VERMONT AGENCY OF NATURAL RESOURCESDepartment of Environmental Conservation

Air Pollution Control DivisionOperating Permit Program

TECHNICAL ANALYSIS OF AN AIR CONTAMINANT SOURCE

#AOP-95-086PIN#-RU96-0087

June 13. 1997

Prepared by: Mark Bannon, Environmental Engineer

APPLICANT: Mr. Brent MerriamQuestech Metals111 Exchange StreetMiddlebury, VT 05753

SOURCE: Questech Metals a.k.a. Intaglio Ltd.111 Exchange StreetMiddlebury, VT 05753

SIC CODE: 3089 - Misc. Plastic Products

CONTACT Mr. Brent MerriamAND RESPONSIBLE (802) 388-4567OFFICIAL:

COUNTY: Addison

AREA DESIGNATION: Attainment for PM10, SO2, NOx, CO, & PbUnclassified for ozone

UTM COORDINATES: 4876770 m N, 646610 m E - Center of Building

Questech

#AOP-95-086

1.0 Executive Summary

On July 12, 1990, the Agency of Natural Resources Air Pollution Control Division ("Agency") issued Air Pollution Control Permit #AP-90-027 to Intaglio Limited, now known as Questech Corporation, approving the construction of a decorative reinforced plastic/metal composite manufacturing operation at 111 Exchange Street in Middlebury, Questech uses a patented process that combines metal powders and plastic to make wall tiles, trim, signs, and plaques.

On November 23, 1992, the Agency issued a modification to Permit #AP-90-027 approving changes to the Questech manufacturing process. The modified Permit (#AP-90-027a) approved new materials and production techniques.

On September 24, 1996, the Agency received an application to modify Permit #AP-90-027a. Questech is proposing to modify condition six (6) of Permit #AP-90-027a to allow increased raw material usage.

1.1 Basis for Review

Pursuant to Section 5-401(11) of the Vermont Air Pollution Control Regulations (hereinafter "Regulations"), manufacturing, processing and application of chemicals including plastics, rubbers and resins is classified as air contaminant sources that may cause or contribute to air pollution.

Pursuant to Section 5-101(103) of the Regulations, a stationary source means any structures, equipment, installations, or operations, or combination thereof, which emit or may emit any air contaminant, which is located on one or more contiguous or adjacent properties and which is owned or operated under common control. Therefore, all of the equipment, operations, and structures at Questech's 111 Exchange Street property in Middlebury are classified together as one stationary source.

Questech is requesting approval to increase its raw material usage above the limits specified in condition six (a) in Air Pollution Control Permit #AP-90-

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027a. This request meets the definition of a modification as defined in Section 5-101 of the Regulations. Therefore, pursuant to Section 5-501 of the Regulations, the modified operations are subject to Agency review and approval.

1.2 Administrative MilestonesOn September 24, 1996, Questech submitted an application proposing to increase the quantities of raw materials used at the facility. On September 30, 1996, Questech submitted a $500 application review fee. The Agency found the application administratively complete on October 7, 1996. Notice of receipt of application was noticed in the Rutland Herald on November 7, 1996. On November 28, 1996, the application was found "technically" complete.

Table A: Administrative Summary

Administratve Item Result or Date

Date application received:

Date administratively complete:

Date and location notice of receipt published:

Date technically complete:

Date and location proposed decision noticed:

Proposed Decision Approved

Date and location of Public Meeting

Deadline for Public Comments

Classifcation of source under section 5-401

Classification of operating permit: (Non-Title V or Title V)

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NSR classification of source: (Major or Non-Major)

Facilities' SIC code(s):

Date Submited to EPA:

Allowable Emissions(ton/yr)

PM CO NOx SO2 VOC

2.0 Facility Description

2.1 Process Descriptions

Questech designs and manufactures reinforced plastic composites used for decorative architectural products including a collection of fire rated metal composite wall tiles, trim and decorative signs, and plaques.

Mold MakingQuestech starts its process by making a model used as a design template for various products. Models are made out of wood, polyurethane, and plexiglas. Small amounts of coating are applied in a small spray booth. The model is glued onto a board. The model sometimes receives additional treatments to aid the mold making process.

Molds consisting of a box frame in which the model is placed. Silicone rubber and small amounts of catalyst are automatically metered and mixed and finally injected into the box unit encapsulating the model. The rubber can be heat cured in an electric oven at less than 150 oF to speed processing. The model is then removed which leaves a silicone rubber mold.

Matrix MixUnsaturated polyester resin (styrene monomer and methyl methacrylate) is combined with a vapor suppressant additive (styrene and paraffin) and powdered fillers in a covered 55-gallon drum equipped with an industrial mixer. This mixture is called matrix. For some products, inorganic fire retardant fillers and fire resistant resins may

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be used. The unsaturated polyester resins require methyl ethyl ketone peroxide as a catalyst for polymerization.

Batch MixThe matrix mixture is then combined with metal powders, pigments, glass, or ceramic and an appropriate catalyst. The mixture is poured into open molds and allowed to harden (setup) for approximately 30 to 40 minutes. Test results have shown that maximum evaporation of VOCs occurs during the first 20 minutes of set up. Once solid, the products are removed. The products are then placed in a curing oven. The parts are baked for 4 hours at a temperature ranging from 175 0F to 225 0F in a propane fueled oven. The oven uses recirculating forced air (544 acfm) that exhausts through a roof vent.

Product ProcessingParts are then deburred (edged) using a belt sander or sandblaster (plastic pellets). An internal dust collection system consisting of collection hoods, a cyclone collector, and a filter bag house removes dust generated from the operation and returns filtered air to the room. Dust consists of plastic, ceramic and aluminum trihydrate.

The decorative surfaces of the parts are then buffed on bench and stand up lathes and semi-automatic machinery. A water-soluble buffing compound is used. Questech currently uses ultrasonics coupled with compatible aqueous chemistry to clean its product. The parts are sealed with a clear coating to protect the decorative surface. Questech uses acrylic polyurethane and acrylic laquer thinner. Ethyl acetate is used as a clean-up solvent. Coatings are applied in a spraybooth that exhausts through a roof vent. Coatings are then cured for 30 minutes at 140 - 200 oF in an eletric forced air recirculating oven equipped with an 80 - 225 cfm exhauster which exhausts through a roof vent.

2.4 Potential Air Contaminant Sources

Pursuant to Section 5-101(103) of the Regulations, a stationary source means any structures, equipment, installations, or operations, or combination thereof, which emit or may emit any air contaminant, which is located on one or more contiguous or adjacent properties and which is owned or operated under common control. Therefore, all of the equipment, operations, and structures located at Questech are classified together as one stationary source.

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Table B: Potential Air contaminant Sources, below, summarizes the processes and equipment which the Agency has determined to have the potential to cause or contribute to air pollution as defined in Section 5-101(7) of the Regulations.

Table B: Potential Air Contaminant SourcesEquipment or Process Pollutant(s) Control/Operating Limit

Model Making Glue polyurethane none

Matrix Mixing styrenemethyl methacrylate

covered containerparaffin added as vapor

suppressantraw resin limit: 300 lb/hr

Casting, Set-up & Curing styrene none

Coating and Drying various volatile organic compounds

spraybooth with fabric filterslow pressure spray guns

coating limit: 6 gal/hr

R&D Lab styrenevarious volatile organic

compounds

coating limit: 1 gal/8hrsMSDSs will be consulted prior to use for compliance with 5-

261

0.9 MMBtu/hr Bryan #2 Oil boiler

0.9 MMBtu/hr Weil-McLain LPG Boiler

combustion emissionsPM, NOx, CO, SO2, VOCs

none

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Table B: Equipment and Stack InformationDESCRIPTION ANDMODEL NUMBER**

STACK #

SIZE OR CAPACITY

(MAX. ALLOWED)

FUEL TYPE(S) OR

PROCESS INPUT

DATE INSTALLE

D

POLLUTION

CONTROL

EQUIPMENT*

FLOW RATE

(ACFM)

STACK

HEIGHT(FT)

EXITTEM

P.(K)

EMISSION RATE (lb/hr) ALLOWABLE

CO NOx PM VOC

SOx

Bryan Boiler CL90-W-FD0 #1 1 0.9 MMBTU/hr

#2 none 175

Notes: * C - Cyclone; S - Scrubber; ESP - Electrostatic Precipitator; FF - Fabric Filter; TO - Thermal Oxidizer; AM - Adsorption Media, CN - Condenser; SCR - Selective Catalytic Reduction; O - Other** Equipment listed in italics indicates that it is approved as an insignificant activity.

2.5 Description of Compliance Monitoring Devices

3.0 Emissions Profile

The quantification and characterization of emissions is necessary to establish the regulatory designation of the proposed modification and consequently the review performed to show compliance. Under Section 5-101 of the Regulations, a major stationary source means a source with allowable emissions of any air contaminant equal to or greater than 50 tons per year (5 tpy for lead). Sources with allowable emissions less than the major source thresholds are considered "non-major" or "minor" stationary sources.

The quantification and characterization of emissions is necessary to establish the regulatory designation of the modification of the boilers and consequently the review performed to show compliance. Under Section 5-101 of the Regulations, a major stationary source means a source with allowable emissions of any air contaminant equal to or greater than 50 tons per year (5 tpy for lead). Sources with allowable emissions less than the major source thresholds are considered "non-major" or "minor" stationary sources.

The designation of a stationary source is determined by its allowable emissions. A source's allowable emissions are developed using applicable emission standards in the Regulations, existing or proposed permit conditions, and engineering estimates based on the reported equipment parameters. If no regulation, enforceable condition, or inherent limit is considered appropriate, then allowable emissions are determined assuming continuous operation of the stationary source (i.e., 8760 hours per year) at maximum capacity.

3.2 Insignificant Activities

3.3 Alternate Operating Scenarios Identified in the Application

3.4 Significant Activity Allowable Emissions

Emissions generated by the combustion of liquid propane gas fuel and fuel oil consists primarily of particulate matter (PM/PM10), sulfur dioxide (SO2), oxides of nitrogen (NOx), carbon monoxide (CO), and volatile organic compounds (VOC). The Agency considers the emissions from the two boilers with a combined heat input of 1.8 million BTUs per hour to be negligible.

The majority of Questech's emissions are generated in the polymerization of its plastic and the coating operations. Questech currently operates under permit #AP-90-027a which places enforceable limits on raw material usage. Table 3:

Existing Allowable Emissions, below, summarizes the existing facilities' allowable emissions as they appear in permit #AP-90-027a.

Table 2: Existing Allowable Emissions (tpy) PM SO2 CO NOx VOC<1 <1 <1 <1 45

Questech is designated an existing non-major stationary source of air contaminants.

3.2 Designation of the Future Source

Questech's existing Allowable emissions were developed using conservative emission estimates available in 1992. Questech has since performed testing to better refine its emissions. The Agency considers the following assumptions valid for estimating the potential emissions from the Questech facility:

Table 3: Assumptions and Factors Used to Estimate EmissionsAssume:

Volatile Organic Compounds from Polymerization: 2 pounds/100 pounds resin used

styrene: 80% MEK: 5%

methyl methacrylate: 15%

Volatile Organic Compounds from Coatings: coatings are 72% volatile

Particulate Emissions From Processes: 1.2 pounds/hr based on 300 lb/hr resin usage limit

These assumptions and factors are based on stack testing performed on February 14, 1996 and evaporative loss testing February 8, 1996. Questech has proposed a maximum resin usage of 300 pounds per hour and a maximum coating usage of 6 gallons per hour. In consideration of the revised emission factors as appear in Table 3, above, Questech's Future Allowable Emissions will be:

3.5 Site-Wide Allowable Emissions

Table 4: Future Allowable Emissions (tpy) PM SO2 CO NOx VOC5 <1 <1 <1 46

Table A: Future Allowables, found in the Appendix, describe the calculations used to estimate future emissions. Questech will be designated as a non-major stationary source of air contaminants after modification. All pollutants will be limited to less than 50 tons per year after the proposed changes are made. Therefore, the modification is considered non-major, since there will not be an increase over fifty tons per year.

5.0 Emission Standards Review

The purpose of this section is to identify potentially applicable regulatory standards that may apply to the operations of the proposed source based on the information supplied in the application. Beyond identifying potentially pertinent standards, a discussion of the facilities' ability to comply is included also based on the information supplied in the application. Compliance will be verified by the Agency once the source is operating.

5.1 Vermont Air Pollution Control Regulations

Based on the information supplied in the application Questech is subject to the following Sections of the Regulations: 5-211(1), 5-241, 5-231(3), 5-251(3), 5-253.20, 5-261, 5-802 and 5-1004.

Section 5-211(1): This section specifies that emissions of visible air contaminants from any stack or vent at Questech may not exceed 20% opacity for a period or periods aggregating to six minutes or more in any hour, and never can they exceed 60% opacity. Visible air contaminants can be emitted from the boiler depending on the quality of operation, maintenance and fuel used. Based on information in the application, Questech is currently complying this section. Questech will be required to maintain and operate the equipment following the manufacturer's recommendations and to conduct annual boiler tuneups.

Sections 5-231(1): This section of the Regulations regulates the emissions of particulate matter (PM) from the processing operations at Questech. Section 5-231(1) regulates PM emitted from industrial process exhaust vents below the discharge rates identified within Table 1: Industrial Process Weight Standards of the Regulations. Assuming a resin limit of 300 lb/hr, emissions from each process stack servicing the resin mixing area is limited to less than 1.2 lb/hr. Questech's process emissions are emitted primarily as volatile compounds, however, it's possible that some of the organic compounds may condense and become entrained as aerosol particulate matter. Therefore, the Agency shall place a limit of 1.2 lb/hr as a limit in any proposed decision.

Sections 5-231(3): Section 5-231(3) regulates PM that may result from the combustion of fuels. The emission standard of 0.5 lb/MMBTU and 0.5 lb/hr applies

to each boiler. The use of liquid propane gas fuel according to the manufactures' specifications should comply with these standards. Excessive opacity would show that emissions are not complying with these particulate limits. Therefore, if excessive opacity is observed, Questech will be required to take corrective actions.

Section 5-241: This Section specifies that a source may not discharge, cause, suffer, allow, or permit air contaminants that will be a source of odors or a nuisance to any considerable number of people or to the public. Styrene and methylmethacrylate are considered odorous. The proposed modification includes provisions to automate the mixing of styrene containing materials. The automation should help to reduce fugitive emissions which contribute to odors. If odors are determined to impact off the property that would cause a nuisance, corrective actions will be required.

Section 5-253.20: This Section regulates the release of volatile organic compounds from facilities not subject to any other subsection of section 5-253. This section is applicable only if the facility has allowable VOC emissions greater than 50 tons per year. Questech's allowable emissions of VOCs are 46 tons per year. Therefore, this source is not subject to section 5-253.20 at this time.

Section 5-261: This Section addresses the release of hazardous air contaminants into the ambient air. This facility was reviewed for compliance in 1992 based on conservative emission estimates. As condition of the 1992 decision, stack testing was required. Based on the stack testing results, new emission factors have been used to estimate emissions. Using the new emission factors in conjunction with increasing the allowable raw resin use to accomodate a third shift, as proposed in this application, will increase the overall emissions by only 2 tons per year. Furthermore, the emissions on a per shift basis (lb/8hr) will not increase. According to Questech's application, all hazardous air contaminants will be emitted at rates below the Action Levels cited in Section 5-261 of the Regulations. Therefore, further review is not required.

Section 5-802: This Section requires sources emitting air contaminants at rates of five tpy or greater to register on an annual basis. Questech has been participating in the registration program since 1990.

Section 5-1004: This Section requires sources subject to Section 5-1003 to apply for an Operating Permit as described in Subchapter X of the Vermont Regulations. Questech is a designated source of air contaminants. Questech has submitted an administratively complete application for an operating permit. Therefore, Questech is currently operating in compliance with this section.

5.2 Federal Regulations

The federal government has not promulgated a national emission standard for hazardous air pollutants (NESHAP) in Title 40 Code of Federal Regulations Subpart 61 applicable to Questech. Furthermore, no New Source Performance Standard (NSPS) Title 40 CFR Subpart 60 that would apply to Questech has been promulgated. The federal government has promulgated Title 40 CFR Subpart 63 in accordance with Section 112 of the 1990 Clean Air Act. The type of activity conducted by Questech is not listed in the Source Category Schedule found in Section 112(e) promulgated on December 3, 1993 and does not appear as a source catergory to be listed in the future. Therefore, further review is not required.

5.0 Hazardous Air Contaminants

Section 5-261 of the Regulations addresses the release of hazardous air contaminants into the ambient air. If Section 5-261 is determined applicable, the source must then apply control technology. This control technology must show that the emissions will be controlled to the "hazardous most stringent emissions rate." An air quality impact evaluation may be required to further assess impacts that may be attributable to the source regarding hazardous ambient air standards.

5.1 Applicability Determination

Applicability with Section 5-261 is based on a comparison of allowable emissions of hazardous air contaminants with their respective "Action Level" (AL). A source is subject to Section 5-261 if any hazardous air contaminant exceeds its respective AL. Exceeding an Action Level only indicates that the source is subject to review under this section; the Action Levels are not emission limits. Table E, below summarizes the hazardous air contaminant emissions from the proposed facility. Coating system HAC emission rates were derived from the 5.5 x 10 -3 lb/hr rate described in section 3.2 multiplied by eight to calculate lb/8hr. Solvent emission rates were provided by EST.

The only contaminant found applicable to Section 5-261 was nickel. The powder coating used in the arc-plasma process contains between 33-45% nickel. Using the mass-balance estimate described in section 3.2, nickel could be potentially emitted at a rate of 0.02 lb/8hr. This

Table E: Hazardous Air Contaminant Emissions

CONTAMINANT EMISSIONS (LB/8HR)

CONTAMINANT EMISSIONS (LB/8HR)

xylene 0.008 methyl ethyl ketone 2.4

toluene 0.08 moly-disulfide 0.04

n-butyl alcohol 0.032 antimony trioxide 0.012

graphite 0.016 dibasic lead phosphite 0.016

formaldehyde 0.004 nitric acid 0.4

copper 0.013 indium 0.001

nickel * 0.019 2-butoxyethanol 0.008* Note: indicates pollutant emitted over the Action Level

estimate assumes that all of the over-spray is exhausted to the collection system and that none of the spray remains in the booth. The Agency has investigated dibasic lead phosphate in regards to the threshold for lead compounds (0.014 lb/8hr). Dibasic lead phosphate is estimated to be emitted at a rate of 0.016 lb/8hr, however, when the lead content is prorated based on the molecular weight, dibasic lead phosphate will not trigger an Action Level.

5.2 Hazardous Most Stringent Emission RateSection 5-261 states that "applicable sources shall apply control technology, production processes, or other techniques adequate to achieve the hazardous most stringent emission rate (HMSER). Once the Agency has determined HMSER for a stationary source and included it in an order, permit, or agreement, said determination shall remain in effect for five years. At the end of said five years, the determination shall expire unless the source demonstrates that such emission rate still represents HMSER."

EST has shown that fabric filtration technology designed to control emissions of particulate matter to 5 microns by 99.999% achieves the HMSER for this source. The HMSER for nickel from the arc-plasma coating processes at EST is 2.5 x 10-3 lb/hr.

5.3 Hazardous Air Contaminant Air Quality Impact Evaluation

Under Section 5-261, the Agency may require a subject source to submit an air quality impact evaluation which shows whether the source shall cause or contribute to ambient air concentrations in excess of any Hazardous Ambient Air Standard. EST has submitted a screening study to further investigate the ambient impacts. The Agency found this study inconclusive due to assumptions employed in the study. Nevertheless, the study showed that a higher stack was needed to promote good dispersion. EST has revised the original design to incorporate a 25-foot stack.

EST has supplemented the impact study with a discussion of the physical behavior of the submicron particles found in the coating. EST concludes that the over-spray materials tend to adhere to each other. As the particles adhere, the particle size increases and more of the material is caught in the control devices. The Agency has determined this argument to be supported by documented investigations into Van der Walls forces and Brownian motion studies.

Considering the physical behavior of the submicron particles and EST's use of a higher stack to provide better dispersion, the Agency has found that this source will not cause or contribute to a violation of the Hazardous Ambient Air Standard for nickel.

5.0 Control Technology Review

Section 5-502 of the Regulations requires that subject new sources and modifications apply control technology adequate to achieve the most stringent emission rate with respect to those air contaminants for which they would have a significant allowable emissions increase. As discussed Section 3.2 above, no significant increase is proposed. Therefore, the provisions of section 5-502 are not applicable to this project.

The proposed 5th CHP boiler is a small industrial class boiler with a heat input rating of 64.2 million Btu/hr while firing its primary fuel which is natural gas. Residual #6 grade fuel oil is being proposed as a secondary fuel. The Agency has determined the most stringent emission rate for sulfur dioxide from this unit is 0.5 lb/MMBtu (equivalent to Subpart Dc New Source Performance Standard) achievable through the use of fuel oil containing no more than 0.5% sulfur by weight.

_____________ has performed a top-down MSER analysis for the air contaminant NOx for this unit. That analysis ranked available options for NOx control based on firing the primary fuel, natural gas. Firing natural gas at the proposed limit resulted in the highest potential emissions. The Agency has determined the most stringent emission rate for oxides of nitrogen from this unit is 0.04 lb/MMBtu achievable through the use of a low-NOx burner and the application of flue-gas recirculation.

6.0 Public Involvement in the Application Process

The Agency found the application administratively complete on October 7, 1996. Notice of receipt of application was noticed in the Rutland Herald on November 7, 1996. On November 28, 1996, the application was found "technically" complete.

7.0 Conclusions

Based on this technical analysis of the proposed modification to Questech's manufacturing process, the following conclusions are made:

A. The proposed project, subject to the recommended permit conditions, will meet the applicable emission standards contained in the Regulations. Furthermore, it is expected that emissions from the proposed modification will not significantly deteriorate air quality, nor will they cause or contribute to a violation of an ambient air quality standard.

B. Pursuant to regulatory definition, the proposed source is designated as a non-major stationary source of air contaminants. The source is subject to the non-major supplementary application review fee of $1,250. According to procedures described in Title 10 V.S.A. '556, the Agency is not required to set up a public comment period.

C. It is expected that this facility will be subject to the requirements described in Section VIII: Registration of Air Contaminant Sources, of the Regulations.

E. Recommended Permit Conditions:

- Construction & Equipment Specifications -

(1) Questech shall install and operate its manufacturing process according to the plans and specifications submitted with its application to the Agency on March 16, 1990, November 23, 1992, and September 24, 1996.

(2) Questech shall operate both the high volume, low pressure turbo spray system and Binks Model 2001ss or equivalent, as described in its applications to the Agency.

(3) The spray booths shall be exhausted through Andrea particulate filters, or equivalent, designed to capture and remove particulate matter greater than 5 microns at an efficiency of at least 90%.

(4) Questech shall vent the exhaust gases from the processing room through a stack or stacks with an outlet greater than four (4) feet above any roofline or structure that may significantly interfere with the dispersion of the exhaust gases. Furthermore, the stack shall be vertical and shall not be equipped with any device that would obstruct the upward discharge of the exhaust gases.

- Operating Restrictions -

(5) Questech shall not process more than an average of 300 pounds of total raw resin per hour.

(6) Questech shall not spray more than an average of 6 gallons of total coatings per hour.

(7) Styrene emissions from the Questech facility shall not exceed the Action Level of 42.5 pounds per eight hours.

(8) Questech shall add a vapor suppressant when mixing polyester resin before casting and set up of production units. Said suppressant shall be of equal or greater efficiency in reducing emissions as the suppressants used during the emissions tests conducted in February 1996.

- R & D Lab Restrictions -

(9) Questech may conduct in-house experimentation investigating coatings and resins. Said experimentation shall be limited to the use of no more than 1 gallon of coating per 8 hours and 10 lbs of resin per 8 hours.

(10) The experimentation shall be conducted within the confines of the Questech processing room.

(11) The resins tested shall be of the same basic composition as those currently used. Material Safety Data Sheets shall be consulted and

emission estimates made before experimentation to ensure that emissions of hazardous air contaminants will remain below the relevant Action Levels specified in the Air Pollution Control Regulations.

- Odors & Visible Emissions -

(12) Emissions of visible air contaminants from any stack or vent at the facility shall not exceed twenty (20) percent opacity for a period or periods aggregating to six minutes or more in any hour, and at no time shall they exceed sixty (60) percent opacity. If any emission testing is conducted to demonstrate compliance with this limit, the owner of operator shall use proposed Reference Method F-1 printed in the Federal Register on August 29, 1986 or an alternative method approved in writing by the Agency before testing.

(13) Questech shall take reasonable precautions at all times to prevent the discharge of objectionable odors beyond the property lines of the facility.

(14) Emissions of particulate matter to the ambient air from each process stack is limited to less than 1.2 lb/hr. If any emission testing is conducted to demonstrate compliance with this limit, the owner of operator shall use Reference Method 5 of Appendix A of Title 40 Code of Federal Regulations Part 60 or an alternative method approved in writing by the Agency before testing.

- Record Keeping & Recording Requirements -

(15) Questech shall calculate and record the average total resin and coating used per hour at least once per day. Questech shall also maintain records or the amount of resin and coatings purchased per calendar year.

(16) Questech shall notify the Agency in writing within fifteen (15) days if any condition of this permit is violated.

(17) The operator shall notify the Agency in writing of any proposed physical or operational change at the facility that may increase the emission rate of any air contaminant to the ambient air. If the Agency finds that a permit amendment is required, a new application and the appropriate application fee shall be submitted. The permit amendment shall be issued before installing or commencing any such change.

(18) All records, reports, and notifications that are required to be submitted to the Agency by this Permit shall be submitted to:

Field Services SectionAir Pollution Control DivisionD.E.C., Agency of Natural Resources103 South Main Street, Bldg 3 SouthWaterbury, Vermont 05671-0402.

(19) All records shall be retained for a minimum period of five (5) years from the date of record and shall be made available to the Agency upon request.

(20) Annual Registration: The operator of a source which emits more than five tons of any and all air contaminants per year shall register the source with the Secretary, and shall renew such registration annually. Each day of operating a source which is subject to registration without a valid, current registration shall constitute a separate violation and subject the operator to a civil penalty not to exceed $100.00 per violation. The registration process shall follow the procedures set forth in Subchapter VIII of the Air Pollution Control Regulations. By February 1 of each year, the operator of each source subject to registration shall submit to the Air Pollution Control Officer source emissions data for the preceding year and any other information required to determine the appropriate registration fee. By May 15 of each year, the operator of each source subject to registration shall pay to the Air Pollution control Officer the appropriate fee, if any.

- Standard Conditions -

(21) These Permit conditions may be modified for cause upon the filing of a written request with the Secretary of the Agency (hereinafter "Secretary") or upon the Secretary's own motion. Any modification shall be granted only with the written approval of the Secretary. If the Secretary determines that modification is appropriate, only the conditions subject to modification shall be re-opened. The filing of a request for modification does not stay any terms or conditions of this Permit. The Secretary may provide opportunity for public comment on any proposed modification of these conditions. If public comments are solicited, the Secretary shall follow the procedures set forth in 10 V.S.A. Section 556 as revised.

(22) Approval to construct or modify under this Permit shall become invalid if construction or modification is not commenced within 18 months after issuance of this Permit, if construction or modification is

discontinued for a period of 18 months or more, or if construction or modification is not substantially completed within a reasonable time. The Agency may extend any one of these periods upon a satisfactory showing that an extension is justified. The term "commence" as applied to the proposed construction or modification of a source means that the owner or operator either has:

(a) Begun, or caused to begin, a continuous program of actual on-site construction or modification of the source, to be completed within a reasonable time; or

(b) Entered into binding agreements or contractual obligations, which cannot be canceled or modified without substantial loss to the owner or operator, to undertake a continuous program of actual on-site construction or modification of the source to be completed within a reasonable time.

(23) This Permit does not convey any property rights of any sort or any exclusive privilege, nor does it authorize any injury to private property or any invasion of personal rights.

(24) By acceptance of this Permit, the owner and operator agree to allow representatives of the State of Vermont access to the properties covered by the Permit, at reasonable times, to ascertain compliance with Vermont environmental and health statutes and regulations and with this Permit.

(25) All data, plans, specifications, analyses and other information submitted or caused to be submitted to the Agency as part of the application for this Permit or an amendment to this Permit shall be complete and truthful. Any such submission that is false or misleading shall be sufficient grounds for denial or revocation of this Permit, and may result in a fine and/or imprisonment under the authority of Vermont statutes.

(26) These Permit conditions shall be binding upon and enforceable against the current owner and operator and all subsequent owners and operators of the source.

(27) The provisions of this Permit are severable. If any provision of this Permit, or its application to any person, entity, or circumstance is held invalid, illegal, or unenforceable by court of competent jurisdiction, the invalidity shall not apply to any other portion of this Permit which can be given effect without the invalid provision or application thereof.

(28) The conditions set forth above supersede all conditions contained in the Agency's Air Pollution Control Permit #AP-90-027a granted to Intaglio, Ltd. on January 29, 1993.

APPENDIX

Figure 1: Plant Layout

Table A: Future Allowable Emissions Calculations