1
Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
GENERAL PERMIT CONDITIONS
TERMINATION OF PERMIT TO INSTALL
Substantial construction for installation must take place within 18 months of the
effective date of this permit. This deadline may be extended by up to 12 months if
application is made to the Director within a reasonable time before the termination date
and the party shows good cause for any such extension.
NOTICE OF INSPECTION
The Director of the Ohio Environmental Protection Agency, or his authorized
representatives, may enter upon the premises of the above-named applicant during
construction and operation at any reasonable time for the purpose of making
inspections, conducting tests, or to examine records or reports pertaining to the
construction, modification or installation of the source (s) of environmental pollutants
identified within this permit.
CONSTRUCTION OF NEW SOURCES
The proposed source (s) shall be constructed in strict accordance with the plans and
application submitted for this permit to the Director of the Ohio Environmental
Protection Agency. There may be no deviation from the approved plans without the
express, written approval of the Agency. Any deviations from the approved plans or the
above conditions may lead to such sanctions and penalties as provided under Ohio
law. Approval of these plans does not constitute an assurance that the proposed
facilities will operate in compliance with all Ohio laws and regulations. Additional
facilities shall be installed upon orders of the Ohio Environmental Protection Agency if
the proposed sources are inadequate or cannot meet applicable standards.
If the construction of the proposed source (s) has already begun or has been completed
prior to the date the Director of the Environmental Protection Agency approves the
permit application and plans, the approval does not constitute expressed or implied
assurance that the proposed facility has been constructed in accordance with the
approved plans. The action of beginning and/or completing construction prior to
obtaining the Director's approval constitutes a violation of Ohio Administrative Code
(OAC) Rule 3745-31-02. Furthermore, issuance of the Permit to Install does not
constitute an assurance that the proposed source will operate in compliance with all
Ohio laws and regulations. Approval of the plans in any case is not to be construed as
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
an approval of the facility as constructed and/or completed. Moreover, issuance of the
Permit to Install is not to be construed as a waiver of any rights that the Ohio
Environmental Protection Agency (or other persons) may have against the applicant for
starting construction prior to the effective date of the permit. Additional facilities shall
be installed upon orders of the Ohio Environmental Protection Agency if the proposed
facilities cannot meet applicable standards.
PERMIT TO INSTALL FEE
In accordance with Ohio Revised Code 3745.11, the specified Permit to Install fee must
be remitted within 30 days of the effective date of this permit to install.
PUBLIC DISCLOSURE
The facility is hereby notified that this permit, and all agency records concerning the
operation of this permitted source, are subject to public disclosure in accordance with
OAC Rule 3745-49-03.
APPLICABILITY
This Permit to Install is applicable only to the contaminant sources identified. Separate
application must be made to the Director for the installation or modification of any other
contaminant sources.
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
BEST AVAILABLE TECHNOLOGY
As specified in OAC Rule 3745-31-05, all new sources must employ Best Available
Technology (BAT) . Compliance with the terms and conditions of this permit will fulfill
this requirement.
PERMIT TO OPERATE APPLICATION
A Permit to Operate application must be submitted to the appropriate field office for
each air contaminant source in this Permit to Install. In accordance with OAC Rule
3745-35-02, the application shall be filed no later than thirty days after commencement
of operation.
SOURCE OPERATION AFTER COMPLETION OF CONSTRUCTION
This facility is permitted to operate each source described by this permit to install for a
period of up to one year from the date the source commenced operation. This
permission to operate is granted only if the facility complies with all requirements
contained in this permit and all applicable air pollution laws and regulations.
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
AIR EMISSION SUMMARY
The air contaminant emissions units listed below comprise the
Permit to Install for Hydro Tube Corp located in Lorain County.
The emissions units listed below shall not exceed the emission
limits/control requirements contained in the table. This
condition in no way limits the applicability of any other state
or federal regulations. Additionally, this condition does not
limit the applicability of additional special terms and
conditions of this permit.
Ohio
EPA
Source
Number
L001
Source
Identification
Description
Open top
vapor
degreaser
using
trichloroe-thy
lene
BAT
Determination
Compliance with the
terms and
conditions of this
permit and
applicable rules.
Applicable
Federal &
OAC Rules
3745-31-05
3745-21-09 (O)
40 CFR Part 63,
Subpart T.
Permit Allowable
Mass Emissions
and/or
Control/Usage
Requirements
VOC:
(Trichloroe-thyl
ene) :
20.6 lbs/hr and
9.5 tpy
See Additional
Special Term and
Condition A.
SUMMARY
TOTAL PERMIT TO INSTALL ALLOWABLE EMISSIONS
Pollutant
Volatile Organic
Compounds
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
(trichloroe-
thylene)
Tons/Year
9.5 TPY
REPORTING REQUIREMENTS
Unless otherwise specified, reports required by the Permit to
Install need only be submitted to Ohio EPA, Northeast District
Office, 2110 E. Aurora Road, Twins burg, Ohio 44087 .
WASTE DISPOSAL
The owner/operator shall comply with any applicable state and
federal requirements governing the storage, treatment, transport
and disposal of any waste material generated by the operation of
the sources.
MAINTENANCE OF EQUIPMENT
This source and its associated air pollution control system (s)
shall be maintained regularly in accordance with good engineering
practices and the recommendations of the respective manufacturers
in order to minimize air contaminant emissions.
MALFUNCTION/ABATEMENT
In accordance with OAC RULE 3745-15-06, any malfunction of the
source (s) or associated air pollution control system (s) shall be
reported immediately to the Ohio EPA, Northeast District Office,
2110 E. Aurora Road, Twins burg, Ohio 44087 .
Except as provided by OAC Rule 3745-15-06 (A) (3) , scheduled
maintenance of air pollution control equipment that requires the
shutdown or bypassing of air pollution control system (s) must be
accompanied by the shutdown of the associated air pollution
sources.
AIR POLLUTION NUISANCES PROHIBITED
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
The air contaminant source (s) identified in this permit may not
cause a public nuisance in violation of OAC Rule 3745-15-07.
BAT FOR OPEN TOP VAPOR DEGREASERS
In accordance with OAC Rule 3745-21-09 (0) (3) , each owner or
operator of an open top vapor degreaser shall:
a. equip the open top vapor degreaser with a cover that can be
opened and closed easily without disturbing the vapor zone;
b. install the following safety switches:
1. a condenser flow switch and thermostat or any other
device which shuts off the sump heat if the condenser
is either not circulating or too warm;
2. a spray safety switch which shuts off the spray pump if
the vapor level drops below any fixed spray nozzle;
3. a vapor level control thermostat or any other device
which shuts off the sump heat when the vapor level
rises too high; and
4. a water flow switch, water pressure switch or any other
device which shuts off the sump heat if the water in a
water-cooled condenser has no flow or no pressure,
whichever is being monitored;
c.
install one of the following devices:
1. a freeboard with a freeboard ratio greater than or
equal to 0.75 - if the open top vapor degreaser opening
is greater than 10 square feet, the cover must be
powered or equipped with mechanical features whereby it
can be readily closed when the degreaser is not in use;
2. refrigerated chiller;
3. enclosed design (cover or door opens only when the dry
part is actually entering or exiting the open top vapor
degreaser) ;
4. carbon adsorption system, with ventilation greater than
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
or equal to 50 cubic feet per minute per square foot of
air/solvent interface (when cover is open) , and
exhausting less than 25 parts per million (ppm) of
solvent averaged over one complete adsorption cycle; or
5. a control system, demonstrated to have control
efficiency equivalent to or greater than any of the
above, and approved by the Director; and
d. operate and maintain the open top vapor degreaser in a
manner which is consistent with good engineering practice
and which minimizes solvent evaporation from the unit.
ADDITIONAL SPECIAL TERMS AND CONDITIONS
A.
Applicable emissions limitations and/or control requirements
for existing or new batch vapor and in-line solvent cleaning
machines complying with the alternative standards provided
in 40 CFR part 63.464
1. The permittee shall ensure that the trichloroethylene
monthly emissions from the solvent cleaning machine do
not exceed the 3-month rolling average limit of 150
kilograms/square meter/month.
B.
Operational restrictions
1. The permittee shall install the following safety
switches on the open top vapor degreaser:
a. a spray safety switch which shuts off the spray
pump if the vapor level drops below any fixed
spray nozzle; and,
b. a water flow switch, water pressure switch or any
other device which shuts off the sump heat if the
water in a water-cooled condenser has no flow or
no pressure, whichever is being monitored.
2. The permittee shall operate and maintain the open top
vapor degreaser in accordance with the following
practices to minimize solvent evaporation from the
unit:
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
a. keep the cover closed at all times except when
processing work loads through the degreaser;
b. minimize solvent carry out by:
i. racking parts so that solvent drains freely
and is not trapped;
ii. moving parts in and out of the degreaser at
less than eleven feet per minute;
iii. holding the parts in the vapor zone at least
thirty seconds or until condensation ceases,
whichever is longer;
iv. tipping out any pools of solvent on the
cleaned parts before removal from the vapor
zone; and,
v. allowing parts to dry within the degreaser
for at least fifteen seconds or until
visually dry, whichever is longer.
c. clean only materials that are neither porous not
absorbent;
d. occupy no more than one-half of the degreaser's
open-top area with a workload;
e. always spray within the vapor level;
f. repair solvent leaks immediately, or shut down the
degreaser;
g. store waste solvent only in covered containers;
h. operate the cleaner such that water cannot be
visually detected in solvent exiting the water
separator;
i. use no ventilation fans near the degreaser
opening;
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
j. when the cover is open, do not expose the open top
vapor degreaser to drafts greater than 131
feet/minute, as measured between three and six
feet upwind and at the same elevation as the tank
lip; and,
k. provide permanent, conspicuous label, summarizing
the operating procedures.
C.
Monitoring and recordkeeping requirements
1. The permittee shall maintain a log of solvent additions
and removals for the solvent cleaning machine.
2. The permittee shall demonstrate compliance with the
3-month rolling average monthly emissions of less than
or equal to 150 kilograms/square meters/month on a
monthly basis as follows:
a. the permittee shall, on the first operating day of
every month, 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. The solvent cleaning machine does not
have to be emptied and filled with fresh unused
solvent prior to the calculations; and,
b. the permittee shall on the first operating day of
the month comply with the following:
i. using the records of solvent additions and
removals for the previous monthly reporting
period, determine trichloroethylene emissions
using the appropriate equation specified in
the "Testing Requirements" section of this
permit;
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
ii. determining
the
total
amount
of
trichloroethylene removed from the solvent
cleaning machine in solid waste during the
most
recent
monthly
reporting
period
(kilograms of solvent per month) as specified
in the "Testing Requirements" section of this
permit; and,
iii. determining the monthly rolling average for
the 3-month period ending with the most
recent reporting period using the appropriate
equation
specified
in
the
"Testing
Requirements" section of this permit.
3. The permittee shall maintain the following records
either in electronic or written form for a period of
five years:
a. the dates and amounts of trichloroethylene that
are added to the solvent cleaning machine;
b. the trichloroethylene composition of wastes
removed from the cleaning machines using the
procedures described in the "Testing Requirements"
section of this permit; and,
c. calculation sheets showing how the monthly
emissions and the rolling 3-month average
emissions of trichloroethylene from the solvent
cleaning machine were determined, and the results
of all calculations.
D.
Reporting requirements
1. The permittee shall submit an annual solvent emission
report by February 1 of each year. The report shall
cover the previous calendar year. The report shall
contain the following:
a. the size (solvent/air interface area) and type of
the solvent cleaning machine;
b. the average monthly trichloroethylene consumption
for the solvent cleaning machine in kilograms per
month; and,
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
c. the
3-month
monthly
rolling
average
trichloroethylene emissions estimates calculated
each month using the method as described in the
"Testing Requirements" section of this permit.
2. The permittee shall submit an exceedance report on a
semiannual basis. If the trichloroethylene three-month
rolling average of 150 kilograms/square meters/month is
exceeded, the permittee shall begin to submit a
quarterly report until such time that the permittee
requests and receives approval of a less frequent
reporting frequency from the Director (appropriate
District Office or local air agency) . The permittee
may receive approval of less frequent reporting if the
following conditions are met: (1) The emissions unit
has demonstrated a full year of compliance without an
exceedance, (2) the permittee continues to comply with
all relevant recordkeeping and monitoring requirements
specified in 40 CFR 63.1, General Provisions, and (3)
the Director (appropriate District Office or local air
agency) does not object to a reduced frequency of
reporting for the affected emissions unit as provided
in paragraph (e) (3) (iii) of subpart A, 40 CFR 63.1,
General Provisions. Each exceedance report shall be
delivered or post marked by the 30th day following the
reporting period. Each exceedance report shall contain
the following:
a. the reason and a description of the exceedance and
action (s) taken to comply with 40 CFR 63.463 (e)
and (f) including written or verbal orders for
replacement parts, a description of the repairs
made, and additional monitoring conducted to
demonstrate
that monitored parameters have
returned to acceptable levels; and,
b. if no exceedance has occurred, a statement to that
effect shall be submitted.
E.
Testing requirements/compliance demonstration
1. The permittee shall on the first operating day of every
month:
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
a. 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 soil. 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 paragraph (1) (b) below. The
solvent cleaning machine does not have to be
emptied and filled with fresh unused solvent prior
to the calculations; and,
b. comply with the following requirements:
i. using the records of all solvent additions
and removals for the three previous monthly
reporting periods required in the "Monitoring
and/or Record keeping Requirements" section
of this permit, determine solvent emissions
(Ei) using the equation below for cleaning
machines with a solvent/air interface;
Ei = (SAi-LSRi-SSRi) /AREAi
Where:
Ei =
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 are per month) .
Sai =
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) .
LSRi =
the total amount of halogenated HAP
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
liquid solvent removed the solvent
cleaning machine during the most recent
monthly reporting period i (kilograms of
solvent per month) .
SSRi =
the total amount of halogenated HAP
liquid solvent removed from the solvent
cleaning machine in solid
waste, obtained as described below
in paragraph (b) of this section,
during the most recent monthly
reporting period i (kilograms of
solvent per month) .
AREAi =
the solvent /air interface area of
the solvent cleaning machine (square
meters) .
ii. determine SSRi from tests conducted using
reference method 25d or from engineering
calculations included in the compliance
report; and,
iii. determine the monthly rolling average EA for
the 3-month period ending with the most
recent reporting period using the equation
below
for
cleaning
machines
with
a
solvent/air interface.
EAi= (Ei) /3, where the summation is from j=1
to j= 3
Where:
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) .
EAn =
the average halogenated HAP solvent
emissions over the preceding 3 monthly
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
reporting periods (kilograms of solvent
per month) .
Ei =halogenated HAP solvent emissions for
each month (j) for the most recent 3
monthly reporting periods (kilograms of
solvent per square meter of solvent/air
interface area per month) .
j=1 =the most recent monthly reporting
period.
j=2 =the monthly reporting period immediately
prior to j=1.
j=3 =the monthly reporting period immediately
prior to j=2.
2. Emissions Limit: 9.5 tpy trichloroethylene
Applicable Compliance Method: To determine the
actual organic compound emission rate, the
following equation shall be used:
E = (Ls - Lw) x D/2000
Where:
E = organic compound emissions rate (tons/year)
Ls =
liquid volume of cleaning solvent
employed each year (gallons)
Lw =
liquid volume of cleaning solvent sent
off-site as waste (gallons)
D =
density
of
cleaning
solvent
(pounds/gallon)
3. The permittee shall determine the facility's
potential to emit (PTE) from all solvent cleaning
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
operations. A facility's total PTE is the sum of
the HAP emissions from all solvent cleaning
operations plus all HAP emissions from other
emissions units from within the facility. The
potential to emit shall be determined in
accordance with the following procedures:
a. determine the potential to emit for each
individual solvent cleaning machine using the
following equation;
PTEi = Hi X Wi X SAIi
Where:
PTEi =
the potential to emit for the
solvent cleaning machine i (kilograms
solvent per year) .
Hi =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.
SAIi =
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
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Facility Name: Hydro Tube Corp
Application Number: 02-2639
Date: April 21, 1999
interface.
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