John R. Kasich, Governor Mary Taylor, Lt. Governor Craig W ...0.13 psia; and d. calculation method used to determine the true vapor pressure of the liquid asphalt material at the specified

John R. Kasich, GovernorMary Taylor, Lt. GovernorCraig W. Butler, Director

50 West Town Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049www.epa.ohio.gov • (614) 644-3020 • (614) 644-3184 (fax)

3/14/2017

BETH MOWREYShelly Liquid DivisionP.O. BOX 266THORNVILLE, OH 43076

RE: FINALAIR POLLUTION PERMIT-TO-INSTALL AND OPERATEFacility ID: 0627000046Permit Number: P0118909Permit Type: Initial InstallationCounty: Gallia

Dear Permit Holder:

Enclosed please find a final Ohio Environmental Protection Agency (EPA) Air Pollution Permit-to-Install and Operate (PTIO) which will allow you to install, modify, and/or operate the described emissions unit(s) in the manner indicated in the permit. Because this permit contains conditions and restrictions, please read it very carefully. In this letter you will find the information on the following topics:

How to appeal this permit How to save money, reduce pollution and reduce energy consumption How to give us feedback on your permitting experience How to get an electronic copy of your permit What should you do if you notice a spill or environmental emergency?

How to appeal this permit

The issuance of this PTIO is a final action of the Director and may be appealed to the Environmental Review Appeals Commission pursuant to Section 3745.04 of the Ohio Revised Code. The appeal must be in writing and set forth the action complained of and the grounds upon which the appeal is based. The appeal must be filed with the Commission within thirty (30) days after notice of the Director's action. The appeal must be accompanied by a filing fee of $70.00, made payable to "Ohio Treasurer Josh Mandel," which the Commission, in its discretion, may reduce if by affidavit you demonstrate that payment of the full amount of the fee would cause extreme hardship. Notice of the filing of the appeal shall be filed with the Director within three (3) days of filing with the Commission. Ohio EPA requests that a copy of the appeal be served upon the Ohio Attorney General's Office, Environmental Enforcement Section. An appeal may be filed with the Environmental Review Appeals Commission at the following address:

Environmental Review Appeals Commission77 South High Street, 17th FloorColumbus, OH 43215

Certified Mail

No TOXIC REVIEWNo SYNTHETIC MINOR TO AVOID MAJOR NSRNo CEMSNo MACT/GACTNo NSPSNo NESHAPSNo NETTINGNo MODELING SUBMITTEDYes SYNTHETIC MINOR TO AVOID TITLE VYes FEDERALLY ENFORCABLE PTIO (FEPTIO)No SYNTHETIC MINOR TO AVOID MAJOR GHG

How to save money, reduce pollution and reduce energy consumption

The Ohio EPA is encouraging companies to investigate pollution prevention and energy conservation. Not only will this reduce pollution and energy consumption, but it can also save you money. If you would like to learn ways you can save money while protecting the environment, please contact our Office of Compliance Assistance and Pollution Prevention at (614) 644-3469. Additionally, all or a portion of the capital expenditures related to installing air pollution control equipment under this permit may be eligible for financing and State tax exemptions through the Ohio Air Quality Development Authority (OAQDA) under Ohio Revised Code Section 3706. For more information, see the OAQDA website: www.ohioairquality.org/clean_air

How to give us feedback on your permitting experience

Please complete a survey at www.epa.ohio.gov/survey.aspx and give us feedback on your permitting experience. We value your opinion.

How to get an electronic copy of your permit

This permit can be accessed electronically via the eBusiness Center: Air Services in Microsoft Word format or in Adobe PDF on the Division of Air Pollution Control (DAPC) Web page, www.epa.ohio.gov/dapc by clicking the "Search for Permits" link under the Permitting topic on the Programs tab.

What should you do if you notice a spill or environmental emergency?

Any spill or environmental emergency which may endanger human health or the environment should be reported to the Emergency Response 24-HOUR EMERGENCY SPILL HOTLINE toll-free at (800) 282-9378. Report non-emergency complaints to the appropriate district office or local air agency.

If you have any questions regarding your permit, please contact Ohio EPA DAPC, Southeast District Office at (740)385-8501 or the Office of Compliance Assistance and Pollution Prevention at (614) 644-3469.

Sincerely,

Michael E. Hopkins, P.E.Assistant Chief, Permitting Section, DAPC

Cc: Ohio EPA-SEDO

Response to CommentsShelly Liquid Division

Permit Number: P0118909Facility ID: 0627000046

Response to CommentsFacility ID: 0627000046Facility Name: Shelly Liquid DivisionFacility Description: Liquid asphalt terminal.

Facility Address:1400 State Route 7 NorthGallipolis, OH 45631Gallia County

Permit: P0118909, Permit-To-Install and Operate - Initial Installation A public notice for the draft permit issuance was published in the Ohio EPA Weekly Review and appeared in the Gallipolis Daily Tribune on 04/27/2016. The comment period ended on 05/27/2016.Hearing date (if held)Hearing Public Notice Date (if different from draft public notice)

The following comments were received during the comment period specified. Ohio EPA reviewed and considered all comments received during the public comment period. By law, Ohio EPA has authority to consider specific issues related to protection of the environment and public health. Often, public concerns fall outside the scope of that authority. For example, concerns about zoning issues are addressed at the local level. Ohio EPA may respond to those concerns in this document by identifying another government agency with more direct authority over the issue.

In an effort to help you review this document, the questions are grouped by topic and organized in a consistent format. PDF copies of the original comments in the format submitted are available upon request.

USEPA’s COMMENTS:

1. Topic: Title V Applicability

a. U.S. EPA Comment: The permit does not address or include Shelly Plant #2 (hot mix asphalt plant), which is situated on a contiguous property, for Title V applicability. Please evaluate total VOC emissions from both plants if determined to be a single source, and verify that a FEPTIO is the appropriate permit type.

b. Shelly Response to U.S. EPA Comment: Emissions from Shelly Plant #2 and Shelly Liquids should not be aggregated for purposes of Title V applicability. The SIC code is different for each facility (SLM is 5171 and Plant #2 is 2951). Furthermore, the Terminal is not a support facility for Plant #2 given that Plant #2 receives liquid asphalt from other sources and less than 10% of the liquid asphalt handled at the Terminal is sent to Plant #2.

c. Ohio EPA Response: A review of the major source definition in OAC rule 3745-77-01 shows that Shelly Liquid Materials and Shelly Plant #2 are (1) located on a contiguous or adjacent property; and (2) under common control of the same person(s); however, they do not belong to the same industrial grouping, nor is Shelly Liquid Materials considered a support facility, as Shelly Plant #2 does not receive more than 50% of the raw material from Shelly Liquid Materials (Shelly Liquid Materials has provided information via email on 6/22/16 that Shelly Plant #2 only receives 2.68% of liquid asphalt from the Gallipolis Terminal and that the other percentage



comes from other suppliers around the state and West Virginia). Based on the SIC being different for each facility, and SLM is not considered a support facility, these two facilities should not be aggregated for Title V applicability.

2. Topic: Monitoring and Recordkeeping Requirements of Liquid Asphalt Throughput [Section B.4.a)]

a. U.S. EPA Comment: Section B.4.a) contains monitoring and recordkeeping requirements to determine compliance with the operational restrictions at the source, with the throughput of liquid asphalt to be determined on a monthly basis. The condition does not specify the methodology with which the throughput will be determined; please specify the methodology, ensuring that the methodology has a level of accuracy appropriate to comply with limitations

b. Shelly Response to U.S. EPA Comment: Shelly will use existing equipment and procedures to measure the throughput of asphalt for each loading rack. The specific measurement techniques should not be established as explicit terms give that such terms could necessitate an excessive volume of permit revisions if Shelly elects to use or install an alternative monitoring technique.

c. Ohio EPA Response: Ohio EPA believes that the monitoring and/or recordkeeping requirements in B.4.a) will ensure compliance with the rolling 12-month period VOC emissions restriction.

3. Topic: Barge of Liquid Asphalt Material Analysis [Section B.4.b)]

a. U.S. EPA Comment: Section B.4.b) requires the facility to collect and analyze a sample of the liquid asphalt material for each barge received or maintain certified material analysis to verify the true vapor pressure of the incoming material. The condition does not specify a timeframe for analysis to be completed or procedures to follow if true vapor pressure is above limitation set in the permit, or reporting timeframe and submitting a corrective action report. Additionally, the condition specifies the true vapor pressure not exceeding 0.13 psiataking into account material storage conditions of 300oF; permit does not include the calculation method to determine true vapor pressure given the required storage conditions of 300oF. To improve clarity and enforceability, the following should be included: a. Timeframe in which an analysis of liquid asphalt material must be completed; b. Timeframe and specific office to submit true vapor pressure exceeding 0.13 psia to; c. Procedures to be following if true vapor pressure exceeds 0.13 psia; and d. calculation method used to determine the true vapor pressure of the liquid asphalt material at the specified storage conditions.

b. Shelly Response to U.S. EPA Comment: Refer to original comments on draft for Condition B.4.b). Shelly developed the vapor pressure estimate for liquid asphalt based on site-specific sampling and an exhaustive review of available reference data. Shelly is confident that the vapor pressure provided in the application represents a conservative estimate and respectfully requests removal of this requirement.

c. Ohio EPA Response: Ohio EPA removed the requirement to collect and analyze a sample of the material received to determine psia. Ohio EPA used the data submitted in permittee’s application to calculate the allowable emissions limits. In calculating the true vapor pressure, Shelly developed a safety factor of 2.45 by taking the ratio of observed values (similar sources, source specific, and literature reference values) at 300oF to the predicted value based on the Clausius-Clapeyron equation (Equation 1-24 of AP 42 7.1.3.1). Compliance will be determined by using the Clausius-Clapeyron equation with the current temperature of the bulk liquid.



4. Topic: Carbon Adsorber Voluntary Restriction [Section B.4.c)]

a. U.S. EPA Comment: Section B identifies carbon adsorber as a voluntary measure for the entire facility. The use of the carbon adsorber is a requirement for EUs T006 and T007 to meet the requirements of OAC rule 3745-31-05(A)(3). The permit should clarify that the use of carbon adsorber are applicable requirements for these EUs.

b. Shelly Response to U.S. EPA Comment: Refer to Shelly’s original comments on draft PTIO Conditions B.3.b) and C.1.g)(2). Deleted voluntary restriction of carbon filter system in B.3.b) and added g)(2) “This emission unit is equipped with a carbon bed for odor minimization.”

c. Ohio EPA Response: Ohio EPA has removed the voluntary restriction because there is no legal authority to add a voluntary restriction not requested by a facility; however, the carbon adsorber is required per BAT for EUs T006 and T007, and those requirements are in those EU specific terms and conditions. Use of a carbon filter and submerged fill was the BAT established for EUs T006 and T007 in 1999 and 2000, respectively; which was upheld in the September 9, 2009 Decision and Judgment Entry that conveyed Ohio EPA accepted the carbon adsorber system that was installed on September 15, 2005 in lieu of the carbon filter for compliance.

5. Topic: Monitoring and Recordkeeping Requirements – Tank Temperatures [Section B.4.a)

a. U.S. EPA Comment: Section B.4.a) includes monitoring and recordkeeping requirements for the facility. Tanks are assumed to be heated to 300o F, without any monitoring requirement to verify the temperature value. Ohio EPA should include monitoring requirements for tank temperatures to verify the values used in the calculations are accurate and representative of actual facility operations.

b. Shelly Response to U.S. EPA Comment: Shelly has calculated PTE from the Terminal under worst-case assumption that all storage vessels would be maintained at 300oF throughout the entire year; therefore, temperature monitoring requirements are not necessary.

c. Ohio EPA Response: Ohio EPA has requirements to maintain monthly records of the bulk liquid temperature as obtained from the temperature gauges on the tanks, which is used in demonstrating compliance with the synthetic minor restriction of VOC emissions.

6. Topic: Monitoring and Recordkeeping Requirements for the Carbon Adsorbers [Section B.4.c)]

a. U.S. EPA Comment: Section B.4.c) has monitoring and recordkeeping requirements for the carbon adsorber includes monitoring of breakthrough for the carbon adsorber system by olefactory means and by a Method 21 analyzer on a weekly basis for initial year and reduced if less than 2 breakthrough events the following year. It is unclear what constitutes a breakthrough event by either olefactory means, value detected by the Method 21 analyzer, or the corrective action to be taken if breakthrough occurs. Relying on olefactory means to determine breakthrough may cause inconsistencies in monitoring. Additionally, once the monitoring schedule is reduced, the monitoring events will never exceed the threshold to increase the monitoring schedule despite any breakthrough events. To improve clarity and enforceability, the permit should include the following: a. include detection level limit for the Method 21 analyzer to define what reading would constitute breakthrough of carbon filter; b. incorporate EPA Reference Method 21 to ensure proper procedures are followed; c. reconsider utilizing olefactory means as monitoring method and utilize RM 21; d. include corrective action procedures for when breakthrough occurs; e. monitoring frequency should be no less than quarterly; f. specify inspection and maintenance procedures; and g. EPA recommends inclusion



of the carbon adsorbtion system.

b. Shelly Response to U.S. EPA Comment: Refer to Shelly’s original comments on draft in Condition B.4.c). Deleted the language for monitoring/recordkeeping for the carbon bed adsorber that is a voluntary restriction. In response to B.4.c)(3), Method 21 is used to measure the concentration of organic compounds. Organic compounds are not necessary odorous. Because these carbon beds are required only for the control of odors, Method 21 measurements would not provide any meaningful indication of whether the carbon beds are operating properly. Shelly respectfully requests removed of these terms. In response to B.4.c)(4), the Gallipolis Terminal is not equipped with carbon storage equipment. If necessary, Shelly will obtain replacement carbon from the supplier as quickly as practicable.

c. Ohio EPA Response: Ohio EPA has removed the voluntary restriction for the carbon bed adsorber and retained the requirements for EUs T006 and T007 since the carbon bed adsorber is BAT. Further, for EUs T006 and T007, Ohio EPA revised the operating restrictions and monitoring and recordkeeping requirements to satisfy US EPA. Method 21 for VOC breakthrough monitoring has been revised, and the requirement to submit a VOC Breakthrough Plan has been added.

7. Topic: PSIA and Temperature [Section B.4.c), B.5.a)(1)b., B.6.a), and C.1.f)]

a. U.S. EPA Comment: 0.13 is referred to as the maximum true pressure allowable; however, this value may cause confusion as to what the actual limit is. The 0.13 psia is meant to take into account the storage tank temperature of 300o F. The temperature is inconsistently specified throughout the permit. Either adjust the limit to factor in the temperature or clarify throughout the permit that the temperature must be adjusted to 300oF in the specified calculation method.

b. Shelly Response to U.S. EPA Comment: Shelly has calculated PTE from the Terminal under worst-case assumption that all storage vessels would be maintained at 300oF throughout the entire year. The asphalt vapor pressure of 0.13 psia represents the maximum true vapor pressure at 300oF; therefore, Shelly will conservatively demonstrate compliance with applicable emission limitations using calculations based on an asphalt vapor pressure of 0.13 psia and liquid storage temperature of 300oF.

c. Ohio EPA Response: The allowable emissions were based on 0.13 psia and 300oF as provided in permittee’s application; however, compliance will be demonstrated by the actual recorded temperature, as well as using the Clausius-Clapeyron equation. In calculating the true vapor pressure, Shelly developed a safety factor of 2.45 by taking the ratio of observed values (similar sources, source specific, and literature reference values) at 300oF to the predicted value based on the Clausius-Clapeyron equation (Equation 1-24 of AP 42 7.1.3.1).

8. Topic: Calculations [Section B.6.a)(1)]

a. U.S. EPA Comment: Section B.6.a)(1) includes the calculations for compliance determination. a. the calculation method references AP-42 Section 7.1.3.2 (11/06) for internal floating roof tanks; SLD owns and operates fixed roof tanks. Review calculation method and include appropriate method. b. calculation method includes fixed value of 0.13 psia as true vapor pressure of liquid loaded; this value should be the analyzed true vapor pressure by B.4.b) to ensure representative of actual facility operations. c. The calculation method includes a calculated value for temperature of bulk liquid; the equation cited does not take the heated tank temperature into consideration; ensure the equation is correct and can account for the holding



temperature in the tank to ensure representative of actual facility operations. Calculation method should be specified in the permit. and d. the temperature scale is missing from the 300oF in the equation. Ensure proper units are included in all calculations.

b. Shelly Response to U.S. EPA Comment: Refer to Shelly’s original comments on draft PTIO. As noted above, PTE is based on 0.13 psia representative of the vessel storage temperature of 300oF, and demonstrates compliance with applicable emissions limits using calculations with those values.

c. Ohio EPA Response: Ohio EPA has revised the calculations.

9. Topic: Monthly VOC Emissions Calculation Method [Section

a. U.S. EPA Comment: Condition B.6.a)(1)b. includes procedures to determine monthly tank VOC emissions. The procedures reference a summation of emissions calculation, including methods from the permittee’s application. The permit should specify calculation method for determining emissions and specify all components of the equation to ensure all emissions are being accounted for.

b. Shelly Response to U.S. EPA Comment: Refer to Shelly’s original comments on draft PTIO, Condition B.6.a)(1)b. Revised and deleted language in the calculations. The tanks at the Gallipolis Terminal are not internal floating roofs.


10. Topic: Monitoring and Recordkeeping Requirements [Section C.1.d)(1)]

a. U.S. EPA Comment: The permit does not include a recordkeeping or compliance method to ensure compliance with the 24.0 pounds per hour VOC limit for J001/J002. Permit should include monthly calculation of VOC emissions in pounds/hour to ensure compliance with the permit limitation.

b. Shelly Response to U.S. EPA Comment: Compliance with the short-term emission limitation of 24.0 lbs/hr is demonstrated through the supporting calculation provided in the PTIO Condition C.1.F)(1)a.

c. Ohio EPA Response: Ohio EPA has added monthly records of the hourly throughput to determine compliance.

11. Topic: Breathing Losses from Fixed Roof Tanks [Section C.1.f)a.]

a. U.S. EPA Comment: The permit does not specify how to include breathing losses from the fixed roof tanks. Please ensure all emissions from the facility are included in the permit.

b. Shelly Response to U.S. EPA Comment: Shelly estimated breathing losses according to AP-42, Section 7.1.3.1. Shelly recommends an update to the permit terms to reference that section.

c. Ohio EPA Response: Calculations have been revised.

12. Topic: Operational Restrictions [Section C.1.c)]

a. U.S. EPA Comment: Section C.1.c) states no operational restrictions placed on J001/J002, however, the equipment descriptions note a restriction of a combined annual throughput of



131,69,741 gallons of liquid asphalt material. This restriction should be reflected in that condition.

b. Shelly Response to U.S. EPA Comment: Shelly agrees with this recommended change.

c. Ohio EPA Response: Ohio EPA has added in the combined annual throughput restriction, and monitoring, recordkeeping and reporting requirements.

13. Topic: Calculation Method in Testing Section [Section C.1.f)(1)]

a. U.S. EPA Comment: Section C.1.f)(1) includes the calculation for compliance determination for J001 and J002. a. The calculation method includes a fixed value of 0.13 psia as the true vapor pressure of the liquid loaded; this value should be the analyzed true vapor pressure to ensure representative of actual facility operations; and b. The calculation method includes a calculated value for temperature of bulk liquid; the equation cited does not taken the heated tank temperature into consideration; ensure the equation is correct and can account for the holding temperature in the tank to ensure representative of actual facility operations. Calculation method should be specified in the permit.

b. Shelly Response to U.S. EPA Comment: Refer to Shelly’s original comments on PTIO Condition C.1.f)(1)a. As noted above in Item 5, Shelly has calculated PTE from the Terminal under worst-case assumption that all storage vessels would be maintained at 300oF throughout the entire year. The asphalt vapor pressure of 0.13 psia represents the maximum true vapor pressure at 300oF; therefore, Shelly will conservatively demonstrate compliance with applicable emission limitations using calculations based on an asphalt vapor pressure of 0.13 psia and liquid storage temperature of 300oF.


14. Topic: Emissions Testing [Section C.1.f)(2)]

a. U.S. EPA Comment: Section C.1.f)(2) includes requirements for emissions testing for J001 and J002; the permit should include conditions for testing once a permit term during peak operating season, at a minimum.

b. Shelly Response to U.S. EPA Comment: Refer to Shelly’s original comments on draft PTIO Condition C.1.f)(2). Deleted testing language. Shelly conducted performance testing in July 2012.

c. Ohio EPA Response: Ohio EPA has modified the language to stipulate testing during peak operating season. In response to Shelly’s comments, Ohio EPA does not agree remove this condition.

15. Topic: Appendix A area

a. U.S. EPA Comment: The permit strategy writeup concludes this permit is not subject to Appendix A of OAC 3745-17-08 due to facility not located in the City of Gallipolis, however the address of the facility states its location is in Gallipolis. Please clarify the non-applicability of OAC 3745-17-08 Appendix A and ensure all applicable requirements are contained in this permit.



b. Shelly Response to U.S. EPA Comment: Shelly has reviewed the municipal boundaries for Gallia County and has confirmed that the Terminal is not located in the City of Gallipolis; therefore, the facility is not in an Appendix A area.

c. Ohio EPA Response: While the facility has a mailing address of Gallipolis, it is not located within the City limits; therefore, the facility is not located within an Appendix A as referend in OAC rule 3745-17-08 and is not applicable to the facility.

SHELLY’s COMMENTS (5/16/16):

16. Topic: Operational Restrictions [Section B.3.b)]

a. Shelly Comment: Deleted voluntary restriction of carbon filter system.

b. Ohio EPA Response: Ohio EPA deleted the voluntary restriction of the carbon adsorber from all EUs since it is not legally required; however, EUs T006 and T007 have BAT requirements for the carbon adsorbers, and the language is moved to the EU specific terms and conditions section. Also, under EU specific miscellaneous requirements section g), Shelly requested added language “The emissions unit is equipped with a carbon bed for odor minimization.”, and such language has been added.

17. Topic: Monitoring and Recordkeeping Requirements [Section B.4.a)c.]

a. Shelly Comment: Deleted; the asphalt storage tanks at the Gallipolis Terminal are heated to approximately 300oF and are insulated; therefore, ambient temperature fluctuations do not affect the bulk liquid temperature.

b. Ohio EPA Response: Ohio EPA replaced this language with the requirement to monitor and record the monthly temperature of the bulk liquid in each storage tank.

18. Topic: Monitoring and Recordkeeping Requirements [Section B.4.a)f.]

a. Shelly Comment: Deleted; the tanks at the Gallipolis Terminal are not internal floating roof tanks.

b. Ohio EPA Response: Ohio EPA deleted this language.

19. Topic: Monitoring and Recordkeeping Requirements [Section B.4.b)]

a. Shelly Comment: Deleted; Shelly developed the vapor pressure estimate for liquid asphalt based on site-specific sampling and an exhaustive review of available reference data. Shelly is confident that the vapor pressure provided in the application represents a conservative estimate and respectfully requests removal of this requirement.

b. Ohio EPA Response: Ohio EPA used the data submitted in permittee’s application to calculate the allowable emissions limits. Ongoing compliance shall be determined in accordance with the calculation in the testing section.

20. Topic: Monitoring and Recordkeeping Requirements [Section B.4.c)(1)-(7)]

a. Shelly Comment: Deleted the language for monitoring/recordkeeping for the carbon bed adsorber that is a voluntary restriction. In response to B.4.c)(3), Method 21 is used to measure



the concentration of organic compounds. Organic compounds are not necessary odorous. Because these carbon beds are required only for the control of odors, Method 21 measurements would not provide any meaningful indication of whether the carbon beds are operating properly. Shelly respectfully requests removed of these terms. In response to B.4.c)(4), the Gallipolis Terminal is not equipped with carbon storage equipment. If necessary, Shelly will obtain replacement carbon from the supplier as quickly as practicable.

b. Ohio EPA Response: Ohio EPA has removed the voluntary restriction for the carbon bed adsorber and retained the requirements for EUs T006 and T007 since the carbon bed adsorber is BAT. Further, for EUs T006 and T007, Ohio EPA revised the operating restrictions and monitoring and recordkeeping requirements to satisfy US EPA. Method 21 for VOC breakthrough monitoring has been revised, and the requirement to submit a VOC Breakthrough Plan has been added.

21. Topic: Reporting Requirements [Section B.5.a)(1)]

a. Shelly Comment: Removed “and/or control device operating parameter limitations” from Section (1).

b. Ohio EPA Response: Ohio EPA will remove the language “and/or control device operating parameter limitations” from Section (1).

22. Topic: Reporting Requirements [Section B.5.a)(1)b.]

a. Shelly Comment: Deleted deviation language regarding material received with psia greater than 0.13.

b. Ohio EPA Response: Removed the requirement in Section (1)b.

23. Topic: Testing Requirements [Section B.6.a)(1)(a)]

a. Shelly Comment: Deleted language and revised under “P” and “M”; replaced 300oF with 459.67 and deleted language on the temperature. The asphalt storage tanks at the Gallipolis Terminal are heated to 300oF and insulated; therefore, ambient temperature fluctuations do not affect the bulk liquid temperature.

b. Ohio EPA Response: Ohio EPA has revised this section.

24. Topic: Testing Requirements [Section B.6.a)(1)(b)]

a. Shelly Comment: Revised and deleted language in the calculations. The tanks at the Gallipolis Terminal are not internal floating roofs.

b. Ohio EPA Response: Ohio EPA has revised the language in the calculations and made changes necessary.

25. Topic: EU ID Description [Section C.1.]

a. Shelly Comment: Removed the tank references from J001 and J002.

b. Ohio EPA Response: Ohio EPA will update the EU description language



26. Topic: Applicable Emissions Limitations and/or Control Requirements [Section C.1.b)(1)a.]

a. Shelly Comment: Response to OEPA’s ‘working copy’ was filling in tons per year as submitted in their application.

b. Ohio EPA Response: In the issued draft PTIO, OEPA already updated the tons per year limits based on information in Shelly’s application.


a. Shelly Comment: Deleted Visible PE BAT.

b. Ohio EPA Response: Ohio EPA does not agree to this change. “Old” BAT is to be used and this is the appropriate “old” BAT language.

28. Topic: Applicable Emissions Limitations and/or Control Requirements [Section C.1.b)(1)b.]

a. Shelly Comment: Deleted less stringent language.

b. Ohio EPA Response: Ohio EPA does not agree to this change. Since “old” BAT is used in C.1.b)(1)a., this less stringent language is applicable.

29. Topic: Testing Requirements – Emissions Limitation [Section C.1.f)(1)a.]

a. Shelly Comment: Response to OEPA’s ‘working copy’ was filling in tons per year as submitted in their application.

b. Ohio EPA Response: In the issued draft PTIO, OEPA already updated the tons per year limits based on information in Shelly’s application.

30. Topic: Testing Requirements – Temperature [Section C.1.f)(1)a.]

a. Shelly Comment: Deleted language and revised under “P; deleted basis language on the temperature. The asphalt storage tanks at the Gallipolis Terminal are heated to 300oF and insulated; therefore, ambient temperature fluctuations do not affect the bulk liquid temperature.

b. Ohio EPA Response: Ohio EPA has revised language in the calculations and made changes necessary.

31. Topic: Testing Requirements – Emissions Limitation [Section C.1.f)(2)a.-g.]

a. Shelly Comment: Deleted testing language. Shelly conducted performance testing in July 2012.

b. Ohio EPA Response: Ohio EPA does not agree to remove this condition. Stack testing is required to determine initial compliance.

32. Topic: Miscellaneous Requirements [Section C.1.g)(2)]

a. Shelly Comment: Added g)(2) “This emission unit is equipped with a carbon bed for odor minimization.”

b. Ohio EPA Response: Ohio EPA accepts this revision and has added that language to Section g).




33. Topic: Monitoring and/or Recordkeeping Requirements [Section B.4.a)a., c., d.]

a. Shelly Comment: Deleted certified accuracy device under a.; deleted daily basis of temperature and inserted monthly basis under b.; deleted and added language for psia under d. to read “as supplied in permittee’s application”.

b. Ohio EPA Response: Ohio EPA has made the changes to the language as requested.

34. Topic: Monitoring and Recordkeeping Requirements [Section B.4.b)]

a. Shelly Comment: Deleted this language regarding material analysis. Shelly requested the removal of this requirement to conduct sampling as the asphalt vapor pressure is a conservative estimate based on information previously submitted, and that Shelly does not receive any certified material analyses with each barge shipment.

b. Ohio EPA Response: Ohio EPA has deleted this requirement.

35. Topic: Testing Requirements [Section B.6.a)(1)a.]

a. Shelly Comment: Deleted annual throughput restriction of 131,670,000 and commented that this compliance demonstration should be performed using the actual data rather than the maximum, worst-case data. Shelly deleted part of the language how true vapor pressure shall be determined using the results of the analysis under “P”. Under “Tβ”, the language was changed to reflect “monthly temperature of bulk liquid” as compliance should be demonstrated using the actual data rather than the maximum, worst-case data.

b. Ohio EPA Response: Ohio EPA has made the requested changes.

36. Topic: Applicable Emissions Limitations and/or Control Requirements, and Testing Requirements [Section C.1.b)(1)a., C.1.f)(1)a., and C.1.f)(1)b.]

a. Shelly Comment: Corrected tons per year limit for VOCs and PE pursuant to application.

b. Ohio EPA Response: Ohio EPA has corrected the tons per year limit.


a. Shelly Comment: Deleted Visible PE BAT.

b. Ohio EPA Response: Ohio EPA does not agree to this change. “Old” BAT is to be used and this is the appropriate “old” BAT language.

38. Topic: Applicable Emissions Limitations and/or Control Requirements [Section C.1.b)(1)b.]

a. Shelly Comment: Deleted less stringent language.

b. Ohio EPA Response: Ohio EPA does not agree to this change. Since “old” BAT is used in C.1.b)(1)a., this less stringent language is applicable.




a. Shelly Comment: Deleted ongoing compliance is based on testing.

b. Ohio EPA Response: Ohio EPA does not agree to remove this condition as stack testing is required to determine initial compliance.


a. Shelly Comment: Deleted testing language. Shelly commented that they will be conducting Method 21 monitoring for the carbon absorbers associated with T006 and T007; therefore, additional performance testing using Method 25 will not be necessary.



41. Topic: Testing Requirements [Section B.6.a)(1)b.]

a. Shelly Comment: Inserted “per the permittee’s application”, and deleted temperature of 300oF.

b. Ohio EPA Response: Ohio EPA is agreeable to these changes.

42. Topic: Testing Requirements [Section C.1.f)(1)a.]

a. Shelly Comment: Deleted temperature of 300oF.

b. Ohio EPA Response: Ohio EPA is agreeable to this change.


a. Shelly Comment: Deleted ongoing compliance is based on testing.

b. Ohio EPA Response: Ohio EPA does not agree to remove this condition as stack testing is required to determine initial compliance.


a. Shelly Comment: Deleted testing language. Shelly commented that they will be conducting Method 21 monitoring for the carbon absorbers associated with T006 and T007; therefore, additional performance testing using Method 25 will not be necessary.


FINAL

Division of Air Pollution ControlPermit-to-Install and Operate

forShelly Liquid Division

Facility ID: 0627000046Permit Number: P0118909Permit Type: Initial InstallationIssued: 3/14/2017Effective: 3/14/2017Expiration: 4/20/2021

Division of Air Pollution ControlPermit-to-Install and Operate

forShelly Liquid Division

Table of Contents

Authorization ..................................................................................................................................................... 1A. Standard Terms and Conditions .................................................................................................................. 3

1. What does this permit-to-install and operate ("PTIO") allow me to do?................................................... 42. Who is responsible for complying with this permit? ................................................................................ 43. What records must I keep under this permit? ......................................................................................... 44. What are my permit fees and when do I pay them?................................................................................ 45. When does my PTIO expire, and when do I need to submit my renewal application? ............................ 46. What happens to this permit if my project is delayed or I do not install or modify my source? ................ 57. What reports must I submit under this permit? ....................................................................................... 58. If I am required to obtain a Title V operating permit in the future, what happens to the operating

provisions and PER obligations under this permit? ................................................................................ 59. What are my obligations when I perform scheduled maintenance on air pollution control equipment? ... 510. Do I have to report malfunctions of emissions units or air pollution control equipment? If so, how must I

report? ................................................................................................................................................... 611. Can Ohio EPA or my local air agency inspect the facility where the emission unit(s) is/are located? ..... 612. What happens if one or more emissions units operated under this permit is/are shut down

permanently? ......................................................................................................................................... 613. Can I transfer this permit to a new owner or operator?........................................................................... 714. Does compliance with this permit constitute compliance with OAC rule 3745-15-07, "air pollution

nuisance"? ............................................................................................................................................. 715. What happens if a portion of this permit is determined to be invalid? ..................................................... 7

B. Facility-Wide Terms and Conditions............................................................................................................. 8C. Emissions Unit Terms and Conditions ....................................................................................................... 13

1. Emissions Unit Group -Loading Racks: J001 and J002,...................................................................... 14

Final Permit-to-Install and OperateShelly Liquid Division


Effective Date: 3/14/2017

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AuthorizationFacility ID: 0627000046Application Number(s): A0047470, A0055313, A0055785Permit Number: P0118909Permit Description: This initial synthetic minor installation permit is for the loading racks at the facility that

had previously not been permitted. After a review of the maximum asphalt handling capacity of the facility, the loading rack emissions are based on a synthetic minor restriction of the liquid asphalt throughput of 131,669,741 gallons per rolling 12-month, as requested by the facility.

Permit Type: Initial InstallationPermit Fee: $1,200.00Issue Date: 3/14/2017Effective Date: 3/14/2017Expiration Date: 4/20/2021Permit Evaluation Report (PER) Annual Date: Jan 1 - Dec 31, Due Feb 15

This document constitutes issuance to:

Shelly Liquid Division1400 State Route 7 NorthGallipolis, OH 45631

of a Permit-to-Install and Operate for the emissions unit(s) identified on the following page.

Ohio Environmental Protection Agency (EPA) District Office or local air agency responsible for processing and administering your permit:

Ohio EPA DAPC, Southeast District Office2195 Front StreetLogan, OH 43138(740)385-8501

The above named entity is hereby granted this Permit-to-Install and Operate for the air contaminant source(s) (emissions unit(s))listed in this section pursuant to Chapter 3745-31 of the Ohio Administrative Code. Issuance of this permit does not constitute expressed or implied approval or agreement that, if constructed or modified in accordance with the plans included in the application, the described emissions unit(s) will operate in compliance with applicable State and federal laws and regulations.

This permit is granted subject to the conditions attached hereto.

Ohio Environmental Protection Agency

Craig W. ButlerDirector




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Authorization (continued)Permit Number: P0118909Permit Description: This initial synthetic minor installation permit is for the loading racks at the facility that

had previously not been permitted. After a review of the maximum asphalt handling capacity of the facility, the loading rack emissions are based on a synthetic minor restriction of the liquid asphalt throughput of 131,669,741 gallons per rolling 12-month, as requested by the facility.

Permits for the following Emissions Unit(s) or groups of Emissions Units are in this document as indicated below:

Group Name: Loading RacksEmissions Unit ID: J001

Company Equipment ID: J001Superseded Permit Number:General Permit Category andType: Not Applicable

Emissions Unit ID: J002Company Equipment ID: J002Superseded Permit Number:General Permit Category andType: Not Applicable




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A. Standard Terms and Conditions




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1. What does this permit-to-install and operate ("PTIO") allow me to do?

This permit allows you to install and operate the emissions unit(s) identified in this PTIO. You must install and operate the unit(s) in accordance with the application you submitted and all the terms and conditions contained in this PTIO, including emission limits and those terms that ensure compliance with the emission limits (for example, operating, recordkeeping and monitoring requirements).

2. Who is responsible for complying with this permit?

The person identified on the "Authorization" page, above, is responsible for complying with this permit until the permit is revoked, terminated, or transferred. "Person" means a person, firm, corporation, association, or partnership. The words "you," "your," or "permittee" refer to the "person" identified on the "Authorization" page above.

The permit applies only to the emissions unit(s) identified in the permit. If you install or modify any other equipment that requires an air permit, you must apply for an additional PTIO(s) for these sources.

3. What records must I keep under this permit?

You must keep all records required by this permit, including monitoring data, test results, strip-chart recordings, calibration data, maintenance records, and any other record required by this permit for five years from the date the record was created. You can keep these records electronically, provided they can be made available to Ohio EPA during an inspection at the facility. Failure to make requested records available to Ohio EPA upon request is a violation of this permit requirement.

4. What are my permit fees and when do I pay them?

There are two fees associated with permitted air contaminant sources in Ohio:

PTIO fee.This one-time fee is based on a fee schedule in accordance with Ohio Revised Code (ORC) section 3745.11, or based on a time and materials charge for permit application review and permit processing if required by the Director.

You will be sent an invoice for this fee after you receive this PTIO and payment is due within 30 days of the invoice date. You are required to pay the fee for this PTIO even if you do not install or modify your operations as authorized by this permit.

Annual emissions fee.Ohio EPA will assess a separate fee based on the total annual emissions from your facility. You self-report your emissions in accordance with Ohio Administrative Code (OAC) Chapter 3745-78. This fee assessed is based on a fee schedule in ORC section 3745.11 and funds Ohio EPA's permit compliance oversight activities. For facilities that are permitted as synthetic minor sources, the fee schedule is adjusted annually for inflation. Ohio EPA will notify you when it is time to report your emissions and to pay your annual emission fees.

5. When does my PTIO expire, and when do I need to submit my renewal application?

This permit expires on the date identified at the beginning of this permit document (see "Authorization"page above) and you must submit a renewal application to renew the permit. Ohio EPA will send a renewal notice to you approximately six months prior to the expiration date of this permit. However, it is




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very important that you submit a complete renewal permit application (postmarked prior to expiration of this permit) even if you do not receive the renewal notice.

If a complete renewal application is submitted before the expiration date, Ohio EPA considers this a timely application for purposes of ORC section 119.06, and you are authorized to continue operating the emissions unit(s) covered by this permit beyond the expiration date of this permit until final action is taken by Ohio EPA on the renewal application.

6. What happens to this permit if my project is delayed or I do not install or modify my source?

This PTIO expires 18 months after the issue date identified on the "Authorization" page above unless otherwise specified if you have not (1) started constructing the new or modified emission sources identified in this permit, or (2) entered into a binding contract to undertake such construction. This deadline can be extended by up to 12 months, provided you apply to Ohio EPA for this extension within a reasonable time before the 18-month period has ended and you can show good cause for any such extension.

7. What reports must I submit under this permit?

An annual permit evaluation report (PER) is required in addition to any malfunction reporting required by OAC rule 3745-15-06 or other specific rule-based reporting requirement identified in this permit. Your PER due date is identified in the Authorization section of this permit.

8. If I am required to obtain a Title V operating permit in the future, what happens to the operating provisions and PER obligations under this permit?

If you are required to obtain a Title V permit under OAC Chapter 3745-77 in the future, the permit-to-operate portion of this permit will be superseded by the issued Title V permit. From the effective date of the Title V permit forward, this PTIO will effectively become a PTI (permit-to-install) in accordance with OAC rule 3745-31-02(B). The following terms and conditions of this permit will no longer be applicable after issuance of the Title V permit: Section B, Term 1.b) and Section C, for each emissions unit, Term a)(2).

The PER requirements in this permit remain effective until the date the Title V permit is issued and is effective, and cease to apply after the effective date of the Title V permit. The final PER obligation will cover operations up to the effective date of the Title V permit and must be submitted on or before the submission deadline identified in this permit on the last day prior to the effective date of the Title V permit.

9. What are my obligations when I perform scheduled maintenance on air pollution control equipment?

You must perform scheduled maintenance of air pollution control equipment in accordance with OAC rule 3745-15-06(A). If scheduled maintenance requires shutting down or bypassing any air pollution control equipment, you must also shut down the emissions unit(s) served by the air pollution control equipment during maintenance, unless the conditions of OAC rule 3745-15-06(A)(3) are met. Any emissions that exceed permitted amount(s) under this permit (unless specifically exempted by rule) must be reported as deviations in the annual permit evaluation report (PER), including nonexempt excess emissions that occur during approved scheduled maintenance.




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10. Do I have to report malfunctions of emissions units or air pollution control equipment? If so, how must I report?

If you have a reportable malfunction of any emissions unit(s) or any associated air pollution control system, you must report this to the [DO/LAA] in accordance with OAC rule 3745-15-06(B). Malfunctions that must be reported are those that result in emissions that exceed permitted emission levels. It is your responsibility to evaluate control equipment breakdowns and operational upsets to determine if a reportable malfunction has occurred.

If you have a malfunction, but determine that it is not a reportable malfunction under OAC rule 3745-15-06(B), it is recommended that you maintain records associated with control equipment breakdown or process upsets. Although it is not a requirement of this permit, Ohio EPA recommends that you maintain records for non-reportable malfunctions.

11. Can Ohio EPA or my local air agency inspect the facility where the emission unit(s) is/are located?

Yes. Under Ohio law, the Director or his authorized representative may inspect the facility, conduct tests, examine records or reports to determine compliance with air pollution laws and regulations and the terms and conditions of this permit. You must provide, within a reasonable time, any information Ohio EPA requests either verbally or in writing.

12. What happens if one or more emissions units operated under this permit is/are shut down permanently?

Ohio EPA can terminate the permit terms associated with any permanently shut down emissions unit. "Shut down" means the emissions unit has been physically removed from service or has been altered in such a way that it can no longer operate without a subsequent "modification" or "installation" as defined in OAC Chapter 3745-31.

You should notify Ohio EPA of any emissions unit that is permanently shut down by submitting a certification that identifies the date on which the emissions unit was permanently shut down. The certification must be submitted by an authorized official from the facility. You cannot continue to operate an emission unit once the certification has been submitted to Ohio EPA by the authorized official.

You must comply with all recordkeeping and reporting for any permanently shut down emissions unit in accordance with the provisions of the permit, regulations or laws that were enforceable during the period of operation, such as the requirement to submit a PER, air fee emission report, or malfunction report. You must also keep all records relating to any permanently shutdown emissions unit, generated while the emissions unit was in operation, for at least five years from the date the record was generated.

Again, you cannot resume operation of any emissions unit certified by the authorized official as beingpermanently shut down without first applying for and obtaining a permit pursuantto OAC Chapter 3745-31.




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13. Can I transfer this permit to a new owner or operator?

You can transfer this permit to a new owner or operator. If you transfer the permit, you must follow the procedures in OAC Chapter 3745-31, including notifying Ohio EPA or the local air agency of the change in ownership or operator. Any transferee of this permit must assume the responsibilities of the transferor permit holder.

14. Does compliance with this permit constitute compliance with OAC rule 3745-15-07, "air pollution nuisance"?

This permit and OAC rule 3745-15-07 prohibit operation of the air contaminant source(s) regulated under this permit in a manner that causes a nuisance. Ohio EPA can require additional controls or modification of the requirements of this permit through enforcement orders or judicial enforcement action if, upon investigation, Ohio EPA determines existing operations are causing a nuisance.

15. What happens if a portion of this permit is determined to be invalid?

If a portion of this permit is determined to be invalid, the remainder of the terms and conditions remain valid and enforceable. The exception is where the enforceability of terms and conditions are dependent on the term or condition that was declared invalid.




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B. Facility-Wide Terms and Conditions




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1. This permit document constitutes a permit-to-install issued in accordance with ORC 3704.03(F) and a permit-to-operate issued in accordance with ORC 3704.03(G).

a) For the purpose of a permit-to-install document, the facility-wide terms and conditions identified below are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) None.

b) For the purpose of a permit-to-operate document, the facility-wide terms and conditions identified below are enforceable under state law only with the exception of those listed below which are federally enforceable.

(1) 2.a), 3.a), 4.a), 5.a) and 6.a)

2. Applicable Emissions Limitations and/or Control Requirements

3. Operational Restrictions

a) The maximum combined annual throughput rate for J001 and J002, combined, shall not exceed 131,669,741 gallons, based upon a rolling, 12-month summation of the throughput rates. Emissions units J001 and J002 have been in operation for more than 12 months and, as such, the permittee has existing records to generate the rolling, 12-month summation of the throughput rate, upon issuance of this permit. The maximum annual throughput rate of EUs J001 and J002 inherently restricts the annual throughput of storage tanks T001, T002, T003, T004, T005, T006, T007, T010, T011, T012 and T013.

Combined potential emissions from all other emissions units at the facility including de minimis units, permit exempt units, and B001 are less than 2 TPY. The permittee is advised that prior to installing any other VOC sources, that they must evaluate facility-wide potential to emit and apply for and obtain any needed federally enforceable restrictions to limit emissions below major source threshold.

4. Monitoring and/or Recordkeeping Requirements

a) The permittee shall maintain monthly records of the following information for J001, J002, T001-T007, and T010-T013:

a. the throughput of liquid asphalt through each loading rack, in gallons;

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

(1) OAC rule 3745-31-05(D)(Synthetic minor restriction to avoid Title V requirements)

Volatile organic compound (VOC) emissions from all permitted sources at the facility (emissions units J001, J002, T001-T007, and T010-T013) shall be less than 98.0 tons per rolling, 12-month period.

See 3.a) below.




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b. the loading loss from the loading rack, in pounds of VOC per 1,000 gallons, as calculated based on the equation in 6.a)(1)a.;

c. the monthly temperature of the bulk liquid (obtained from the temperature gauge on tank), in oR;

d. the true vapor pressure of the liquid loaded;

e. the VOC emissions, in tons, as calculated based on the equations in 6.a)(1)a. and b.; and

f. the rolling, 12-month summation of the total VOC emissions, in tons, as calculated based on the equation in 6.a)(1)c.

5. Reporting Requirements

a) The permittee shall submit quarterly deviation (excursion) reports for J001, J002, T001-T007, and T010-T013 that identify:

(1) all deviations (excursions) of the following emission limitations, operational restrictions and/or control device operating parameter limitations that restrict the potential to emit (PTE) of any regulated air pollutant and have been detected by the monitoring, record keeping and/or testing requirements in this permit:

a. all exceedances of the rolling, 12-month VOC limitation and/or throughput rate.

b. the probable cause of each deviation (excursion);

c. any corrective actions that were taken to remedy the deviations (excursions) or prevent future deviations (excursions); and

d. the magnitude and duration of each deviation (excursion).

If no deviations (excursions) occurred during a calendar quarter, the permittee shall submit a report that states that no deviations (excursions) occurred during the quarter. The quarterly reports shall be submitted, electronically through Ohio EPA Air Services, each year by January 31 (covering October to December), April 30 (covering January to March), July 31 (covering April to June), and October 31 (covering July to September), unless an alternative schedule has been established and approved by the Director (the appropriate District Office or local air agency).

6. Testing Requirements

a) Compliance with the emissions limitations and/or control requirements specified in b)(1) of these terms and conditions shall be determined in accordance with the following methods:

(1) Emissions Limitation:VOC emissions from all permitted sources at the facility (emissions units J001, J002, T001-T007, and T010-T013) shall be less than 98.0 tons per rolling, 12-month period.




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Applicable Compliance Method:Compliance with the rolling, 12-month emissions limitation for VOC shall be demonstrated by the following calculations based on the emissions estimation equations in AP-42 Chapter 5.2 (6/08) and AP-42 Section 7.1.3.1 (11/06) and the information collected pursuant to the recordkeeping requirements in 4.a) of this permit.

a. Rolling, 12-month Loading Rack VOC Emissions

X = (G)(LL) * 1 ton/2,000 lbs

where:

X =tons of VOC emissions per rolling, 12-month from the loading racks;G= annual throughput of liquid asphalt through the loading racks, in Mgallons;

andLL = VOC loading loss, in pounds of VOC per 1,000 gallons of liquid asphaltloaded, calculated based on the following equation:

LL = 12.46 X SPM/T

where:

LL = maximum hourly VOC loading loss of 0.26 pounds of VOC per 1,000 gallons of liquid loaded;

S = saturation factor for clean cargo tank of 1.45 from AP-42 Table 5.2-1 (6/08);

P = true vapor pressure of liquid loaded as adjusted based on site-specific data as provided in permittee’s application;

M = molecular weight of vapors of 84 lb/lb-mole from information obtained by permittee; and

T = monthly temperature of bulk liquid.

b. Normal tank operations:

Y =∑ VOC emissions per month from each tank (EUs T001-T007, T010-T013) during normal operation, as calculated using the following equations:

LT = (LS + LW) X 1 ton/2,000 lbs

where:

LT = total loss in tons per month;LS = standing storage losses in lbs/month; as calculated based on Equation 1-2 from AP-42 Chapter 7.1 (11/06);LW = working losses in lbs/month; as calculated based on Equation 1-29 from

AP-42 Chapter 7.1 (11/06);

Maximum potential based on loading rack synthetic minor restriction per the permittee’s application, physical characteristics of the tanks, liquid asphalt properties, tank heated temperature per the permittee’s application, and the




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vapor pressure adjustment based on site-specific data as provided in the permittee’s application.

c. Total VOC Emissions (per rolling, 12-month period)

N∑ (X) + (Y) is ≤ 98.0 tons VOC, as a rolling 12-month summationi =1

where:

N = months in the rolling, 12-month period.

7. The emission units in this permit are not subject to the requirements of Title 40, Code of Federal Regulations, Part 63, Subpart LLLLL given that the facility is not a major source of hazardous air pollutants.

8. The emission units in this permit are not subject to the requirements of Title 40, Code of Federal Regulations, Part 63, Subpart AAAAAAA given that the facility does not contain any asphalt blowing stills and is not classified as “asphalt roofing manufacturing.”

9. The emission units in this permit are not subject to the requirements of Title 40, Code of Federal Regulations, Part 60, Subpart UU given that the permittee does not blow asphalt for use in the manufacture of asphalt products and does not produce any asphalt roofing products.




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C. Emissions Unit Terms and Conditions




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1. Emissions Unit Group -Loading Racks: J001 and J002,

EU ID Operations, Property and/or Equipment DescriptionJ001 Asphalt Loading Rack #1 (J001) - Uncontrolled asphalt loading rack with one connection

manifold. Maximum combined annual throughput restriction with loading rack #2 (J002) of 131,669,741 gallons per year based on a synthetic minor restriction.

J002 Asphalt Loading Rack #2 (J002) - Uncontrolled asphalt loading rack with two connection manifold. Maximum combined annual throughput restriction with loading rack #1 (J001) of 131,669,741 gallons per year based on a synthetic minor restriction.

a) This permit document constitutes a permit-to-install issued in accordance with ORC 3704.03(F) and a permit-to-operate issued in accordance with ORC 3704.03(G).

(1) For the purpose of a permit-to-install document, the emissions unit terms and conditions identified below are federally enforceable with the exception of those listed below which are enforceable under state law only.

a. g)(1).

(2) For the purpose of a permit-to-operate document, the emissions unit terms and conditions identified below are enforceable under state law only with the exception of those listed below which are federally enforceable.

a. None.

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operation(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures are identified below. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(A)(3) Volatile Organic Compound (VOC) emissions shall not exceed 24.0 pounds per hour and 17.32 tons per year

Particulate emissions (PE) shall not exceed 6.77 pounds per hour and 4.89 tons per year.

Visible PE from the stack serving this emissions unit shall not exceed zero percent (0%) opacity as a six-minute average.

b. OAC rule 3745-17-07(A) Visible PE from the stack serving this emissions unit shall not exceed 20%




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Applicable Rules/Requirements Applicable Emissions Limitations/Control Measuresopacity as a six-minute average, except as provided by the rule.

This PE limitation is less stringent than the limitation listed under OAC rule 3745-31-05(A)(3).

c. OAC rule 3745-17-11(B)(Table 1)

This PE limitation is less stringent than the limitation listed under OAC rule 3745-31-05(A)(3).

d. OAC rule 3745-31-05(D)(Synthetic Minor to avoid Title V applicability)

See Section B. above.

(2) Additional Terms and Conditions

a. None.

c) Operational Restrictions

(1) Annual Throughput from J001 and J002, combined, shall not exceed 131,669,741 gallons per rolling, 12-month period.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following for J001 and J002:

a. Total operating hours;

b. Average hourly emissions (lbs/hr); and

c. Total throughput of J001 and J002 combined.

e) Reporting Requirements

(1) All applications, notifications or reports required by terms and conditions in this permit to be submitted or "reported in writing" are to be submitted to Ohio EPA through the Ohio EPA's eBusiness Center: Air Services web service ("Air Services"). Ohio EPA will accept hard copy submittals on an as-needed basis if the permittee cannot submit the required documents through the Ohio EPA eBusiness Center. In the event of an alternative hard copy submission in lieu of the eBusiness Center, the post-marked date or the date the document is delivered in person will be recognized as the date submitted. Electronic submission of applications, notifications, or reports required to be submitted to Ohio EPA fulfills the requirement to submit the required information to the Director, the District Office or Local Air Agency, and/or any other individual or organization specifically identified as an additional recipient identified in this permit unless otherwise specified. Consistent with OAC rule 3745-15-03, the required application, notification or report is considered to be "submitted" on the date the




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submission is successful using a valid electronic signature. Signature by the signatory authority may be represented as provided through procedures established in Air Services.

(2) The permittee shall submit an annual Permit Evaluation Report (PER) to the Ohio EPA. The PER must be submitted by the due date identified in the Authorization section of this permit. The permit evaluation report shall cover a reporting period of no more than twelve months for each air contaminant source identified in this permit.

(3) The permittee shall submit a deviation report for any exceedance of the average hourly emissions limit within 30 days.

(4) The permittee shall submit quarterly deviation (excursion) reports that identify:

a. all deviations (excursions) of the following emission limitations, operational restrictions and/or control device operating parameter limitations that restrict the potential to emit (PTE) of any regulated air pollutant and have been detected by the monitoring, record keeping and/or testing requirements in this permit:

any exceedance of the combined throughput limitation of 131,669,741 gallons of liquid asphalt during a rolling, 12-month period

b. the probable cause of each deviation (excursion);

c. any corrective actions that were taken to remedy the deviations (excursions) or prevent future deviations (excursions); and

d. the magnitude and duration of each deviation (excursion).

If no deviations (excursions) occurred during a calendar quarter, the permittee shall submit a report that states that no deviations (excursions) occurred during the quarter.

The quarterly reports shall be submitted each year by January 31 (covering October to December), April 30 (covering January to March), July 31 (covering April to June), and October 31 (covering July to September), unless an alternative schedule has been established and approved by the Director (the appropriate District Office or local air agency).

f) Testing Requirements

(1) Compliance with the Emissions Limitations and/or Control Requirements specified in section b) of these terms and conditions shall be determined in accordance with the following methods:

a. Emissions Limitation:

VOC emissions shall not exceed 24.0 pounds per hour and 17.32 tons per year.

Applicable Compliance Method:The short-term emissions limitation was derived by the following calculation based on a maximum liquid asphalt throughput of 90,000 gallons per hour, a




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maximum true vapor pressure of 0.13 psia, and a maximum temperature of bulk liquid loaded of 759.67 R:

X (lb/hr) = (G/1,000 gallons)(LL)

where:

X =pounds of VOC emissions per hour;G= maximum hourly liquid asphalt throughput of the loading rack of 90,000

gallons, andLL = maximum hourly VOC loading loss of 0.26 pounds of VOC per 1,000

gallons of liquid loaded, calculated based on the following equation:

LL = 12.46 X SPM/T

where:

LL = loading loss, in lb VOC/1,000 gallons of liquid loaded;S = saturation factor for clean cargo tank of 1.45 from AP-42 Table

5.2-1 (6/08);P = maximum true vapor pressure of liquid loaded of 0.13 psia; vapor

pressure results from analysis of liquid asphalt at Gallipolis facility;M = molecular weight of vapors of 84 lb/lb-mole from information in

permittee’s application; andT = maximum temperature of bulk liquid.

Ongoing compliance is based on emissions testing as required in f)(2).

Compliance with the tons per year synthetic minor limitation was arrived at by the following calculation:

Maximum loading rate of 131,669,741 gal/yr * 1/1,000 * 0.26 lb VOC/gal * 1/2,000 = 17.32 tons per year

b. Emissions Limitation:

PE shall not exceed 6.77 pounds per hour and 4.89 tons per year.

Applicable Compliance Method:Compliance with the short-term emissions limitation shall be determined by multiplying the pounds per hour VOC emissions (as determined in f)(1)a., above) by the appropriate scaling factor to convert the calculated emission rates for VOC to emission rates for PM. The scaling factors were determined using literature values relevant to the asphalt industry based on historic PM/VOC portioning data for asphalt storage tanks (as provided in the permittee’s application), where particulate is approximately 22% of the hydrocarbon fume and VOCs are 78%.

Normal tank operations:

X =(hourly VOC emissions / 0.78) * 0.22




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PM emissions calculated based on Table 4 of Estimates of Air Emissions from Asphalt Storage Tanks and Truck Loading (Environmental Progress Vol. 18, No. 4, by David C. Trumbore).

Compliance with the tons per year synthetic minor limitation was arrived at by the following calculation:

(17.32 tons VOC/yr / 0.78) * 0.22

(2) The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the following requirements:

a. The emission testing shall be conducted within the first peak production season following issuance of this permit, and as required by the Director.

b. The emission testing shall be conducted to demonstrate compliance with the VOC limitation, and shall be tested at a location prior to the carbon adsorber.

c. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission rate(s):

Method 25 from 40 CFR Part 60, Appendix A.

Alternative U.S. EPA approved test methods may be used with prior approval from the Ohio EPA.

d. During the emissions testing, the emissions unit shall be operated under operational conditions approved in advance by the appropriate Ohio EPA District Office or local air agency. Operational conditions that may need to be approved include, but are not limited to, the production rate, the type of material processed, material make-up (solvent content, etc.), or control equipment operational limitations (burner temperature, precipitator voltage, etc.). In general, testing shall be done under “worst case” conditions expected during the life of the permit. As part of the information provided in the “Intent to Test” notification form described below, the permittee shall provide a description of the emissions unit operational conditions they will meet during the emissions testing and describe why they believe “worst case” operating conditions will be met. Prior to conducting the test(s), the permittee shall confirm with the appropriate Ohio EPA District Office or local air agency that the proposed operating conditions constitute “worst case”. Failure to test under the approved conditions may result in Ohio EPA not accepting the test results as a demonstration of compliance.

e. Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test" notification to the appropriate Ohio EPA District Office or local air agency. The "Intent to Test" notification shall describe in detail the proposed test methods and procedures, the emissions unit operating parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA District Office's or local air agency's refusal to accept the results of the emission test(s).




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f. Personnel from the appropriate Ohio EPA District Office or local air agency shall be permitted to witness the test(s), examine the testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the performance of the control equipment.

g. A comprehensive written report on the results of the emissions test(s) shall be signed by the person or persons responsible for the tests and submitted to the appropriate Ohio EPA District Office or local air agency within 30 days following completion of the test(s). The permittee may request additional time for the submittal of the written report, where warranted, with prior approval from the appropriate Ohio EPA District Office or local air agency.

g) Miscellaneous Requirements

(1) Modeling to demonstrate compliance with, the “Toxic Air Contaminant Statute”, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit’s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires a permittee to apply for and obtain a new or modified PTIO prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new PTIO.

(2) The emissions unit is equipped with a carbon bed for odor minimization.

John R. Kasich, Governor Mary Taylor, Lt. Governor Craig W ...0.13 psia; and d. calculation method used to determine the true vapor pressure of the liquid asphalt material at the specified

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