michael l. parson, governor carol s. comer, director · project number: 2012-10-007 installation...

Michael L. Parson, Governor

DEC 1 9 2018 Mr. Michael Niemann GKN Aerospace North America, Inc. 142 James S. McDonald Boulevard Hazelwood, MO 63042

Re: Part 70 Operating Permit Renewal Installation ID: 189-1489, Permit Number: OP2018-086

Dear Mr. Niemann:

Carol S. Comer, Director

Enclosed with this letter is your Part 70 operating permit. Please review this document carefully. Operation of your installation in accordance with the rules and regulations cited in this document is necessary for continued compliance. It is very important that you read and understand the requirements contained in your permit.

This permit may include requirements with which you may not be familiar. If you would like the department to meet with you to discuss how to understand and satisfy the requirements contained in this permit, an appointment referred to as a Compliance Assistance Visit (CA V) can be set up with you. To request a CA V, please contact your local regional office or fill out an online request. The regional office contact information can be found at http://dnr.mo.gov/regions/. The online CAV request can be found at http://dnr.mo.gov/cav/compliance.htm.

You may appeal this permit to the Administrative Hearing Commission (AHC), P.O. Box 1557, Jefferson City, MO 65102, as provided in RSMo 643.078.16 and 621.250.3. If you choose to appeal, you must file a petition with the AHC within thirty days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed. If it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the AHC.

If you have any questions or need additional information regarding this permit, please contact the Air Pollution Control Program (APCP) at (573) 751-4817, or you may write to the Department of Natural Resources, Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102.

Sincerely,

AIR POLLUTION CONTROL

1/). I Q f~ . / ttt: 1,aJL~ . /6 Michael J. Stansfield, P .E. Operating Permit Unit Chief

MJS:bgj

Enclosures

c: PAMS File: 2012-10-007 ·~ ._.., Recycled paper

~[§) MISSOURI ~,, & I DEPARTMENT OF ~ \:11 NATURAL RESOURCES Air Pollution Control Program

PART 70 PERMIT TO OPERA TE

Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to operate the air contaminant source(s) described below, in accordance with the laws, rules, and conditions set forth herein.

Operating Permit Number: OP2018-086 Expiration Date: DEC 1 9 2023

Installation ID: 189-1489 Project Number: 2012-10-007

Installation Name and Address GKN Aerospace North America, Inc. 142 James S. McDonald Boulevard Hazelwood, MO 63042 St. Louis County

Installation Description:

Parent Company's Name and Address GKN Aerospace North America, Inc. 222 West Las Colinas Boulevard, Suite 1600-N Irving TX, 75039

GKN Aerospace North America, Inc. (GKN) manufactures various aerospace components. The components are sold to aircraft and space vehicle manufacturers for integration into final aerospace and defense products. These products include military and commercial aircraft, helicopters, missiles, space launch vehicles and other space systems and sensing systems. Examples of permitted equipment include paint spray booths, halogenated solvent degreasers, boilers, and plating lines. GKN is a major source of trichloroethylene, a hazardous air pollutant (HAP).

DEC 1 9 2018

Effective Date

GKN Aerospace North America, Inc. Installation ID: 189-1489

Table of Contents

Part 70 Operating Permit 2 Project No. 2012-10-007

I. INSTALLATION EQUIPMENT LISTING ............................................................................................. 4

EMISSION UNITS WITH LIMITATIONS ......................................................................................................... 4 EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS ............................................................................... 4

II. PLANT WIDE EMISSION LIMITATIONS ............................................................................................ 6

III. EMISSION UNIT SPECIFIC EMISSION LIMITATIONS ....................................................................... 7

AS-STL-0 l - PLANT-WIDE ADHESIVE/SEALANT USAGE .................................................................................... 7 BF-STL-01- MISCELLANEOUS INTERIOR PAINTING ............................................................................................ 7

Permit Condition (AS-STL-01 and BF-STL-01) - 001 ................................................................................... 7 10 CSR 10-5.295 Control of Emissions from Aerospace Manufacture and Rework Facilities ................... 7

BF-001-03 AND BF-002-03 - HAND WIPE SOLVENT BUILDING FUGITIVES ........................................................ 8 Permit Condition (BF-001-03 and BF-002-03) - 001.. .................................................................................... 8

IO CSR 10-6.075 Maximum Achievable Control Technology ................................................................... 8 40 CFR 63 Subpart GG National Emission Standards for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities ........................................................................................................... 8 IO CSR 10-5.295 Control of Emissions from Aerospace Manufacture and Rework Facilities ................... 8

BF-STL-02-PLANT-WIDE SPRAY GUN CLEANING .......................................................................................... 12 Permit Condition (BF-STL-02) - 001 ............................................................................................................ 12

10 CSR 10-6.075 Maximum Achievable Control Technology ................................................................. 12 40 CFR 63 Subpart GG National Emission Standards for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities ......................................................................................................... 12 10 CSR 10-5.295 Control of Emissions from Aerospace Manufacture and Rework Facilities ................. 12

BL-001-01 AND BL-001-02-BOILERS .............................................................................................................. 14 Permit Condition (BL-001-01 and BL-001-02)- 001 ................................................................................... 14

10 CSR 10-6.060 ........................................................................................................................................ 14 Construction Permits Required - SLCDH Air Pollution Control Program Permit Nos. 6953 & 6954 ....... 14

Permit Condition (BL-001-1 and BL-001-02) - 002 ..................................................................................... 15 IO CSR 10-6.070 New Source Performance Regulations .......................................................................... 15 40 CFR Part 60 Subpart Db Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units ......................................................................................................................................... 15

Permit Condition (BL-001-1 and BL-001-02) - 003 ..................................................................................... 16 IO CSR 10-6.075 Maximum Achievable Control Technology Regulations ............................................. 16 40 CFR Part 63 Subpart DDDDD National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters ....................................... 16

CC-STL-01 - PLANT-WIDE COLD CLEANERS .................................................................................................... 20 Permit Condition (CC-STL-01) - 001 ........................................................................................................... 20

10 CSR 10-5.300 Control of Emissions from Solvent Metal Cleaning ..................................................... 20 CL-001-01-COATING LINE ............................................................................................................................... 23

Permit Condition (CL-001-01 and CL-002-01) - 001 ................................................................................... 23 10 CSR 10-6.075 Maximum Achievable Control Technology ................................................................. 23 40 CFR 63 Subpart GG National Emission Standards for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities ......................................................................................................... 23 10 CSR 10-5.295 Control of Emissions from Aerospace Manufacture and Rework Facilities ................. 23

Permit Condition (CL-001-01) - 002 ............................................................................................................. 34 10 CSR 10-6.060 Construction Permits Required ..................................................................................... 34 SLCDH Air Pollution Control Program Construction Permit# 7824 ........................................................ 34

Permit Condition (CL-001-02) - 002 ............................................................................................................. 36 10 CSR 10-6.060 Construction Permits Required ..................................................................................... 36



SLCDH Air Pollution Control Program Construction Permit# 6259 ........................................................ 36 VD-001-0lAND VD-002-01 - VAPOR DEGREASER ............................................................................................ 37

Permit Condition (VD-001-01 and VD-002-01) - 001 .................................................................................. 37 10 CSR 10-6.075 Maximum Achievable Control Technology ................................................................. 37 40 CFR Part 63, Subpart T National Emission Standards for Halogenated Solvent Cleaning .................. 37

PL-001-02A ALUMINUM PROCESS LINE TANKS (TANK #Al4 & TANK #Al6) ............................................... 40 Permit Condition (PL-001-02A) - 001 .......................................................................................................... 40

10 CSR 10-6.060 Construction Permits Required ..................................................................................... 40 SLCDH Air Pollution Control Program Construction Permit# 7824 ........................................................ 40

HW-STL-01 -HANDLING OF HAzARDOUS WASTE ........................................................................................... 41 Permit Condition (HW-STL-01) - 001 .......................................................................................................... 41

10 CSR 10-6.075 Maximum Achievable Control Technology ................................................................. 41 40 CFR 63 Subpart GG National Emission Standards for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities ......................................................................................................... 41

GB-027-01 GRIT BLAST SYSTEM 12 FEET······································································································· 42 Permit Condition (GB-027-01) - 001 ............................................................................................................ 42

10 CSR 10-6.400 Restriction of Particulate Matter from Industrial Processes ......................................... 42

FP809813 - FIRE PUMP DIESEL ENGINE············································································································· 42 GEM020-01 EMERGENCY DIESEL GENERATOR .............................................................................................. 42 GEM027-01 - EMERGENCY NATURAL GAS GENERATOR .................................................................................. 42

Permit Condition (FP809813, GEM020-01 and GEM027-01) - 001 ............................................................ 42 10 CSR 10-6.075 Maximum Achievable Control Technology Regulations ............................................. 42 40 CFR Part 63, Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines ............................................................................. 42

Permit Condition (FP809813 and GEM020-01)-002 .................................................................................... 47 10 CSR 10-6.260 Restriction of Emissions of Sulfur Compounds ............................................................ 47

Permit Condition (FP809813 and GEM020-01 )-003 .................................................................................... 48 10 CSR 10-6.261 Control of Sulfur Dioxide Emissions ............................................................................ 48

GEM02-01 - 128 HP NATURAL GAS EMERGENCY GENERATOR ....................................................................... 49 GEM00 1-02 - 135 HP NATURAL GAS EMERGENCY GENERATOR ..................................................................... 49

Permit Condition (GEM02 and GEMO0l-02)- 001.. .................................................................................... 49 10 CSR 10-6.070 New Source Performance Regulations .......................................................................... 49 40 CFR Part 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines ................................................................................................................................... 49

IV. CORE PERMIT REQUIREMENTS .................................................................................................... 52

V. GENERAL PERMIT REQUIREMENTS .............................................................................................. 58

VI. ATTACHMENTS ...................................•.......................................................................................... 63

Attachment A- Specialty Coating VOC Limitations ................................................................................. 64 Attachment B - Opacity Emission Observations ........................................................................................ 65 Attachment C - Method 9 Opacity Emissions Observations ...................................................................... 66 Attachment D - Solvent Containing Waste Transfer Log ........................................................................... 67 Attachment E - Inspection/Maintenance/Repair/Malfunction Log ............................................................. 68 Attachment F - Purchase Records for Cold Cleaning Solvent .................................................................... 69 Attachment G - Employee Solvent Metal Cleaning Training Log ............................................................. 70 Attachment H - Inspection/Maintenance/Repair/Malfunction Log ............................................................ 71


Part 70 Operating Permit

I. Installation Equipment Listing

EMISSION UNITS WITH LIMITATIONS

4 Project No. 2012-10-007

The following list provides a description of the equipment at this installation that emits air pollutants and that are identified as having unit-specific emission limitations.

Emission Unit Description of Emission Unit

AS-STL-001 Plant-Wide Adhesive/Sealant Usage

BF-001-03 Hand Wipe Solvent Building Fugitives in Building 0 1

BF-002-03 Hand Wipe Solvent Building Fugitives in Building 02

BF-STL-01 Miscellaneous Interior Painting

BF-STL-02 Plant-Wide Spray Gun Cleaning (Miscellaneous Solvent & Cleaner Use)

BL-001-01 External Combustion Boiler Rated at 120.3 MMBtu/hr

BL-001-02 External Combustion Boiler Rated at 120.3 MMBtu/hr

CC-STL-01 Plant-Wide Cold Cleaners

CL-001-01 Coating Line (Paint Booths)

CL-002-01 Coating Line (Paint and Adhesive Booth)

VD-001-01 Vapor Degreaser (Trichloroethylene)

VD-002-01 Vapor Degreaser (Trichloroethylene)

PL-001-02A Aluminum Process Line Process Tanks A14 and A16

HW-STL-01 Plant-Wide Handling of Hazardous Waste Generated from Aerospace Activities

GB-027-01 Grit Blast System 12 feet, Cyclone & Bag Filter

FP809813 Diesel Fire Pump (Engine< 500 Horsepower)

GEM020-01 250 Horsepower Diesel Emergency Generator

GEM02-01 128 Horsepower Natural Gas Emergency Generator

GEM027-01 220 Horsepower Natural Gas Emergency Generator

GEM00l-02 135 Horsepower Natural Gas Emergency Generator

EMISSION UNITS WITHOUT SPECIFIC LIMITATIONS The following list provides a description of the equipment that does not have unit specific limitations at the time of permit issuance.

Description of Emission Source Emission

Unit

CC-STL-0lC

CU-STL-01

CU-STL-01

CS-STL-01

Description of Emission Unit

Plant-wide cleaning units less than 1 gal or 1 ft2 surface area

Plant-wide Composite Emissions

Composite Material Mfg. ( electrovert process)

(6) Natural gas make-up air heaters (12.2 MMBtu/hr, Installed in 1980)



Emission Unit

CS-STL-01

CT-STL-0lA

MS-029A-04

MP-STL-01

LH-STL-01 MS-STL-01

OV-STL-01

OV-STL-02

VR-STL-01

SC-STL-01

ST-STL-D

WE-STL-01

DT-STL-01

DT-STL-02

FC-027-01

MS-STL-03

MT-STL-01

OV-STL-03

PT-STL-01

WT-STL-01

MS-027-04

PI-027-058

PI-027-059

EF-027-098

PL-001-02B

PL-001-03

EF029A-016

Description of Emission Unit

Plant-wide combustion (indirect fired natural gas< 10 MMBtu/hr)

Plant-wide forced draft cooling towers (3 for bldg 1 & 3 for bldg 2)

Fiber placement machine for composites

Plant-wide maintenance painting

Miscellaneous lab hoods ( 5) Particulate creating sources (metal & composite working operations such as milling, use of cutting oils, cutting, grinding, sanding & load out of chips & cuttings; the majority of which are vented inside buildings) (5) Electric curing ovens (3)

Plant-wide electric burn-off ovens

Plant-wide diesel/no. 2 fuel oil refueling - vehicle &/or tank

Plant-wide salt corrosion chambers

Plant-wide diesel/no. 2 fuel oil storage tanks (<=10,000 gallons) (4)

Plant-wide welding (2)

Quench baths (2)

Heated wax tanks (wax, peel coat, etc.)

Floor cleaning

Bundling/packaging systems

Miscellaneous coolant storage tanks (12)

Process ovens (hydrogen releases from metal plating operations) (2)

Small process tanks (etching, plating, cleaning, stripping, etc.)

Waste oil storage tanks (3)

Hazardous waste shelter for less than 90 day storage in drums and containers

Liquid penetrant inspection booth (not subject to MACT GG)

Dye penetrant inspection booth (not subject to MACT GG)

Cutting fluid concentrator

Aluminum Process Line (Tanks 1 through 13, Tank 15, and tanks 17 through -22)

Titanium Process Line (Tanks 1,2,5,6,7,8,9,11)

Metal Strip & Preparation Line Acid/ Alkaline; Mist Eliminator (Tanks 1-17)



II. Plant Wide Emission Limitations

6 Project No. 2012-10-007

The installation shall comply with each of the following emission limitations. Consult the appropriate sections in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of the date that this permit is issued. The plant wide conditions apply to all emission units at this installation. All emission units are listed in Section I under Emission Units with Limitations and Emission Units without Limitations.

None.



III. Emission Unit Specific Emission Limitations

7 Project No. 2012-10-007

The installation shall comply with each of the following emission limitations. Consult the appropriate sections in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of the date that this permit is issued.

AS-STL-01 - Plant-Wide Adhesive/Sealant Usage BF-STL-01- Miscellaneous Interior Painting

(Miscellaneous Specialty Coating Emission Units)

Emission Description

Unit AS-STL-01 Plant-wide adhesive/sealant usage BF-STL-01 Miscellaneous Interior Painting

Permit Condition (AS-STL-01 and BF-STL-01) - 001 10 CSR 10-5.295 Control of Emissions from Aerospace Manufacture and Rework Facilities

Emission Limitation: 1) The permittee shall not cause, permit, or allow the emissions of volatile organic compounds (VOC)

from the coating of aerospace vehicles or components to exceed the VOC content limits listed in Table I (see Attachment A) expressed in pounds per gallon of coating, excluding water and exempt solvents delivered to a coating applicator that applies specialty coatings. [10 CSR 10-5.295(3)((A)3.]

2) The requirements for primers, topcoats, specialty coatings, and chemical milling maskants specified in subsection (3)(A) of this rule do not apply to the use oflow-volume coatings in these categories for which the rolling twelve (12) month total of each separate formulation used at the installation does not exceed fifty (50) gallons, and the combined rolling twelve (12) month total of all such primers, topcoats, specialty coatings, and chemical milling maskants used does not exceed two hundred (200) gallons. Coatings exempted under subsection (3)(I) of this rule are not included in the fifty (50) and two hundred (200) gallon limits. [10 CSR 10-5.295(3)((1))

Monitoring/Recordkeeping: 1) The permittee shall: [10 CSR 10-5.295(4)(B)l. A. & BJ

a) Maintain a list of coatings in use with category and VOC content as applied; and b) Record each coating volume usage on a monthly basis; and

2) All records must be kept on site for a period of five (5) years and made available to the department or its designated agent upon request. [10 CSR 10-5.295(4)(C)]

3) The permittee shall determine compliance for coatings which are not waterborne (water-reducible): determine the VOC content of each formulation less water and less exempt solvents as applied using manufacturer's supplied data or Method 24 of 40 CFR part 60, Appendix A. If there is a discrepancy between the manufacturer's formulation data and the results of the Method 24 analysis, compliance shall be based on the results from the Method 24 analysis. For waterborne (water reducible) coatings, manufacturer's supplied data alone can be used to determine the VOC content of each formulation. [10 CSR 10-5.295(5)(A)]


Reporting:


The permittee shall report to the St. Louis County Department of Health (SLCDH) Air Pollution Control Program, 6121 North Hanley Road, Berkeley, Missouri 63134 and the Missouri Department of Natural Resources Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, or AirComplianceReporting(@,dnr.mo.gov. no later than 30 days after the discovery that the VOC content limit set in this rule (Attachment A) is exceeded. Any deviations from this permit condition shall also be reported in the semi-annual monitoring report and annual compliance certification, as required by Section V of this permit.

BF-001-03 and BF-002-03 - Hand Wipe Solvent Building Fugitives


Unit BF-001-03 Hand wipe solvent building fugitives in building 1 BF-002-03 Hand wipe solvent building fugitives in building 2

Permit Condition (BF-001-03 and BF-002-03) - 001 10 CSR 10-6.075 Maximum Achievable Control Technology 40 CFR 63 Subpart GG National Emission Standards for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities 10 CSR 10-5.295 Control of Emissions from Aerospace Manufacture and Rework Facilities

Operational Limitation/Equipment Specification: 1) Housekeeping measures:

The permittee shall comply with the requirements in §63.744(a)(l) through (4) (listed below) unless the cleaning solvent used is identified in Table 1 of §63.744 or meets the definition of "Non-HAP material" in §63.742. The requirements of §63.744 a)(l) through (4) of do not apply to spent cleaning solvents, and solvent-laden applicators that are subject to and handled and stored in compliance with 40 CFR Parts 262 through 268 (including the air emission control requirements in 40 CFR part 265, subpart CC). [§63.744(a)] a) Unless the permittee satisfies the requirements in 63.744(a)(4), place used solvent-laden cloth,

paper, or any other absorbent applicators used for cleaning in bags or other closed containers. Ensure that these bags and containers are kept closed at all times except when depositing or removing these materials from the container. Use bags and containers of such design so as to contain the vapors of the cleaning solvent. Cotton-tipped swabs used for very small cleaning operations are exempt from this requirement. [§63.744(a)(l)]

b) Unless the permittee satisfies the requirements in 63.744 (a)(4), store fresh and spent cleaning solvents, except semi-aqueous solvent cleaners, used in aerospace cleaning operations in closed containers. [§63.744(a)(2)]

c) The permittee shall conduct the handling and transfer of cleaning solvents to or from enclosed systems, vats, waste containers, and other cleaning operation equipment that hold or store fresh or spent cleaning solvents in such a manner that minimizes spills. [§63.744(a)(3)]

d) The permittee shall demonstrate to the Director that equivalent or better alternative measures are in place compared to the use of closed containers for the solvent-laden materials described in §63.744(a)(l), or the storage of solvents described in §63.744 (a)(2). [§63.744(a)(4)]



2) Hand-wipe cleaning: a) The permittee shall use cleaning solvents that meet one of the requirements specified in §63.744

(b)(l), (b)(2), and (b)(3) (listed below). [§63.744(b)] i) Meet one of the composition requirements in Table 1 of §63.744 (see below);

[§63.744(b)(l)]

Table I-Composition Requirements for Approved Cleaning Solvents

Cleaning Solvent type Aqueous

Hydrocarbonbased

Composition Requirements

Cleaning solvents in which water is the primary ingredient (~80 percent of cleaning solvent solution as applied must be water). Detergents, surfactants, and bioenzyme mixtures and nutrients may be combined with the water along with a variety of additives, such as organic solvents ( e.g., high boiling point alcohols), builders, saponifiers, inhibitors, emulsifiers, pH buffers, and antifoaming agents. Aqueous solutions must have a flash point greater than 93 °C (200 °F) (as reported by the manufacturer), and the solution must be miscible with water.

Cleaners that are composed of photochemically reactive hydrocarbons and/or oxygenated hydrocarbons and have a maximum vapor pressure of 7 mm Hg at 20 °C (3.75 in. H2O and 68 °F). These cleaners also contain no HAP.

ii) Have a composite vapor pressure of 45 millimeters of Mercury (mmHg) (24.1 inches water (in H2O)) or less at 20 degrees Celsius (°C) (68 degrees Fahrenheit (°F)); or [§63.744(b)(2)]

iii) Demonstrate that the volume of hand-wipe solvents used in cleaning operations has been reduced by at least 60% from a baseline adjusted for production. The baseline shall be established as part of an approved alternative plan administered by the State. [§63.744(b)(3)]

b) The following cleaning operations are exempt from the requirements of (3) Hand-wipe cleaning: [§63.744(e)] i) Cleaning during the manufacture, assembly, installation, maintenance, or testing of

components of breathing oxygen systems that are exposed to the breathing oxygen; ii) Cleaning during the manufacture, assembly, installation, maintenance, or testing of parts,

subassemblies, or assemblies that are exposed to strong oxidizers or reducers ( e.g., nitrogen tetroxide, liquid oxygen, or hydrazine);

iii) Cleaning and surface activation prior to adhesive bonding; iv) Cleaning of electronic parts and assemblies containing electronic parts; v) Cleaning of aircraft and ground support equipment fluid systems that are exposed to the

fluid, including air-to-air heat exchangers and hydraulic fluid systems; vi) Cleaning of fuel cells, fuel tanks, and confined spaces; vii) Surface cleaning of solar cells, coated optics, and thermal control surfaces; viii) Cleaning during fabrication, assembly, installation, and maintenance of upholstery,

curtains, carpet, and other textile materials used in the interior of the aircraft; ix) Cleaning of metallic and nonmetallic materials used in honeycomb cores during the

manufacture or maintenance of these cores, and cleaning of the completed cores used in the manufacture of aerospace vehicles or components;

x) Cleaning of aircraft transparencies, polycarbonate, or glass substrates; xi) Cleaning and cleaning solvent usage associated with research and development, quality

control, and laboratory testing;



xii) Cleaning operations, using nonflammable liquids, conducted within five feet of energized electrical systems. Energized electrical systems means any AC or DC electrical circuit on an assembled aircraft once electrical power is connected, including interior passenger and cargo areas, wheel wells and tail sections; and

xiii) Cleaning operations identified as essential uses under the Montreal Protocol for which the Administrator has allocated essential use allowances or exemptions in 40 CFR 82.4.

Compliance Determinations: 1) Each cleaning operation subject to this subpart shall be considered in noncompliance if the permittee

fails to institute and carry out the housekeeping measures required under §63.744(a). Incidental emissions resulting from the activation of pressure release vents and valves on enclosed cleaning systems are exempt from this paragraph. [§63.749(c)] a) Hand-wipe cleaning: An affected hand-wipe cleaning operation shall be considered in

compliance when all hand-wipe cleaning solvents, excluding those used for hand cleaning of spray gun equipment under §63.744(c)(3), meet either the composition requirements specified in §63.744(b)(l) or the vapor pressure requirement specified in §63.744(b)(2). [§63.749(c)(l)]

Monitoring: I) Composition determination: The permittee shall determine compliance with the hand-wipe cleaning

solvent approved composition list specified in §63.744(b)(l) for hand-wipe cleaning solvents using data supplied by the manufacturer of the cleaning solvent. The data shall identify all components of the cleaning solvent and shall demonstrate that one of the approved composition definitions is met. [63.750(a)]

2) Vapor pressure determination: The permittee shall determine the composite vapor pressure ofhandwipe cleaning solvents used in a cleaning operation subject to this subpart as follows: [63.750(b)] a) For single-component hand-wipe cleaning solvents, the vapor pressure shall be determined by

using MSDS or other manufacturer's data, standard engineering reference texts, or other equivalent methods. [ 63. 7 50(b )(1)]

b) The composite vapor pressure of a blended hand-wipe solvent shall be determined by quantifying the amount of each organic compound in the blend using manufacturer's supplied data or a gas chromatographic analysis in accordance with ASTM E 260-91 (incorporated by reference as specified in 63 .14 of Subpart A of 40 CFR Part 63) and by calculating the composite vapor pressure of the solvent by summing the partial pressures of each component. The vapor pressure of each component shall be determined using the manufacturer's data, standard engineering texts or other equivalent methods. The following equation shall be used to determine the composite vapor pressure: [63.750(b)(2)]

PP = ~ (W,)(vP;)I Mw, cLiw nw nw

1=! _w + I-e + I-' MWw e=I MWe 1=1 Mw,

Where: Wi = Weight of the "i"th VOC compound, grams. Ww = Weight of water, grams. We= Weight of non-HAP, nonVOC compound, grams. MWi = Molecular weight of the "i"th VOC compound, gig-mole. MWw = Molecular weight of water, gig-mole. MWe = Molecular weight of exempt compound, gig-mole.



PPc = VOC composite partial pressure at 20°C, mm Hg.

11 Project No. 2012-10-007

VPi = Vapor pressure of the "i"th VOC compound at 20°C, mm Hg. (§63.750(b))

Recordkeeping: 1) The permittee shall record the information specified below: [§63.752(b)]

a) The name, vapor pressure, and documentation showing the organic HAP constituents of each cleaning solvent used for affected cleaning operations at the facility. [§63.752(b)(l)]

b) For each cleaning solvent used in hand-wipe cleaning operations that complies with the composition requirements specified in §63.744(b)(l) or for semi-aqueous cleaning solvents used for flush cleaning operations: [§63.752(b)(2)] i) The name of each cleaning solvent used; and [§63.752(b)(2)(i)] ii) All data and calculations that demonstrate that the cleaning solvent complies with one of the

composition requirements. [§63.752(b)(2)(ii)] iii) Annual records of the volume of each solvent used, as determined from facility purchase

records or usage records. [§63.752(b)(2)(iii)] c) For each cleaning solvent used in hand-wipe cleaning operations that does not comply with the

composition requirements in §63.744(b)(l), but does comply with the vapor pressure requirement in §63.744(b)(2): [§63.752(b)(3)] i) The name of each cleaning solvent used: [§63.752(b)(3)(i)] ii) The composite vapor pressure of each cleaning solvent used: [§63.752(b)(3)(ii)] iii) All vapor pressure test results, if appropriate, data and calculations used to determine the

composite vapor pressure of each cleaning solvent; and [§63.752(b)(3)(iii)] iv) The amount (in gallons) of each cleaning solvent used each month at each operation.

[§63. 752(b )(3)(iv)] d) For each cleaning solvent used for exempt hand-wipe cleaning operations specified in §63.744(e)

that does not conform to the vapor pressure or composition requirements of §63.744(b): [§63.752(b)(4)] i) The identity and amount (in gallons) of each cleaning solvent used each month at each

operation; and [§63.752(b)(4)(i)] ii) A list of the exempt processes to which the cleaning operation applies. [§63.752(b)(4)(ii)]

2) For cleaning solvents subject to 10 CSR 10-5.295, the permittee shall maintain: a) A list of materials with corresponding water contents for aqueous and semi-aqueous hand-wipe

cleaning solvents; b) A current list of cleaning solvents in use with their respective vapor pressure, or for blended

solvents, VOC composite vapor pressure for all vapor pressure compliant hand-wipe cleaning solvents. This list shall include the monthly amount of each applicable solvent used; and

c) A current list of exempt hand-wipe cleaning processes for all cleaning solvents with a vapor pressure greater than forty-five (45) mmHg used in exempt hand-wipe cleaning operations. This list shall include the monthly amount of each applicable solvent used.

Reporting: The permittee shall report to the SLCDH Air Pollution Control Program, 6121 North Hanley Road, Berkeley, Missouri 63134 and the Missouri Department of Natural Resources Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102: 1) Semi-annual reports occurring every six (6) months that identify:

a) Any instance where a non-compliant cleaning solvent is used for a nonexempt hand-wipe cleaning operation;



b) A list of any new cleaning solvents used for hand-wipe cleaning in the previous six (6) months, and as appropriate, their composite vapor pressure or notification that they comply with the composition requirements; and

c) If the operations have been in compliance for the semiannual period, a statement that the cleaning operations have been in compliance with the applicable standards. Sources shall also submit a statement of compliance signed by a responsible company official certifying that the facility is in compliance with all applicable requirements.

2) Semi-annual reports are due by: a) October 1st for monitoring which covers the January through June time period, and b) April 1st for monitoring which covers the July through December time period.

BF-STL-02- Plant-Wide Spray Gun Cleaning


Unit BF-STL-02 Plant-Wide Spray Gun Cleaning (Miscellaneous Solvent & Cleaner Use)

Permit Condition (BF-STL-02) - 001 10 CSR 10-6.075 Maximum Achievable Control Technology 40 CFR 63 Subpart GG National Emission Standards for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities 10 CSR 10-5.295 Control of Emissions from Aerospace Manufacture and Rework Facilities

Operational Limitation/Equipment Specification: 1) Housekeeping measures:

The permittee shall comply with the requirements in §63.744(a)(l) through (4) (listed below) unless the cleaning solvent used is identified in Table 1 of §63.744 or meets the definition of "Non-HAP material" in §63.742. The requirements of §63.744 a)(l) through (4) of do not apply to spent cleaning solvents, and solvent-laden applicators that are subject to and handled and stored in compliance with 40 CFR Parts 262 through 268 (including the air emission control requirements in 40 CFR Part 265, Subpart CC). [§63.744(a)] a) Unless the permittee satisfies the requirements in 63.744(a)(4), place used solvent-laden cloth,

paper, or any other absorbent applicators used for cleaning in bags or other closed containers. Ensure that these bags and containers are kept closed at all times except when depositing or removing these materials from the container. Use bags and containers of such design so as to contain the vapors of the cleaning solvent. Cotton-tipped swabs used for very small cleaning operations are exempt from this requirement. [§63.744(a)(l)]

b) Unless the permittee satisfies the requirements in 63.744 (a)(4), store fresh and spent cleaning solvents, except semi-aqueous solvent cleaners, used in aerospace cleaning operations in closed containers. [§63.744(a)(2)]

c) The permittee shall conduct the handling and transfer of cleaning solvents to or from enclosed systems, vats, waste containers, and other cleaning operation equipment that hold or store fresh or spent cleaning solvents in such a manner that minimizes spills. [§63.744(a)(3)]

d) The permittee shall demonstrate to the Director that equivalent or better alternative measures are in place compared to the use of closed containers for the solvent-laden materials described in §63.744(a)(l), or the storage of solvents described in §63.744 (a)(2). [§63.744(a)(4)]


2) Spray gun cleaning:


a) The permittee shall use one or more of the techniques, or their equivalent, specified in §63.744(c)(l) through (c)(4) (listed belo0w). Spray gun cleaning operations using cleaning solvent solutions that contain HAP and VOC below the de minimis levels specified in §63.741(f) are exempt from the requirements in §63.744 (c)(l) through (c)(4). [§63.744(c)] i) Enclosed system. [§63.744(c)(l)]

(1) Clean the spray gun in an enclosed system that is closed at all times except when inserting or removing the spray gun. Cleaning shall consist of forcing solvent through the gun. [§63.744(c)(l)(i)]

(2) If leaks are found during the monthly inspection required in §63.751(a), repairs shall be made as soon as practicable, but no later than 15 days after the leak was found. If the leak is not repaired by the 15th day after detection, the cleaning solvent shall be removed, and the enclosed cleaner shall be shut down until the leak is repaired or its use is permanently discontinued. [§63 .744( c )(1 )(ii)]

ii) Nonatomized cleaning. Clean the spray gun by placing cleaning solvent in the pressure pot and forcing it through the gun with the atomizing cap in place. No atomizing air is to be used. Direct the cleaning solvent from the spray gun into a vat, drum, or other waste container that is closed when not in use. [§63.744(c)(2)]

iii) Disassembled spray gun cleaning. Disassemble the spray gun and clean the components by hand in a vat, which shall remain closed at all times except when in use. Alternatively, soak the components in a vat, which shall remain closed during the soaking period and when not inserting or removing components. [§63.744(c)(3)]

iv) Atomizing cleaning. Clean the spray gun by forcing the cleaning solvent through the gun and direct the resulting atomized spray into a waste container that is fitted with a device designed to capture the atomized cleaning solvent emissions .. [§63.744(C)(4)]

b) Cleaning of the nozzle tips of automated spray equipment systems, except for robotic systems that can be programmed to spray into a closed container, shall be exempt from the requirements of §63.744(c). [§63.744(c)(5)]

Compliance Determinations: 1) Each cleaning operation subject to this subpart shall be considered in noncompliance if the permittee

fails to institute and carry out the housekeeping measures required under §63.744(a). Incidental emissions resulting from the activation of pressure release vents and valves on enclosed cleaning systems are exempt from this paragraph. [§63.749(c)] a) An affected spray gun cleaning operation shall be considered in compliance when each of the

following conditions is met: [§63.749(c)(2)] i) One of the four techniques specified in §63.744 (c)(l) through (c)(4) is used;

[§63. 749(c)(2)(i)] ii) The technique selected is operated according to the procedures specified in §63.744 (c)(l)

through (c)(4) as appropriate; and [§63.749(c)(2)(ii)] iii) If an enclosed system is used, monthly visual inspections are conducted and any leak

detected is repaired within 15 days after detection. If the leak is not repaired by the 15th day after detection, the solvent shall be removed and the enclosed cleaner shall be shut down until the cleaner is repaired or its use is permanently discontinued .. [§63. 749( c )(2)(iii)]


Monitoring:


The permittee using an enclosed spray gun cleaner under §63. 7 44( c )(1) shall visually inspect the seals and all other potential sources of leaks associated with each enclosed gun spray cleaner system at least once per month. Each inspection shall occur while the system is in operation. [§63.75l(a)]

Recordkeeping: The permittee shall keep a record of all leaks from enclosed spray gun cleaners identified pursuant to §63.75l(a) that includes for each leak found: [§63.752(b)(5)] 1) Source identification; [§63.752(b)(5)(i)] 2) Date leak was discovered; and [§63.752(b)(5)(ii)] 3) Date leak was repaired. [§63.752(b)(5)(iii)]

Reporting: The permittee shall report to the SLCDH Air Pollution Control Program, 6121 North Hanley Road, Berkeley, Missouri 63134 and the Missouri Department of Natural Resources Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102: 1) Semi-annual reports occurring every six (6) months that identify: [§63.753(b)]

a) Any instance where a non-compliant spray gun cleaning method is used; b) Any instance where leaks from enclosed spray gun cleaners are not repaired within 15 days; and c) If the operations have been in compliance for the semiannual period, a statement that the

cleaning operations have been in compliance with the applicable standards. Sources shall also submit a statement of compliance signed by a responsible company official certifying that the facility is in compliance with all applicable requirements.

2) The permittee shall submit semiannual reports by: a) October 1st for monitoring which covers the January through June time period, and b) April 1st for monitoring which covers the July through December time period.

BL-001-01 and BL-001-02 - Boilers

(Both boilers are equipped with continuous oxygen trim system) Emission

Description Unit

BL-001-01 Boiler #1 - 120.3 MMBtu/hr Nebraska boiler with flue gas recirculation system, ( constructed 2005); Fuel: Natural Gas

BL-001-021 Boiler #2 - 120.3 MMBtu/hr Nebraska boiler with flue gas recirculation system, ( constructed 2005); Fuel: Natural Gas

Permit Condition (BL-001-1 and BL-001-02) - 001 10 CSR 10-6.060 Construction Permits Required - SLCDH Air Pollution Control Program Permit Nos. 6953 & 6954

Operational Limitation/Equipment Specification: 1) The flue gas recirculation (FGR) system shall be in operation in accordance with the manufacturer's

guidelines, whenever the boiler(s) is (are) in operation. 2) Should the FGR system on one of the boilers fail to operate properly, the other boiler shall be

utilized exclusively, or to the greatest extent possible, until the failed system is repaired.



3) Number two (#2) fuel oil shall only be burned when natural gas is unavailable to GKN due to an emergency or for testing of the burner. Interruptible gas service does not constitute an emergency.

4) For testing purposes, or should an emergency arise requiring the burning of #2 oil, the oil utilized shall contain no more than five hundredths of one percent (0.05%) sulfur by weight.

5) The permittee shall minimize the fuel oil used for testing purposes. The fuel oil burners shall be removed from the boilers after each test.

Monitoring/Recordkeeping: 1) The permittee shall maintain a record of the sulfur content of the fuel oil as purchased ( ex. bill of

lading, MSDS, or other), except as shown in the Statement of Basis, "Other Regulatory Determinations."

2) The permittee shall retain records for the previous 60 month period and make them available to the St. Louis County Air Pollution Control Program, or its designated agent, at any reasonable time.

Reporting: 1) The permittee shall notify the SLCDH Air Pollution Control Program, 6121 North Hanley Road,

Berkeley, Missouri 63134 of any FGR failure by no later than the next working day. 2) The permittee shall notify the SLCDH Air Pollution Control Program of fuel oil testing at least 24

hours prior to testing, and in the case of an emergency, by no later than the next working day. 3) The permittee shall submit a written report of the amount of fuel oil used during each test within ten

days of the end of the testing. 4) The permittee shall also report any deviations from this permit condition in the semi-annual

monitoring report and annual compliance certification, as required by Section V of this permit..

Permit Condition (BL-001-1 and BL-001-02) - 002 10 CSR 10-6.070 New Source Performance Regulations 40 CFR Part 60 Subpart Db Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units

Emission Limitation: 1) The permittee shall not cause to be discharged into the atmosphere from the boilers any gases that

contain NOx (expressed as NO2) in excess of 0.2 lb/MMBtu. [§60.44b(a)(l)] 2) The NOx standards apply at all times including periods of startup, shutdown, or malfunction.

[§60.44b(h)]

Monitoring: 1) The permittee shall determine compliance with the emission limits on a 30-day rolling average basis.

[§60.44b(i)] 2) Steam temperature and flue gas oxygen shall be used in the linear equation for predicting NOx

emissions. An electronic database shall be utilized to calculate and maintain predicted NOx emissions. All values shall be recorded in 15-minute intervals. This data shall then be used to calculate daily NOx emissions that are recorded and used to tabulate a 30-day rolling average.

Reporting: 1) The permittee shall submit semiannual compliance reports to the SLCDH Air Pollution Control

Program, 6121 North Hanley Road, Berkeley, Missouri 63134 and the Missouri Department of Natural Resources' Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102-0176,



or AirComplianceReporting@,dnr.mo.gov, by the 30th day following the end of the reporting period, in accordance with 60.49b(g) and 60.49b(w).

2) The permittee shall submit a Notification of Alternative Fuel Use if at any time an alternative fuel is used in the boilers.

3) The permittee shall report to the SLCDH Air Pollution Control Program, 6121 North Hanley Road, Berkeley, Missouri 63134 and the Missouri Department ofNatural Resources' Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102-0176, or [email protected], no later than 30 days after the discovery of an exceedance of the nitrogen oxide emission limit.

Permit Condition (BL-001-1 and BL-001-02) - 003 10 CSR 10-6.075 Maximum Achievable Control Technology Regulations 40 CFR Part 63 Subpart DDDDD National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters

Work Practice Standards: 1) As stated in §63.7500, the permittee must comply with the following applicable work practice

standards: [Items 1 and 4 of Table 3 to Subpart DDDDD of Part 63] a) The permittee shall conduct a tune-up of the boilers every five years as specified in §63.7540. b) The permittee must have a one-time energy assessment performed by a qualified energy assessor.

An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in this table, satisfies the energy assessment requirement. A facility that operated under an energy management program developed according to the ENERGY STAR guidelines for energy management or compatible with ISO 50001 for at least one year between January 1, 2008 and the compliance date specified in §63.7495 that includes the affected units also satisfies the energy assessment requirement. The energy assessment must include the following with extent of the evaluation for items listed below appropriate for the onsite technical hours listed in §63.7575: i) A visual inspection of the boiler or process heater system. ii) An evaluation of operating characteristics of the boiler or process heater systems,

specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints.

iii) An inventory of major energy use systems consuming energy from affected boilers and process heaters and which are under the control of the boiler/process heater owner/operator.

iv) A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage.

v) A review of the facility's energy management program and provide recommendations for improvements consistent with the definition of energy management program, if identified.

vi) A list of cost-effective energy conservation measures that are within the facility's control. vii)A list of the energy savings potential of the energy conservation measures identified. viii) A comprehensive report detailing the ways to improve efficiency, the cost of specific

improvements, benefits, and the time frame for recouping those investments. 2) At all times, The permittee must operate and maintain the boilers, including associated air pollution

control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Director that may include, but is not limited to, monitoring results, review of operation and maintenance



procedures, review of operation and maintenance records, and inspection of the boilers. [§63. 7500(a)(3)]

Initial Compliance Demonstration: 1) The permittee must include with the Notification of Compliance Status a signed certification that

either the energy assessment was completed according to Table 3 to this subpart, and that the assessment is an accurate depiction of the permittee's facility at the time of the assessment, or that the maximum number of on-site technical hours specified in the definition of energy assessment applicable to the facility has been expended. [§63.7545(e)]

2) The permittee must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in §63.7545(e). [§63.7545(f)]

Continuous Compliance Demonstration with the Work Practice Standards: 1) The permittee must conduct a tune-up of the boilers every 5 years as specified in §63.7540 (a)(IO)(i)

through (vi) (listed below). The permittee may delay the burner inspection specified in paragraph 63.7540 (a)(I0)(i) until the next scheduled or unscheduled unit shutdown, but the permittee must inspect each burner at least once every 72 months. The permittee must set the oxygen level no lower than the oxygen concentration measured during the most recent tune-up. [§63.7540(a)(12)] a) As applicable, inspect the burner, and clean or replace any components of the burner as

necessary (the permittee may perform the burner inspection any time prior to the tune-up or delay the burner inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the burner inspection until the first outage, not to exceed 36 months from the previous inspection. At units where entry into a piece of process equipment or into a storage vessel is required to complete the tune-up inspections, inspections are required only during planned entries into the storage vessel or process equipment; [§63.7540(a)(lO)(i)]

b) Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available; [§63. 7540(a)(l O)(ii)]

c) Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (the permittee may delay the inspection until the next scheduled unit shutdown); [§63.7540(a)(I0)(iii)]

d) Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications; [§63. 7540(a)(l 0)(iv)]

e) Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer; and [§63.7540(a)(I0)(v)]

f) Maintain on-site and submit, if requested by the Director, a report containing the information in §63.7540 (a)(l0)(vi)(A) through (C) (listed below), [§63.7540(a)(I0)(vi)] i) The concentrations of CO in the effluent stream in parts per million by volume, and oxygen

in volume percent, measured at high fire or typical operating load, before and after the tuneup of the boiler or process heater; [§63.7540(a)(10)(vi)(A)]

ii) A description of any corrective actions taken as a part of the tune-up; and [§63. 7540(a)(l 0)(vi)(B)]

iii) The type and amount of fuel used over the 12 months prior to the tune-up, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel used by each unit. [§63.7540(a)(l0)(vi)(C)]



2) If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days of startup. [§63. 7540(a)(l3)]

3) The permittee must report each instance in which the permittee did not meet operating limit in Tables 3 to this subpart that applies to the permittee. These instances are deviations from the operating limits, respectively, in this subpart. These deviations must be reported according to the requirements in §63.7550. [§63.7540(b)]

Reporting: 1) Notification:

a) If the permittee intends to use a fuel other than natural gas to fire the boiler(s) during a period of natural gas curtailment or supply interruption, as defined in §63.7575, the permittee must submit a notification of alternative fuel use within 48 hours of the declaration of each period of natural gas curtailment or supply interruption, as defined in §63.7575. The notification must include the information specified in §63.7545(£)(1) through (5) (listed below). [§63.7545(£)] i) Company name and address. [§63.7545(£)(1)] ii) Identification of the affected unit. [§63.7545(£)(2)] iii) Reason the permittee is unable to use natural gas or equivalent fuel, including the date when

the natural gas curtailment was declared or the natural gas supply interruption began. [§63.7545(£)(3)]

iv) Type of alternative fuel that the permittee intends to use. [§63.7545(£)(4)] v) Dates when the alternative fuel use is expected to begin and end. [§63.7545(£)(5)]

b) If the permittee has switched fuels or made a physical change to the boiler(s) and the fuel switch or physical change resulted in the applicability of a different subcategory, the permittee must provide notice of the date upon which the permittee switched fuels or made the physical change within 30 days of the switch/change. The notification must identify: [§63.7545(h)] i) The name of the owner or operator of the affected source, as defined in §63.7490, the

location of the source, the boiler(s) that have switched fuels, were physically changed, and the date of the notice. [§63.7545(h)(l)]

ii) The currently applicable subcategory under this subpart. [§63.7545(h)(2)] iii) The date upon which the fuel switch or physical change occurred. [§63.7545(h)(3)

2) Reports: a) The permittee must submit each report in the table below that applies to the permittee.

[§63.7550(a) and Table 9 to Subpart DDDDD of 40 CFR Part 63]

The Permittee The permittee Must Submit the Must Submit a The Report Must Contain Report

I. Compliance a. Information required in §63.7550(c)(l) and (5); and Every 5 years report according to the

requirements in §63. 7550(b ).

b. If there are no deviations the requirements for work practice standards for periods of startup and shutdown in Table 3 to this subpart that apply to the permittee, a statement that there were no deviations from work practice standards during the reporting period; and



C. If the permittee has deviation from a work practice standard for periods of startup and shutdown, during the reporting period, the report must contain the information in §63.7550(d).

b) Unless the EPA Administrator has approved a different schedule for submission of reports under §63.l0(a), the permittee must submit each report, according to §63.7550(h)(3), by the date in Table 9 to Subpart DDDDD of 40 CFR Part 63and according to the requirements in §63.7550(b)(l) through (4) (listed below). For units that are subject only to a requirement to conduct subsequent annual, tune-up according to §63.7540(a)(l0), and not subject to emission limits or Table 4 operating limits, the permittee may submit only a 5-year compliance report, as applicable, as specified in §63.7550(b)(l) through (4), instead of a semi-annual compliance report. [§63.7550(b)] i) The first compliance report must cover the period beginning on the compliance date that is

specified for each boiler in §63.7495 and ending on December 31 within 5 years, after January 31, 2016 as specified in §63.7495. [§63.7550(b)(l)]

ii) The first 5-year compliance report must be postmarked or submitted no later than January 31. [§63. 7550(b )(2)]

iii) Each 5-year compliance reports must cover the applicable 5-year periods from January 1 to December 31. [§63.7550(b)(3)]

iv) Each 5-year compliance reports must be postmarked or submitted no later than January 31. [§63. 7550(b )( 4)]

v) The permittee may submit the first and subsequent compliance reports according to the dates specified in Section V of this Permit instead of according to the dates in §63.7550(b)(l) through (4) (listed above). [§63.7550(b)(5)]

c) A compliance report must contain the following information depending on how the facility chooses to comply with the limits set in this rule. [§63.7550(c)] i) For the requirements of a tune up the permittee must submit a compliance report with the

information in §63.7550(c)(5)(i) through (iii), §63.7550 (xiv) and (xvii), and §63.7550(c)(5)(iv) (listed below). [§63.7550(c)(l)]

ii) Company and Facility name and address. [§63.7550(c)(5)(i)] iii) Process unit information. [§63.7550(c)(5)(ii)] iv) Date ofreport and beginning and ending dates of the reporting period. [§63.7550(c)(5)(iii)] v) The total operating time during the reporting period. [§63.7550(c)(5)(iv)] vi) Include the date of the most recent tune-up for each unit subject to only the requirement to

conduct 5-year tune-up according to §63.7540(a)(10). Include the date of the most recent burner inspection if it was not done on a 5-year period and was delayed until the next scheduled or unscheduled unit shutdown. [§63.7550(c)(5)(xiv)]

vii) Statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report. [§63.7550(c)(5)(xiv)]

d) For each deviation from the work practice standards for periods of startup and shutdown, the compliance report must additionally contain the information required in §63. 7 5 50( d)(l) and (2) (listed below). [§63.7550(d)] i) A description of the deviation and which work practice standard from which the permittee

deviated. [§63.7550(d)(l)] ii) Information on the number, duration, and cause of deviations (including unknown cause), as

applicable, and the corrective action taken. [§63.7550(d)(2)]

GKN Aerospace North America, Inc. Installation ID: 189-14 89


e) The permittee must submit all reports required by Table 9 of this subpart electronically to the EPA via the CEDRI. (CEDRI can be accessed through the EPA's CDX.) The permittee must use the appropriate electronic report in CED RI for this subpart. Instead of using the electronic report in CEDRI for this subpart, the permittee may submit an alternate electronic file consistent with the XML schema listed on the CEDRI Web site (http://www.epa.gov/ttn/chief/cedri/index.html), once the XML schema is available. If the reporting form specific to this subpart is not available in CED RI at the time that the report is due, the permittee must submit the report to the Administrator at the appropriate address listed in §63 .13. The permittee must begin submitting reports via CED RI no later than 90 days after the form becomes available in CEDRI. [§63.7550(h)(3)]

Recordkeeping: 1) The permittee must keep a copy of each notification and report that the permittee submitted to

comply with this subpart, including all documentation supporting any Initial Notification or Notification of Compliance Status that the permittee submitted, according to the requirements in §63. lO(b )(2)(xiv). [§63. 7555(a)(l )]

2) If the permittee operates a unit in the unit designed to bum gas 1 subcategory that is subject to this subpart, and the permittee uses an alternative fuel other than natural gas, refinery gas, gaseous fuel subject to another subpart under this part, other gas 1 fuel, or gaseous fuel subject to another subpart of this part or part 60, 61, or 65, the permittee must keep records of the total hours per calendar year that alternative fuel is burned and the total hours per calendar year that the unit operated during periods of gas curtailment or gas supply emergencies. [§63.7555(h)]

3) The permittee's records must be in a form suitable and readily available for expeditious review, according to §63.l0(b)(l). [§63.7560(a)]

4) As specified in §63 .1 0(b )( 1 ), the permittee must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. [§63.7560(b)]

5) The permittee must keep each record on site, or they must be accessible from on site (for example, through a computer network), for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63. lO(b )(1 ). The permittee can keep the records off site for the remaining 3 years. [§63.7560(c)]

CC-STL-01 - Plant-Wide Cold Cleaners


Unit CC-STL-01 Plant-wide cold cleaners greater than 1 gallon and 1 square foot (ft2) surface area that are not

subject to 10 CSR 10-5.295

Permit Condition (CC-STL-01) - 001 10 CSR 10-5.300 Control of Emissions from Solvent Metal Cleaning

Emission Limitation: I) The permittee shall not use cold cleaning solvent with a vapor pressure greater than 1.0 millimeters

of Mercury (mmHg) (0.019 psi) at 20 degrees Celsius (20°C) (68 degrees Fahrenheit (68°F)). [10 CSR 10-5.300(3)(A)l.A]

2) Exception: The permittee may use an alternative method for reducing cold cleaning emissions if the level of emission control is equivalent to or greater than the requirements of subparagraph (3)(A) I .A



and (3)(A)l.B of 10 CSR 10-5.300. The director and the U.S Environmental Protection Agency (EPA) must approve the alternative method. [10 CSR 10-5.300(3)(A)l.D]

Operational Limitation/Equipment Specification: The permittee shall comply with the following operational limitations and equipment specifications unless an exemption under 10 CSR 10-5.300(1)(D) applies: 1) Equipment specifications [10 CSR 10-5.300(3)(A)l]:

a) Each cold cleaner will have a cover, which will prevent the escape of solvent vapors from the solvent bath while in the closed position, or an enclosed reservoir, which will limit the escape of solvent vapors from the solvent bath whenever parts are not being processed in the cleaner. [10 CSR 10-5.300(3)(A) l.C]

b) Exemptions under (l)(D) of the regulation may apply. c) Alternate methods for reducing cold cleaning emissions may be used if the permittee shows the

emission control is at least equivalent to the control in (a) above and is approved by the Director and the EPA [10 CSR 10-5.300(3)(A)l.D]

d) When one (1) or more of the following conditions exist, the cover shall be designed to operate easily such that minimal disturbing of the solvent vapors in the tank occurs. (For covers larger than ten (10) square feet, this shall be accomplished by either mechanical assistance or by a power system). [10 CSR 10-5.300(3)(A)l.E] i) The solvent vapor pressure is greater than 0.3 psi measured at one hundred degrees

Fahrenheit (100°F). [10 CSR 10-5.300(3)(A)l.E(I)] ii) The solvent is agitated. [10 CSR 10-5.300(3)(A)l.E(II)] iii) The solvent is heated. [l O CSR 10-5.300(3)(A) 1.E(III)]

e) Each cold cleaner shall have an internal drainage facility so that parts are enclosed under the cover while draining. [10 CSR 10-5.300(A)l.F]

f) If an internal drainage facility as in 10 CSR 10-5.300(3)(A)l.F cannot fit into the cleaning system and the solvent vapor pressure is less than 0.6 psi measured at one hundred degrees Fahrenheit (100°F), then the cold cleaner shall have an external drainage facility which provides for the solvent to drain back into the solvent bath. [10 CSR 10-5.300(3)(A)l.G]

g) Solvent sprays shall be a solid fluid stream (not a fine, atomized or shower type spray) and at a pressure which does not cause splashing above or beyond the freeboard. [10 CSR 10-5.300(3)(A)l.H]

h) A permanent conspicuous label summarizing the operating procedures shall be affixed to the equipment or in a location readily visible during operation of the equipment. [10 CSR 10-5.300(3)(A)l.l]

i) Any cold cleaner which uses a solvent that has a solvent vapor pressure greater than 0.6 psi measured at one hundred degrees Fahrenheit (100°F) or heated above one hundred twenty degrees Fahrenheit (120°F) must use one (1) of the following control devices: [10 CSR 10-5.300(3)(A)l.J] i) A freeboard ratio of at least 0.75 [10 CSR 10-5.300(3)(A)l.J(I)] ii) Water cover (solvent must be insoluble in and heavier than water)

[10 CSR 10-5.300(3)(A)l.J(II)] iii) Other control system that has a mass balance demonstrated overall VOC emission reduction

efficiency of at least sixty-five percent (65%) and is approved by the Director and EPA prior to use. [10 CSR 10-5.300(3)(A)l.J(III)]

2) Operating procedures:



a) Cold cleaner covers shall be closed whenever parts are not being handled in the cleaners, or solvent must drain into an enclosed reservoir except when performing maintenance or collecting solvent samples. [10 CSR 10-5.300(3)(B)l.A].

b) Cleaned parts shall be drained in the free board area for at least fifteen (15) seconds, or until dripping stops, whichever is longer. [10 CSR 10-5.300(3)(B)l.B]

c) Whenever a cold cleaner fails to perform within the operating parameters established by 10 CSR 10-5.300, the unit shall be shut down and shall remain shut down until operation is restored to meet 10 CSR 10-5.300's operating requirements. [10 CSR 10-5.300(3)(B)l.C]

d) Solvent leaks shall be repaired immediately, or the cold cleaner shall be shut down until the leaks are repaired. [10 CSR 10-5.300(3)(B)l.D]

e) Waste material removed from a cold cleaner shall be disposed of by one of the methods listed in 10 CSR 10-5.300 or equivalent method approved by the director and EPA. [10 CSR 10-5.300(3)(B) 1.E]

f) Waste solvent shall be stored in closed containers only. [10 CSR 10-5.300(3)(B)l.F] 3) Operator and Supervisor Training:

a) Persons who operate a cold cleaner shall be trained in the operational and equipment requirements specified in 10 CSR 10-5 .300 for the permittee's particular solvent metal cleaning process. [10 CSR 10-5.300(3)(C)l]

b) The supervisor of any person who operates a cold cleaner shall receive equal or greater operational training than the operator. [10 CSR 10-5.300(3)(C)2]

c) Persons who operate a cold cleaner shall receive a procedural review at least once each twelve (12) months. [10 CSR 10-5.300(3)(C)3]

Monitoring/ Recordkeeping: 1) The permittee shall maintain the following records for each purchase of cold cleaner solvent

(Attachment F): [10 CSR 10-5.300(4)(B)] a) Name and address of the solvent supplier. [10 CSR 10-5.300(4)(B)l] b) Date of purchase. [10 CSR 10-5.300(4)(B)2] c) Type of solvent purchased. [10 CSR 10-5.300(4)(B)3] d) Vapor pressure of solvent in mm Hg at 20°C or 68°F. [10 CSR 10-5.300(4)(B)4]

2) The permittee shall keep records of all types and amounts of solvents containing waste material from cleaning or degreasing operations transferred either to a contract reclamation service or to a disposal facility and all amounts distilled on the premises. (see Attachment D). The record also shall include maintenance and repair logs that occurred on the degreaser and any associated control equipment (Attachments E). These records shall be kept current and made available for review on a monthly basis. The director may require additional recordkeeping if necessary to adequately demonstrate compliance with 10 CSR 10-5.300. [10 CSR 10-5.300(4)(A)]

3) The permittee shall keep records of solvent metal cleaning training as required by 10 CSR 10-5.300(3)(C) (Attachment G).

4) All records shall be retained for five years and be available to the director upon request. [10 CSR 10-5.300(4)E]

Reporting: The permittee shall report any deviations/exceedances of this permit condition using the semi-annual monitoring report and annual compliance certification to the SLCDH Air Pollution Control Program, 6121 North Hanley Road, Berkeley, Missouri 63134, and the Missouri Department of Natural Resources Air Pollution Control Program, Compliances and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, or [email protected], as required by Section V of this permit.



CL-001-01 - Coating Line


Emission Manufacturer/ Unit Release Point Model#

Detailed Paint Booth # 1. SB-027-0lA, B DeVilbiss Control Device: Low temperature fabric filter

Detailed Paint Booth #2. SB-027-02A, B DeVilbiss Control Device: Low temperature fabric filter

Detailed Paint Booth #3. SB-027-03A, B DeVilbiss

CL-001-01 Control Device: Low temperature fabric filter

Detailed Paint Booth #4. SB-027-04A, B DeVilbiss Control Device: Low temperature fabric filter

Detailed Paint Booth #5. SB-027-05 DeVilbiss Control Device: Low temperature fabric filter

787 Paint Booth - Spray/Drying Booth. SB-027-06 Garmat/ Control Device: 3 stage filtration (dry filter) G90-18

Paint, Adhesive and Sanding Booth. SB-029-01 DeVilbiss Control Device: 3 stage filtration (dry filter)

CL-002-01 Spray/Drying Booth #1. SB-029-02 Inside Control Device: 3 stage filtration (dry filter) Dimensions/

Spray/Drying Booth #2. SB-029-03 CAT-28-DT

Control Device: 3 stage filtration (dry filter)

Permit Condition (CL-001-01 and CL-002-01) - 001 10 CSR 10-6.075 Maximum Achievable Control Technology

Year Installed

1945

1943

1943

1943

1943

2014

1997

2002

2002

40 CFR 63 Subpart GG National Emission Standards for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities 10 CSR 10-5.295 Control of Emissions from Aerospace Manufacture and Rework Facilities

Emission Limitation: 1) The permittee shall comply with the requirements for the organic HAP and VOC content limits

specified in §63.745(c)(l) through (c)(4) (listed below) for primer and topcoat coating application operation that are uncontrolled (no control device is used to reduce organic HAP emissions from the operation). [§63.745(a) and (c)] a) Primers:

i) The permittee shall limit organic HAP emissions from primers to an organic HAP content level of no more than 350 grams per liter (g/L) (2.9 pounds per gallon (lb/gal) of primer (less water), as applied. [§63.745(c)(l)]

ii) The permittee shall limit VOC emissions from primers to a VOC content level of no more than 350 g/L (2.9 lb/gal) of primer (less water and exempt solvents), as applied. [§63.745(c)(2)]

b) Topcoats: i) The permittee shall limit organic HAP emissions from topcoats to an organic HAP content

level of no more than: 420 g/L (3.5 lb/gal) of coating (less water) as applied. [§63.745(c)(3)]



ii) The permittee shall limit VOC emissions from topcoats to a VOC content level of no more than: 420 g/L (3.5 lb/gal) of coating (less water and exempt solvents) as applied. [§63.745(c)(4)]

2) The requirements for primers and topcoats do not apply to the use oflow-volume coatings in these categories for which the annual total of each separate formulation used at a facility does not exceed 50 gallons, and the combined annual total of all such primers and topcoats used at a facility does not exceed 200 gallons. [§63.741(g)]

3) The requirements for primers and topcoats do not apply to the application of: a) Specialty coatings, including those coatings listed as specialty coatings in Appendix A to Subpart

GG, [§63.742, Definitions] b) Coatings used on space vehicles designed to travel beyond the limit of the earth's atmosphere,

except for depainting operations, or [§63.74l(h)] c) Coatings associated with the rework of antique aerospace vehicles or components. [§63.741G)]

Compliance Methods: The permittee shall accomplish compliance with the organic HAP and VOC content limits specified in emission limitation 1) and 2) by using the methods specified in §63.745 (e)(l) and (2) (listed below) either by themselves or in conjunction with one another. [§63.745(e)] 1) Use primers and topcoats (including self-priming topcoats) with HAP and VOC content levels equal

to or less than the limits specified in §63.745 (c)(l) through (4); or [§63.745(e)(l)] 2) Use the averaging provisions described in §63.743(d). [§63.745(e)]

Operational Limitation/Equipment Specification: 1) Application Equipment: Except as provided in §63.745(f)(3), the permittee shall comply with the

requirements specified in paragraphs §63.745 (f)(l) and (f)(2) (listed below). [§63.745(f)] a) All spray applied primers and topcoats (including self-priming topcoats) shall be applied using

one or more of the following spray application techniques: [§63.745(f)(l)] i) High volume low pressure (HVLP) spraying; [§63.745(f)(l)(i)] ii) Electrostatic spray application; [§63.745(f)(l)(ii)] iii) Airless spray application; [§63. 745(f)(l )(iii)] iv) Air-assisted airless spray application; or [§63.745(f)(l)(iv)] v) Any other coating spray application methods that achieve emission reductions or a transfer

efficiency equivalent to or better than HVLP spray, electrostatic spray, airless spray, or airassisted airless spray application methods as determined according to the requirements in §63.750(i). [§63.745(f)(l)(v)]

b) The permittee shall operate all coating spray application devices used to apply primers or topcoats (including self-priming topcoats) according to company procedures, local specified operating procedures, and/or the manufacturer's specifications, whichever is most stringent, at all times. Spray application equipment modified by the facility shall maintain a transfer efficiency equivalent to HVLP spray, electrostatic spray, airless spray, or air-assisted airless spray application techniques. [§63.745(f)(2)]

2) Inorganic HAP Emissions: Except as provided in §63.745(g)(4), the permittee shall comply with the applicable requirements in §63.745(g)(l) through (3) (listed below) for coatings that are sprayapplied (as defined in §63.742). [§63.745(g)] a) The permittee shall apply these coatings in a booth, hangar, or portable enclosure in which air

flow is directed downward onto or across the part or assembly being coated and exhausted through one or more outlets. [§63.745(g)(l)]

b) The permittee shall control the air stream from this operation as follows: [§63.745(g)(2)]



i) The permittee must choose one of the following:

25 Project No.2012-10-007

(1) Before exhausting it to the atmosphere, pass the air stream through a dry particulate filter system certified using the methods described in §63.750(0) to meet or exceed the efficiency data points in Tables 2 and 3 of this section; or

(2) Before exhausting it to the atmosphere, pass the air stream through a waterwash system that shall remain in operation during all coating application operations; or

(3) Before exhausting it to the atmosphere, pass the air stream through an air pollution control system that meets or exceeds the efficiency data points in Tables 2 and 3 of this section and is approved by the permitting authority.

3) If the pressure drop across the dry particulate filter system, as recorded pursuant to §63.752(d)(l), is outside the limit(s) specified by the filter manufacturer or in locally prepared operating procedures, the permittee shall shut down the operation immediately and take corrective action. The operation shall not be resumed until the pressure drop is returned within the specified limit(s). [§63.745(g)(3)]

Compliance Dates and Determinations: 1) General: The facility shall be considered in noncompliance if the permittee uses a control device,

other than one specified in this subpart, that has not been approved by the Director, as required by §63.743(c). [§63.749(b)]

2) Performance test periods for organic HAP and VOC content levels from primer and topcoat application operations: For uncontrolled coatings that are not averaged, each 24 hours is considered a performance test. For compliant and non-compliant coatings that are averaged together, each 30-day period is considered a performance test, unless the Air Pollution Control Program specifies a shorter averaging period as part of an ambient ozone control program. [§63.749(d)(l)]

3) The primer application operation is considered in compliance when the conditions specified in §63.749(d)(3)(i), (d)(3)(iii) and (d)(3)(iv) (listed below), and in §63.749(e) are met. Failure to meet any one of the conditions identified in these paragraphs shall constitute noncompliance. The compliance demonstration for a primer may be based on the organic HAP content or the VOC content of the primer; demonstrating compliance with both the HAP content limit and the VOC content limit is not required. If a primer contains HAP solvents that are exempt from the definition of VOC in §63. 741 and 40 CFR 51.100, then the HAP content must be used to demonstrate compliance. [§63.749(d)(3)] a) For all uncontrolled primers, all values of Hi and Ha (as determined using the procedures

specified in §63.750(c) and (d)) are less than or equal to the applicable HAP content limit in §63.745(c)(l), and all values of Gi and Ga (as determined using the procedures specified in §63.750(e) and (f)) are less than or equal to the applicable VOC content limit in §63.745(c)(2). [§63. 749(d)(3)(i)]

b) The permittee uses an application technique specified in §63.745 (f)(l)(i) through (f)(l)(viii), or [§63. 749( d)(3 )(iii)(A)]

c) The permittee uses an alternative application technique, as allowed under §63.745(f)(l)(ix), such that the emissions of both organic HAP and VOC for the implementation period of the alternative application method are less than or equal to the emissions generated using HVLP or electrostatic spray application methods as determined using the procedures specified in §63. 750(i). [§63. 749(d)(3)(iii)(B)]

d) The permittee operates all application techniques in accordance with the manufacturer's specifications or locally prepared operating procedures, whichever is more stringent. [§63. 749( d)(3)(iv)]

4) The topcoat application operation is considered in compliance when the conditions specified in §63.749 (d)(4)(i), (d)(4)(iii) and (d)(4)(iv) (listed below), and in paragraph (e) of this section are



met. Failure to meet any of the conditions identified in these paragraphs shall constitute noncompliance. [§63.749(d)(4)] a) The topcoat application operation is considered in compliance when the conditions specified in

§63.749(d)(4)(i)(A) are met. The compliance demonstration for a topcoat may be based on the organic HAP content or the voe content of the coating; demonstrating compliance with both the HAP content limit and the voe content limit is not required. If a topcoat contains HAP solvents that are exempt from the definition ofVOe in §63.741 and 40 eFR 51.100, then the HAP content must be used to demonstrate compliance. [§63.749(d)(4)(i)] i) For all uncontrolled topcoats, all values of Hi and Ha ( as determined using the procedures

specified in §63.750(c) and (d)) are less than or equal to the applicable HAP content limit in §63.745(c)(3), and all values of Gi and Ga (as determined using the procedures specified in §63.750(e) and (f)) are less than or equal to the applicable voe content limit in §63. 745( c )( 4). [§63. 749(d)( 4)(i)(A)]

b) The permittee uses an application technique specified in §63.745(f)(l)(i) through (f)(l)(iv); or [§63.749( d)( 4)(iii)(A)]

c) The permittee uses an alternative application technique, as allowed under §63.745(f)(l)(v), such that the emissions of both organic HAP and voe for the implementation period of the alternative application method are less than or equal to the emissions generated using HVLP spray, electrostatic spray, airless spray, or air-assisted airless spray application methods, as determined using the procedures specified in §63.750(i). [§63.749(d)(4)(iii)(B)]

d) The permittee operates all application techniques in accordance with the manufacturer's specifications or locally prepared operating procedures. [§63.749(d)(4)(iv)]

5) Inorganic HAP emissions - primer and topcoat application operations. For each primer or topcoat, application operation that emits inorganic HAP, the operation is in compliance when: [§63.749(e)] a) It is operated according to the requirements specified in §63.745(g)(l) through (g)(3); and

[§63.749(e)(l)] b) It is shut down immediately whenever the pressure drop or water flow rate is outside the limit(s)

established for them and is not restarted until the pressure drop or water flow rate is returned within these limit(s), as required under §63.745(g)(3). [§63.749(e)(2)]

Test Methods and Procedures 1) Organic HAP content level determination - compliant primers and topcoats:

For those uncontrolled primers and topcoats complying with the primer or topcoat organic HAP content limits specified in §63.745(c) without being averaged, the permittee shall use procedures in §63. 7 50 ( c )( 1) through (3) to determine the mass of organic HAP emitted per volume of coating (less water) as applied. As an alternative to the procedures in §63.750 (c)(l) through (3), the permittee may use the coating manufacturer's supplied data to demonstrate that organic HAP emitted per volume of coating (less water), as applied, is less than or equal to the applicable organic HAP limit specified in §63.745(c). The permittee may add non-HAP solvent to those coatings when using the coating manufacturer's supplied data to demonstrate compliance based on the HAP content of the coating provided that the permittee also maintains records of the non-HAP solvent added to the coating. [§63.750(c)] a) For coatings that contain no exempt solvents, the permittee shall determine the total organic

HAP content using manufacturer's supplied data or Method 24 of 40 eFR part 60, appendix A, to determine the voe content. The voe content shall be used as a surrogate for total HAP content for coatings that contain no exempt solvent. If there is a discrepancy between the manufacturer's formulation data and the results of the Method 24 analysis, compliance shall be based on the results from the Method 24 analysis. When Method 24 is used to determine the voe content of



water-reducible coatings, the precision adjustment factors in Reference Method 24 shall be used. If the adjusted analytical voe content is less than the formulation solvent content, then the analytical voe content should be set equal to the formulation solvent content. [§63.750(c)(l)]

b) For each coating formulation as applied, the permittee shall determine the organic HAP weight fraction, water weight fraction (if applicable), and density from manufacturer's data. If the value for organic HAP weight fraction cannot be determined using the manufacturer's data, the permittee shall use Method 311 of 40 eFR part 63, appendix A, or submit an alternative procedure for determining the value for approval by the Director. If the values for water weight fraction (if applicable) and density cannot be determined using the manufacturer's data, the permittee shall submit an alternative procedure for determining their values for approval by the Director. Recalculation is required only when a change occurs in the coating formulation. Ifthere is a discrepancy between the manufacturer's formulation data and the results of the Method 311 analysis, compliance shall be based on the results from the Method 311 analysis. [§63.750(c)(2)]

c) For each coating as applied, the permittee shall calculate the mass of organic HAP emitted per volume of coating (lb/gal) less water as applied using equations 1, 2, and 3: [§63.750(c)(3)]

Eq. l

where: V wi = volume (gal) of water in one gal of coating i. Dci = density (lb of coating per gal of coating) of coating i. W wi = weight fraction ( expressed as a decimal) of water in coating i. Dw = density of water, 8.33 lb/gal.

where: MHi = mass (lb) of organic HAP in one gal of coating i. Dci = density (lb of coating per gal of coating) of coating i. WHi = weight fraction (expressed as a decimal) of organic HAP in coating i.

H= MH, I (1 - vW,) Eq.3

where: Hi= mass of organic HAP emitted per volume of coating i (lb/gal) less water as applied. MHi = mass (lb) of organic HAP in one gal of coating i. V wi = volume (gal) of water in one gal of coating i

2) Organic HAP content level determination - averaged primers and topcoats. For those uncontrolled primers and topcoats that are averaged together in order to comply with the primer and topcoat organic HAP content limits specified in §63.745(c), the permittee shall use the following procedure determine the monthly volume-weighted average mass of organic HAP emitted per volume of coating (less water) as applied, unless the permitting agency specifies a shorter averaging period as part of an ambient ozone control program. [§63. 750( d)]



a) The permittee shall determine the total organic HAP weight fraction as applied of each coating. If any ingredients, including diluent solvent, are added to a coating prior to its application, the organic HAP weight fraction of the coating shall be determined at a time and location in the process after all ingredients have been added. [§63.750(d)(l)(i)]

b) The permittee shall determine the total organic HAP weight fraction of each coating as applied each month. [§63.750(d)(l)(ii)] i) If no changes have been made to a coating, either as supplied or as applied, or if a change has

been made that has a minimal effect on the organic HAP content of the coating, the value previously determined may continue to be used until a change in formulation has been made by either the manufacturer or the user. [§63.750(d)(l)(ii)(A)]

ii) If a change in formulation or a change in the ingredients added to the coating takes place, including the ratio of coating to diluent solvent, prior to its application, either of which results in a more than minimal effect on the organic HAP content of the coating, the total organic HAP weight fraction of the coating shall be redetermined. [§63.750(d)(l)(ii)(B)]

c) The permittee may use manufacturer's formulation data to determine the total organic HAP content of each coating and any ingredients added to the coating prior to its application. If the total organic HAP content cannot be determined using the manufacturer's data, the permittee shall use Method 311 of 40 CFR Part 63, Appendix A for determining the total organic HAP weight fraction, or shall submit an alternative procedure for determining the total organic HAP weight fraction for approval by the Director. If there is a discrepancy between the manufacturer's formulation data and the results of the Method 311 analysis, compliance shall be based on the results from the Method 311 analysis. [§63. 750( d)(l )(iii)]

d) The permittee shall determine the volume both in total gallons as applied and in total gallons (less water) as applied of each coating. If any ingredients, including diluent solvents, are added prior to its application, the volume of each coating shall be determined at a time and location in the process after all ingredients (including any diluent solvent) have been added. [§63.750( d)(2)(i)]

e) The permittee shall determine the volume of each coating (less water) as applied each month, unless the Air Pollution Control Program specifies a shorter period as part of an ambient ozone control program. [§63.750(d)(2)(ii)]

f) The permittee may determine the volume applied from company records. [§63.750(d)(2)(iii)] g) The permittee shall determine the density of each coating as applied. If any ingredients,

including diluent solvent, are added to a coating prior to its application, the density of the coating shall be determined at a time and location in the process after all ingredients have been added. [ §63. 750( d)(3)(i)]

h) The permittee shall determine the density of each coating as applied each month, unless the Air Pollution Control Program specifies a shorter period as part of an ambient ozone control program. [§63.750(d)(3)(ii)] i) If no changes have been made to a coating, either as supplied or as applied, or if a change has

been made that has a minimal effect on the density of the coating, then the value previously determined may continue to be used until a change in formulation has been made by either the manufacturer or the user. [§63.750(d)(3)(iii)(A)]

ii) If a change in formulation or a change in the ingredients added to the coating takes place, including the ratio of coating to diluent solvent, prior to its application, either of which results in a more than minimal effect on the density of the coating, then the density of the coating shall be redetermined. [§63.750(d)(3)(iii)(B)]



i) The permittee may determine the density may determine from company records, including manufacturer's data sheets. If the density of the coating cannot be determined using the company's records, including the manufacturer's data, then the permittee shall submit an alternative procedure for determining the density for approval by the Administrator. [§63. 750( d)(3)(iii)]

j) The permittee shall calculate the total volume in gallons as applied (less water) by summing the individual volumes of each coating (less water) as applied, which were determined under §63.750 (d)(2). [§63.750(d)(4)]

k) The permittee shall calculate the volume-weighted average mass of organic HAP in coatings emitted per unit volume (lb/gal) of coating (less water) as applied during each 30-day period using equation 4: [§63.750(d)(5)]

Eq.4

where: Ha= volume-weighted average mass of organic HAP emitted per unit volume of coating (lb/gal)

(less water) as applied during each 30-day period for those coatings being averaged. n = number of coatings being averaged. WHi = weight fraction (expressed as a decimal) of organic HAP in coating i as applied that is

being averaged during each 30-day period. Dci = density (lb of coating per gal of coating) of coating i as applied that is being averaged

during each 30-day period. Vci = volume (gal) of coating i as applied that is being averaged during the 30-day period. C1w = total volume (gal) of all coatings (less water) as applied that are being averaged during

each 30-day period.

3) VOC content level determination-compliant primers, topcoats: For those uncontrolled primers and topcoats complying with the primer and topcoat voe content levels specified in §63.745(c) without being averaged, the permittee shall use the procedures in §63.750 (e)(l) through (3) to determine the mass ofVOe emitted per volume of coating (less water and exempt solvents) as applied. As an alternative to the procedures in §63.750(e)(l) through (3), the permittee may use coating manufacturer's supplied data to demonstrate that voe emitted per volume of coating (less water and exempt solvents), as applied, is less than or equal to the applicable voe limit specified in §63.745(c). [§63.750(e)] a) The permittee shall determine the voe content of each formulation (less water and exempt

solvents) as applied using manufacturer's supplied data or Method 24 of 40 eFR Part 60, Appendix A, to determine the voe content. The voe content shall be used as a surrogate for total HAP content for coatings that contain no exempt solvent. If there is a discrepancy between the manufacturer's formulation data and the results of the Method 24 analysis, compliance shall be based on the results from the Method 24 analysis. When Method 24 is used to determine the voe content of water-reducible coatings, the precision adjustment factors in Reference Method 24 shall be used. If the adjusted analytical VOC content is less than the formulation solvent content, then the analytical voe content should be set equal to the formulation solvent content. [§63.750(e)(l)]



b) For each coating applied, calculate the mass of VOC emitted per volume of coating (lb/gal) (less water and exempt solvents) as applied using equations 5, 6, and 7: [§63.750(e)(2)]

Eq.5

where: V wi = volume (gal) of water in one gal of coating i. Dci = density (lb of coating per gal of coating) of coating i. W wi = weight fraction ( expressed as a decimal) of water in coating i. Dw = density of water, 8.33 lb/gal.

where: Mvi = mass (lb) of VOC in one gal of coating i. Dci = density (lb of coating per gal of coating) of coating i. Wvi = weight fraction (expressed as a decimal) of VOC in coating i.

Eq.7

where: Gi = mass of VOC emitted per volume of coating i (lb/gal) (less water and exempt solvents) as

applied. Mvi = mass (lb) of VOC in one gal of coating i. V wi = volume (gal) of water in one gal of coating i. V xi = volume (gal) of exempt solvents in one gal of coating i.

c) If the VOC content is found to be different when EPA Method 24 is used during an enforcement inspection from that used by the permittee in calculating Ga, compliance shall be based, except as provided in §63.750(e)(3)(ii), upon the VOC content obtained using EPA Method 24. [§63. 750( e )(3)(i)]

d) If the VOC content of a coating obtained using Method 24 would indicate noncompliance as determined under either §63.749 (d)(3)(i) or (d)(4)(i), the permittee may elect to average the coating with other uncontrolled coatings and (re)calculate Gi (using the procedure specified in §63.750(f)), provided appropriate and sufficient records were maintained for all coatings included in the average (re )calculation. The (re )calculated value of Gi (Ga in paragraph (f)) for the averaged coatings shall then be used to determine compliance. [§63.750(e)(3)(i)]

4) VOC content level determination-averaged primers and topcoats: For those uncontrolled primers and topcoats that are averaged within their respective coating category in order to comply with the primer and topcoat VOC content limits specified in §63.745(c)(2) and (c)(4), the following procedure shall be used to determine the monthly volumeweighted average mass of VOC emitted per volume of coating (less water and exempt solvents) as applied, unless the Air Pollution Control Program specifies a shorter averaging period as part of an ambient ozone control program. [§63.750(f)]



a) The permittee shall determine the VOC content (lb/gal) as applied of each coating. If any ingredients, including diluent solvent, are added to a coating prior to its application, the VOC content of the coating shall be determined at a time and location in the process after all ingredients have been added. [§63.750(f)(l)(i)]

b) The permittee shall determine the VOC content of each coating as applied each month, unless the Air Pollution Control Program specifies a shorter period as part of an ambient ozone control program. [§63. 750(f)(l )(ii)] i) If no changes have been made to a coating, either as supplied or as applied, or if a change has

been made that has a minimal effect on the VOC content of the coating, the value previously determined may continue to be used until a change in formulation has been made by either the manufacturer or the user. [§63.750(f)(l)(ii)(A)]

ii) If a change in formulation or a change in the ingredients added to the coating takes place, including the ratio of coating to diluent solvent, prior to its application, either of which results in a more than minimal effect on the VOC content of the coating, the VOC content of the coating shall be redetermined. [§63.750(f)(l)(ii)(B)]

c) The permittee shall determine the VOC content of each primer, topcoat, and specialty coating formulation (less water and exempt solvents) as applied using EPA Method 24 or from manufacturer's data. [§63.750(f)(l)(iii)]

d) The permittee shall determine the volume both in total gallons as applied and in total gallons (less water and exempt solvents) as applied of each coating. If any ingredients, including diluent solvents, are added prior to its application, the volume of each coating shall be determined at a time and location in the process after all ingredients (including any diluent solvent) have been added. [§63.750(f)(2)(i)]

e) The permittee shall determine the volume of each coating (less water and exempt solvents) as applied each day. [§63.750(f)(2)(ii)]

f) The permittee may determine the volume applied from company records. [§63.750(f)(2)(iii)] g) The permittee shall calculate the total volume in gallons (less water and exempt solvents) as

applied by summing the individual volumes of each coating (less water and exempt solvents) as applied, which were determined under paragraph (f)(2) of this section. [§63.750(f)(3)]

h) The permittee shall calculate the volume-weighted average mass of VOC emitted per unit volume (lb/gal) of coating (less water and exempt solvents) as applied for each coating category during each 30-day period using equation 8: [§63.750(f)(4)]

n

I(vocLvc1 G = _i=~I ___ _

a Clwes

Eq.9

where: Ga= volume weighted average mass of VOC per unit volume of coating (lb/gal) (less water and

exempt solvents) as applied during each 30-day period for those coatings being averaged. n = number of coatings being averaged.

(VOC)ci = VOC content (lb/gal) of coating i (less water and exempt solvents) as applied (as determined using the procedures specified in paragraph (f)(l) of this section) that is being averaged during the 30-day period.

Yci = volume (gal) of coating i (less water and exempt solvents) as applied that is being averaged during the 30-day period.



Ciwes = total volume (gal) of all coatings (less water and exempt solvents) as applied during each 30-day period for those coatings being averaged.

i) If the VOC content is found to be different when EPA Method 24 is used during an enforcement inspection from that used by the permittee in calculating Ga, recalculation of Ga is required using the new value. If more than one coating is involved, the recalculation shall be made once using all of the new values. [§63.750(f)(5)(i)]

j) If recalculation is required, the permittee may elect to include in the recalculation of Ga uncontrolled coatings that were not previously included provided appropriate and sufficient records were maintained for these other coatings to allow daily recalculations. [§63.750(f)(5)(ii)]

k) The recalculated value of Ga under either paragraph (f)(5)(i) or (f)(5)(ii) of this section shall be used to determine compliance. [§63.750(f)(5)(iii)]

5) Inorganic HAP emissions-dry particulate filter certification requirements: Dry particulate filters used to comply with §§63.745(g)(2) or 63.746(b)(4) must be certified by the filter manufacturer or distributor, paint/depainting booth supplier, and/or the permittee using method 319 in Appendix A of this Part 63, to meet or exceed the efficiency data points found in Tables 2 and 3, or 4 and 5 of §63.745 for existing or new sources respectively. [§63.750(0)]

Monitoring: 1) Dry particulate filter - primer, topcoat, and specialty coating application operations. [§63.751(c)]

a) The permittee using a dry particulate filter system to meet the requirements of §63.745(g)(2) shall, while primer and topcoat application operations are occurring, continuously monitor the pressure drop across the system and read and record the pressure drop once per shift following the recordkeeping requirements of §63.752(d), or install an interlock system as specified in §63. 745(g)(2)(iv)(C). [§63. 751 ( c)(l )]

2) Use of an alternative monitoring method: [§63.751(e)] Until permission to use an alternative monitoring method has been granted by the Administrator under this paragraph, the permittee shall remain subject to the requirements of §63. 7 51. [§63.751(e)(l)]

3) Reduction of monitoring data: [§63.751(±)] a) The permittee may record the data in reduced or nomeduced form (e.g., grams per liter (g/L),

pounds per gallon (lb/gal), parts per million (ppm) pollutant and% 02 or nanograms per Joule (ng/J) of pollutant). [§63.750(±)(1)]

b) The permittee shall convert all emission data into units specified in this subpart for reporting purposes. After conversion into units specified in this subpart, the data may be rounded to the same number of significant digits as used in this subpart to specify the emission limit ( e.g., rounded to the nearest 1 % overall reduction efficiency). [§63.750(±)(2)]

Recordkeeping: 1) General: The permittee shall fulfill all recordkeeping requirements specified in §63.l0(a), (b), (d),

and (f), except §63.10(b)(2)(i), (iv) and (v). The permittee must also record and maintain according to §63.l0(b)(l) the information specified in §63.752 (a)(l) through (3) (listed below). [63.752(a)] a) In the event that an affected unit fails to meet an applicable standard, record the number of

failures. For each failure record the date, time, and duration of each failure. [63.752(a)(l )] b) For each failure to meet an applicable standard, record and retain a list of the affected sources or

equipment, an estimate of the quantity of each regulated pollutant emitted over any emission limit and a description of the method used to estimate the emissions. [63.752(a)(2)]


Part 70 Operating Permit 33 Project No.2012-10-007

c) Record actions taken to minimize emissions in accordance with §63.743(e), and any corrective actions taken to return the affected unit to its normal or usual manner of operation. [63.752(a)(3)]

2) Primer and topcoat operations-organic HAP and VOC: The permittee shall record the information specified in 63.752 (c)(l) through (4) (listed below), as appropriate. The permittee using coating manufacturer's supplied data to demonstrate compliance with the applicable organic HAP or voe limit specified in §63.745(c) may retain the manufacturer's documentation and annual purchase records in place of the records specified in 63.752 (c)(2) and (3). The permittee using the coating manufacturer's supplied data to demonstrate compliance based on the HAP content of the coating, and adding non-HAP solvent to those coatings, must also maintain records of the non-HAP solvent added to the coating. [63.752(c)] a) The name and voe content as received and as applied of each primer, topcoat, and specialty

coating used at the facility. [63.752(c)(l)] b) For uncontrolled primers, topcoats, and specialty coatings that meet the organic HAP and voe

content limits in §63.745(c)(l) through (c)(6) without averaging: [63.752(c)(2)] i) The mass of organic HAP emitted per unit volume of coating as applied (less water) (Hi) and

the mass of voe emitted per unit volume of coating as applied (less water and exempt solvents) (Gi) for each coating formulation within each coating category used each month (as calculated using the procedures specified in §63.750(c) and (e)); [63.752(c)(2)(i)]

ii) All data, calculations, and test results (including EPA Method 24 results) used in determining the values of Hi and Gi; and [63.752(c)(2)(ii)]

iii) The volume (gal) of each coating formulation within each coating category used each month. [ 63. 752( C )(2)(iii)]

c) For "low HAP content" uncontrolled primers with organic HAP content less than or equal to 250 g/1 (2.1 lb/gal) less water as applied and voe content less than or equal to 250 g/1 (2.1 lb/gal) less water and exempt solvents as applied: [63.752(c)(3)] i) Annual purchase records of the total volume of each primer purchased; and [63.752(c)(3)(i)] ii) All data, calculations, and test results (including EPA Method 24 results) used in determining

the organic HAP and voe content as applied. These records shall consist of the manufacturer's certification when the primer is applied as received, or the data and calculations used to determine Hi if not applied as received. [ 63. 7 52( c )(3 )(ii)]

d) For primers and topcoats, and specialty coatings complying with the organic HAP or voe content level by averaging: [63.752(c)(4)] i) The monthly volume-weighted average masses of organic HAP emitted per unit volume of

coating as applied (less water) (Ha) and of voe emitted per unit volume of coating as applied (less water and exempt solvents) (Ga) for all coatings (as determined by the procedures specified in §63.750(d) and (f)); and [63.752(c)(4)(i)]

ii) All data, calculations, and test results (including EPA Method 24 results) used to determine the values of Ha and Ga. [ 63. 7 52( c )( 4 )(ii)]

3) Primer and topcoat coating application operations-inorganic HAP emissions: [63.752(d)] a) The permittee complying with §63.745(g) for the control of inorganic HAP emissions from

primer and topcoat application operations through the use of a dry particulate filter system or a HEP A filter system shall record the pressure drop across the operating system once each shift during which coating operations occur. [63.752(d)(l)]

b) This log shall include the acceptable limit(s) of pressure drop, the booth manufacturer recommended parameter( s) that indicate the booth performance, as applicable, as specified by the filter or booth manufacturer or in locally prepared operating procedures.


Reporting:


The permittee shall submit the following information to the SLCDH Air Pollution Control Program, 6121 North Hanley Road, Berkeley, Missouri 63134 and the Missouri Department of Natural Resources Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102: 1) Semiannual reports occurring every 6 months from the date of the notification of compliance status

that identify: [63.753(c)(l)] a) For primers and topcoats where compliance is not being achieved through the use of averaging

or a control device, the HAP or VOC content in manufacturer's supplied data as recorded under §63.752(c), or each value of Hi and Gi, as recorded under §63.752(c)(2)(i), that exceeds the applicable organic HAP or VOC content limit specified in §63.745(c); [63.753(c)(l)(i)]

b) For primers and topcoats where compliance is being achieved through the use of averaging, each value of Ha and Ga, as recorded under §63.752(c)(4)(i), that exceeds the applicable organic HAP or VOC content limit specified in §63.745(c); [63.753(c)(l)(ii)]

c) All times when a primer or topcoat application operation was not immediately shut down when the pressure drop across a dry particulate filter or HEP A filter system was outside the limit( s) specified by the filter or booth manufacturer or in locally prepared operating procedures; [ 63. 753( C )(1 )(vi)]

d) If the operations have been in compliance for the semiannual period, a statement that the operations have been in compliance with the applicable standards; and, [63.753(c)(l)(vii)]

2) Annual reports beginning 12 months after the date of the notification of compliance status listing the number of times the pressure drop or water flow rate for each dry filter or waterwash system, as applicable, was outside the limit(s) specified by the filter or booth manufacturer or in locally prepared operating procedures. [63.753(c)(2)]

3) The permittee shall submit semiannual reports by: a) October 1st for monitoring which covers the January through June time period, and b) April 1st for monitoring which covers the July through December time period.

Permit Condition (CL-001-01) - 002 10 CSR 10-6.060 Construction Permits Required SLCDH Air Pollution Control Program Construction Permit# 7824

This permit condition, the requirements of Construction Permit #7824, applies to the Spray/Drying Booth Garmat G90-Model year 2013 (SB-027-06).

Emission Limitation: The permittee shall emit less than 10.0 tons of any individual hazardous air pollutant (HAP) in any consecutive twelve (12) month period from spray gun using Garmat G90-Model year 2013. [Construction Permit No. 7824, Special Condition 4.A.]

Operational Limitation/Equipment Specification: Control Device Requirement - Garmat G90-18, Model Year 2013: 1) The permittee shall control emissions of particulate matter greater than two and one-half microns in

aerodynamic diameter (PM2s) from the spray guns using booth-Garmat G90-18, Model Year 2013, using fabric filters with no less than 95% capture efficiency. [Construction Permit No. 7824, Special Condition 3.A.]



2) The permittee shall operate and maintain the filter(s) in accordance with the manufacturer's specifications. Replacement filters shall be kept on hand at all times. [Construction Permit No. 7824, Special Condition 3.B.]

3) Garmat G90-18, Model Year 2013, shall be completely enclosed during operations. [Construction Permit No. 7824, Special Condition 3.C.]

4) The permittee shall maintain documentation of the filter efficiency of paint spray booth exhaust filter material. GKN Aerospace Services, Inc. may use published filter efficiency data provided by filter manufacturer or vendor. [Construction Permit No. 7824, Special Condition 3.D.]

5) The filters shall be equipped with a gauge or meter, which indicates the pressure drop across the control device. The gauges or meters shall be located such that the Department of Natural Resources' employees may easily observe them. [Construction Permit No. 7824, Special Condition 3.E.]

6) The permittee shall monitor and record the operating pressure drop across the filters at least once every 24 hours when operations occur. The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance warranty. [Construction Permit No. 7824, Special Condition 3 .F.]

7) The permittee shall maintain an operating and maintenance log for the filters which shall include the following: [Construction Permit No. 7824, Special Condition 3.G.] a) Incidents of Malfunction, with impact on emissions, duration of event, probable cause, and

corrective actions; and [Construction Permit No. 7824, Special Condition 3.G.1] b) Maintenance activities, with inspection schedule, repair actions, and replacements, etc.

[Construction Permit No. 7824, Special Condition 3.G.2]

Monitoring/Recordkeeping: 1) The permittee shall calculate monthly and 12- month rolling total emissions of individual HAPs

from spray guns using booth-Garmat 090-18 using monthly throughput for each coating, the asmixed concentration of individual HAPs, 45% spray transfer efficiency, and 98% capture of HAPs solids. [Construction Permit No. 7824, Special Condition 4.B.]

2) The permittee shall track the total consumption of applied topcoats and primers. The HAP content shall be calculated based on the Manufacturer's Safety Data Sheets (SDS) for each topcoat/primer that is applied at this emission point. Total consumption may be used to demonstrate compliance in lieu of tracking individual HAP.

3) The permittee shall maintain monthly and 12-month rolling total emissions records sufficient to demonstrate compliance with the HAPs emission limitation of Special Condition 4.A. of Construction Permit No. 7824. [Construction Permit No. 7824, Special Condition 4.C.]

4) The permittee shall maintain all records required by this permit for not less than five years and shall make them available immediately to any Saint Louis County Department of Health or Missouri Department of Natural Resources' Personnel upon request. [Construction Permit No. 7824, Special Condition 5.A.]

Reporting: 1) The permittee shall report to the SLCDH Air Pollution Control Program, 6121 N. Hanley Rd.

Berkeley MO 63134 (or current address) no later than ten days after the end of the month during which any record required by this permit shows an exceedance of a limitation imposed by this permit. [Construction Permit No. 7824, Special Condition 5.B.]

2) Any deviations from this permit condition shall also be reported in the semi-annual monitoring report and annual compliance certification as required by Section V of this permit.



Permit Condition (CL-001-02) - 002 10 CSR 10-6. 060 Construction Permits Required SLCDH Air Pollution Control Program Construction Permit# 6259

36 Project No. 2012-10-007

This permit condition, the requirements of Construction Permit #6259, applies to the Paint and Adhesive Booth (SB-029-01)

Emission Limitation: The permittee shall not emit VOC and HAP from the paint, adhesives and sanding booth #SB-029-01 in excess of 1.75 tons in any consecutive twelve (12) month period.

Monitoring/Recordkeeping: 1) Record at a minimum the following information:

a) The HAP and VOC content of all materials and solvents used. b) The monthly usage records of VOC and HAP containing materials.

2) Emissions factors for VOC and HAP emissions may be obtained from the safety data sheet (SDS) for each material used; if a range of VOC and HAP contents are provided, the permittee shall use the highest value in the range to demonstrate compliance. If the VOC or HAP content is listed in percent by weight (wt%) the VOC or HAP content can be calculated using the following equation: (examples given for VOC's). a) voe content (lb/gal)= Density (lb/gal) X voe content (wt%) If specific gravity is listed the density can be calculated using the following equation: b) Density (lb/gal)= Specific Gravity x 8.34 lb/gal

3) Calculate monthly emissions by multiplying throughput and emission factor for each material used. 4) The permittee shall record the monthly and rolling twelve (12) month totals ofVOC and HAP

emissions from the adhesive, paint and sanding booth (SB-029-01). These records shall be complete within ten (10) days of the end of each month.

5) Calculate rolling 12-month VOC emissions by adding current month's emissions to previous eleven months emissions.

6) Compare emission total to limit and indicate whether or not compliance was met. 7) Include startup, shutdown and malfunction (S SM) emissions, if any, from the same 12

month period as reported to the Air Pollution Control Program, in accordance with 10 CSR 10- 6.050 Startup, Shutdown and Malfunction Conditions.

8) The permittee shall also maintain all records required by this permit condition, on-site, for the sixty (60) most recent months and shall immediately make such records available to SLCDH Air Pollution Control Program, or its designated agent, at any reasonable time.

Reporting: If the records indicate that a violation of the above emission limitation or standard has occurred, the permittee shall notify the SLCDH Air Pollution Control Program by no later than the next working day after the records are complete. Any deviations from this permit condition shall also be reported in the semi-annual monitoring report and annual compliance certification as required by Section V of this permit.



VD-001-0land VD-002-01- Vapor Degreaser

Emission .·

Manufacturer/ Unit

Description Model#

VD-001-01 Vapor Degreaser (VD-027-01): Open top batch vapor Phillips degreaser solvent cleaning machine ( utilizing trichloroethylene)

VD-002-01 Vapor Degreaser (VD-029-01): Open top batch vapor Baron-Blakeslee/ degreaser solvent cleaning machine ZCVSH-16.49-SW ( utilizing trichloroethylene)

Permit Condition (VD-001-01 and VD-002-01) - 001 10 CSR 10-6.075 Maximum Achievable Control Technology 40 CFR Part 63, Subpart T National Emission Standards for Halogenated Solvent Cleaning

Emission Limitation/Standards: § 63.464 Alternative standards.

Year Installed

1998

2014

1) The permittee shall comply with the requirements specified in §63.464 (a)(l)(i) and (a)(l)(ii) (listed below). [§63.464(a)(l)] a) The permittee shall maintain a log of solvent additions and deletions for each solvent cleaning

machine. [§63.464(a)(l)(i)] b) The permittee shall ensure that the emissions from each solvent cleaning machine are equal to or

less than 150 kilograms per square meter (kg/m2) of solvent/air interface per month, averaged

over three consecutive months using the three month rolling average compliance method. [§63 .464(a)(l )(ii)]

2) The permittee shall demonstrate compliance with the applicable 3-month rolling average monthly emission limit on a monthly basis as described in §63.465(b) and (c). [§63.464(b)]

3) If the applicable 3-month rolling average emission limit is not met, an exceedance has occurred. The permittee shall report all exceedances as required in §63.468(h). [§63.464(c)]

Compliance Demonstration/Monitoring: 1) On the first operating day of every month the permittee shall ensure that the solvent cleaning

machine system contains only clean liquid solvent. This includes, but is not limited to, fresh unused solvent, recycled solvent, and used solvent that has been cleaned of soils. A fill line must be indicated during the first month the measurements are made. The solvent level within the machine must be returned to the same fill-line each month, immediately prior to calculating monthly emissions as specified in §63.465(c). The solvent cleaning machine does not have to be emptied and filled with fresh unused solvent prior to the calculations. [§63.465(b)]

2) The permittee shall, on the first operating day of the month, comply with the requirements specified in paragraphs §63.465 (c)(l) through (3) (listed below). [§63.465(c)] a) Using the records of all solvent additions and deletions for the previous monthly reporting period

· required under §63.464(a), the permittee shall determine solvent emissions (Ei) using equation 2 for cleaning machines with a solvent/air interface: [§63.465(c)(l)]

SA- -LSR· -SSR· E· = l l l

l AREAi (2)



where: Er = the total halogenated HAP solvent emissions from the solvent cleaning machine

during the most recent monthly reporting period i, (kilograms of solvent per square meter of solvent/air interface area per month).

SA1 = the total amount of halogenated HAP liquid solvent added to the solvent cleaning machine during the most recent monthly reporting period i, (kilograms of solvent per month).

LSR1 = the total amount of halogenated HAP liquid solvent removed from the solvent cleaning machine during the most recent monthly reporting period i, (kilograms of solvent per month).

SSR1 = the total amount of halogenated HAP solvent removed from the solvent cleaning machine in solid waste, obtained as described in §63.467(c)(2), during the most recent monthly reporting period i, (kilograms of solvent per month).

AREA1 = the solvent/air interface area of the solvent cleaning machine (square meters). b) The permittee shall determine SSRi using the method specified in paragraph §63.465(c)(2)(i) or

(c)(2)(ii) of this section. [§63.465(c)(2)] (i) From tests conducted using EPA reference method 25d. [§63.465(c)(2)(i)] (ii) By engineering calculations included in the compliance report. [§63.465(c)(2)(ii)]

c) The permittee shall determine the monthly rolling average, EA, for the 3-month period ending with the most recent reporting period using equation 4 for cleaning machines with a solvent/air interface: [§63.465(c)(3)]

Where:

(4)

EAi = the average halogenated HAP solvent emissions over the preceding 3 monthly reporting periods, (kilograms of solvent per square meter of solvent/air interface area per month).

E, = halogenated HAP solvent emissions for each month G) for the most recent 3 monthly reporting periods (kilograms of solvent per square meter of solvent/air interface area).

J = 1 = the most recent monthly reporting period. J = 2 = the monthly reporting period immediately prior to j=l. J = 3 = the monthly reporting period immediately prior to j=2.

d) The permittee shall determine their potential to emit from all solvent cleaning operations, using the procedures described in §63.465 (e)(l) and (e)(3) (listed below). A facility's total potential to emit is the sum of the HAP emissions from all solvent cleaning operations, plus all HAP emissions from other sources within the facility. [§63.465(e)] i) Determine the potential to emit for each individual solvent cleaning using equation 6.

[§63.465(e)(l)]

(6)



Where: PTEi = the potential to emit for solvent cleaning machine i (kilograms of solvent per year). H = hours of operation for solvent cleaning machine i (hours per year).

= 8760 hours per year, unless otherwise restricted by a Federally enforceable requirement.

Wi = the working mode uncontrolled emission rate (kilograms per square meter per hour).

= 1.95 kilograms per square meter per hour for batch vapor and cold cleaning machines.

= 1.12 kilograms per square meter per hour for in-line cleaning machines. SAL= solvent/air interface area of solvent cleaning machine i (square meters). Section

63.461 defines the solvent/air interface area for those machines that have a solvent/air interface.

ii) Sum the PTEi for all solvent cleaning operations to obtain the total potential to emit for solvent cleaning operations at the facility. [§63.465(e)(2)]

Recordkeeping: The permittee shall maintain records specified in §63.467(e)(2)] (c)(l) through (3) (listed below) either in electronic or written form for a period of 5 years. [§63.467(c)] 1) The dates and amounts of solvent that are added to the solvent cleaning machine. [§63.467(c)(l)] 2) The solvent composition of wastes removed from cleaning machines as determined using the

procedure described in §63.465(c)(2). [§63.467(c)(2] 3) Calculation sheets showing how monthly emissions and the rolling 3-month average emissions from

the solvent cleaning machine were determined, and the results of all calculations. [§63.467(c)(3)]

Reporting: 1) The permittee shall submit a solvent emission report every year. This solvent emission report shall

contain the requirements specified in §63.468(g)(l) through (g)(3) (listed below). [§63.468(g)] a) The size and type of each unit subject to this subpart (solvent/air interface area or cleaning

capacity). [§63.468(g)(l )] b) The average monthly solvent consumption for the solvent cleaning machine in kilograms per

month. [§63.468(g)(2)] c) The 3-month monthly rolling average solvent emission estimates calculated each month using

the method as described in §63.465(c). [§63.468(g)(3)] 2) The permittee shall submit an exceedance report to the Director semiannually except when, the

Director determines on a case-by-case basis that more frequent reporting is necessary to accurately assess the compliance status of the source or, an exceedance occurs. Once an exceedance has occurred the permittee shall follow a quarterly reporting format until a request to reduce reporting frequency under §63.468(i) is approved. Exceedance reports shall be delivered or postmarked by the 30th day following the end of each calendar half or quarter, as appropriate. The exceedance report shall include the applicable information in paragraphs §63 .468(h)(2) and (3) (listed below). [§63.468(h)] a) If an exceedance has occurred, the reason for the exceedance and a description of the actions

taken. [§63 .468(h)(2)]



b) If no exceedances of a parameter have occurred, or a piece of equipment has not been inoperative, out of control, repaired, or adjusted, such information shall be stated in the report. [§63 .468(h)(3)

3) The permittee who is required to submit an exceedance report on a quarterly (or more :frequent) basis may reduce the frequency ofreporting to semiannual if the conditions in §63.468 (i)(l) through (i)(3) (listed below) are met. [§63.468(i)] a) The source has demonstrated a full year of compliance without an exceedance. [§63.468(i)(l)] b) The permittee continues to comply with all relevant recordkeeping and monitoring requirements

specified 40 CFR 63 Subpart A (General Provisions) and this subpart. [§63.468(i)(2)] c) The Director does not object to a reduced frequency of reporting for the affected source as

provided in §63.10(e)(3)(iii) of 40 CFR 63 Subpart A (General Provisions). [§63.468(i)(3)]

PL-001-02A-Aluminum Process Line Tanks (Tank #A14 & Tank #Al6)

Emission ..

Unit Description

PL-001-02A Tank #Al 4: - Dichromate seal tank

Tank #Al 6: - Boric-sulfuric acid anodizing tank

Permit Condition (PL-001-02A) - 001 10 CSR 10-6.060 Construction Permits Required SLCDH Air Pollution Control Program Construction Permit# 7824

Operational Limitation/Equipment Specification:

..

The permittee shall control the boric-sulfuric acid anodizing tank (tank# A16) and dichromate seal tank (tank# A14) on the aluminum process line (PL-001-02) with packed bed wet scrubber(s). [Construction Permit No. 7824, Special Condition 2] 1) The scrubber(s) and any related instrumentation or equipment shall be operated and maintained in

accordance with the manufacturer's specifications. The scrubber(s) shall be equipped with a gauge or meter that indicates the pressure drop across the scrubber. The gauge and meter shall be located in such a way that it may be easily observed by Department of Natural Resources' personnel. [Construction Permit No. 7824, Special Condition 3.A.]

2) The permittee shall monitor and record the operating pressure drop across each scrubber at least once every twenty-four (24) hours. The pressure drop across the scrubbers shall be maintained within the range of0.34 to 1.12 inches of water (H2O) .. [Construction Permit No. 7824, Special Condition 3.B.]

3) The flow rate through the scrubber(s) shall be maintained within the design conditions specified by the manufacturer's performance warranty. [Construction Permit No. 7824, Special Condition 3.C.]

4) The permittee shall maintain an operating and maintenance log for the scrubber(s), which shall include the following: [Construction Permit No. 7824, Special Condition 3.D.] a) Incidents of malfunction, with impact on emissions, duration of event, probable cause, and

corrective actions; b) Maintenance activities, with inspection schedule, repair actions, and replacements, etc.; and c) A record of regular inspection schedule, the date and results of all inspections, including any

actions or maintenance activities that result from the inspection. Either paper copy or electronic formats are acceptable.



5) In the event the scrubber performance is outside the manufacturer's performance warranty, the permittee shall restore operation of the scrubber to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause (other than those caused by excused startup or shutdown conditions). Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action, or any necessary follow-up actions to return operation to within the indicator range and designated condition.

Recordkeeping/Reporting: 1) The permittee shall maintain all records required by this permit for not less than five years and shall

make them available immediately to any Saint Louis County Department of Health or Missouri Department of Natural Resources' Personnel upon request. (Construction Permit No. 7824, Special Condition 5.A.]

2) Any deviations from this permit condition shall also be reported in the semi-annual monitoring report and annual compliance certification as required by Section V of this permit.

HW-STL-01-Handling Of Hazardous Waste

Emission .: ·.· .

Unit Description

.. · .

HW-STL-01 Plant-wide handling of hazardous waste generated from aerospace activities (not subject to Resource Conservation and Recovery Act (RCRA) Regulations)

Permit Condition (HW-STL-01) - 001 10 CSR 10-6.075 Maximum Achievable Control Technology 40 CFR 63 Subpart GG National Emission Standards for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities

Standards: Handling and Storage of Waste: (§63.748] The permittee shall handle and store waste that contains organic HAP from aerospace primer, topcoat, or specialty coating operations as specified in §63.748 (a)(l) or (a)(2) (listed below). The requirements of §63.748 (a)(l) or (a)(2) do not apply to spent wastes that contain organic HAP that are subject to and handled and stored in compliance with 40 CFR Parts 262 through 268 (including the air emission control requirements in 40 CFR Part 265, Subpart CC). [§63.748(a)] 1) The permittee shall conduct the handling and transfer of the waste to or from containers, tanks, vats,

vessels, and piping systems in such a manner that minimizes spills. [§63.748(a)(l)] 2) The permittee shall store all waste that contains organic HAP in closed containers. (§63.748(a)(2)]

Reporting: The permittee shall report any deviations/exceedances of this permit condition using the semi-annual monitoring report and annual compliance certification to the SLCDH Air Pollution Control Program, 6121 N. Hanley Rd. Berkeley MO 63134 (or current address) and the Air Pollution Control Program, Compliances and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as required by Section V of this permit.



GB-027-01 - Grit Blast System 12 feet

Emission .. ··

Unit Description

.

GB-027-01 Walk-in grit blaster with cyclone and bag filter

Permit Condition (GB-027-01) - 001 10 CSR 10-6.400 Restriction of Particulate Matter from Industrial Processes

Emission Limitation: 1) The permittee shall not cause, suffer, allow or permit the emissions of particulate matter (PM) in any

one (1) hour from the grit blaster (GB-027-01) in excess of 3.8 pounds. 2) The permittee shall not cause, allow or permit the emission of particulate matter from the grit blaster

(GB-027-01) in a concentration in excess of 0.30 grain per standard cubic foot of exhaust gases.

Monitoring/Recordkeeping/Reporting: Not required (See Statement of Basis).

FP809813 - Fire Pump Diesel Engine GEM020-0l - Emergency Diesel Generator

GEM027-01 - Emergency Natural Gas Generator

Emission Unit ·. . Description

FP809813 Fire Pump Diesel Engine - < 500 Horsepower (HP) General Motors (engine)/Fairbanks Morse (Fire Pump) located in Building 10. Model: PTA-lSD-50. Type: 6 cylinder 4 stroke lean bum engine, with a displacement of 4.3 liters per cylinder. Manufacture/Installation Date: 1970

GEM020-01 Emergency Diesel Generator - 250 HP Caterpillar engine located in Building 9 Type: 6 cylinder 4 stroke lean bum engine, with a displacement of 4.05 liters per cylinder.

Manufacture/Installation Date: - 1978)

GEM027-01 Emergency Natural Gas Generator - 220 HP Minneapolis Moine engine Type: 6 cylinder 4 stroke lean bum engine, with a displacement of 4.05 liters per cylinder.

Manufacture/Installation Date: - 1978)

Permit Condition (FP809813, GEM020-01 and GEM027-01) - 001

10 CSR 10-6.075 Maximum Achievable Control Technology Regulations 40 CFR Part 63, Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

Emission Limitation/Standards: 1) As stated in §6602 the permittee must comply with the following requirements for existing

compression ignition stationary RICE :S500 HP: [Table 2c to Subpart ZZZZ of Part 63]

.


For Each .....

Emergency CI RICE 1

(FP8098 l 3 and GEM020-01) Emergency stationary SI RICE (GEM027-0l)


The Permittee Must Meet the Following Requirement, Except Durini:! Periods of Startup a. Change oil and filter every 500

hours of operation or annually, whichever comes first;

b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first;2

c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary3

43 Project No. 2012-10-007

During Periods of Startup the Permittee must

Minimize the engine's time spent at idle and minimize the engine's startup time at startup to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the non-startup emission limitations apply.

1 If an emergency engine is operating during an emergency and it is not possible to shut down the engine in order to perform the work practice requirements on the schedule required in Table 2c of this subpart, or if performing the work practice on the required schedule would otherwise pose an unacceptable risk under federal, state, or local law, the work practice can be delayed until the emergency is over or the unacceptable risk under federal, state, or local law has abated. The work practice should be performed as soon as practicable after the emergency has ended or the unacceptable risk under federal, state, or local law has abated. Sources must report any failure to perform the work practice on the schedule required and the federal, state or local law under which the risk was deemed unacceptable.

2The permittee has the option to utilize an oil analysis program as described in §63.6625(i) or (j) in order to extend the specified oil change requirement in Table 2c of this subpart.

3The permittee can petition the Director pursuant to the requirements of 40 CFR 63.6(g) for alternative work practices.

Monitoring, Operation and Maintenance Requirements: 1) The permittee must operate and maintain the stationary RICE according to the manufacturer's

emission-related written instructions or develop the permittee's 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. [§63.6625(e)]

2) The permittee must install a non-resettable hour meter if one is not already installed. [§63.6625(±)] 3) The permittee must minimize the engine's time spent at idle during startup and minimize the engine's

startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup in Table 2c to Subpart ZZZZ of Part 63 apply. [§63.6625(h)]

4) The permittee has the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Tables 2c to this subpart. The oil analysis must be performed at the same frequency specified for changing the oil in Table 2c to this subpart (see Emission Limitation/Standards of this permit condition). The analysis program must at a minimum analyze the following three parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If all of these condemning limits are not exceeded, the permittee is not required to change the oil. If any of the limits are exceeded, the permittee must change the oil before continuing to use the engine. The permittee must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine. [§63.6625(i)]


Compliance Requirements:


1) The permittee must be in compliance with the emission limitations and operating limitations in Subpart ZZZZ of 40 CFR Part 63 that apply to the permittee at all times. [§63.6605(a)]

2) The permittee must demonstrate continuous compliance with each requirement of emission limitation and operating limitation in Table 2c to Subpart ZZZZ of 40 CFR Part 63 (see Emission Limitation/Standards of this permit condition) according to methods specified below (from Table 6 to Subpart ZZZZ of 40 CFR Part 63). [§63.6640(a)]

For Each ... Complying with the requirements to ...

Existing stationary Work or Management practices CI RICE not subject to any numerical emission limitations

The permittee must demonstrate continuous compliance by ...

Operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions; or

ii Develop and follow the permittee's 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.

3) The permittee must at all times operate and maintain the emergency fire pumps and emergency generators in a manner consistent with safety and good air pollution control practices for minimizing emissions. [§63.6605(b)]

4) The permittee must operate the emergency stationary RICE according to the requirements in paragraphs (f)(l) through (4) of §63.6640. In order for the engine to be considered an emergency stationary RICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in paragraphs (f)(l) through (4) of §63.6640, is prohibited. If you do not operate the engine according to the requirements in paragraphs (f)(l) through (4) of §63.6640, the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines. [§63.6640(f)] a) There is no time limit on the use of emergency stationary RICE in emergency situations.

[ §63. 6640( f)(l)] b) The permittee may operate the emergency stationary RICE for any combination of the purposes

specified in paragraph (f)(2)(i) §63.6640 for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by paragraphs (f)(3) and (4) of §63.6640 counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2). [§63.6640(f)(2)] i) The emergency stationary RICE may be operated for maintenance checks and readiness

testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency RICE beyond 100 hours per calendar year. §63.6640(f)(2)(i)]



c) The emergency stationary RICE may be operated for up to 50 hours per calendar year in nonemergency situations. Except as provided in paragraph (f)(4)(ii) of §63.6640, the 50 hours per year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. i) The 50 hours per year for non-emergency situations can be used to supply power as part of a

financial arrangement with another entity if all of the following conditions are met: [§63 .6640(t)( 4)(ii)] (A) The engine is dispatched by the local balancing authority or local transmission and

distribution system operator. [§63 .6640(t)( 4 )(ii)(A)] (B) The dispatch is intended to mitigate local transmission and/or distribution limitations so

as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. [§63.6640(t)(4)(ii)(B)]

(C) The dispatch follows reliability, emergency operation or similar protocols that follow specific North American Electric Reliability Corporation NERC, regional, state, public utility commission or local standards or guidelines. [§63.6640(t)(4)(ii)(C)]

(D) The power is provided only to the facility itself or to support the local transmission and distribution system. [§63.6640(t)(4)(ii)(D)]

(E) The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator. [§63.6640(t)(4)(ii)(E)]

Recordkeeping: 1) The permittee must keep the records described in paragraphs (a)(l) through (a)(5), (b)(l) through

(b)(3) and (c) of §63.6655. [§63.6655(a)] a) A copy of each notification and report that you submitted to comply with Subpart ZZZZ of 40

CFR Part 63, including all documentation supporting any Initial Notification or Notification of Compliance Status that you submitted, according to the requirement in §63.10(b)(2)(xiv). [§63.6655(a)(l)]

b) Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment. [§63.6655(a)(2)]

c) Records of actions taken during periods of malfunction to minimize emissions in accordance with §63.6605(b). [§63.6655(a)(5)]

2) The permittee must keep the records required in Table 6 of Subpart ZZZZ of 40 CFR Part 63 to show continuous compliance with each emission or operating limitation that applies to you. [§63.6655(d)]

3) The permittee's records must be in a form suitable and readily available for expeditious review according to §63.lO(b)(l). [§63.6660(a)]

4) As specified in §63 .1 0(b )( 1 ), the permittee must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. [§63.6660(b)]

5) The permittee must keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63. lO(b)(l). [§63.6660(c)]


Reporting:


1) The permittee must report each instance in which you did not meet each emission limitation or operating limitation in Table 2c to Subpart ZZZZ of 40 CFR Part 63 that applies. These instances are deviations from the emission and operating limitations in Subpart ZZZZ of 40 CFR Part 63. These deviations must be reported according to the requirements in §63.6650. [§63.6640(b)]

2) The permittee must also report each instance in which the permittee did not meet the requirements in Table 8 to Subpart ZZZZ of 40 CFR Part 63 - Applicability of General Provisions to Subpart ZZZZ that apply. [§63.6640(e)]

3) Reporting requirements [§63.6650] a) Pursuant to 40 CFR §63.6650(b)(5), the permittee shall report any deviations/exceedances of this

permit condition using the semi-annual monitoring report and annual compliance certification to the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as required by Section V of this permit instead of according to the dates specified in in paragraphs (b)(l) through (b)(4) of §63.6650.

b) The Compliance report must contain the information in paragraphs ( c )(1) through ( 6) of §63 .6650. [§63 .6650( C )]

(1) Company name and address. [§63.6650(c)(l)] (2) Statement by a responsible official, with that official's name, title, and signature, certifying

the accuracy of the content of the report. [§63.6650(c)2)] (3) Date ofreport and beginning and ending dates of the reporting period. [§63.6650(c)(3)] (4) If the permittee had a malfunction during the reporting period, the compliance report must

include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report must also include a description of actions taken by the permittee during a malfunction of an affected source to minimize emissions in accordance with §63.6605(b), including actions taken to correct a malfunction. [§63.6650( C )( 4)]

(5) If there are no deviations from any emission or operating limitations that apply, a statement that there were no deviations from the emission or operating limitations during the reporting period. [§63.6650(c)(5)]

c) For each deviation from an emission or operating limitation that occurs for the stationary RICE where the permittee is not using a CMS to comply with the emission or operating limitations in Subpart ZZZZ of 40 CFR Part 63, the Compliance report must contain the information in paragraphs (c)(l) through ( 4) of §63.6650 and the information in paragraphs (d)(l) and (2) of §63.6650. [§63.6650(d)] (1) The total operating time of the stationary RICE at which the deviation occurred during the

reporting period. [§63.6650(d)(l)] (2) Information on the number, duration, and cause of deviations (including unknown cause, if

applicable), as applicable, and the corrective action taken. [§63.6650(d)(2)] d) The permittee must report all deviations as defined in Subpart ZZZZ of 40 CFR Part 63 in the

semiannual monitoring report required by 40 CFR 70.6 (a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A). If the permittee submits a Compliance report pursuant to Table 7 of Subpart ZZZZ of 40 CFR Part 63 along with, or as part of, the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A), and the Compliance report includes all required information concerning deviations from any emission or operating limitation in Subpart ZZZZ of 40 CFR Part 63, submission of the Compliance report shall be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring report. However,



submission of a Compliance report shall not otherwise affect any obligation the permittee may have to report deviations from permit requirements to the permit authority. [§63.6650(£)]

e) If the permittee operates the emergency stationary RICEs for the purpose specified in §63.6640(f)(4)(ii) (item 4c Compliance Requirements of this Permit Condition), the permittee must submit an annual report according to the requirements in §63.6650 (h)(l) through (3) except §63.6650 (h)(l) (v) and (vi) (listed below). [§63.6650(h)] (1) The report must contain the following information: [§63.6650 (h)(l)]

(i) Company name and address where the engine is located. (ii) Date of the report and beginning and ending dates of the reporting period. (iii) Engine site rating and model year. (iv) Latitude and longitude of the engine in decimal degrees reported to the fifth decimal

place. (v) Hours spent for operation for the purpose specified in §63.6640(£)( 4)(ii), including the

date, start time, and end time for engine operation for the purposes specified in §63.6640(£)( 4)(ii). The report must also identify the entity that dispatched the engine and the situation that necessitated the dispatch of the engine.

(vi) If there were no deviations from the fuel requirements in §63.6604 that apply to the engine (if any), a statement that there were no deviations from the fuel requirements during the reporting period.

(vii) If there were deviations from the fuel requirements in §63.6604 that apply to the engine (if any), information on the number, duration, and cause of deviations, and the corrective action taken.

(2) The permittee must submit the subsequent annual reports for each calendar year no later than March 31 of the following calendar year.

(3) The permittee must submit the annual report electronically using the subpart specific reporting form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, the written report must be submitted to the Administrator at the appropriate address listed in §63.13.

Permit Condition (FP809813 and GEM020-01)-002

10 CSR 10-6.260 Restriction of Emissions of Sulfur Compounds 1

Emission Limitation: The permittee shall not cause or permit the emission into the atmosphere of gases containing more than 500 ppmv of sulfur dioxide or more than 35 mg/m3 of sulfuric acid or sulfur trioxide or any combination of those gases averaged on any consecutive three-hour time period from the Emergency Generators. [10 CSR 10-6.260(3)(A)2.]

1 10 CSR 10-6.260 was rescinded on November 30, 2015 and replaced by 10 CSR 10-6.261; however, the provisions of 10 CSR 10-6.260 currently remain in the State Implementation Plan and are federally enforceable. The provisions of 10 CSR 10-6.260 will expire and the provisions of 10 CSR 10-6.261 will become federally enforceable once 10 CSR 10-6.261 is incorporated into the federally-approved SIP as a final EPA action. Permit Condition (FP809813 and GEM020-01)-002 will expire and the limitations thereof will no longer apply to the installation once 10 CSR 10-6.261 is incorporated into the SIP.


Operational Limitation:


The permittee shall be limited to burning low sulfur fuel oil with a sulfur content of no more than 15 ppmv to meet the limits of this rule.

Monitoring/Recordkeeping: 1) The permittee shall maintain an accurate record of the sulfur content of fuel used. Fuel purchase

receipts, analyzed samples, or fuel oil supplier certifications that verify the fuel type and sulfur content will be acceptable.

2) Record keeping shall be accomplished in accordance with the requirements of 10 CSR 10-6.065( 6)(C) l.C General Record Keeping and Reporting Requirements, as stated in Section V of this permit.

Reporting: The permittee shall report any deviations/exceedances of this permit condition using the annual compliance certification to the SLCDH St. Louis County Air Pollution Control Program, 6121 North Hanley Road, Berkeley, MO 63134 and the Air Pollution Control Program's Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, or [email protected], as required by Section V of this permit.

Permit Condition (FP809813 and GEM020-01)-003 10 CSR 10-6.261 Control of Sulfur Dioxide Emissions2

Emission Limitation: The permittee must limit the fuel sulfur content of the fuel oil to no more than 8,812 parts per million (ppm). [10 CSR 10-6.261(3)(C)]

Compliance Demonstration: The permittee must determine compliance with the fuel sulfur content limitation of this permit condition as follows: 1) Fuel delivery records; or 2) Fuel sampling and analysis; or 3) Fuel supplier certification letters may be used as an alternate method of compliance.

Recordkeeping: 1) The permittee must maintain fuel delivery/purchase receipts and/or fuel sampling tests as applicable

or fuel oil supplier certification letters. 2) The permittee must maintain the fuel supplier certification information to certify all fuel deliveries.

Bills of lading and/or other fuel delivery documentation containing the following information for all fuel purchases or deliveries are deemed acceptable to comply with the requirements of this rule: a) The name, address, and contact information of the fuel supplier; b) The type of fuel ( diesel or #2 fuel oil); c) The sulfur content or maximum sulfur content expressed in percent sulfur by weight or in ppm

sulfur; and d) The heating value of the fuel.

3) The permittee must use fuel sampling and analysis to determine sulfur weight percent, or equivalent, offuel(s) in accordance with 10 CSR 10-6.040. This requirement does not apply if the permittee uses the fuel supplier certification as a method of compliance.

2 Ibid.

GKN Aerospace North America, Inc. Installation ID: 189-14 89


4) The permittee must retain all reports and records on-site for a minimum of five (5) years and make available within five (5) business days upon written or electronic request by the Director.

Reporting: 1) The permittee must furnish the Director all data necessary to determine compliance status. 2) The permittee shall report any excess emissions other than startup, shutdown, and malfunction

excess emissions already required to be reported under 10 CSR 10-6.050 to the Director for each calendar quarter within thirty (30) days following the end of the quarter. In all cases, the notification must be written and include the information listed in 10 CSR 10-6.261 (4) (A) 1.

3) The permittee shall report any deviations/exceedances of this permit condition using the annual monitoring report and annual compliance certification to the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, or [email protected], as required by Section V of this permit.

GEM02-01-128 HP Natural Gas Emergency Generator GEM00l-02- 135 HP Natural Gas Emergency Generator

Emission .

Unit Description

GEM02-01 Emergency Natural Gas Generator- 128 HP Olympian (CAT), Model #G80LG2, Serial #GXC0 1528 Type: 10 cylinder 4 stroke lean bum spark ignition engine, with a displacement of 6.8 liters per cylinder.

Manufacture/Installation Date: - 2012

GEM00l-02 Emergency Natural Gas Generator - 135 HP Ford, Model #MTU 10V0068 GSl00 Type: IO cylinder 4 stroke lean bum spark ignition engine, with a displacement of 6.8 liters per cylinder.

Manufacture/Installation Date: 2015

Permit Condition (GEM02 and GEM00l-02) - 001

10 CSR 10-6.070 New Source Performance Regulations 40 CFR Part 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

Emission Limitation/Standards: 1) The permittee shall comply with the following emission standards

[§60.4233(e) and Subpart JJJJ, Table 1]



Emission Standards3

Engine Type and Fuel Maximum

e:IHP-hr nnmvd at 15% 02 Engine Power

NOx co vocd NOx co vocd GEM02-01 (128 HP) 25 <HP< 130 0 10 387 NIA NIA NIA NIA

GEM00l-02 (135 HP) HP~ 130 2.0 4.0 1.0 160 540 86

a Owners and operators of stationary non-certified SI engines may choose to comply with the emission standards in units of either g/HP-hr or ppmvd at 15 percent 02.

c The emission standards applicable to emergency engines between 25 HP and 130 HP are in terms ofNOx + HC.

d For purposes of this subpart, when calculating emissions of volatile organic compounds, emissions of formaldehyde should not be included.

2) The permittee shall operate and maintain the stationary SI ICE to achieve the emission standards as required in §60.4233 over the entire life of the engine. (§60.4234]

Operational Limitation: The permittee shall install a non-resettable hour meter upon startup of the emergency engine. (§60.4237(c)]

Compliance Method: 1) The permittee shall demonstrate compliance according to the following method: [§60.4243(b)]

a) Demonstrating compliance with the emission standards specified in §60.4233(e) and according to the requirements specified in §60.4244 and according to the following: [§60.4243(b)(2)] i) The permittee shall keep a maintenance plan and records of conducted maintenance and

shall, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, the permittee shall conduct an initial performance test to demonstrate compliance. [§60.4243(b)(2)(i)]

2) The permittee must operate the emergency stationary ICE according to the requirements in §60.4243(d)(l) through (3). In order for the engine to be considered an emergency stationary ICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in §60.4243(d)(l) through (3), is prohibited. If the permittee do not operate the engine according to the requirements in §60.4243(d)(l), §60.4243(d)(2)(i) and§60.4243(d)(3), the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines. [§60.4243(d)] a) There is no time limit on the use of emergency stationary ICE in emergency situations.

(§60.4243( d)(l )] b) The permittee may operate the emergency stationary ICE for any combination of the purposes

specified in §60.4243(d)(2)(i) for a maximum of 100 hours per calendar year. Any operation for nonemergency situations as allowed by §60.4243(d)(3) counts as part of the 100 hours per calendar year allowed in §60.4243(d)(2). [§60.4243(d)(2)] i) Emergency stationary ICE may be operated for maintenance checks and readiness testing,

provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The permittee may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the permittee maintains records indicating that federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar year. [§60.4243(d)(2)(i)]



3) Emergency stationary ICE may be operated for up to 50 hours per calendar year in nonemergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in §60.4243(d)(2). Except as provided in §60.4243(d)(3)(i), the 50 hours per year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. [§60.4243(d)(3)] a) The 50 hours per year for non-emergency situations can be used to supply power as part of a

financial arrangement with another entity if all of the following conditions are met: [§60.4243( d)(3)(i)] i) The engine is dispatched by the local balancing authority or local transmission and

distribution system operator; [§60.4243(d)(3)(i)(A)] ii) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to

avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. [§60.4243(d)(3)(i)(B)]

iii) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. [§60.4243( d)(3)(i)(C)]

iv) The power is provided only to the facility itself or to support the local transmission and distribution system. [§60.4243(d)(3)(i)(D)]

v) The permittee identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator. [§60.4243(d)(3)(i)(E)]

Performance Testing: While conducting performance tests, the permittee shall follow the procedures in §60.4244(a) through (e). [§60.4244]

Notifications, Recordkeeping. and Reporting: 1) The permittee shall meet the following notification, reporting and recordkeeping requirements:

[§60.4245] a) The permittee shall retain records of the following information: [§60.4245(a)]

i) All notifications submitted to comply with this subpart and all documentation supporting any notification. [§60.4245(a)(l)]

ii) Maintenance conducted on the engine. [§60.4245(a)(2)] 2) The permittee shall retain records of the hours of operation of the engine that is recorded through the

non-resettable hour meter. The permittee shall document how many hours are spent for emergency operation; including what classified the operation as emergency and how many hours are spent for non-emergency operation. [§60.4245(b)]

3) The permittee shall submit a copy of each performance test as conducted in §60.4244 within 60 days after the test has been completed. [§60.4245(d)]

4) For engines that operate or are contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in §60.4243( d)(2)(ii) and (iii) or that operates for the purposes specified in §60.4243(d)(3)(i), the permittee must submit an annual report according to the requirements in paragraphs §60.4245( e )(1) through (3).



IV. Core Permit Requirements

52 Project No. 2012-10-007

The installation shall comply with each of the following regulations or codes. Consult the appropriate sections in the Code of Federal Regulations ( CFR), the Code of State Regulations ( CSR), and local ordinances for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of the date that this permit is issued. The following are only excerpts from the regulation or code, and are provided for summary purposes only.

10 CSR 10-6.045 Open Burning Requirements 1) General Provisions. The open burning of tires, petroleum-based products, asbestos containing

materials, and trade waste is prohibited, except as allowed below. Nothing in this rule may be construed as to allow open burning which causes or constitutes a public health hazard, nuisance, a hazard to vehicular or air traffic, nor which violates any other rule or statute.

2) Certain types of materials may be open burned provided an open burning permit is obtained from the director. The permit will specify the conditions and provisions of all open burning. The permit may be revoked if the owner or operator fails to comply with the conditions or any provisions of the permit.

10 CSR 10-6.050 Start-up, Shutdown and Malfunction Conditions 1) In the event of a malfunction, which results in excess emissions that exceed one hour, the permittee

shall submit to the director within two business days, in writing, the following information: a) Name and location of installation; b) Name and telephone number of person responsible for the installation; c) Name of the person who first discovered the malfunction and precise time and date that the

malfunction was discovered. d) Identity of the equipment causing the excess emissions; e) Time and duration of the period of excess emissions; f) Cause of the excess emissions; g) Air pollutants involved; h) Estimate of the magnitude of the excess emissions expressed in the units of the applicable

requirement and the operating data and calculations used in estimating the magnitude; i) Measures taken to mitigate the extent and duration of the excess emissions; and j) Measures taken to remedy the situation that caused the excess emissions and the measures taken

or planned to prevent the recurrence of these situations. 2) The permittee shall submit the paragraph 1 information to the director in writing at least ten days

prior to any maintenance, start-up or shutdown activity which is expected to cause an excessive release of emissions that exceed one hour. If notice of the event cannot be given ten days prior to the planned occurrence, notice shall be given as soon as practicable prior to the activity.

3) Upon receipt of a notice of excess emissions issued by an agency holding a certificate of authority under section 643.140, RSMo, the permittee may provide information showing that the excess emissions were the consequence of a malfunction, start-up or shutdown. The information, at a minimum, should be the paragraph 1 list and shall be submitted not later than 15 days after receipt of the notice of excess emissions. Based upon information submitted by the permittee or any other pertinent information available, the director or the commission shall make a determination whether the excess emissions constitute a malfunction, start-up or shutdown and whether the nature, extent and duration of the excess emissions warrant enforcement action under section 643 .080 or 643 .151, RSMo.



4) Nothing in this rule shall be construed to limit the authority of the director or commission to take appropriate action, under sections 643.080, 643.090 and 643.151, RSMo to enforce the provisions of the Air Conservation Law and the corresponding rule.

5) Compliance with this rule does not automatically absolve the permittee of liability for the excess emissions reported.

10 CSR 10-6.060 Construction Permits Required The permittee shall not commence construction, modification, or major modification of any installation subject to this rule, begin operation after that construction, modification, or major modification, or begin operation of any installation which has been shut down longer than five years without first obtaining a permit from the permitting authority.

10 CSR 10-6.065 Operating Permits The permittee shall file a complete application for renewal of this operating permit at least six months before the date of permit expiration. In no event shall this time be greater than eighteen months. The permittee shall retain the most current operating permit issued to this installation on-site. The permittee shall immediately make such permit available to any Missouri Department of Natural Resources personnel upon request.

10 CSR 10-6.080 Emission Standards for Hazardous Air Pollutants and 40 CFR Part 61 Subpart M National Emission Standard for Asbestos The permittee shall follow the procedures and requirements of 40 CFR Part 61, Subpart M for any activities occurring at this installation which would be subject to provisions for 40 CFR Part 61, Subpart M, National Emission Standard for Asbestos.

10 CSR 10-6.100 Alternate Emission Limits Proposals for alternate emission limitations shall be submitted on Alternate Emission Limits Permit forms provided by the department. An installation owner or operator must obtain an Alternate Emission Limits Permit in accordance with 10 CSR 10-6.100 before alternate emission limits may become effective.

10 CSR 10-6.110 Reporting of Emission Data, Emission Fees and Process Information 1) The permittee shall submit a Full Emissions Report either electronically via MoEIS, which requires

Form 1.0 signed by an authorized company representative, or on Emission Inventory Questionnaire (EIQ) paper forms on the frequency specified in this rule and in accordance with the requirements outlined in this rule. Alternate methods of reporting the emissions, such as spreadsheet file, can be submitted for approval by the director.

2) Public Availability of Emission Data and Process Information. Any information obtained pursuant to the rule(s) of the Missouri Air Conservation Commission that would not be entitled to confidential treatment under 10 CSR 10-6.210 shall be made available to any member of the public upon request.

3) The permittee shall pay an annual emission fee per ton of regulated air pollutant emitted according to the schedule in the rule. This fee is an emission fee assessed under authority of RSMo. 643.079.

10 CSR 10-6.130 Controlling Emissions During Episodes of High Air Pollution Potential This rule specifies the conditions that establish an air pollution alert (yellow/orange/red/purple), or emergency (maroon) and the associated procedures and emission reduction objectives for dealing with each. The permittee shall submit an appropriate emergency plan if required by the Director.


10 CSR 10-6.150 Circumvention


The permittee shall not cause or permit the installation or use of any device or any other means which, without resulting in reduction in the total amount of air contaminant emitted, conceals or dilutes an emission or air contaminant which violates a rule of the Missouri Air Conservation Commission.

10 CSR 10-6.165 Restriction of Emission of Odors This requirement is not federally enforceable.

No person may cause, permit or allow the emission of odorous matter in concentrations and frequencies or for durations that odor can be perceived when one volume of odorous air is diluted with seven volumes of odor-free air for two separate trials not less than 15 minutes apart within the period of one hour. This odor evaluation shall be taken at a location outside of the installation's property boundary.

10 CSR 10-6.170 Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin 1) The permittee shall not cause or allow to occur any handling, transporting or storing of any material;

construction, repair, cleaning or demolition of a building or its appurtenances; construction or use of a road, driveway or open area; or operation of a commercial or industrial installation without applying reasonable measures as may be required to prevent, or in a manner which allows or may allow, fugitive particulate matter emissions to go beyond the premises of origin in quantities that the particulate matter may be found on surfaces beyond the property line of origin. The nature or origin of the particulate matter shall be determined to a reasonable degree of certainty by a technique proven to be accurate and approved by the director.

2) The permittee shall not cause nor allow to occur any fugitive particulate matter emissions to remain visible in the ambient air beyond the property line of origin.

3) Should it be determined that noncompliance has occurred, the director may require reasonable control measures as may be necessary. These measures may include, but are not limited to, the following: a) Revision of procedures involving construction, repair, cleaning and demolition of buildings and

their appurtenances that produce particulate matter emissions; b) Paving or frequent cleaning of roads, driveways and parking lots; c) Application of dust-free surfaces; d) Application of water; and e) Planting and maintenance of vegetative ground cover.

10 CSR 10-6.180 Measurement of Emissions of Air Contaminants 1) The director may require any person responsible for the source of emission of air contaminants to

make or have made tests to determine the quantity or nature, or both, of emission of air contaminants from the source. The director may specify testing methods to be used in accordance with good professional practice. The director may observe the testing. All tests shall be performed by qualified personnel.

2) The director may conduct tests of emissions of air contaminants from any source. Upon request of the director, the person responsible for the source to be tested shall provide necessary ports in stacks or ducts and other safe and proper sampling and testing facilities, exclusive of instruments and sensing devices as may be necessary for proper determination of the emission of air contaminants.

3) The director shall be given a copy of the test results in writing and signed by the person responsible for the tests.



10 CSR 10-6.220 Restriction of Emission of Visible Air Contaminants

Emission Limitation:

55 Project No. 2012-10-007

1) The permittee shall not cause or permit to be discharged into the atmosphere from any source, not exempted under 10 CSR 10-6.220, any visible emissions with an opacity greater than 20%.

2) Exception: The permittee may discharge into the atmosphere visible emissions of up to 40% for a period not aggregating more than one (1) six (6) minutes period in any 60 minutes.

Monitoring: 1) The permittee shall conduct opacity readings on each emission unit using the procedures contained

in USEPA Test Method 22. The permittee is only required to take readings when the emission unit is operating and when the weather conditions allow. If the permittee observes no visible or other significant emissions using these procedures, then no further observations are required. For emission units with visible emissions perceived or believed to exceed the applicable opacity standard, a source representative would then conduct a Method 9 observation.

2) The permittee must maintain the following monitoring schedule: a) The permittee shall conduct weekly observations for a minimum of eight (8) consecutive weeks

after permit issuance. b) Should the permittee observe no violations of this regulation during this period then-

i) The permittee may observe once every two (2) weeks for a period of eight (8) weeks. ii) If a violation is noted, monitoring reverts to weekly. iii) Should no violation of this regulation be observed during this period then

(1) The permittee may observe once per month. (2) If a violation is noted, monitoring reverts to weekly.

3) If the source reverts to weekly monitoring at any time, monitoring frequency will progress in an identical manner from the initial monitoring frequency.

Recordkeeping: 1) The permittee shall maintain records of all observation results using Attachment B ( or its

equivalent), noting: a) Whether any air emissions (except for water vapor) were visible from the emission units; b) All emission units from which visible emissions occurred; c) Whether the visible emissions were normal for the process; d) The permittee shall maintain records of any equipment malfunctions, which may contribute to

visible emissions; and, 2) The permittee shall maintain records of any Method 9 test performed in accordance with this permit

condition. (See Attachment C).

10 CSR 10-6.250 Asbestos Abatement Projects - Certification, Accreditation, and Business Exemption Requirements The permittee shall conduct all asbestos abatement projects within the procedures established for certification and accreditation by 10 CSR 10-6.250. This rule requires individuals who work in asbestos abatement projects to be certified by the Missouri Department of Natural Resources Air Pollution Control Program. This rule requires training providers who offer training for asbestos abatement occupations to be accredited by the Missouri Department of Natural Resources Air Pollution Control Program. This rule requires persons who hold exemption status from certain requirements of this rule to allow the department to monitor training provided to employees.



10 CSR 10-6.280 Compliance Monitoring Usage

56 Project No. 2012-10-007

1) The permittee is not prohibited from using the following in addition to any specified compliance methods for the purpose of submission of compliance certificates: a) Monitoring methods outlined in 40 CFR Part 64; b) Monitoring method(s) approved for the permittee pursuant to 10 CSR 10-6.065, "Operating

Permits", and incorporated into an operating permit; and c) Any other monitoring methods approved by the director.

2) Any credible evidence may be used for the purpose of establishing whether a permittee has violated or is in violation of any such plan or other applicable requirement. Information from the use of the following methods is presumptively credible evidence of whether a violation has occurred at an installation: a) Monitoring methods outlined in 40 CFR Part 64; b) A monitoring method approved for the permittee pursuant to 10 CSR 10-6.065, "Operating

Permits", and incorporated into an operating permit; and c) Compliance test methods specified in the rule cited as the authority for the emission limitations.

3) The following testing, monitoring or information gathering methods are presumptively credible testing, monitoring, or information gathering methods: a) Applicable monitoring or testing methods, cited in:

i) 10 CSR 10-6.030, "Sampling Methods for Air Pollution Sources"; ii) 10 CSR 10-6.040, "Reference Methods"; iii) 10 CSR 10-6.070, "New Source Performance Standards"; iv) 10 CSR 10-6.080, "Emission Standards for Hazardous Air Pollutants"; or

b) Other testing, monitoring, or information gathering methods, if approved by the director, that produce information comparable to that produced by any method listed above.

10 CSR 10-5.040 Use of Fuel in Hand-Fired Equipment Prohibited No owner or operator shall operate applicable hand-fired fuel burning equipment unless the owner or operator meets the conditions set forth in 10 CSR 10-5.040. This regulation shall apply to all hand-fired fuel-burning equipment at commercial facilities including, but not limited to, furnaces, heating and cooking stoves and hot water furnaces. It shall not apply to wood-burning fireplaces and wood-burning stoves in dwellings, nor to fires used for recreational purpose, nor to fires used solely for the preparation of food by barbecuing or to other equipment exempted under 10 CSR 10-5.040. Hand-fired fuel-burning equipment is any stove, furnace, or other fuel-burning device in which fuel is manually introduced directly into the combustion chamber.

10 CSR 10-5.060 Refuse Not to be Burned in Fuel Burning Installations (Rescinded on February 11, 1979, Contained in State Implementation Plan) No person shall bum or cause or permit the burning of refuse in any installation which is designed for the primary purpose of burning fuel.

40 CFR Part 82 Protection of Stratospheric Ozone (Title VI) 1) The permittee shall comply with the standards for labeling of products using ozone-depleting

substances pursuant to 40 CFR Part 82, Subpart E: a) All containers in which a class I or class II substance is stored or transported, all products

containing a class I substance, and all products directly manufactured with a class I substance must bear the required warning statement if it is being introduced into interstate commerce pursuant to 40 CFR §82.106.



b) The placement of the required warning statement must comply with the requirements of 40 CFR §82.108.

c) The form of the label bearing the required warning statement must comply with the requirements of 40 CFR §82.110.

d) No person may modify, remove, or interfere with the required warning statement except as described in 40 CFR §82.112.

2) The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F, except as provided for motor vehicle air conditioners (MVACs) in Subpart B of 40 CFR Part 82: a) Persons opening appliances for maintenance, service, repair, or disposal must comply with the

required practices described in 40 CFR §82.156. b) Equipment used during the maintenance, service, repair, or disposal of appliances must comply

with the standards for recycling and recovery equipment described in 40 CFR §82.158. c) Persons performing maintenance, service, repair, or disposal of appliances must be certified by

an approved technician certification program pursuant to 40 CFR §82.161. d) Persons disposing of small appliances, MV A Cs, and MV AC-like appliances must comply with

the record keeping requirements of 40 CFR §82.166. ("MV AC-like" appliance as defined at 40 CFR §82.152).

e) Persons owning commercial or industrial process refrigeration equipment must comply with the leak repair requirements pursuant to 40 CFR §82.156.

f) 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 40 CFR §82.166.

3) If the permittee manufactures, transforms, imports, or exports a class I or class II substance, the permittee is subject to all the requirements as specified in 40 CFR part 82, Subpart A, Production and Consumption Controls.

4) If the permittee performs a service on motor (fleet) vehicles when this service involves ozonedepleting substance refrigerant ( or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the permittee is subject to all the applicable requirements contained in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. 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 "MV AC" as used in Subpart B does not include the air-tight sealed refrigeration system used as refrigerated cargo, or system used on passenger buses using HCFC-22 refrigerant.

5) The permittee shall be allowed to switch from any ozone-depleting substance to any alternative that is listed in the Significant New Alternatives Program (SNAP) promulgated pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives Policy Program. Federal Only - 40 CFR Part 82.



V. General Permit Requirements

58 Project No. 2012-10-007

The installation shall comply with each of the following requirements. Consult the appropriate sections in the Code of Federal Regulations (CFR) and Code of State Regulations (CSR) for the full text of the applicable requirements. All citations, unless otherwise noted, are to the regulations in effect as of the date that this permit is issued,

10 CSR 10-6.065(6)(C)l.B Permit Duration 10 CSR 10-6.065(6)(E)3.C Extension of Expired Permits This permit is issued for a term of five years, commencing on the date of issuance. This permit will expire at the end of this period unless renewed. If a timely and complete application for a permit renewal is submitted, but the Air Pollution Control Program fails to take final action to issue or deny the renewal permit before the end of the term of this permit, this permit shall not expire until the renewal permit is issued or denied.

10 CSR 10-6.065(6)(C)l.C General Record Keeping and Reporting Requirements 1) Record Keeping

a) All required monitoring data and support information shall be retained for a period of at least five years from the date of the monitoring sample, measurement, report or application.

b) Copies of all current operating and construction permits issued to this installation shall be kept on-site for as long as the permits are in effect. Copies of these permits shall be made immediately available to any Missouri Department of Natural Resources' personnel upon request.

2) Reporting a) All reports shall be submitted to the Air Pollution Control Program, Compliance and

Enforcement Section, P. 0. Box 176, Jefferson City, MO 65102, or [email protected]. gov.

b) The permittee shall submit a report of all required monitoring by: i) October 1st for monitoring which covers the January through June time period, and ii) April 1st for monitoring which covers the July through December time period.

c) Each report shall identify any deviations from emission limitations, monitoring, record keeping, reporting, or any other requirements of the permit, this includes deviations or Part 64 exceedances.

d) Submit supplemental reports as required or as needed. All reports of deviations shall identify the cause or probable cause of the deviations and any corrective actions or preventative measures taken. i) Notice of any deviation resulting from an emergency ( or upset) condition as defined in

paragraph (6)(C)7.A of 10 CSR 10-6.065 (Emergency Provisions) shall be submitted to the permitting authority either verbally or in writing within two working days after the date on which the emission limitation is exceeded due to the emergency, if the permittee wishes to assert an affirmative defense. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that indicate an emergency occurred and the permittee can identify the cause(s) of the emergency. The permitted installation must show that it was operated properly at the time and that during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or requirements in the permit. The notice must contain a description of the emergency, the steps taken to mitigate emissions, and the corrective actions taken.



ii) Any deviation that poses an imminent and substantial danger to public health, safety or the environment shall be reported as soon as practicable.

iii) Any other deviations identified in the permit as requiring more frequent reporting than the permittee's semiannual report shall be reported on the schedule specified in this permit, and no later than ten days after any exceedance of any applicable rule, regulation, or other restriction.

e) Every report submitted shall be certified by the responsible official, except that, if a report of a deviation must be submitted within ten days after the deviation, the report may be submitted without a certification if the report is resubmitted with an appropriate certification within ten days after that, together with any corrected or supplemental information required concerning the deviation.

f) The permittee may request confidential treatment of information submitted in any report of deviation.

10 CSR 10-6.065(6)(C)l.D Risk Management Plan Under Section 112(r) If the installation is required to develop and register a risk management plan pursuant to Section 112(R) of the Act, the permittee will verify that it has complied with the requirement to register the plan.

10 CSR 10-6.065(6)(C)l.F Severability Clause In the event of a successful challenge to any part of this permit, all uncontested permit conditions shall continue to be in force. All terms and conditions of this permit remain in effect pending any administrative or judicial challenge to any portion of the permit. If any provision of this permit is invalidated, the permittee shall comply with all other provisions of the permit.

10 CSR 10-6.065(6)(C)l.G General Requirements 1) The permittee must comply with all of the terms and conditions of this permit. Any noncompliance

with a permit condition constitutes a violation and is grounds for enforcement action, permit termination, permit revocation and re-issuance, permit modification or denial of a permit renewal application.

2) The permittee may not use as a defense in an enforcement action that it would have been necessary for the permittee to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit

3) The permit may be modified, revoked, reopened, reissued or terminated for cause. Except as provided for minor permit modifications, the filing of an application or request for a permit modification, revocation and reissuance, or termination, or the filing of a notification of planned changes or anticipated noncompliance, does not stay any permit condition.

4) This permit does not convey any property rights of any sort, nor grant any exclusive privilege. 5) The permittee shall furnish to the Air Pollution Control Program, upon receipt of a written request

and within a reasonable time, any information that the Air Pollution Control Program reasonably may require to determine whether cause exists for modifying, reopening, reissuing or revoking the permit or to determine compliance with the permit. Upon request, the permittee also shall furnish to the Air Pollution Control Program copies of records required to be kept by the permittee. The permittee may make a claim of confidentiality for any information or records submitted pursuant to 10 CSR 10-6.065(6)(C) 1.



10 CSR 10-6.065(6)(C)l.H Incentive Programs Not Requiring Permit Revisions No permit revision will be required for any installation changes made under any approved economic incentive, marketable permit, emissions trading, or other similar programs or processes provided for in this permit.

10 CSR 10-6.065(6)(C)l.I Reasonably Anticipated Operating Scenarios None.

10 CSR 10-6.065(6)(C)3 Compliance Requirements 1) Any document (including reports) required to be submitted under this permit shall contain a

certification signed by the responsible official. 2) Upon presentation of credentials and other documents as may be required by law, the permittee shall

allow authorized officials of the Missouri Department of Natural Resources, or their authorized agents, to perform the following (subject to the installation's right to seek confidential treatment of information submitted to, or obtained by, the Air Pollution Control Program): a) Enter upon the premises where a permitted installation is located or an emissions-related activity

is conducted, or where records must be kept under the conditions of this permit; b) Have access to and copy, at reasonable times, any records that must be kept under the conditions

of this permit; c) 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 this permit; and

d) As authorized by the Missouri Air Conservation Law, Chapter 643, RSMo or the Act, sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with the terms of this permit, and all applicable requirements as outlined in this permit.

3) All progress reports required under an applicable schedule of compliance shall be submitted semiannually ( or more frequently if specified in the applicable requirement). These progress reports shall contain the following: a) Dates for achieving the activities, milestones or compliance required in the schedule of

compliance, and dates when these activities, milestones or compliance were achieved, and b) An explanation of why any dates in the schedule of compliance were not or will not be met, and

any preventative or corrective measures adopted. 4) The permittee shall submit an annual certification that it is in compliance with all of the federally

enforceable terms and conditions contained in this permit, including emissions limitations, standards, or work practices. These certifications shall be submitted annually by April 1st, unless the applicable requirement specifies more frequent submission. These certifications shall be submitted to EPA Region VII, 11201 Renner Blvd., Lenexa, KS 66219, as well as the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102. All deviations and Part 64 exceedances and excursions must be included in the compliance certifications. The compliance certification shall include the following: a) The identification of each term or condition of the permit that is the basis of the certification; b) The current compliance status, as shown by monitoring data and other information reasonably

available to the installation; c) Whether compliance was continuous or intermittent; d) The method(s) used for determining the compliance status of the installation, both currently and

over the reporting period; and



e) Such other facts as the Air Pollution Control Program will require in order to determine the compliance status of this installation.

10 CSR 10-6.065(6)(C)6 Permit Shield 1) Compliance with the conditions of this permit shall be deemed compliance with all applicable

requirements as of the date that this permit is issued, provided that: a) The applicable requirements are included and specifically identified in this permit, or b) The permitting authority, in acting on the permit revision or permit application, determines in

writing that other requirements, as specifically identified in the permit, are not applicable to the installation, and this permit expressly includes that determination or a concise summary of it.

2) Be aware that there are exceptions to this permit protection. The permit shield does not affect the following: a) The provisions of section 303 of the Act or section 643.090, RSMo concerning emergency

orders, b) Liability for any violation of an applicable requirement which occurred prior to, or was existing

at, the time of permit issuance, c) The applicable requirements of the acid rain program, d) The authority of the Environmental Protection Agency and the Air Pollution Control Program of

the Missouri Department of Natural Resources to obtain information, or e) Any other permit or extra-permit provisions, terms or conditions expressly excluded from the

permit shield provisions.

10 CSR 10-6.065(6)(C)7 Emergency Provisions 1) An emergency or upset as defined in 10 CSR 10-6.065(6)(C)7.A shall constitute an affirmative

defense to an enforcement action brought for noncompliance with technology-based emissions limitations. To establish an emergency- or upset-based defense, the permittee must demonstrate, through properly signed, contemporaneous operating logs or other relevant evidence, the following: a) That an emergency or upset occurred and that the permittee can identify the source of the

emergency or upset, b) That the installation was being operated properly, c) That the permittee took all reasonable steps to minimize emissions that exceeded technology

based emissions limitations or requirements in this permit, and d) That the permittee submitted notice of the emergency to the Air Pollution Control Program

within two working days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and any corrective actions taken.

2) Be aware that an emergency or upset shall not include noncompliance caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error.

10 CSR 10-6.065(6)(C)8 Operational Flexibility An installation that has been issued a Part 70 operating permit is not required to apply for or obtain a permit revision in order to make any of the changes to the permitted installation described below if the changes are not Title I modifications, the changes do not cause emissions to exceed emissions allowable under the permit, and the changes do not result in the emission of any air contaminant not previously emitted. The permittee shall notify the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as well as EPA Region VII, 11201 Renner Blvd.,



Lenexa, KS 66219, at least seven days in advance of these changes, except as allowed for emergency or upset conditions. Emissions allowable under the permit means a federally enforceable permit term or condition determined at issuance to be required by an applicable requirement that establishes an emissions limit (including a work practice standard) or a federally enforceable emissions cap that the source has assumed to avoid an applicable requirement to which the source would otherwise be subject. 1) Section 502(b )(10) changes. Changes that, under section 502(b )(10) of the Act, contravene an

express permit term may be made without a permit revision, except for changes that would violate applicable requirements of the Act or contravene federally enforceable monitoring (including test methods), record keeping, reporting or compliance requirements of the permit. a) Before making a change under this provision, The permittee shall provide advance written notice

to the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as well as EPA Region VII, 11201 Renner Blvd., Lenexa, KS 66219, describing the changes to be made, the date on which the change will occur, and any changes in emission and any permit terms and conditions that are affected. The permittee shall maintain a copy of the notice with the permit, and the APCP shall place a copy with the permit in the public file. Written notice shall be provided to the EPA and the APCP as above at least seven days before the change is to be made. If less than seven days notice is provided because of a need to respond more quickly to these unanticipated conditions, the permittee shall provide notice to the EPA and the APCP as soon as possible after learning of the need to make the change.

b) The permit shield shall not apply to these changes.

10 CSR 10-6.065(6)(C)9 Off-Permit Changes 1) Except as noted below, the permittee may make any change in its permitted operations, activities or

emissions that is not addressed in, constrained by or prohibited by this permit without obtaining a permit revision. Insignificant activities listed in the permit, but not otherwise addressed in or prohibited by this permit, shall not be considered to be constrained by this permit for purposes of the off-permit provisions of this section. Off-permit changes shall be subject to the following requirements and restrictions: a) The change must meet all applicable requirements of the Act and may not violate any existing

permit term or condition; the permittee may not change a permitted installation without a permit revision if this change is subject to any requirements under Title IV of the Act or is a Title I modification;

b) The permittee must provide contemporaneous written notice of the change to the Air Pollution Control Program, Compliance and Enforcement Section, P.O. Box 176, Jefferson City, MO 65102, as well as EPA Region VII, 11201 Renner Blvd., Lenexa, KS 66219. This notice shall not be required for changes that are insignificant activities under 10 CSR 10-6.065(6)(8)3 of this rule. This written notice shall describe each change, including the date, any change in emissions, pollutants emitted and any applicable requirement that would apply as a result of the change.

c) The permittee shall keep a record describing all changes made at the installation that result in emissions of a regulated air pollutant subject to an applicable requirement and the emissions resulting from these changes; and

d) The permit shield shall not apply to these changes.

10 CSR 10-6.020(2)(R)34 Responsible Official The application utilized in the preparation of this permit was signed by Michael Niemann, Senior Director of Engineering. On July 8, 2014, the Air Pollution Control Program was informed that Charles W. Pierson, EHS Manager is now the responsible official. If this person terminates employment, or is



reassigned different duties such that a different person becomes the responsible person to represent and bind the installation in environmental permitting affairs, the owner or operator of this air contaminant source shall notify the Director of the Air Pollution Control Program of the change. Said notification shall be in writing and shall be submitted within 30 days of the change. The notification shall include the name and title of the new person assigned by the source owner or operator to represent and bind the installation in environmental permitting affairs. All representations, agreement to terms and conditions and covenants made by the former responsible person that were used in the establishment of limiting permit conditions on this permit will continue to be binding on the installation until such time that a revision to this permit is obtained that would change said representations, agreements and covenants.

10 CSR 10-6.065(6)(E)6 Reopening-Permit for Cause This permit may be reopened for cause if: 1) The Missouri Department of Natural Resources (MDNR) receives notice from the Environmental

Protection Agency (EPA) that a petition for disapproval of a permit pursuant to 40 CFR § 70.8( d) has been granted, provided that the reopening may be stayed pending judicial review of that determination,

2) MDNR or EPA determines that the permit contains a material mistake or that inaccurate statements were made which resulted in establishing the emissions limitation standards or other terms of the permit,

3) Additional applicable requirements under the Act become applicable to the installation; however, reopening on this ground is not required if-: a) The permit has a remaining term of less than three years; b) The effective date of the requirement is later than the date on which the permit is due to expire;

or c) The additional applicable requirements are implemented in a general permit that is applicable to

the installation and the installation receives authorization for coverage under that general permit, 4) The installation is an affected source under the acid rain program and additional requirements

(including excess emissions requirements), become applicable to that source, provided that, upon approval by EPA, excess emissions offset plans shall be deemed to be incorporated into the permit; or

5) MDNR or EPA determines that the permit must be reopened and revised to assure compliance with applicable requirements.

10 CSR 10-6.065(6)(E)l.C Statement of Basis This permit is accompanied by a statement setting forth the legal and factual basis for the permit conditions (including references to applicable statutory or regulatory provisions). This Statement of Basis, while referenced by the permit, is not an actual part of the permit.

VI. Attachments

Attachments follow.



Attachment A - Specialty Coating VOC Limitations

Specialty Coating Pounds per Gallon Grams per Liter

Ablative Coating 5.0 600 Adhesion Promoter 7.4 890 Adhesive Bonding Primers:

Cured at 250°F or below 7.1 850 Cured above 250°F 8.6 1030

Adhesives: Commercial Interior Adhesive 6.3 760 Cyanoacrylate Adhesive 8.5 1020 Fuel Tank Adhesive 5.2 620 Nonstructural Adhesive 3.0 360 Rocket Motor Bonding Adhesive 7.4 890 Rubber-Based Adhesive 7.1 850 Structural Autoclavable Adhesive 0.5 60 Structural Nonautoclavable Adhesive 7.1 850

Antichafe Coating 5.5 660 Bearing Coating 5.2 620 Caulking and Smoothing Compounds 7.1 850 Chemical Agent-Resistant Coating 4.6 550 Clear Coating 6.0 720 Commercial Exterior Aerodynamic 5.4 650 Structure Primer Compatible Substrate Primer 6.5 780 Corrosion Prevention Compound 5.9 710 Cryogenic Flexible Primer 5.4 645 Cryoprotective Coating 5.0 600 Dry Lubricative Material 7.3 880 Electric or Radiation-Effect Coating 6.7 800 Electrostatic Discharge and 6.7 800 Electromagnetic Interference (EMI) Coating Elevated Temperature Skydrol Resistant 6.2 740 Commercial Primer Epoxy Polyamide Topcoat 5.5 660 Fire-Resistant (interior) Coating 6.7 800

64 Project No. 2012-10-007

Specialty Coating

Flexible Primer Flight Test Coatings:

Missile or Single Use Aircraft All Others

Fuel-Tank Coating High-Temperature Coating Insulation Covering Intermediate Release Coatine: Lacquer Maskant:

Bonding Maskant Critical Use and Line Sealer Maskant Seal Coat Maskant

Metallized Epoxy Coating Mold Release Optical Anti-Reflective Coating Part Marking Coating Pretreatment Coating Rain Erosion-Resistant Coating Rocket Motor Nozzle Coating Scale Inhibitor Screen Print Ink Sealants:

Extrudable/Rollable/Brushable Sealant Sprayable Sealant

Silicone Insulation Material Solid Film Lubricant Specialized Function Coating Temporary Protective Coating Thermal Control Coating Wet Fastener Installation Coating Wing Coating

Pounds per Gallon Grams per Liter

5.3 640

3.5 420 7.0 840 6.0 720 7.1 850 6.2 740 6.3 750 6.9 830

10.3 1230 8.5 1020 10.3 1230 6.2 740 6.5 780 6.3 750 7.1 850 6.5 780 7.1 850 5.5 660 7.3 880 7.0 840

2.3 280 5.0 600 7.1 850 7.3 880 7.4 890 2.7 320 6.7 800 5.6 675 7.1 850



Attachment B - Opacity Emission Observations

. · Visible Emissions ·.·.·

Emissfon • Dite Time

Source No Yes1 Cause . .·

1Ifthere are v1s1ble em1ss10ns, the perm1ttee shall complete the excess em1ss10ns columns.

65 Project No. 2012-10-007

. Excess Emissions •

Corrective Action Initial



Attachment C - Method 9 Opacity Emissions Observations

Method 9 Opacity Emissions Observations

Company Observer

Location Observer Certification Date

Date Emission Unit

Time Control Device

Hour Minute Seconds .. Steam Plume ( check if applicable)

0 15 30 45 Attached Detached 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

SUMMARY OF AVERAGE OPACITY

Set Number Time

Start End Sum

Readings ranged from ______ to ______ % opacity.

66 Project No.2012-10-007

,••

Comments

Opacity Average.

Was the emission unit in compliance at the time of evaluation? ___________ _ YES NO Signature of Observer



Attachment D - Solvent Containing Waste Transfer Log

10 CSR 10-5.300 Compliance Demonstration

Amount ofTotal Amount of Solvent Amount of Solvent Transferred to a Transferred to a

Date Solvent Transferred Contract .Reclamation Disposal Facility

(gallons) Service (2:allons) fo:allons)

67 Project No. 2012-10-007

Amount of Solvent Distilled on the Premises

fo:allons)



Attachment E - Inspection/Maintenance/Repair/Malfunction Log


Date Equipment/Emission Unit Activities Performed ,• .·

68 Project No. 2012-10-007

. ·· ....



Attachment F - Purchase Records for Cold Cleaning Solvent


Date Solven,t Supplier Solve.nt Supplier

Type of Solvent Name Address

69 Project No.2012-10-007

Solvent Volatility in mmHe at 20°C (68°F)



Attachment G - Employee Solvent Metal Cleaning Training Log


Date Title of Solvent Metal Cleaning Training Cqt1rs~. · .. .·. •··

70 Project No. 2012-10-007

Instructor



Attachment H - Inspection/Maintenance/Repair/Malfunction Log

Emission Unit # ------------------

Inspection/ Malfunction Activities Date/Time

Maintenance Activities Malfunction Impact Duration Cause

71 Project No. 2012-10-007

Action Initials


Part 70 Operating Permit SB - 1 Project No. 2012-10-007

STATEMENT OF BASIS

INSTALLATION DESCRIPTION GKN Aerospace North America, Inc. (GKN) manufactures various aerospace components. The components are sold to aircraft and space vehicle manufacturers for integration into final aerospace and defense products. These products include military and commercial aircraft, helicopters, missiles, space launch vehicles and other space systems and sensing systems. Examples of permitted equipment include paint spray booths, halogenated solvent degreasers, boilers, and plating lines. GKN is a major source of trichloroethylene, a hazardous air pollutant (HAP).

The installation's equipment includes two vapor degreasers using trichloroethylene, paint booths, electric ovens, plating lines and two 120.3 MMBtu/hr boilers fired on natural gas. The paint booth emissions are controlled by dry filters.

Updated Potential to Emit for the Installation and R rt d A. P II E .. epo e Ir o utant m1ss1ons, tons 1er year

Pollutants Potential Reported Actual Emissions

• to Emit1 2017, · .. ·. 2016 2015 2014 .••· 2013

Particulate Matter 30.52 12.98 12.91 13.11 12.84 13.60

< Ten Microns (PM10) Particulate Matter

27.92 11.01 10.94 11.14 10.87 11.63 < 2.5 Microns (PM2s)

Sulfur Oxides (SOx) 2.14 0.07 0.07 0.07 0.14 0.19

Nitrogen Oxides (NOx) 50.56 5.36 5.70 5.90 6.22 7.74

Volatile Organic 118.40 45.64 51.97 49.65 52.94 54.71

Compounds (VOC)

Carbon Monoxide (CO) 119.42 9.45 9.67 10.13 8.29 15.52

Hazardous Air Pollutants 80.12 0.45 0.45 2.01 1.19 3.75

(HAP's)

Ammonia (NH3) 4.36 0.36 0.38 0.31 0.59 0.36

1Each emission unit was evaluated at 8,760 hours of uncontrolled annual operation unless otherwise noted.

• Emissions from the emergency generators were evaluated at 500 hours of operation per year.

Permit Reference Documents These documents were relied upon in the preparation of the operating permit. Because they are not incorporated by reference, they are not an official part of the operating permit.

1) Part 70 Operating Permit Renewal Application, received October 1, 2012; 2) Part 70 Operating Permit Significant Modification Application, received September 15, 2015; 3) 2017 Emissions Inventory Questionnaire, received April 10, 2018;

.

...


Part 70 Operating Permit SB -2 Project No. 2012-10-007

4) U.S. EPA document AP-42, Compilation of Air Pollutant Emission Factors; Volume I, Stationary Point and Area Sources, Fifth Edition;

5) webFIRE; 6) All documents listed in Construction Permit History; and 7) Operating Permit OP2008-023.

Applicable Requirements Included in the Operating Permit but Not in the Application or Previous Operating Permits In the operating permit application, the installation indicated they were not subject to the following regulation(s). However, in the review of the application, the agency has determined that the installation is subject to the following regulation(s) for the reasons stated.

None

Other Air Regulations Determined Not to Apply to the Operating Permit The Air Pollution Control Program (APCP) has determined the following requirements to not be applicable to this installation at this time for the reasons stated.

1) 10 CSR 10-6.405, Restriction of Particulate Matter Emissions from Fuel Burning Equipment Used for Indirect Heating. This regulation does not apply to the installation. 10 CSR 10-6.405(1 )(E) exempts installations which exclusively com bust natural gas. And also Per 10 CSR 10-6.405( 1 )( C), the boilers are exempt from this rule because they are subject to the provisions of 10 CSR 10-6.070.

2) 10 CSR 10-5.220, Control of Petroleum Liquid Storage, Loading and Transfer; 10 CSR 10-5.443, Control of Gasoline Reid Vapor Pressure; 10 CSR 10-5.500, Control of Emissions from Emissions from Volatile Organic Liquid Storage. These rules do not apply to the diesel/no. 2 fuel oil tanks or refueling operations because tank sizes are less than 40,000 gallons and gasoline is not stored or dispensed at this installation.

3) 10 CSR 10-5.300, Control of Emission From Solvent Metal Cleaning. This rule does not apply to the halogenated degreasers due to the exemption under 10 CSR 10-5.300(1 )(D) l .C.

4) 10 CSR 10-5.330, Control of Emissions from Industrial Surface Coating. This rule has not been included in the operating permit because it is Air Pollution Control Program policy not to enforce the requirements of this rule that overlap with the requirements of 10 CSR 10-5 .295, Control of Emissions from Aerospace Manufacture and Rework Facilities. GKN is subject to 10 CSR 10-5.295.

5) 10 CSR 10-5.455, Control of Emissions from Solvent Cleanup Operations. This rule has not been included in the operating permit because the installation is subject to the Aerospace NESHAP and is therefore exempt from the rule.

6) 10 CSR 10-5.510, Control of Emissions of Nitrogen Oxides; 10 CSR 10-6.270, Acid Rain Source Permits Required. These rules have not been included in the operating permit because the potential to emit NOx from



the two boilers does not exceed 100 tons and otherwise do not meet the applicability requirements of the rules.

7) 10 CSR 10-5.520, Control of Volatile Organic Compound Emissions from Existing Major Sources. This rule has not been included in the operating permit because the installation is subject to one or more rules under Title 10, Chapter 5 of the Code of State Regulations ( CSR) that applies to volatile organic compound (VOC) emissions from a product process or a raw material, intermediate or product tank.

8) 10 CSR 10-5.540, Control of Emissions from Batch Process Operations. This rule has not been included in the operating permit because the installation does not operate any batch operations which meets the requirement of a potential to emit 100 tons per year of V OCs nor do they have any operations within the SIC codes listed in the rule.

9) 10 CSR 10-5.570, Control of Sulfur Emissions from Stationary Boilers. This regulation does not apply to the installation. This regulation applies to boilers and process heaters with a capacity of 50 MMBtu/hr or greater. The boilers are rated at 120.3 MMBtu/hr each; however, the boilers exclusively burn natural gas and are exempt from the requirements of the rule per 10 CSR 10-5.570(1 )(C)5.

Construction Permit History The following STLCO APCP construction permits were issued to this installation: 1) Permit #6259 (Operating Permit #6693): This permit was issued February 5, 1997 for the

installation of paint and adhesive booth with Air Tech 3 stage filter. The special condition language was modified to clarify the requirements of the permit. In addition, the period for maintaining records was extended to 5 years to coincide with 10 CSR 10-6.065, Operating Permits, requirements.

2) Permit #6258 (Operating Permit #6694): This permit was issued February 5, 1997 for the installation of Baron-Blackeslee vapor degreaser. Special conditions of this permit superseded by Project #2014-08-008, Permit# 7871.

3) Permit #6690: This permit was issued December 22, 1997 for the construction ofTCE vapor degreaser (VD-027-01). This permit does not contain any special conditions.

4) Permit #6691: This permit was issued September 12, 1997 for the installation of a dehydrate waste dascool 2003A, emulsified cutting oil. This permit does not contain any special conditions.

5) Permit #6692: This permit was issued June 20, 1988 for the construction metal strip and preparation line, acid/alkaline with mist eliminator. This permit does not contain any special conditions.

6) Permit 6700: This permit was issued November 30, 1979 for the operation of aluminum plating line with scrubber and mist eliminator. Special conditions of this permit superseded by project #2013-11-032, Permit #7824 and #7825.


Part 70 Operating Permit SB -4 Project No. 2012-10-007

7) Permit #6701: This permit was issued January 8, 2001 for the operation ofliquid spray penetrant booth with dry filters. This permit does not contain any special conditions.

8) Permit #6702: This permit was issued January 8, 2001 for the operation of dye penetrant process booth, electro-static with dry filters. This permit does not contain any special conditions.

9) Permit #6706: This permit was issued January 8, 2001 for the operation of titanium line with mist eliminator. This permit does not contain any special conditions.

10) Permit #6711: This permit was issued January 8, 2001 for the operation of detail paint booth 4 with dry filter. This permit does not contain any special conditions.





15) Permit #6716: This permit was issued January 8, 2001 for the operation of grit blast system 12' with cyclone and bag filter. This permit does not contain any special conditions.

16) Permit #6788: This permit was issued February 15, 2002 for the construction of composite material manufacturing. (MACT), resin injection. This permit does not contain any special conditions.

17) Permit #6825: This permit was issued September 13, 2002 for the construction of spray/drying booth # 1, with 3 stage filtration system. This permit does not contain any special conditions.

18) Permit #6826: This permit was issued September 13, 2002 for the construction of spray/drying booth #2, with 3 stage filtration system. This permit does not contain any special conditions.

19) Permit #6953: This permit was issued September 28, 2005 for the construction of 120.3 MMBtu/hr Nebraska boiler #1 with FGR. This permit contains special conditions. The special conditions are incorporated into this operating permit.

20) Permit #6954: This permit was issued September 28, 2005 for the construction of 120.3 MMBtu/hr Nebraska boiler #2 with FGR. This permit contains special conditions. The special conditions are incorporated into this operating permit.

21) Permit #7255: This permit was issued September 28, 2005 for the operation of parts washer #1, cold cleaner. This permit does not contain any special conditions.



22) Permit #7295: This permit was issued March 12, 2009 for the operation of paint booth CH53K with ATI 3000 triple filtration system. This permit does not contain any special conditions.

23) Permit #7362: This permit was issued June 17, 2010 for the operation of titanium line, acid etching process with mist eliminator. This permit does not contain any special conditions.

24) Permit #7677: This permit was issued October 12, 2011 for the operation of 250 HP diesel emergency generator, Caterpillar, installed 6/1/78. This permit does not contain any special conditions.

25) Permit #7678: This permit was issued October 12, 2011 for the operation of 160 HP diesel emergency generator, Fairbanks Morse, installed 6/1/70. This permit does not contain any special conditions.

26) Permit #7679: This permit was issued October 12, 2011 for the operation of 220 HP natural gas emergency generator, Cummins/Ford, installed 6/1/83. This permit does not contain any special conditions.

27) Permit #7680: This permit was issued October 12, 2011 for the operation of 350 HP natural gas emergency generator, Caterpillar, installed 6/1/81. This permit does not contain any special conditions.

28) Permit #7681: This permit was issued October 12, 2011 for the operation of 220 HP natural gas emergency generator, Minneapolis Moine, installed 6/1/78. This permit does not contain any special conditions.

29) Permit #7706: This permit was issued March 6, 2012 for the operation of 350 HP natural gas emergency generator, Olympian Model G80LG, Mfg: 1/18/12. This permit does not contain any special conditions.

30) Permit #7824 and #7825 (Project #AP2013-l 1-032): These permits were issued January 6, 2014 for the addition of one paint spray booth with integrated 2.0 MMBtu/hr natural gas curing oven, addition of one seal tank to an existing aluminum process line, and addition of one anodize tank to an existing aluminum process line. These permits contain special conditions including condition that supersede all special conditions found in the previously issued construction permit #6700, issued by the St. Louis County Department of Health Air Pollution Control Program.

Special Condition 3 .B of Permit #7824 which states "The operating pressure drop shall be maintained within the design conditions specified by the manufacturer's performance warranty" has been revised in this permit to include the numerical values for the pressure drop. And also included corrective actions to be taken when the pressure drop is outside of the performance warranty.

31) Permit #7871 (Project #AP2014-085-008): This permit was issued September 9, 2014 for the construction of one open top batch vapor solvent cleaning machine. The conditions of this permit supersede all special conditions found in the previously issued St. Louis County construction



permit #6258 (operating permit #6694), issued by the St. Louis County Department of Health Air Pollution Control Program.

32) Permit #7960: This permit was issued March 215, 2016 for the construction of one stationary natural gas emergency use engine (Ford Engine Model: MTU 10V0068 GSlO0, 135 HP, lO0kW). There are no special conditions associated with this permit.

33) Permit #7962: This permit was issued March 23, 2016 for the operation of cold cleaner parts washer (26x36x8, 15 gallon capacity). There are no special conditions associated with this permit.

New Source Performance Standards (NSPS) Applicability The installation is potentially subject to several NSPS rules. Below is a summary of the potentially applicable subparts and the facilities applicability and compliance status to those subparts. 1) 40 CFR Part 60 - Subpart A, General Provisions.

The installation becomes subject to Subpart A - General Provisions upon becoming subject to an NSPS standard. If the installation is subject to various NSPS Standards; therefore, they are also subject to Subpart A.

2) 40 CFR Part 60, Subpart D, Standards of Performance for Fossil-Fuel-Fired Steam Generators for Which Construction is Commenced After August 17, 1971. The provisions of this subpart apply to each fossil-fuel-fired steam generating unit of more than 73 megawatts heat input rate (250 million Btu per hour) constructed, modified, or reconstructed after August 17, 1971 and not covered under Subpart Da.

None of the boilers are rated at greater than 73 megawatts heat input rate (250 million Btu per hour). Therefore, this subpart does not apply to GKN.

3) 40 CFR Part 60, Subpart Da, Standards of Performance for Electric Utility Steam Generating Units for Which Construction is commenced After September 18, 19 7 8. The provisions of this subpart apply to each electric utility fossil-fuel-(either alone or in combination with any other fuel) fired steam generating unit of more than 73 megawatts heat input rate (250 million Btu per hour) constructed, modified, or reconstructed after September 18, 1978.

None of the boilers are electric utility steam generating units as defined in this subpart nor are rated at greater than 73 megawatts heat input rate (250 million Btu per hour). Therefore, this subpart does not apply to GKN.

4) 40 CFR Part 60 Subpart Db, Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units This subpart applies to each steam generating unit that commences construction, modification, or reconstruction after June 19, 1984, and that has a heat input capacity from fuels combusted in the steam generating unit of greater than 29 megawatts (MW) (100 million British thermal units per hour (MMBtu/hr)).

This subpart applies because the boilers (BL-001-01 and BL-001-01-02) are steam generating units constructed, modified, or reconstructed after June 19, 1984 and each has heat input capacity from fuels combusted of greater than 29 MW (100 MMBtu/hr).



5) 40 CFR Part 60, Subpart K - Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification commenced After June 11, 1973. 40 CFR Part 60, Subpart Ka, Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification commenced After May 18, 1978, and Prior to July 23, 1984. 40 CFR Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after July 23, 1984.

These subparts do not do not apply to any of the storage tanks covered under this permit because the storage capacity of each tank is below each of the applicability thresholds of the subparts and because the tanks only store diesel/no. 2 fuel oil.

6) 40 CFR Part 60 Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. This subpart is applicable to owners and operators of stationary compression ignition (CI) internal combustion engines (ICE) and other persons who construct, reconstruct, or modify an engine after July 11, 2005.

The diesel generators do not meet the construction and manufacture date identified in this subpart. These generators have also not been modified or reconstructed since they were installed. Thus, they are not subject to 40 CFR Part 60, Subpart IIII.

7) 40 CFR Part 60, Subpart JJJJ, Standards of Performance for Spark Ignition Internal Combustion Engines. The natural gas fired spark ignition internal combustion engines ( emergency generators identified as GEM02 and GEM00 1-02) at this installation do meet the construction and manufacture date identified in this subpart. Thus, they are subject to 40 CFR Part 60, Subpart JJJJ.

8) NSPS Applicability Summary Based upon a comparison of the installations operations to each NSPS Standard, the installation is subject to the following NSPS Standards: • 40 CFR Part 60 - Subpart Db, Standards of Performance for Industrial-Commercial-Institutional

Steam Generating Units; and • 40 CFR Part 60 - Subpart JJJJ. Standards of Performance for Spark Ignition Internal

Combustion Engines.

Maximum Achievable Control Technology (MACT) Applicability 10 CSR 10-6.075, Maximum Achievable Control Technology Regulations National Emission Standards for Hazardous Air Pollutants (NESHAPS) promulgated after the 1990 Clean Air Act Amendments are found in 40 CFR Part 63. The 1990 Clean Air Act Amendments, significantly expanded EP A's authority to regulate hazardous air pollutants. These standards require application of technology based emissions standards referred to as Maximum Achievable Control Technology (MACT). Consequently, these post-1990 NESHAPs are also referred to as MACT standards. MACT is a technology-based standard, as opposed to the original conception ofNESHAPs as a risk-based standard.



Section 112 of the Clean Air Act lists 187 hazardous air pollutants to be regulated by source category. EPA has identified "source categories" that must meet technology requirements to control HAP emissions and is required to develop standards for all industries that emit one or more of the HAPs in significant quantities. The standards are based on emissions levels already achieved by best- performing similar facilities.

Industries subject to MACT standards are classified as either major sources or area sources. • Major sources are sources that emit 10 tons per year of any of the listed HAPs, or 25 tons per

year of a mixture of HAPs. • Area sources are sources that emit less than 10 tons per year of a single HAP or less than 25 tons

per year of a combination of HAPs. Area sources must employ Generally Available Control Technology (GACT) which is based on appropriate practices/ techniques commercially available and taking into account economic and technical considerations.

MACT standards are applicable to major sources, while GACT standards are applicable to area sources.

The installation has the potential to emit various HAPs. The total HAPs that are potentially emitted are greater than the 10/25 tons per year, thus the installation is a major source of HAPs.

Based upon a comparison of the installation operations to each area source MACT Standard, the installation is potentially subject to the following MACT standards: (NOTE: This is not an analysis of every MACT standard, it is an analysis of the MACT standards that are potentially applicable to the installation).

1) 40 CFR Part 63, Subpart N, National Emission Standards for Chromium Emissions From Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks. The provisions of this subpart apply to each chromium electroplating or chromium anodizing tank at facilities performing hard chromium electroplating, decorative chromium electroplating, or chromium anodizing.

This subpart does not apply to GKN since the chrome anodizing tank is no longer in use and the permits have been terminated.

2) 40 CFR Part 63, Subpart T, National Emission Standards for Halogenated Solvent Cleanin. This rule applies to each individual batch vapor, in-line vapor, in-line cold, and batch cold solvent cleaning machine that uses any solvent containing methylene chloride, perchloroethylene, trichloroethylene, 1, 1, I-trichloroethane, carbon tetrachloride or chloroform, or any combination of these halogenated HAP solvents, in a total concentration greater than 5 percent by weight, as a cleaning and/or drying agent. Wipe cleaning activities, such as using a rag containing halogenated solvent or a spray cleaner containing halogenated solvent, are not covered under this rule.

a) VD-001-01 and VD-002-01 Vapor Degreasers:- GKN operates batch vapor degreasers (VD-001-01 and VD-002-0) to clean metal parts. The solvent used in the cleaning machines is trichloroethylene (CAS No. 79-01-6). Subsequently, the provisions for batch vapor cleaning machines of Subpart T apply to the vapor degreasers.

b) CC-STL-01 Cold Solvent Cleaning Stations the solvent used in these metal cleaners is stoddard, a petroleum solvent. These units do not use halogenated solvents as defined in 40 CFR 63.460;



therefore the parts washers are not subject to the MACT standards for halogenated solvent cleaning.

3) 40 CFR Part 63, Subpart GG, National Emission Standards for Aerospace Manufacturing and Rework Facilities. This subpart applies to facilities that are engaged, either in part or in whole, in the manufacture or rework of commercial, civil, or military aerospace vehicles or components and that are major sources as defined in §63 .2.

The provisions of this subpart apply to the installation as indicated in the permit. The Mechanical and Chemical Depainting Requirement do not apply to GKN because six or less completed aerospace vehicles are depainted in a calendar year.

4) 40 CFR 63 Subpart DD, Hazardous Air Pollutants from Off-Site Waste and Recovery Operations. The provisions of this subpart apply to the owner and operator of a plant site for which the plant site major source of hazardous air pollutant (HAP) emissions as defined in 40 CFR 63.2 where one or more of operations that receives off-site materials are located and managed at the plant site in a waste management operation or recovery operation.

This subpart does not apply to the handling or storage of hazardous waste since the installation does not receive off-site waste.

5) 40 CFR Part 63, Subpart MMMM, National Emission Standards for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and Products. This subpart applies to a facility that owns or operates a miscellaneous metal parts and products surface coating operation that is a major source, or is located at a major source, or is part of a major source of HAP emissions.)

This subpart does not apply to this facility as stated in the January 20, 2004 letter where GKN withdrew their Part 1 application for this MACT standard. The MACT does not apply because the coating operations at the facility are either exempt according to the rule and/or the coating operations are already addressed by the Aerospace NESHAP.

6) 40 CFR Part 63, Subpart WWWW, Reinforced Plastic Composites Production does not apply to this facility as stated in the August 18, 2003 letter where GKN withdrew their Part 1 application for this MACT standard. The facility does not process enough styrene-containing materials to meet the applicability levels of this MACT.

7) 40 CFR Part 63, Subpart DDDDD, Boilers/Process Heaters did apply to this facility due to BL-001-01 and BL-001-01-02, the external combustion boilers that have a maximum rated capacity that exceeds the applicability threshold of the subpart (> 10 MMBtu/hr).

8) 40 CFR Part 63 Subpart JJJJJJ, National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources This regulation does not apply the boilers and process heaters at this facility because GKN is a major source of hazardous air pollutants (HAPS).



9) 40 CFR Part 63 Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines This regulation applies to the following Emergency equipment and is included in the operation permit under Permit Condition (FP809813, GEM020-01 and GEM027-01) - 001:

' ' . Rated' Equipment Description HP Fu~l Type Ignition Type Installation Date

Fire Pump Engine (FP809813) < 500 Diesel CI

Emergency Generator (GEM020-0l) 250 Diesel Cl

Emergency Generator (GEM027-0l) 220 Natural Gas SI

National Emission Standards for Hazardous Air Pollutants (NESHAP) Applicability 10 CSR 10-6.080, Emission Standards for Hazardous Air Pollutants

1970

1978

1978

National Emission Standards for Hazardous Air Pollutants (NESHAPS) are stationary source standards for hazardous air pollutants. NESHAPS were originally required by the 1970 Clean Air Act (CAA). These standards were developed for sources and source categories that were determined to pose adverse risk to human health by the emission of HAPs. The Part 61 NESHAPs regulate only 7 hazardous air pollutants - Asbestos, Beryllium, Mercury, Vinyl Chloride, Benzene, Arsenic, Radon/Radionuclides. Prior to 1990, the Clean Air Act required EPA to set standards for each toxic air pollutant individually, based on its particular health risks. Thus, NESHAPs are risk based standards that apply to all existing and new/ modified sources regardless if they are a minor or major HAP Facility. (NOTE: This is not an analysis of every NESHAP standard; it is an analysis of the NESHAP standard that is potentially applicable to the installation).

1) 40 CFR Part 61 Subpart M-National Emission Standard/or Asbestos. The installation is not subject to any NESHAP standard with the exception of Subpart M - National Emission Standard for Asbestos. The installation is potentially subject to Subpart M. If the installation conducts any demolition or renovation projects to a building(s) containing asbestos, they must determine applicability with the following NESHAP regulations: • Demolition and Renovation - 40 CFR 61.145 • Waste Disposal for Manufacturing, Fabricating, Demolition, Renovation, and Spraying - 40 CFR

61.150

Compliance Assurance Monitoring (CAM) Applicability 40 CFR Part 64, Compliance Assurance Monitoring (CAM) The CAM rule applies to each pollutant specific emission unit that: • Is subject to an emission limitation or standard, and • Uses a control device to achieve compliance, and • Has pre-control emissions that exceed or are equivalent to the major source threshold. 40 CFR Part 64 is not applicable because none of the pollutant-specific emission units uses a control device to achieve compliance with a relevant standard.

Greenhouse Gas Emissions Note that this source is subject to the Greenhouse Gas Reporting Rule. However, the preamble of the GHG Reporting Rule clarifies that Part 98 requirements do not have to be incorporated in Part 70 permits operating permits at this time. In addition, Missouri regulations do not require the installation to



report CO2 emissions in their Missouri Emissions Inventory Questionnaire; therefore, the installation's CO2 emissions were not included within this permit. The applicant is required to report the data directly to EPA. The public may obtain CO2 emissions data for this installation by visiting http://epa.gov/ ghgreporting/ ghgdata/reportingdatasets.html.

Other Regulatory Determinations 1) 10 CSR 10-6.260, Restriction of Emissions of Sulfur Compounds and

10 CSR 10-6.261, Control of Sulfur Dioxide Emissions. 10 CSR 10-6.260 was rescinded on November 30, 2015 and replaced by 10 CSR 10-6.261; however, the provisions of 10 CSR 10-6.260 currently remain in the State Implementation Plan and thus are federally enforceable and applicable to the installation. The provisions of 10 CSR 10-6.260 will expire and the provisions of 10 CSR 10-6.261 will become federally enforceable once 10 CSR 10-6.261 is incorporated into the federally-approved SIP as a final EPA action a) 10 CSR 10-6.260(3)(A)2. and 10 CSR 10-6.261(3)(C) apply to all the "new" emergency

generators at the GKN that use fuel oil. There are no "existing" emergency generators at GKN. (Existing sources in the St. Louis metropolitan area as defined in 10 CSR 10,-6.020: any equipment, machine, device, article, contrivance, or installation that is existing, installed, or under construction on March 24, 1967.)

GKN is in compliance with the SO2 emissions limit of 500 ppmv averaged on any consecutive 3-hour period and SO3 /H2SO4 limit of 35 mg/m3 averaged on any consecutive 3-hour period for fuel oil of 10 CSR 10-6.260(3)(A)2 and also with the 8,812 ppm sulfur limit of 10 CSR 10-6.261(3)(C). GKN has and will continue to purchase low sulfur fuel oil (i.e., :S 15 ppmv sulfur content) to meet the limit of this rule.

b) According to 10 CSR 10-6.260(1)(A)(2) and 10 CSR 10-6.261(1)(A), natural gas and liquefied petroleum gas (propane) fired sources are exempt from the requirements of these rules.

2) 10 CSR 10-6.220, Restriction of Emission of Visible Air Contaminants is applicable to the installation, but has not been applied within this permit for the following emission units. Applicability of this regulation to the installation's visible emissions sources is discussed in the following table:

. ·• ·: \ Emission Unit Description ·.· UlCSR l0~6.i20 Applicability

.. ... :.. . .. · .. .. : ... .. . . . · .... >.:. . :

FP809813,

: .

GEM020-0l, Facility Wide Internal 10 CSR 10-6.220(l)(A) exempts stationary internal GEM02-0l, Combustion Engines (Diesel combustion engines operated in the St. Louis

GEM027-0l and and Natural Gas) metropolitan area. GEM00l-02 BL-001-01, Facility-Wide Boilers and These sources are subject to this regulation.

BL-001-02 and Miscellaneous Combustion However, emission units combusting natural gas are CS-STL-01 Equipment (During Natural assumed to be in compliance with this regulation

Gas Firing) without any monitoring.

.•:

CT-STL-0lA Facility-Wide Cooling Towers The regulation is applicable to the cooling towers, but was not applied within this permit. The cooling towers during normal operation emit little or no visible emissions. The cooling towers can emit large



amounts of water vapor which make it difficult to determine if/how much visible contaminant is being emitted. The Air Pollution Control Program is not requiring any monitoring, record keeping, or reporting for the cooling towers at this time; but, should visible emissions become an issue, these requirements may be added in the future.

3) 10 CSR 10-6.400, Restriction of Emission of Particulate Matter From Industrial Processes 10 CSR 10-6.400 limits the amount of particulate matter that is allowed from an emission unit, and is dependent on the process weight rate material processed. The emission units to which this rule applies are listed below. The following calculations provide the allowable particulate emission rate based on 10 CSR 10-6.400 and the potential (maximum) emission rate including particulate emission control equipment. Potentials to emit presented below were calculated based on sources Maximum Design Rate (MDR). If the emissions from these emission units can not violate the limits of this rule then evidence of this is demonstrated in the following calculations. One of the following equations from 10 CSR 10-6.400 is used to calculate the PM allowable limit:

E = 4.1 0P067 for process weight rates up to 30 tons (60,000 lbs) per hour, and E = 55.0PO.IJ - 40 for process weight rates greater than 30 tons (60,000 lbs) per hour Where: E = rate of emission in lb/hr; and

P = process weight rate in tons/hr (maximum hourly design rate)

a) GB-027-01 - Grit Blast System (12 feet) P = 1,700.00 lb/hr Emission factor= 0.69 lb/1000 lb (AP-42, 13.2.6-1) E = 4.10 x (1,700/2000)°-67 = 3.68 lb/hr PM Emission= 1,700 lb/hr x 0.69 lb/1000 lb = 1.173 lb/hr

At maximum design rates, the potential PM emission rate for the grit blast system based on AP-42 factors [§13.2.6, Table 13.2.6-1.] is less than the allowable PM emission limit. No monitoring, record keeping or reporting is required. Moreover, the grit blaster is exempt from construction permitting (by 10 CSR 10-6.061 (B)6.C., ifless than 100 cubic feet.) and therefore may be exempt from the process weight rate rule per 10 CSR 10-6.400(1 )B.8.

b) CL-001-01 Coating Line (Spray booth 1 through 5) CL-002-01 Coating Line (Clean & Prime booth, Spray booth 1 and 2) According to 10 CSR 10-6.400(1 )(B) 14., the provisions of this rule shall not apply to coating operations equipped with a control system designed to control at least ninety-five percent (95%) of the particulate overspray provided the system is operated and maintained in accordance with manufacturers' specifications or comparable maintenance procedures that meet or exceed manufacturers' specifications. The spray booths are required by 40 CFR Part 63, Subpart GG to be equipped with fabric filters; therefore, the spray booths are exempt from the provisions of this rule.


Part 70 Operating Permit SB - 13 Project No.2012-10-007

Other Regulations Not Cited in the Operating Permit or the Above Statement of Basis Any regulation which is not specifically listed in either the Operating Permit or in the above Statement of Basis does not appear, based on this review, to be an applicable requirement for this installation for one or more of the following reasons: 1. The specific pollutant regulated by that rule is not emitted by the installation; 2. The installation is not in the source category regulated by that rule; 3. The installation is not in the county or specific area that is regulated under the authority of that rule; 4. The installation does not contain the type of emission unit which is regulated by that rule; 5. The rule is only for administrative purposes.

Should a later determination conclude that the installation is subject to one or more of the regulations cited in this Statement of Basis or other regulations which were not cited, the installation shall determine and demonstrate, to the APCP's satisfaction, the installation's compliance with that regulation(s). If the installation is not in compliance with a regulation which was not previously cited, the installation shall submit to the APCP a schedule for achieving compliance for that regulation(s).



Response to Public Comments

RPC-1 Project No. 2012-10-007

The draft P70 Operating Permit, Project 2015-04-056, for GKN Aerospace North America, Inc. (189-1489) was placed on public notice as of April 28, 2017, for a 30-day comment period. The public notice was published on the Department of Natural Resources' Air Pollution Control Program's web page at: http://dm.mo.gov/env/apcp/permit-public-notices.htm. on Friday, April 28, 2017. On May23, 2017, the Air Pollution Control Program received comments from Mark A. Smith, Air Permitting and Compliance Branch Chief for EPA Region VII.

Comment #1: The Monitoring requirements in Permit Condition (BL-001-1 and BL-001-02)-002 requires the permittee to determine compliance with the emission limit (0.2 lbs NOx/MMBtu) on a 30-day rolling average basis. However, the monitoring requirement does not state how ( emphasis added) compliance is determined and there is no requirement for the permittee to maintain compliance records. Based on PA's response in the order granting in part a petition for objection to the operating permit for Yuhuang chemical, Inc.-Methanol Plant in St. James Parish, Louisiana (August 31, 2016), Permit Condition (BL-0011-1 and BL-001-02)-002 may not be enforceable. The concept of federal enforceability has been interpreted to encompass a requirement for practical enforceability and in order for emission limits to be enforceable as a practical matter, the permit must clearly specify how ( emphasis added) emissions will be measured or determined for purposes of demonstrating compliance with the limits. Thus, limitations must be supported by monitoring, record keeping and reporting requirements sufficient to enable regulators and citizens to determine whether the limits have been achieved. Permit Condition (BL-001-1 and BL-001-02)-002 does not justify how NOx is to be measured or determined for purposes of demonstrating compliance and there is no record keeping specified for confirmation of compliance certification. Therefore, in order to ensure that the unit specific emission limits are enforceable as a practical matter, MDNR is encouraged to ensure the final permit clearly states or demonstrates how (emphasis added) GKN Aerospace will calculate actual NOx emissions to demonstrate compliance with the emission limits and provide record keeping that verifies achievement of the limitation. To the extent that the final permit depends on emission factors for calculating emissions to demonstrate compliance, the permit should specify the source of the emission factor(s).

Response to Comment: Changes to the Permit Condition (BL-001-1 and BL-001-02)-002 has been made as a result of this comment. The following has been included to the monitoring section of Permit Condition (BL-001-1 and BL-001-02)-002.

"Steam temperature and flue gas oxygen shall be used in the linear equation for predicting NOx emissions. An electronic database shall be utilized to calculate and maintain predicted NOx emissions. All values shall be recorded in 15-minute intervals. This data shall then be used to calculate daily NOx emissions that are recorded and used to tabulate a 30-day rolling average.

GKN was inspected by EPA in April of 2016. The inspection report states that GKN uses a predictive emission monitoring system (PEMS) to determine NOx emissions. The PEMS test was conducted in March 2007. The 30-day average NOx emissions for both boilers were below the limit. No exceedances were reported. The 02 monitor is calibrated daily and the calibration gases were not out of date.

GKN Aerospace North America, Inc. Installation ID: I 89-1489

Part 70 Operating Permit RPC-2 Project No. 2012-10-007

Comment #2: Permit Condition (CL-001-02)-002 limits the VOC and HAP to less than 1.75 tons in any consecutive twelve (12) month period and requires the permittee to record monthly and rolling twelve (12) month totals. The permit condition also requires the records be complete within ten (10) days of the end of each month. However, Permit Condition (CL-001-02)-002 does not specify how ( emphasis added) VOC and HAP emissions are determined and therefore Permit Condition (CL-001-02)-002 may not be federally enforceable. Therefore, in order to ensure that the unit specific emission limits are enforceable as a practical matter, MDNR is encouraged to ensure the final permit clearly states or demonstrates how ( emphasis added) GKN Aerospace will calculate actual VOC and HAP emissions to demonstrate compliance with the emission limits. To the extent that the final permit depends on emission factors for calculating emissions to demonstrate compliance, the permit should specify the source of the emission factor(s).

Response to Comment: Compliance for (CL-001-01)-002 is determined by tracking total consumption of applied topcoats and primers. The VOC and HAP content is calculated based on the SDS for each topcoat/primer that is applied at this emission point. Total consumption may be used to demonstrate compliance in lieu of tracking individual VOC and HAP. Therefore, the permit condition has been modified as a result of this comment.

Comment #3: it is MDNR's customary practice to provide examples of the data collection records used by the permittee to verify compliance with their permit conditions. These examples are normally included in the operating permit as attachments available for public review and comment. However, this draft operating permit renewal for GKN Aerospace has several permit conditions which require the collection of compliance verification data and examples are not attached. Specific permit conditions without the customary compliance verification attachments include:

• (BF-001-03 and BF-002-03)-001 • (BL-001-1 and BL-001-02)-002 • (CL-001-01 and CL-002-01)-001 • (CL-001-01)-002 • (CL-001-02)-002 and • (VD-001-01 and VD-002-01)-001

EPA recommends MDNR consider adherence to their customary practice and include all compliance verification records as attachments to this operating permit.

Response to Comment: Permit Condition (BF-001-03 and BF-002-03)-001 incorporates the requirements of 40 CFR 63 Subpart GG National Emission Standards for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities. The Monitoring and Recordkeeping sections of the permit condition are incorporated from Subpart GG and are explicit in what is to be monitored and recorded. While the draft permit did not contain an example of the data collection record, it is believed that the permit condition itself contains the necessary detail on what is to be monitored and recorded.

Permit Condition (BL-001-1 and BL-001-02)-002 incorporates the nitrogen oxide requirements of 40 CFR Part 60 Subpart Db Standards of Performance for Industrial-CommercialInstitutional Steam Generating Units. Per an inspection report from an inspection conducted by EPA in April of 2016, GKN conducted a predictive emissions monitoring system (PEMS) test in March 2007. This test provided the information necessary for GKN to predict, on an on-going basis, the emissions of NOx using a linear equation that incorporates steam temperature and flue



gas oxygen values. GKN uses this information to calculate and record in an electronic database the predicted NOx emissions. All values are recorded in 15-minute intervals. This data is then used to calculate daily NOx emissions that are recorded and used to tabulate a 30-day rolling average. The 02 monitor is calibrated daily and the calibration gases were not out of date at the time of the im,pection. GKN submits semi-annual compliance reports as required by the subpart.

Permit Condition (CL-001-01 and CL-002-01)-001 incorporates the requirements of 40 CFR 63 Subpart GG National Emission Standards for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities. The Monitoring and Recordkeeping sections of the permit condition are incorporated from Subpart GG and are explicit in what is to be monitored and recorded. While the draft permit did not contain an example of the data collection record, it is believed that the permit condition itself contains the necessary detail on what is to be monitored and recorded.

Permit Condition (CL-001-01)-002 incorporates the permit conditions of St. Louis county construction permit 7824 for emissions of HAP 's from the spray/drying booth Garmat 090 -Model Year 2013 (SB-027-06). The Monitoring and Recordkeeping sections of the permit condition are incorporated from the construction permit and are explicit in what is to be monitored and recorded. While the draft permit did not contain an example of the data collection record, it is believed that the permit condition itself contains the necessary detail on what is to be monitored and recorded.

Permit Condition (CL-001-01)-002 and (CL-001-02)-002 incorporate the permit conditions of St. Louis county construction permit 6259 for emissions of VOC and HAP 's from the Paint and Adhesive Booth SB-029-01. The Monitoring/Recordkeeping section of the permit condition has been modified to more clearly delineate how to demonstrate compliance with the permit condition.

Permit Condition (VD-001-01 and VD-002-01)-00Jincorporates the requirements of 40 CFR Part 63, Subpart T National Emission Standards for Halogenated Solvent Cleaning. The Monitoring and Recordkeeping sections of the permit condition are incorporated from Subpart T and are explicit in what is to be monitored and recorded. While the draft permit did not contain an example of the data collection record, it is believed that the permit condition itself contains the necessary detail on what is to be monitored and recorded.

Comment #4: Permit Condition (PL-001-02A )-001 incorporates special conditions from St. Louis County Department of Health (SLCDH) Air Pollution Control Program (APCP) Construction Permit #7824, as they apply to the dichromate seal tank and the boric-sulfuric acid anodizing tank. The Operational Limitation / Equipment Specification requires the permittee to control both tanks with packed bed wet scrubbers and to monitor and record the pressure drop across each scrubber at least once every twenty- four (24) hours and maintain the pressure drop within the design condition specified by manufacturer's performance warranty; and to maintain the flow rate through the scrubber within the design conditions specified by the manufacturer's warranty. EPA believes that the actual numerical values of the pressure drop requirements and flow rates are readily available to the permittee; however, the same information is not readily available for regulatory and public inspection and therefore, EPA recommends that numerical values for the pressure drop operating range and flow rate range for each



wet scrubber be inserted into this permit condition. Additionally, this permit condition does not mention what corrective action(s) the permittee is required to take, in the event the scrubber performance is outside the manufacturer's performance warranty. EPA recommends MDNR consider including the corrective action(s) taken when pressure drop and/ or scrubber flow rates are outside the performance warranty.

Response to Comment: This permit condition is modified as recommended.

Comment #5: Permit Condition (BL-001-1 and BL-001-02)-003 incorporates applicable requirements from 40 CFR Part 63, Subpart DDDDD: National Emission Standards for Hazardous Air Pollutants: Industrial, Commercial and Institutional Boilers and Process Heaters as they apply to Boiler 1 and Boiler 2. Initial Compliance Demonstration requirement 1) and Continuous Compliance Demonstration with the Work Practice Standards requirement 3) both refer the permittee to Table 3 "to this subpart." Operating permits do not normally include "subparts" and as an assist to the permittee in maintaining their compliance, EPA believes it might be beneficial to incorporate the applicable portions of Table 3 within Permit Condition (BL-001-1 and BL-001-02)-003.

Response to Comment: The draft permit has already contained applicable portions of Table 3 in the Work Practice Standards section of Permit Condition (BL-001-1 and BL-001-02)-003. Therefore, no change has been made to the draft as a result of this comment.