/or dry filters with an overall efficiency of 99% for particulate matter emissions

control. The filter(s) shall be operated at a pressure differential of at least 0.4” WC.

S. EUG EVAP-NEW: New Evaporative VOC Emissions


-- -- WSW Protective Spray (new automatic unit) 2007

i. The above unit is subject to 40 CFR Part 63, Subpart XXXX.

T. EUG CB-HAND: Emissions from the equipment listed below are estimated based on existing

equipment items and are insignificant.


CB-UNLD CB-UNLD Carbon Black Unloading 2005

U. Plant-Wide Total Emissions Limitations [OAC 252:100-8-6(a)]

Pollutant Emissions Limitations,

TPY

PM2.5/PM10 84.64

SO2 1.29

NOx 83.97

VOC 516.47

CO 65.52


DRAFT

2. The permittee shall be authorized to operate the facility 24 hours per day, every day of the

year, up to the following raw material usage rates, 12-month rolling totals: [OAC 252:100-8-6(a)]

Raw Material Usage Limitations VOC

Content

Solids

Content Annually

Rubber solvent 407,088 lbs 100% --

Green tire carcass spray compound

concentrate 680,000 lbs 1.0% 51.6%

Anti-blem spray compound 432,867 lbs --- 28.5%

Bladder spray compound 94,718 lbs 1.2% --

Inks 11,629 lbs 100% --

Isopropanol solvent 28,961 lbs 100% --

Other ink solvents 1,100 lbs 100% --

Maintenance solvent 3,163 lbs 100% --

Cured tire protectant spray 64,286 lbs 5.6% 20%

Rubber 370,200,000 lbs -- --

Silane (compounded on-site) 1,580,000 lbs -- --

Silane (cured on-site) 1,580,000 lbs -- --

3. Tire production shall not exceed 42,250 tires per day. [OAC 252:100-8-6(a)]

4. All records necessary to demonstrate compliance with permit conditions shall be maintained

on site for at least five years from the date of recording, and shall be available for review by

regulatory personnel during normal business hours. Such records include, but are not necessarily

limited to, the following: [OAC 252:100-43]

a. Tire production, both reject and acceptable tires (daily).

b. Pressure differential of each baghouse (daily when units served are operated).

c. Solvent and HAP content of tread-end cementing adhesives and green tire sprays,

including, but not limited to, material safety data sheets.

c. Usage of each raw material shown in Specific Condition No. 2 (monthly & 12-month

rolling totals).

d. Process rate of the No. 3 tread-end cementer (EUG “TRED3”), including volume of

cement used, number of treads processed, and solvent content of cement (monthly &

12-month rolling totals).

e. Type of solvent used in the parts washers, amounts of solvent used, and amounts

recovered for disposal (monthly & 12-month rolling totals).

f. Inspection and maintenance of cyclones used as air pollution controls on grinding

operations (monthly).


DRAFT

g. Material safety data sheets or equivalent documentation showing the organic solvent,

HAP, and solids content of the following raw materials: carcass spray, bladder spray,

blem repair ink, rubber ink, cured tired protectant, all cements, and all solvents.

h. Records as required by NSPS, Subparts BBB and IIII.

i. Records as required by NESHAP, Subpart XXXX.

j. Records as required by 40 CFR Part 63, Subpart ZZZZ, for the emergency engines.

k. Records as required by 40 CFR Part 63, Subpart DDDDD, for the boilers.

l. For the fuel(s) burned, the appropriate document(s) as described in Specific Condition

No. 1.

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

[OAC 252:100-43]

a. Kerosene, rubber solvent, and diesel storage tanks: vapor pressures of liquids stored.

b. Parts washers: usage of organic solvents (12-month rolling totals).

c. Throughput of solvents in tanks A-1 and A-2 (monthly and 12-month rolling totals).

d. Number of valves, flanges, etc. associated with propane tanks.

e. Calculations of emissions from the TUO and WSW operations(monthly and 12-

month rolling totals).

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

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

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

a. OAC 252:100-11 Alternative Emissions Reduction

b. OAC 252:100-15 Mobile Sources

c. OAC 252:100-23 Cotton Gins

d. OAC 252:100-24 Grain Elevators

e. OAC 252:100-35 Carbon Monoxide

f. OAC 252:100-47 Landfills


DRAFT

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

operating permit (September 17, 2003), the permittee shall submit to Air Quality Division of

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

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

8. The facility is subject to 40 CFR Part 63, Subpart XXXX, and shall comply with all applicable

standards. [40 CFR Part 63, Subpart XXXX]

a. 63.5980, What is the purpose of this subpart?

b. 63.5981, Am I subject to this subpart?

c. 63.5982, What parts of my facility does this subpart cover?

d. 63.5983, When do I have to comply with this subpart?

e. 63.5984, What emission limits must I meet for tire production affected sources?

f. 63.5985, What are my alternatives for meeting the emission limits for tire production

affected sources?

g. 63.5986, What emission limits must I meet for tire cord production affected sources?

h. 63.5987, What are my alternatives for meeting the emission limits for tire cord

production sources?

i. 63.5988, What emission limits must I meet for puncture sealant application affected

sources?

j. 63.5989, What are my alternatives for meeting the emission limits for puncture sealant

affected sources?

k. 63.5990, What are my general requirements for complying with this subpart?

l. 63.5991, By what date must I conduct an initial compliance demonstration or

performance test?

m. 63.5992, When must I conduct subsequent performance tests?

n. 63.5993, What performance test and other procedures must I use?

o. 63.5994, How do I conduct tests and procedures for tire production affected sources?

p. 63.5995, What are my monitoring, installation, operation, and maintenance

requirements?


DRAFT

q. 63.5996, How do I demonstrate initial compliance with the emission limits for tire

production affected facilities?

r. 63.5997, How do I conduct tests and procedures for tire cord production affected

sources?

s. 63.5998, What are my monitoring, installation, operation, and maintenance

requirements?

t. 63.5999, How do I demonstrate initial compliance with the emission limits for tire cord

production affected facilities?

u. 63.6000, How do I conduct tests and procedures for puncture sealant application affected

sources?

v. 63.6001, What are my monitoring, installation, operation, and maintenance

requirements?

w. 63.6002, How do I demonstrate initial compliance with the emission limits for puncture

sealant application affected sources?

x. 63.6003, How do I monitor and collect data to demonstrate continuous compliance with

the emission limits for tire production affected sources?

y. 63.6004, How do I demonstrate initial compliance with the emission limits for tire

production affected sources?

z. 63.6005, How do I monitor and collect data to demonstrate continuous compliance with

the emission limits for tire cord production affected sources?

aa. 63.6006, How do I demonstrate continuous compliance with the emission limits for tire

cord production affected sources?

bb. 63.6007, How do I monitor and collect data to demonstrate continuous compliance with

the emission limits for puncture sealant application affected sources?

cc. 63.6008, How do I demonstrate continuous compliance with the emission limits for

puncture sealant application affected sources?

dd. 63.6009, What notifications must I submit and when?

ee. 63.6010, What reports must I submit and when?

ff. 63.6011, What records must I keep?


DRAFT

gg. 63.6012, In what form and how long must I keep my records?

hh. 63.6013, What parts of the General Provisions apply to me?

ii. 63.6014, Who implements and enforces this subpart?

jj. 63.6015, What definitions apply to this subpart?

9. This facility is considered an existing Prevention of Significant Deterioration (PSD) facility.

As such, the facility is subject to the provisions of OAC 252:100-8-36.2(c) for any project as

defined therein. [OAC 252:100-8-36.2(c)]

10. On issuance, Permit No. 2018-0965-TVR3 replaces and supersedes Permit No. 2013-1159-

TVR2 (M-1), which will be cancelled.

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 73101-1677

Permit No.: 2018-0965-TVR3

Michelin North America, Inc. ,

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

a tire manufacturing plant, 1101 Michelin, Ardmore, Carter County subject to standard

conditions dated June 21, 2016, and specific conditions, both attached

This permit shall expire five (5) years from the issuance date below, except as authorized under

Section VIII of the Standard Conditions.

_______ __________________________

Division Director Date

Air Quality Division

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

Michelin North America

Attn: Mr. Thomas Howell

1101 Michelin Road

Ardmore, OK 73401

Re: Permit Application No. 2018-0965-TVR3

Ardmore Rubber Tire Manufacturing Plant

Section 26 – T4S – R1E

Ardmore, Carter County, Oklahoma

Dear Mr. Howell:

Enclosed is the permit authorizing operation of the referenced facility. 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 1st of every year. Any questions concerning the form or submittal

process should be referred to the Emissions Inventory Staff at (405) 702-4100.

Thank you for your cooperation in this matter. If we may be of further service, please contact our

office at (405)702-4100.

Sincerely,

David S. Schutz, P.E.

New Source Permits Section

AIR QUALITY DIVISION

Enclosure

MAJOR SOURCE AIR QUALITY PERMIT

STANDARD CONDITIONS

(June 21, 2016)

SECTION I. DUTY TO COMPLY

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

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

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

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

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

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

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

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

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

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

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

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

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

location listed.

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

D. It shall not be a defense for a permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

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

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

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

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

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

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

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

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

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

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

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

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

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

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

MAJOR SOURCE STANDARD CONDITIONS June 21, 2016 2

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

B. Records of required monitoring shall include:

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

(2) the date or dates analyses were performed;

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

(4) the analytical techniques or methods used;

(5) the results of such analyses; and

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

true, accurate, and complete.”

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

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


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

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

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

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

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

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

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

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

continuous monitoring system or monitoring device is inoperative.

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

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

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

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

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

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

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

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

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

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

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

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

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

or an equivalent method approved by Air Quality.

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

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

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

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

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

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

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

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

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

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


SECTION IV. COMPLIANCE CERTIFICATIONS

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

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

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

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


SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions

established for alternate operating scenarios, emissions trading, and emissions averaging, but

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

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

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

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

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

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

SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

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

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

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

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

SECTION VIII. TERM OF PERMIT

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

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

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

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

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

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

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

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

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

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

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

SECTION IX. SEVERABILITY

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

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

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

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


SECTION X. PROPERTY RIGHTS

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

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

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

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

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

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

SECTION XI. DUTY TO PROVIDE INFORMATION

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

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

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

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

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

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

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

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

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

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

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

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

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

SECTION XII. REOPENING, MODIFICATION & REVOCATION

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

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

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

anticipated noncompliance does not stay any permit condition.

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

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

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

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

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

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

date of this permit.

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

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


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

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

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

misleading information to the DEQ.

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

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

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

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

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

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

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

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

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

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

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

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

SECTION XIII. INSPECTION & ENTRY

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

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

permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(17)

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

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

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

kept under the conditions of the permit;

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

conditions of the permit;

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

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

operations regulated or required under the permit; and

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

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

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


SECTION XIV. EMERGENCIES

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

emergency;

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

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

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

permit.

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

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

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

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

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

SECTION XV. RISK MANAGEMENT PLAN

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

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

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


SECTION XVI. INSIGNIFICANT ACTIVITIES

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

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

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

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

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

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

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

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

for single HAP that the EPA may establish by rule.

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

SECTION XVII. TRIVIAL ACTIVITIES

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

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

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

requirement applies is not trivial even if included on the trivial activities list.

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

SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the

need for any permit revision or any notification to the DEQ (unless specified otherwise in the

permit). When an operating scenario is changed, the permittee shall record in a log at the facility

the scenario under which it is operating. [OAC 252:100-8-6(a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:

(1) result in no net emissions increases,

(2) are not modifications under any provision of Title I of the federal Clean Air Act, and

(3) do not cause any hourly or annual permitted emission rate of any existing emissions unit

to be exceeded;

provided that the facility provides the EPA and the DEQ with written notification as required

below in advance of the proposed changes, which shall be a minimum of seven (7) days, or

twenty four (24) hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the

DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such

change, the written notification required above shall include a brief description of the change

within the permitted facility, the date on which the change will occur, any change in emissions,

and any permit term or condition that is no longer applicable as a result of the change. The

permit shield provided by this permit does not apply to any change made pursuant to this

paragraph. [OAC 252:100-8-6(f)(2)]


SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility

unless elsewhere covered by a more restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized

in the specific examples and under the conditions listed in the Open Burning Subchapter.

[OAC 252:100-13]

(2) No particulate emissions from any fuel-burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(3) For all emissions units not subject to an opacity limit promulgated under 40 C.F.R., Part

60, NSPS, no discharge of greater than 20% opacity is allowed except for:

[OAC 252:100-25]

(a) Short-term occurrences which consist of not more than one six-minute period in any

consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours.

In no case shall the average of any six-minute period exceed 60% opacity;

(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7;

(c) An emission, where the presence of uncombined water is the only reason for failure to

meet the requirements of OAC 252:100-25-3(a); or

(d) Smoke generated due to a malfunction in a facility, when the source of the fuel

producing the smoke is not under the direct and immediate control of the facility and

the immediate constriction of the fuel flow at the facility would produce a hazard to

life and/or property.

(4) No visible fugitive dust emissions shall be discharged beyond the property line on which

the emissions originate in such a manner as to damage or to interfere with the use of

adjacent properties, or cause air quality standards to be exceeded, or interfere with the

maintenance of air quality standards. [OAC 252:100-29]

(5) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2

lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur

dioxide. [OAC 252:100-31]

(6) Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and

with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or

greater under actual conditions shall be equipped with a permanent submerged fill pipe or

with a vapor-recovery system. [OAC 252:100-37-15(b)]

(7) All fuel-burning equipment shall at all times be properly operated and maintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36]


SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of

ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an order for production or importation of certain

class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the

requirements of §82.4;

(2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain

class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping

requirements at §82.13; and

(3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,

HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane

(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an

ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air

conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term

“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the

vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the

air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger

buses using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions

reduction except as provided for MVACs in Subpart B: [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, service, repair, or disposal must comply

with the required practices pursuant to § 82.156;

(2) Equipment used during the maintenance, service, repair, or disposal of appliances must

comply with the standards for recycling and recovery equipment pursuant to § 82.158;

(3) Persons performing maintenance, service, repair, or disposal of appliances must be

certified by an approved technician certification program pursuant to § 82.161;

(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply

with record-keeping requirements pursuant to § 82.166;

(5) Persons owning commercial or industrial process refrigeration equipment must comply

with leak repair requirements pursuant to § 82.158; and

(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant

must keep records of refrigerant purchased and added to such appliances pursuant to §

82.166.


SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is

not inconsistent with Federal requirements, to provide for incorporation of requirements

established through construction permitting into the Source’s Title V permit without causing

redundant review. Requirements from construction permits may be incorporated into the Title V

permit through the administrative amendment process set forth in OAC 252:100-8-7.2(a) only if

the following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the

procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice to

the public that this permit is subject to EPA review, EPA objection, and petition to

EPA, as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit

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

process; that the public will not receive another opportunity to provide comments when

the requirements are incorporated into the Title V permit; and that EPA review, EPA

objection, and petitions to EPA will not be available to the public when requirements

from the construction permit are incorporated into the Title V permit.

(2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR §

70.8(a)(1).

(3) A copy of the draft construction permit is sent to any affected State, as provided by 40

C.F.R. § 70.8(b).

(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period

as provided by 40 C.F.R.§ 70.8(a) and (c).

(5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day

comment period of any EPA objection to the construction permit. The DEQ shall not

issue the permit until EPA’s objections are resolved to the satisfaction of EPA.

(6) The DEQ complies with 40 C.F.R. § 70.8(d).

(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8(a).

(8) The DEQ shall not issue the proposed construction permit until any affected State and

EPA have had an opportunity to review the proposed permit, as provided by these

permit conditions.

(9) Any requirements of the construction permit may be reopened for cause after

incorporation into the Title V permit by the administrative amendment process, by DEQ

as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40

C.F.R. § 70.7(f) and (g).

(10) The DEQ shall not issue the administrative permit amendment if performance tests fail

to demonstrate that the source is operating in substantial compliance with all permit

requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the

Title V review process.


SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing

shall preclude the use, including the exclusive use, of any credible evidence or information,

relevant to whether a source would have been in compliance with applicable requirements if the

appropriate performance or compliance test or procedure had been performed.

[OAC 252:100-43-6]

Documents

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITYPREP-24 PE-722 Inner Liner (PGI) Extruder 2011 PREP-25 PE-280 VMI Apex Extruders 1 & 2 2016 PREP-26 PE-280 VMI Apex Extruders 3 & 4 2017