DAQ-2024-007396

1
DAQC-328-24
Site ID 11199 (B1)

MEMORANDUM

TO: FILE – MIDWESTERN FABRICATORS, LLC

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Jeremiah R. Marsigli, Environmental Scientist

DATE: April 11, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Salt Lake County,
FRS # UT0000004903500354

INSPECTION DATE: March 21, 2024

SOURCE LOCATION: 1235 South Pioneer Road, Salt Lake City, UT 84104

MAILING ADDRESS: 1235 South Pioneer Road, Salt Lake City, UT 84104

SOURCE CONTACT: Shaun Crossley, Vice President
[phone]

OPERATING STATUS: Operating

PROCESS DESCRIPTION:

MWF manufactures stripping towers, ductwork, storage tanks, troughs, large tank covers, and clarifier
covers made from a mixture of glass fibers and polyester and styrene monomers for reinforcement of the
fiber product.

The glass fibers are pre-manufactured and arrive on large spools and in mats. The primary resins
consumed at this facility are styrene-based polyester and vinyl ester resins. A catalyst, inhibitor, hardener
or accelerator such as benzene peroxide or ketones may be added at some time to speed up or slow down
polymerization processes.

Molds are constructed and lined with a hard gel coat. Production begins by spraying a removable gel coat
onto the mold. Next, chopping guns cut fiberglass into predetermined lengths, shoot them through a resin
spray, and onto the mold to reinforce the gel coating. Other plastic monomers may be added at this point
to strengthen the product, especially when fabricating storage tanks. Additional application procedures
used are continuous lamination by filament winding and manual applications of fiberglass mat. Laminated
gel coat is cured and trimmed or machined into the desired part.

Emissions and their controls: Organic vapors are emitted from the resins (especially styrene) during the
mixing, polymerization, and curing process. Vapors from the styrene are controlled as much as possible
by using a lower monomer to polyester ratio. The source is also required to adhere to the Subpart
WWWW requirements by storing used rags and VOC and HAP containing materials in covered

0 3
2
containers. In addition, HAPs and VOC usages are limited. Particulate capturing filters banks have been
installed in the workshop areas to catch the sprays and coatings, and cutting and sawing debris during the
trimming and machining processes.

APPLICABLE
REGULATIONS: Title V Operating Permit 3500354005, dated July 28, 2020
SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-415-6b)

Status: This is a federally enforceable permit.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: In compliance. The permittee has operated in compliance with this permit. See status under
each condition below for specific details.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that
the Director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this
permit. Upon request, the permittee shall also furnish to the Director copies of records
required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))

3
I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The
filing of a request by the permittee for a permit modification, revocation and reissuance, or
termination, or of a notification of planned changes or anticipated noncompliance shall not
stay any permit condition, except as provided under R307-415-7f(1) for minor permit
modifications. (R307-415-6a(6)(c))

Status: In compliance. The permittee appeared to be complying with all conditions of this permit at
the time of inspection. This permit is not being modified, revoked, reopened, or terminated for
cause at this time.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: In compliance. This permit has not expired.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the Director
takes final action on the permit renewal application. In such case, the terms and conditions
of this permit shall remain in force until permit renewal or denial. This protection shall
cease to apply if, subsequent to the completeness determination required pursuant to R307-
415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline
specified in writing by the Director any additional information identified as being needed to
process the application. (R307-415-7b(2))

Status: In compliance. Application for renewal is due by January 28, 2025.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: No portion of this permit is being challenged at this time.

4
I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In compliance. Emission fees have been paid as invoiced.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: No property rights have been conveyed.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: No permit revisions have been required for the items listed in this condition.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements.
(R307-415-6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In compliance. Access was granted to the facility and records. No claims of confidentiality
were made.
5
I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: In compliance. All documents submitted by the company have been signed by the responsible
official.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum, the
monitoring and related recordkeeping and reporting requirements in this permit. If
necessary, the permittee also shall identify any other material information that must
be included in the certification to comply with section 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period
covered by the certification, including whether compliance during the period was
continuous or intermittent. The certification shall be based on the method or means
designated in Provision I.L.1.b. The certification shall identify each deviation and
take it into account in the compliance certification. The certification shall also
identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part
64 occurred; and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

6
I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director: (R307-415-
6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In compliance. The most recent certification was received by DAQ on January 5, 2024. This
report was reviewed under separate cover and found to meet the requirements of this
condition.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed
in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-
112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110
prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))

Status: It appears that all applicable requirements have been included in this permit. Nothing in this
permit affects any of the items in I.M.2 above.

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
7
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or operator error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emission standards, or other
requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director 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 corrective actions taken. This notice fulfills the
requirement of Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-415-6g(5))

Status: In compliance. No emergency events were recorded or reported during the 12-month period
preceding this inspection.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

Status: This is not an inspection item.

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

Status: This is not an inspection item.

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

Status: This is not an inspection item.

8
I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: This is not an inspection item.

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be
retained by the permittee for a period of at least five years from the date of the
monitoring sample, measurement, report, or application. Support information
includes all calibration and maintenance records, all original strip-charts or
appropriate recordings for continuous monitoring instrumentation, and copies of all
reports required by this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable: (R307-415-
6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more
frequently if specified in Section II. All instances of deviation from permit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a
responsible official in accordance with Provision I.K of this permit.
(R307-415-6a(3)(c)(i)

9
I.S.2.c The Director shall be notified promptly of any deviations from permit requirements
including those attributable to upset conditions as defined in this permit, the
probable cause of such deviations, and any corrective actions or preventative
measures taken. Prompt, as used in this condition, shall be defined as written
notification within the number of days shown under "Enforceable Dates and
Timelines" at the front of this permit. Deviations from permit requirements due to
breakdowns shall be reported in accordance with the provisions of R307-107.
(R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be
submitted to the Director are to be sent to the following address or to such other
address as may be required by the Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]
I.S.3.b All reports, notifications or other submissions required by this permit to be
submitted to the EPA should be sent to one of the following addresses or to such
other address as may be required by the Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Office of Partnerships and Regulatory Assistance Air and Radiation Program (mail
code 8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In compliance. Records were reviewed during inspection and appeared to be complete.
Semi-annual monitoring reports have been submitted.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if the
effective date of the requirement is later than the date on which this permit is due to
10
expire, unless the terms and conditions of this permit have been extended pursuant
to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other
terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to
assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date
of this permit and are in conflict with existing permit conditions.
(R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit.
(R307-415-7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: Not evaluated. Permit reopening is handled by DAQ’s engineering branch.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: In compliance. Emission inventories have been submitted as required.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: This is determined during the NOI/permitting process.
SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

11
II.A.2 1: Chopper Guns
Ten chopper guns for spraying fiberglass-resin mix. These units are nonatomized mechanical
resin applicators per 40 CFR 63 Subpart WWWW. The permittee shall use nonatomized resin
applicators for all resin application.

II.A.3 2: Gel Coat Guns
Three spray guns used for applying gel coat finishes. These units are atomized spray gel coat
applicators per 40 CFR 63 Subpart WWWW. No unit-specific applicable requirements.

II.A.4 3: Natural Gas Fired Heaters
Individually rated less than 5MMBTU/hr. Natural gas by design. No unit-specific applicable
requirements.

II.A.5 4: Workshop Exhausts
Ground-level vents equipped with paint arrestor particulate filters to control particulate emissions.

Status: In compliance. No unapproved equipment was observed onsite.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 Conditions on permitted source (Source-wide).

II.B.1.a Condition:

Emissions of Styrene from the permitted source shall be no greater than 36.1 tons per rolling 12-month
period. [Origin: DAQE-AN111990011-13]. [R307-401-8]

II.B.1.a.1 Monitoring:

HAP emissions shall be determined on a rolling 12-month total. No later than 20 days after the
end of each month, a new 12-month total shall be calculated using data from the previous twelve
months.

II.B.1.a.2 Recordkeeping:

HAP emissions shall be determined by maintaining a record of HAP emitting materials used each
month. Records of consumption/production shall be kept for all periods when the plant is in
operation. The records shall include the following data for each material used:

(a) Name of the HAP emitting material, such as; resin, gelcoat, catalyst, etc.
(b) Pounds of each HAP emitting material used.
(c) Percent by weight of all HAP in each material used.
(d) Unified Emission Factor (UEF) used.
(e) The amount of HAP emitted monthly by each material used, calculated by the following
procedure:
HAP Emission (lb) =
Material Usage (lb) x Specific HAP Content (% wt) x Specific UEF Factor
(f) The amount of HAP emitted monthly from all materials used.
12
(g) The amount of HAPs reclaimed for the month shall be similarly quantified and subtracted
from the quantities calculated above, to provide the monthly total HAP emissions.
(h) The most current version (at time of use) of the ANSI/ACMA/ICPA Estimating Emission
Factors for Open Molding Composite Processes ("UEF") document shall be employed to
determine emission factors for use to calculate HAP emissions.

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records are kept and available for inspectors. Usage and rolling totals are
submitted semi-annually in the required Subpart WWWW reports. Almost all HAP and VOC
emissions are from styrene. VOC emissions are typically around 15 tons per year, or less than half
the permitted limit. The 12-month rolling total of styrene emission through February 29, 2024, were
14.4 tons.

II.B.1.b Condition:

Emissions of VOC from the permitted source shall be no greater than 38.6 tons per rolling 12-month
period. [Origin: DAQE-AN111990011-13]. [R307-401-8]

II.B.1.b.1 Monitoring:

VOC emissions shall be determined on a rolling 12-month total. No later than 20 days after the
end of each month, a new 12-month total shall be calculated using data from the previous twelve
months.

II.B.1.b.2 Recordkeeping:

VOC emissions shall be determined by maintaining a record of VOC emitting materials used each
month. Records of consumption/production shall be kept for all periods when the plant is in
operation. The records shall include the following data for each material used:

(a) Name of the VOC emitting material, such as; resin, gelcoat, catalyst, etc.
(b) Pounds of each VOC emitting material used.
(c) Percent by weight of all VOC in each material used.
(d) Unified Emission Factor (UEF) used.
(e) The amount of VOC emitted monthly by each material used, calculated by the following
procedure:
VOC Emission (lb) =
Material Usage (lb) x Specific VOC Content (% wt) x Specific UEF Factor
(f) The amount of VOC emitted monthly from all materials used.
(g) The amount of VOCs reclaimed for the month shall be similarly quantified and subtracted
from the quantities calculated above, to provide the monthly total VOC emissions.
(h) The most current version (at time of use) of the ANSI/ACMA/ICPA Estimating Emission
Factors for Open Molding Composite Processes ("UEF") document shall be employed to
determine emission factors for use to calculate VOC emissions.

13
II.B.1.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Records are kept and available for inspectors. Usage and rolling totals are
submitted semi-annually in the required Subpart WWWW reports. The 12-month rolling total of
VOC emissions through February 29, 2024, were 15.1 tons.

II.B.1.c Condition:

Unless otherwise specified in this permit, at all times, including periods of startup, shutdown, and
malfunction, the permittee shall, to the extent practicable, maintain and operate any permitted plant
equipment, including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director which may
include, but is not limited to, monitoring results, opacity observations, review of operating and
maintenance procedures, and inspection of the source. [Origin: DAQE-AN111990011-13]. [R307-401-8,
R307-401-8(2)]

II.B.1.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.c.2 Recordkeeping:

The permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The facility appeared to be maintained in a manner consistent with good air
pollution control practices. Maintenance records are kept, but are minimal due to the nature of the
process.

II.B.1.d Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction for
class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction.
[Origin: 40 CFR 82 Subpart F]. [40 CFR 82.150(b)]

II.B.1.d.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

14
II.B.1.d.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.d.3 Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance. The company certified compliance in the most recent annual compliance
certification report.

II.B.1.e Condition:

The permittee shall comply with all applicable requirements in 40 CFR 63, Subpart WWWW - National
Emissions Standards for Hazardous Air Pollutants: Reinforced Plastic Composites Production including,
but not limited to, the following: all operations, including repair operations, shall meet the applicable
organic HAP emission limits and work practice standards in Table 3 and 4 of 40 CFR 63 Subpart
WWWW. [Origin: 40 CFR 63 Subpart WWWW]. [40 CFR 63.5785(a), 40 CFR 63.5805(b), 40 CFR
63.5805(g), 40 CFR 63.5835(a)]

II.B.1.e.1 Monitoring:

The permittee shall perform all applicable monitoring required in 40 CFR 63.5796, 63.5797,
63.5805, 63.5810 (first paragraph), (a), (b), (d), 63.5895(d), 63.5900(a), (a)(2)-(a)(4), (c). The
permittee shall certify, in the annual compliance statement required in Section I of this permit, its
compliance status with the applicable requirements of 40 CFR 63, Subpart WWWW.

II.B.1.e.2 Recordkeeping:

The permittee shall maintain all records required in 40 CFR 63.5915(a)(1), (c), (d), 63.5895(c),
(d), 63.5920. There are no additional recordkeeping requirements except as outlined in Provision
I.S.1 of this permit.

II.B.1.e.3 Reporting:

The permittee shall submit all reports required in 40 CFR 63.5900, 63.5905, 63.5910(a), (b), (c),
(d), (g), (h), (i), 63.5912(c), 63.9(h). There are no additional reporting requirements except as
outlined in Section I of this permit.

Status: In compliance. Due to the process type, most of the requirements of Subpart WWWW do not apply.
Semi-annual reports have been submitted as required. The permittee has maintained consumption
records.

15
II.B.1.f Condition:

For applicable requirements originating in 40 CFR 63 Subpart WWWW:
At all times, including periods of startup, shutdown, and malfunction, the permittee shall operate and
maintain any affected source, including associated air pollution control equipment and monitoring
equipment, in a manner consistent with safety and good air pollution control practices for minimizing
emissions. During a period of startup, shutdown, or malfunction, this general duty to minimize emissions
requires that the permittee reduce emissions from the affected source to the greatest extent which is
consistent with safety and good air pollution control practices. The general duty to minimize emissions
during a period of startup, shutdown, or malfunction does not require the permittee to achieve emission
levels that would be required by the applicable standard at other times if this is not consistent with safety
and good air pollution control practices, nor does it require the permittee to make any further efforts to
reduce emissions if levels required by the applicable standard have been achieved. Determination of
whether such operation and maintenance procedures are being used will be based on information
available to the Director which 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 source.
[Origin: 40 CFR 63 Subpart WWWW, 40 CFR 63 Subpart A]. [40 CFR 63.5835(c), 40 CFR 63.6(e)(1)(i)]

II.B.1.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.f.2 Recordkeeping:

The permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. The facility appeared to be operated in compliance with good air pollution control
practices. Maintenance records were made available at the time of this inspection.

II.B.1.g Condition:

1. Except as provided in R307-361-4, the permittee shall not manufacture, blend, or repackage, supply,
sell, or offer for sale within the counties in R307-361-2; or solicit for application or apply within those
counties any architectural coating with a VOC content in excess of the corresponding limit specified
in Table 1.
TABLE 1
VOC Content Limit for Architectural and Industrial Maintenance Coatings
(Limits are expressed as VOC content, thinned to the manufacturer's maximum thinning
recommendation, excluding any colorant added to tint bases.)

COATING CATEGORY VOC Content Limit
(grams/liter)
Flat coatings 50
Non-flat coatings 100
Non-flat/high-gloss coatings 150
16
Specialty Coatings
Aluminum roofing 450
Basement Specialty Coatings 400
Bituminous Specialty Coatings 400
Bituminous roof coatings 270
Bituminous roof primers 350
Bond beakers 350
Calcimine recoaters 475
Concrete curing compounds 350
Concrete/masonry sealer 100
Concrete surface retarders 780
Conjugated oil varnish 450
Conversion varnish 725
Driveway sealers 50
Dry fog coatings 150
Faux finishing coatings 350
Fire resistive coatings 350
Floor coatings 100
Form-release compounds 250
Graphic arts coatings (sign paints) 500
High temperature coatings 420
Impacted Immersion Coatings 780
Industrial maintenance coatings 250
Low solids coatings 120
Magnesite cement coatings 450
Mastic texture coatings 100
Metallic pigmented coatings 500
Multi-color coatings 250
Nuclear coatings 450
Pre-treatment wash primers 420
Primers, sealers, and undercoaters 100
Reactive penetrating sealer 350
Reactive penetrating carbonate stone sealer 500
Recycled coatings 250
Roof coatings 250
Rust preventative coatings 250
Shellacs:
Clear 730
Opaque 550
Specialty primers, sealers, and undercoaters 100
Stains 250
Stone consolidant 450
Swimming pool coatings 340
Thermoplastic rubber coatings and mastic 550
Traffic marking coatings 100
Tub and tile refinish 420
Waterproofing membranes 250
Wood coating 275
Wood Preservatives 350
Zinc-Rich Primer 340

17
2. If a coating is recommended for use in more than one of the specialty coating categories listed in
Table 1, the most restrictive (lowest) VOC content limit shall apply.

a. This requirement applies to usage recommendations that appear anywhere on the coating
container, anywhere on any label or sticker affixed to the container, or in any sales, advertising, or
technical literature supplied by a manufacturer or anyone acting on their behalf.

b. Paragraph 2 (R307-361-5(2)) does not apply to the following coating categories:
(i) Aluminum roof coatings
(ii) Bituminous roof primers
(iii) High temperature coatings
(iv) Industrial maintenance coatings
(v) Low-solids coatings
(vi) Metallic pigmented coatings
(vii) Pretreatment wash primers
(viii) Shellacs
(ix) Specialty primers, sealers and undercoaters
(x) Wood Coatings
(xi) Wood preservatives
(xii) Zinc-rich primers
(xiii) Calcimine recoaters
(xiv) Impacted immersion coatings
(xv) Nuclear coatings
(xvi) Thermoplastic rubber coatings and mastic
(xvii) Concrete surface retarders
(xviii) Conversion varnish

3. Sell-through of coatings. A coating manufactured prior to January 1, 2015, may be sold, supplied, or
offered for sale for up to three years after January 1, 2015. A coating manufactured before January 1,
2015, may be applied at any time. Paragraph 3 (R307-361-5(3)) does not apply to any coating that
does not display the date or date code required by R307-361-6(1)(a).

4. Painting practices. All architectural coating containers used when applying the contents therein to a
surface directly from the container by pouring, siphoning, brushing, rolling, padding, ragging or other
means, shall be closed when not in use. These architectural coating containers include, but are not
limited to, drums, buckets, cans, pails, trays or other application containers. Containers of any VOC-
containing materials used for thinning and cleanup shall also be closed when not in use.

5. Thinning. The permittee shall not apply or solicit the application of any architectural coating that is
thinned to exceed the applicable VOC limit specified in Table 1.

6. Rust preventative coatings. The permittee shall not apply or solicit the application of any rust
preventative coating manufactured before January 1, 2015 for industrial use, unless such a rust
preventative coating complies with the industrial maintenance coating VOC limit specified in Table 1.

7. Coatings not listed in Table 1. For any coating that does not meet any of the definitions for the
specialty coatings categories listed in Table 1, the VOC content limit shall be determined by
classifying the coating as a flat, non-flat, or non-flat/high gloss coating, based on its gloss, as defined
in R307-361-3 and the corresponding flat, non-flat, or non-flat/high gloss coating VOC limit in Table
1 shall apply.

18
8. The following coatings are exempt from the requirements of this condition (R307-361).

a. Any architectural coating that is supplied, sold, offered for sale, or manufactured for use outside
of the counties in R307-361-2 or for shipment to other manufacturers for reformulation or
repackaging.

b. Any aerosol coating product.

c. Any architectural coating that is sold in a container with a volume of one liter (1.057 quarts) or
less, including kits containing containers of different colors, types or categories of coatings and
two component products and including multiple containers of one liter or less that are packaged
and shipped together with no intent or requirement to ultimately be sold as one unit.

(i) The exemption in paragraph 8.c (R307-361-4(3)) does not include bundling of containers
one liter or less, which are sold together as a unit with the intent or requirement that they be
combined into one container.

(ii) The exemption in paragraph 8.c (R307-361-4(3)) does not include packaging from which the
coating cannot be applied. This exemption does include multiple containers of one liter or
less that are packaged and shipped together with no intent or requirement to ultimately sell
as one unit.

9. The requirements of Table 1 do not apply to operations that are exclusively covered by Department of
Defense military technical data and performed by a Department of Defense contractor and/or on site
at installations owned and/or operated by the United States Armed Forces.

[Origin: R307-361]. [R307-361-2]

II.B.1.g.1 Monitoring:

The permittee shall use the following test methods.
(a) Determination of VOC content.
(i) For the purpose of determining compliance with the VOC content limits in Table 1, the
VOC content of a coating shall be calculated by following the appropriate formula
found in the definitions of VOC actual, VOC content, and VOC regulatory found in
R307-361-3.
(ii) The VOC content of a tint base shall be determined without colorant that is added after
the tint base is manufactured.
(iii) If the manufacturer does not recommend thinning, the VOC content shall be calculated
for the product as supplied.
(iv) If the manufacturer recommends thinning, the VOC content shall be calculated
including the maximum amount of thinning solvent recommended by the manufacturer.
(v) If the coating is a multi-component product, the VOC content shall be calculated as
mixed or catalyzed.
(vi) If the coating contains silanes, siloxanes, or other ingredients that generate ethanol or
other VOC during the curing process, the VOC content shall include the VOCs emitted
during curing.

19
II.B.1.g.2 Recordkeeping:

Records demonstrating compliance with this condition shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.1.g.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. Midwestern Fabricators has not used, manufactured, blended, repackaged,
supplied, or sold any architectural and industrial maintenance coatings.

II.B.2 Conditions on Workshop Exhausts (4).

II.B.2.a Condition:

Visible emissions shall be no greater than 10% opacity. [Origin: DAQE-AN111990011-13]. [R307-305,
R307-401-8]

II.B.2.a.1 Monitoring:

In lieu of monitoring via visible emissions observations, the external vents and particulate filters
shall be inspected weekly. Inspections shall consist of the following:

(a) Inspection for holes in the particulate filters.
(b) Inspection of the particulate filters to determine proper installation within the support rack.

II.B.2.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance. No visible emissions were observed upon surveying the workshop exterior. A weekly
walkthrough of the facility is performed and includes filter inspections. In addition, production
workers are aware of filter change requirements and change filters as need arises. All filters were in
place and appeared to be functioning during this inspection. The company has installed gauges on
each filter bank to show differential pressure. The gauges are inspected weekly and set to show
proper operating ranges.

II.C Emissions Trading
(R307-415-6a(10))

Not applicable to this source.

20
II.D Alternative Operating Scenarios.
(R307-415-6a(9))

Not applicable to this source.

SOURCE INSPECTION EVALUATION:

EMISSIONS INVENTORY: Taken from DAQ’s 2022 emissions inventory:

Pollutant Tons/yr
VOC 3.09
Styrene 5.374
PM10 0.015
NOx 0.20
SO2 0.001
CO 0.18

PREVIOUS ENFORCEMENT
ACTIONS: None during the previous 5 years.

COMPLIANCE STATUS &
RECOMMENDATIONS: Midwestern Fabricators should be found in compliance with the
conditions of the Title V Operating Permit evaluated at the time
inspection.

HPV STATUS: Not Applicable

COMPLIANCE
ASSISTANCE: No

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual.

ATTACHMENT: VEO Form