                   STATEMENT OF BASIS TO ISSUE A PERMIT TO 
          CONSTRUCT / RECONSTRUCT / MODIFY AN AIR CONTAMINANT SOURCE

Lincoln-Lancaster County Health Department
Environmental Public Health Division
Air Quality Program
3131 O Street
Lincoln, Nebraska 68510
Phone: (402) 441-8040             Fax: (402) 441-3890
                                                   Shavonna Lausterer, MPH, CPH
                                                                Health Director
                                                      Scott E. Holmes, REHS, MS
                                   Environmental Public Health Division Manager
                Gary R. Bergstrom, Jr.
                                                 Air Quality Program Supervisor

LLCHD Air Quality Program Source Number:
                                     00192
LLCHD Air Quality Program Construction Permit Number:
                                      199
Proposed Permit Issue Date:
                               September 1, 2018
The Lincoln-Lancaster County Health Department (LLCHD) has made the preliminary determination to issue a permit to construct / reconstruct / modify an air contaminant source to the following:
Permit Holder Name:
Mapes Panels, LLC
Address:
2929 Cornhusker Hwy.
City, County, State, ZIP:
Lincoln, Lancaster County, Nebraska  68504
The proposed permit allows for construction/reconstruction/modification at the following source:
Facility Site Name:
Mapes Panels, LLC
Facility Address:
2929 Cornhusker Hwy.
City, County, State, ZIP:
Lincoln, Lancaster County, Nebraska 68504
Facility NAICS:
332323:	Ornamental and Architectural Metal Work Manufacturing
In accordance with requirements set forth under Article 2, Section 14 of the Lincoln-Lancaster County Air Pollution Control Programs Regulations and Standards (LLCAPCPRS), the LLCHD may not issue a construction permit until the public has been given the opportunity to comment on the draft permit.
Within the 30-day public comment period, any interested person, agency, group, or affected state may request or petition the Director of the LLCHD for a public hearing.  All requests for public hearing must be made in writing, and must state the nature of the issues to be raised and all arguments and factual grounds supporting their position.  If a public hearing is granted by the Director, the hearing will be advertised by public notice at least 30 days prior to its occurrence. 
A final determination on this permit will be made following the opportunity of the public to review and comment on the draft permit, and any/all comments received have been addressed.  
The conclusion of this document will include a recommendation to either approve or deny the issuance of a construction permit for this source.


         Table of Contents
Section 1  -  Introduction	2
Section 2  -  Permitting History	2
Section 3  -  Source Characterization	2
Section 4  -  Emission Characterization	7
Section 5  -  Applicable and Non-Applicable Regulations & Requirements	11
Section 6  -  Discussion of Proposed Permit Conditions, Monitoring, Reporting, Notification and Record Keeping Requirements	12
Section 7  -  Summary of Permit Conditions Enforceable by Agency	16
Section 8  -  Compliance Assurance Monitoring	16
Section 9  -  Pollution Prevention Opportunities	16
Section 10  -  Air Quality Program Recommendation	16
Section 11  -  Public Participation	16
         
Section 1  -  Introduction

Mapes Panels, LLC (hereinafter referred to as `Mapes' or `the source') operates an existing architectural panel manufacturing facility located at 2929 Cornhusker Highway in Lincoln, Nebraska. Mapes is submitting this construction permit application as a request to classify the existing panel production facility as an area source of hazardous air pollutants (HAP) emissions and a no permit required source under the operating permit program.  The construction permit application has been deemed to be complete and accurate by the Department.
This facility will continue to produce laminated architectural panels consisting of various substrates, including but not limited to metal, plastic, wood, and glass.  The lamination process involves application of adhesive via spraying. Emissions from the spray coat applicator are controlled by a thermal oxidizer (TO).


Section 2  -  Permitting History
   2.1  -  Class I Operating Permit
      On January 28, 2008, Mapes Industries submitted an application to renew the Class I operating permit.  The emission calculations in the permit were based on an estimated maximum potential throughput rate of 76,672 gallons of adhesive.  The owner/operator elected to accept an adhesive throughput limit of 73,724 gallons of adhesive per year.
      In early August, 2008, while drafting the proposed operating permit, the LLCHD determined that 40 CFR Part 63, Subpart MMMM may apply to the source, as the panel laminating operation involved the spray coating of metal with adhesive.  The LLCHD contacted the EPA's Region 7 office to confirm that spray coating of adhesive was covered by Subpart MMMM, which the EPA confirmed to be true.  Though the permit was scheduled for renewal on September 10, 2008, issuance of the renewal permit was delayed indefinitely so LLCHD and Mapes personnel could determine the compliance status of Mapes.  Mapes was asked to obtain specific information regarding the adhesive used in their panel lamination process so the LLCHD could determine whether the adhesive would be considered a `compliant material' in accordance with the requirements of Subpart MMMM.  After several months of unsuccessful attempts to obtain the information, Mapes asked the LLCHD for assistance in obtaining the information form the material manufacturer.  June 1, 2009, the material manufacturer supplied the requested information to the Department.  It was determined in mid-August 2009 that the adhesive may or may not be a compliant material, depending on how it would be classified.
      In November of 2009, after investigating how the material would be classified under the rule, the LLCHD sought guidance from EPA Region 7 as to whether the adhesive would be considered a `general use' coating, or a `high performance architectural coating'.  Through multiple conversations with EPA Region 7, it was determined that the adhesive was not a `high performance architectural coating', and was considered a `general use' coating.  Because of the level of organic HAP in the adhesive, and the organic HAP emission limit set forth in Subpart MMMM, it was determined that the adhesive did not qualify as a compliant material, and that Mapes was in violation of the Subpart MMMM emission limit.
      Further investigation into the matter from the LLCHD and EPA Region 7 revealed that Mapes was also subject to 40 CFR Part 63 Subparts QQQQ and PPPP, as the same adhesive that is spray-coated onto metal is also applied to plastic and wood substrates.  On October 28, 2010, a Complaint and Order (Notice of Violation) was issued to Mapes Industries, Inc. for violating the emission limits set forth in Subparts MMMM, PPPP, and QQQQ.  Mapes Industries sought adhesive formulations that would qualify for the `compliant material' compliance option, but were unable to find a suitable adhesive formulation to replace the one already in use.  As such, the LLCHD determined that Mapes would have to meet compliance with the rules by utilizing the `emission rate with add-on controls' compliance option.  In late 2010, Mapes installed and began operating a regenerative thermal oxidizer to control organic HAP emissions from their panel laminating process.  On August 4, 2011, Mapes conducted emission testing on the regenerative thermal oxidizer to demonstrate the destruction/removal efficiency of the regenerative thermal oxidizer, and to demonstrate that the emission capture system qualifies as a `permanent total enclosure' as described in EPA Test Method 204.
   2.2  -  Class I (Title V) `Major Source' Operating Permit Renewal  -  January 1, 2013
      The operating permit renewal incorporated the applicable federal regulations set forth in 40 CFR Part 63, Subparts MMMM, PPPP, and QQQQ.  The permit also contained requirements designed to ensure compliance with the most stringent emission limit set forth under those rules, including a minimum destruction/removal efficiency of 98.1% for the `regenerative thermal oxidizer' (RTO) and to maintain the emission capture system as a `permanent total enclosure'.
  -  Class I (Title V) `Major Source' Operating Permit  -  Proposed Modification
      In September of 2013, Mapes notified the LLCHD that the `regenerative thermal oxidizer' (RTO) temperature being maintained on a 3-hour block average did not meet the minimum requirement of 1,715 °F as required in the January 1, 2013 operating permit renewal.  Mapes indicated that, when running lower adhesive application rates for certain substrates, the thermal oxidizer temperature would regularly fall below the minimum required temperature, which was the result of less `fuel' in form of VOCs being consumed in the RTO.  Mapes performed a subsequent performance test on November 20, 2013 to determine the destruction/removal efficiency of VOCs when running the oxidizer at a lower VOC load, and therefore a lower temperature.  The result of that performance test indicated that at a minimum 3-hour block average temperature of 1,620 °F, the RTO achieved a destruction/removal efficiency of 95.9%.  Even at this lower destruction/removal efficiency, Mapes will be well within compliance of their emission limits, using the current adhesive and adhesive formulation.
   2.4  -  Proposed Issuance of Construction Permit #199	
      This document serves as the factual and legal basis for the proposed issuance of Construction Permit #199 to Mapes.  
 On April 1, 2014, the Lincoln‐Lancaster County Health Department (LLCHD) issued Mapes a Title V permit to operate a Class I air contaminant source, which included requirements for applicable major source national emission standards for hazardous air pollutants (NESHAPs) Subparts MMMM, PPPP, and QQQQ. On June 28, 2017 Mapes submitted a timely and complete operating permit renewal application to the LLCHD. 
 On January 25, 2018, the United States Environmental Protection Agency (EPA) retracted the previous `Once‐In‐Always‐In' (OIAI) policy as it pertained to the NESHAPs and Title V. The OIAI policy was established in a memo issued in 1995, and required that any source that operated as a major HAP emitter after the `first compliance date' of applicable MACT/NESHAP standards would always be considered a major HAP source under the applicable MACT/NESHAPs. The OIAI policy has prevented Mapes from avoiding the major source NESHAP Subparts MMMM, PPPP, and QQQQ requirements, despite having installed control equipment which greatly reduces emissions of HAPs and results in actual HAP emissions well below major source thresholds.  Rescission of the OIAI policy allows Mapes to become an area source of HAPs.  Because area sources of HAPs are not subject to the major source MACT standards in Subparts MMMM, PPPP, and QQQQ, Mapes would no longer be subject to these subparts upon issuance of a construction permit that establishes the facility as an area source of HAPs.
 On May 21[st], 2018, Mapes submitted a minor source construction permit application requesting that the LLCHD withdraw the June 28, 2017 operating permit renewal application concurrent with issuance of a construction permit to establish the facility as an area source of HAPs, as Mapes will no longer have potential emissions above either the Class I or Class II operating permit thresholds. Additionally, Mapes will no longer be subject to any of the major source NESHAPs, including Subparts MMMM, PPPP, and QQQQ.
         The sections that follow provide more information on the source, the nature of emissions from the source, evaluation of the potential to emit, and a discussion of conditions set forth in the draft permit. 
Section 3  -  Source Characterization
   3.01  -  Source Description
      Mapes' previous operating permit identifies the spray coat applicator process as subject to NESHAPs Subparts MMMM, PPPP, and QQQQ. NESHAP Subparts MMMM, PPPP, and QQQQ pertain to surface coating of metal, wood, and plastic at major HAP facilities. Mapes became subject to these major source NESHAP requirements because the facility did not request enforceable minor source permit limitations on HAP emissions as of the applicable compliance dates for each of the rules.
      Based on the applicable NESHAPs, Mapes installed a TO to control emissions associated with the spray coat applicator. The TO has been tested and is shown to reduce HAP emissions by over 95%. The general operating schedule of the plant has resulted in actual HAP emissions well below the major source thresholds for many years.
      In order to ensure that Mapes remains a minor source of HAPs and a no-permit-required source under the operating permit program, the facility‐wide HAP emissions shall be limited to less than 2.5 tons per year for any individual HAP and less than 10 tons per year for combined HAPs. This construction permit does not pertain to a new, modified, or reconstructed source of HAPs.  Therefore, the T‐BACT requirements in Article 2, Section 27, paragraph (B) of the LLCAPCPRS do not apply to this permitting action.
      Mapes has calculated potential‐to‐emit (PTE) for the adhesive application process using a TO destruction efficiency of 95%, the VOC and HAP contents from the most recent Safety Data Sheet (SDS) for the adhesive currently used, and the adhesive throughput value that reaches just below the Class II threshold for single HAP (2.5 tpy). This adhesive throughput value is approximately twice the actual throughput in recent years.
      Since the NESHAPs are no longer applicable, this construction permit requires the use of a thermal oxidizer (TO) as a federally enforceable permit requirement and the maintenance of the average combustion chamber temperature at or above the level established during a manufacturer performance test, or at the level recorded during the most recent valid performance test. This will require Mapes to maintain the TO combustion chamber temperature at a level that ensures adequate control to remain a minor HAP source. 
      The emissions unit(s) set forth in Section 3.02 (below) will be subject to the requirements of the proposed construction permit.  
   3.02  -  Significant Sources of Air Pollution
                             Emission Unit (EU) #
                                SCC Code Number
                          Emission Point Description
                         Emission Segment Description
                                      1-1
                                  4-02-007-11
                  Architectural Panel Laminating - Spray Line
                                Spray Adhesive
                                      3-1
                                  1-02-006-02
                       Thermal Oxidizer (1.21 MMBtu/hr)
                                  Natural Gas
   3.03  -  Insignificant Activities
      The source is allowed to operate insignificant activities, which are described in the instructions for Section 4, Insignificant Activities, of the operating permit renewal application.  Insignificant activities may include diesel fuel storage tanks, space heaters, or propane or natural gas fired combustion units, such as boilers or other small combustion units, with a heat input capacity of less than eight (8) or ten (10) million British thermal units per hour (MMBtu/hr), respectively.  Insignificant activities at this source include the following:
                            Insignificant Activity
                            Additional Information
                                  Sawcutting
                             Panel sawing stations
      
      
   3.04  -  Source Aerial View
   Main Production Building
   

   Section 4  -  Emission Characterization
   4.01  -  Emission Calculation Factors and Methods
      The procedures for performing emission calculations are provided in the construction permit application.  These procedures will be used to provide the emissions information required for the annual emissions inventory.
   4.02  -  Maximum Potential Emission Calculations and Totals
      4.02.01  -  Maximum Potential to Emit (MPTE)  -  Criteria Pollutants
         The following emissions are derived from the approved application for this facility.  
                                 Emission Unit
                              Annual Process Rate
                                     PM10
                                   (lbs/yr)
                                     PM2.5
                                   (lbs/yr)
                                      NOx
                                   (lbs/yr)
                                      SOx
                                   (lbs/yr)
                                      VOC
                                   (lbs/yr)
                                      CO
                                   (lbs/yr)
                                     CO2e
                                   (lbs/yr)
                                     LEAD
                                   (lbs/yr)
                                  Total HAPs
                                   (lbs/yr)
                                      1-1
                                64,500 gallons
                                       -
                                       -
                                       -
                                       -
                                    208,572
                                       -
                                       -
                                       -
                                    139,757
                                      3-1
                                  10.24 MMcf
                                     77.82
                                     77.82
                                     1,024
                                     6.14
                                     56.32
                                    860.16
                                   1,236,278
                                     0.01
                                     19.34
                                                                   Total Pounds
                                     77.82
                                     77.82
                                     1,024
                                     6.14
                                    208,628
                                    860.16
                                   1,236,278
                                     0.01
                                    139,776
                                                                     Total Tons
                                     0.04
                                     0.04
                                     0.51
                                     0.00
                                    104.31
                                     0.43
                                    618.14
                                   <0.01
                                     69.89
        
        
      4.02.02  -  Maximum Potential to Emit (MPTE)  -  Hazardous Air Pollutants (HAPs)
         The maximum potential emissions of hazardous air pollutants is summarized below:
                                   HAP Name
                                     CAS #
                                  Emissions 
                                     (lbs)
                                  Emissions 
                                    (tons)
Xylene
                                   1330-20-7
                                     475.4
                                     0.24
Toluene
                                   108-88-3
                                   39,757.8
                                     19.88
Hexane
                                   110-54-3
                                   99,524.1
                                     49.76
                                                                         Totals
                                    139,757
                                     69.88
      4.02.03  -  Maximum Potential to Emit  -  Permit Threshold Evaluation
         The following table summarizes the source's potential to emit, and compares it to applicable construction permit and PSD permit thresholds:
Criteria Pollutant
                                   Emissions
                                     (tpy)
                       Construction Permitting Threshold
                                Meet or Exceed?
                                  PSD Const.
                                  Permitting
                                   Threshold
                                Meet or Exceed?
                                     PM10
                                     0.04
                                  >= 15 tpy
No
                                  >= 15 tpy
No
                                     PM2.5
                                     0.04
                                  >= 10 tpy
No
                                  >= 10 tpy
No
                                      NOx
                                     0.51
                                  >= 40 tpy
No
                                  >= 40 tpy
No
                                      SOx
                                     0.00
                                  >= 40 tpy
No
                                  >= 40 tpy
No
                                      VOC
                                    104.31
                                  >= 40 tpy
Yes
                                  >= 40 tpy
Yes
                                      CO
                                     0.43
                                  >= 50 tpy
No
                                  >= 100 tpy
No
                                     CO2e
                                    618.14
                                      N/A
N/A
                                  75,000 tpy
No
                                     Lead
                                   <0.01
                                  >= 0.6 tpy
No
                                  >= 0.6 tpy
No
Hazardous Air Pollutant
                                   Emissions
(tpy)
Class II Permitting Threshold
Meet or Exceed?
                                    Class I
                                  Permitting
Threshold
Meet or Exceed?
Greatest Single HAP
                                     49.76
                                  >= 2.5 tpy
Yes
>= 10.0 tpy
Yes
Total Combined HAPs
                                     69.88
                                 >= 10.0 tpy
Yes
>= 25.0 tpy
Yes

      4.03  -  Limited Potential Emission Calculations and Totals
      The owner/operator has elected to accept control device requirements in their construction permit.  The `limited/controlled potential to emit' is presented in the following subsections.  

      4.03.01  -  Limited Potential to Emit  -  Criteria Pollutants
         The following emissions are derived from the approved application for this facility. The maximum annual process rates reported in this table are from Table 7-A of the approved construction permit application.  APTE values reported in this table are from Table 7-A of the approved construction permit application.
                                 Emission Unit
                              Annual Process Rate
                                     PM10
                                   (lbs/yr)
                                     PM2.5
                                   (lbs/yr)
                                      NOx
                                   (lbs/yr)
                                      SOx
                                   (lbs/yr)
                                      VOC
                                   (lbs/yr)
                                      CO
                                   (lbs/yr)
                                     CO2e
                                   (lbs/yr)
                                     LEAD
                                   (lbs/yr)
                                  Total HAPs
                                   (lbs/yr)
                                      1-1
                                64,500 gallons
                                       -
                                       -
                                       -
                                       -
                                    10,429
                                       -
                                       -
                                       -
                                     6,988
                                      3-1
                                  10.24 MMcf
                                     77.82
                                     77.82
                                     1,024
                                     6.14
                                     56.32
                                    860.16
                                   1,240,000
                                     0.01
                                     19.34
                                                                   Total Pounds
                                     77.82
                                     77.82
                                     1,024
                                     6.14
                                    10,485
                                    860.16
                                   1,240,000
                                     0.01
                                   7,007.34
                                                                     Total Tons
                                     0.04
                                     0.04
                                     0.51
                                     0.00
                                     5.24
                                     0.43
                                    620.00
                                   <0.01
                                     3.50

         
      
      4.03.02  -  Limited Potential to Emit  -  Hazardous Air Pollutants (HAPs)
         The maximum potential emissions of hazardous air pollutants from this source will be minimal, with the combined MPTE for all HAPs summarized below:
                                   HAP Name
                                     CAS #
                                  Emissions 
                                     (lbs)
                                  Emissions 
                                    (tons)
Xylene
                                   1330-20-7
                                     23.8
                                     0.01
Toluene
                                   108-88-3
                                    1,987.9
                                     0.99
Hexane
                                   110-54-3
                                    4,976.2
                                     2.49
                                                                         Totals
                                    6,987.9
                                     3.50
      4.03.03  -  Limited Potential to Emit  -  Permit Threshold Evaluation
         The following table summarizes the source's limited potential to emit, and compares it to applicable `minor NSR' construction permit and `PSD' construction permit thresholds:
Criteria Pollutant
                                   Emissions
                                     (tpy)
                       Construction Permitting Threshold
                                Meet or Exceed?
                                  PSD Const.
                                  Permitting
                                   Threshold
                                Meet or Exceed?
                                     PM10
                                     0.04
                                  >= 15 tpy
No
                                  >= 15 tpy
No
                                     PM2.5
                                     0.04
                                  >= 10 tpy
No
                                  >= 10 tpy
No
                                      NOx
                                     0.51
                                  >= 40 tpy
No
                                  >= 40 tpy
No
                                      SOx
                                     0.00
                                  >= 40 tpy
No
                                  >= 40 tpy
No
                                      VOC
                                     5.24
                                  >= 40 tpy
No
                                  >= 40 tpy
No
                                      CO
                                     0.43
                                  >= 50 tpy
No
                                  >= 100 tpy
No
                                     CO2e
                                    618.14
                                      N/A
N/A
                                  75,000 tpy
No
                                     Lead
                                   <0.01
                                  >= 0.6 tpy
No
                                  >= 0.6 tpy
No
Hazardous Air Pollutant
                                   Emissions
(tpy)
Class II Permitting Threshold
Meet or Exceed?
                                    Class I
                                  Permitting
Threshold
Meet or Exceed?
Greatest Single HAP
                                     2.49
                                  >= 2.5 tpy
No
>= 10.0 tpy
No
Total Combined HAPs
                                     3.50
                                 >= 10.0 tpy
No
>= 25.0 tpy
No
   4.04  -  Permit Threshold Evaluation
      This construction permit is being issued at the request of the owner/operator to establish federally-enforceable limits on the potential-to-emit.  Because the potential to emit is limited by the permit to levels that are lower than the Class II operating permit thresholds set forth in Article 2, Section 5, paragraph (A)(2) of the LLCAPCPRS, this source will no longer require a Class I (Title V) operating permit, and also will not require a Class II operating permit. 
Section 5  -  Applicable and Non-Applicable Regulations & Requirements
   5.01  -  Applicable Regulations under the LLCAPCPRS
 The following sections (§) of the LLCAPCPRS are applicable requirements of the proposed permit:
               Table 5-A: Applicable Regulations of the LLCAPCPRS
 Article 1:  Administration and Enforcement
                                      §1
 Intent
                                      §2
 Unlawful Acts  -  Permits Required
                                      §3
 Violations  -  Hearings  -  Orders
                                      §4
 Appeal Procedure
                                      §5
 Variance
                                      §6
 Fees
                                      §7
 Compliance  -  Actions to Enforce  -  Penalties for Non-Compliance
                                      §8
 Procedure for Abatement
                                      §9
 Severability
 Article 2:  Regulations and Standards
                                      §1
 Definitions
                                      §4
 Ambient Air Quality Standards
                                      §6
 Emissions Reporting  -  When Required
                                      §14
 Permits  -  Public Participation
                                      §15
 Permit Modifications  -  Reopening for Cause
                                      §16
 Stack Heights  -  Good Engineering Practice (GEP)
                                      §17
 Construction Permits  -  When Required
                                      §20
 Particulate Emissions  -  Limitations and Standards
                                      §24
 Sulfur Compound Emissions  -  Existing Sources  -  Emission Standards
                                      §28
 Hazardous Air Pollutants  -  MACT Emission Standards
                                      §29
 Operating and Construction Permit Emission Fees
                                      §32
 Dust  -  Duty to Prevent Escape Of
                                      §33
 Compliance  -  Time Schedule For
                                      §34
 Emission Sources  -  Testing  -  Monitoring
                                      §35
 Compliance  -  Exceptions Due to Startup Shutdown or Malfunction
                                      §36
 Control Regulations  -  Circumvention  -  When Excepted
                                      §37
 Compliance  -  Responsibility of Owner/Operator Pending Review by Director
                                      §38
 Emergency Episodes  -  Occurrence and Control  -  Contingency Plans
 Appendices
                                       I
 Emergency Emission Reduction Regulations
                                  II & III
 Hazardous Air Pollutants (HAPs)
   5.02  -  Applicable Regulations under the Lincoln Municipal Code
 The following sections of the Lincoln Municipal Code (LMC) apply to this source:
       Table 1-B: Applicable Sections of LMC Chapter 8.06: Air Pollution
                                   §8.06.130
 Odor Nuisances Prohibited(Not Federally Enforceable)
                                   §8.06.140
 Open Burning(Not Federally Enforceable)
                                   §8.06.145
 Open Burning Permits(Not Federally Enforceable)
                                   §8.06.150
 Air Pollution Nuisances Prohibited(Not Federally Enforceable)
   5.03  -  Applicable Federal Regulations
 The following Federal Regulations are applicable requirements of the proposed permit.  Non-applicability of specific Federal Regulations is provided in Table 1-E of the proposed permit:
                   Table 1-C: Applicable Federal Regulations
 40 CFR Part 63:	National Emission Standards for Hazardous Air Pollutants for Source Categories (Source Category NESHAPs)
                                    Subpart
 Subpart Title
                                       A
 General Provisions
   5.04  -  Non-Applicable Local Regulations
 The following sections of the LLCAPCPRS are not applicable requirements of the proposed permit:
             Table 5-D: Non-Applicable Regulations of the LLCAPCPRS
 Article 2:  Regulations and Standards
                                      §2
 Major Sources  -  Defined
                                      §5
 Operating Permits  -  When Required
                                      §7
 Operating Permits  -  Application
                                      §8
 Operating Permits  -  Content
                                      §9
 General Operating Permits for Class I and II Sources
                                      §10
 Operating Pmts. for Temp. Sources & Notification of Relocation of Port. Equip.
                                      §11
 Emergency Operating Permits  -  Defense
                                      §12
 Operating Permit Renewal and Expiration
                                      §13
 Class I Operating Permit  -  EPA Review  -  Affected States Review
                                      §18
 New Source Performance Standards (NSPS)
                                      §19
 Prevention of Significant Deterioration (PSD) of Air Quality
                                      §21
 Compliance Assurance Monitoring (CAM)
                                      §22
 Incinerator Emission Standards
                                      §23
 Hazardous Air Pollutants  -  Emission Standards
                                      §25
 Nitrogen Oxides  -  Emissions Standards for Existing Stationary Sources
                                      §26
 Acid Rain
                                      §27
 Hazardous Air Pollutants  -  Maximum Achievable Control Technology (MACT)
                                §3, §30, §31
 Reserved
   5.05  -  Non-Applicable Federal Regulations
 The following Federal Regulations are not applicable requirements of the proposed permit:
                 Table 1-E: Non-Applicable Federal Regulations
                                   Regulation
 Non-Applicable Subparts, Section(s), or Appendix
                                 40 CFR Part 51
 Appendix S: Emission Offset Interpretive Ruling
                                 40 CFR Part 52
 Subpart A §52.21: Prevention of Significant Deterioration of Air Quality
                                 40 CFR Part 60
 Entire rule is non-applicable at the time of permit issuance
                                 40 CFR Part 61
 Entire rule is non-applicable at the time of permit issuance
                                 40 CFR Part 63
 All subparts, except those listed as applicable in Table 1-C
                                 40 CFR Part 64
 Entire rule is non-applicable at the time of permit issuance
                                 40 CFR Part 68
 Entire rule is non-applicable at the time of permit issuance
                                 40 CFR Part 98
 Entire rule is non-applicable at the time of permit issuance
   5.06  -  Non-Applicable Requirements  -  Narrative Discussion
      Many of the Specific Conditions of this permit, explained in greater detail in the following section, have been established based on self-imposed conditions agreed upon by the owner/operator to establish this source as an `area source' of hazardous air pollutants, and also to avoid applicability of `maximum achievable control technology' standards for hazardous air pollutants (also referred to as `MACT') set forth in 40 CFR Part 63, Subparts MMMM, PPPP, and QQQQ.  The combination of an adhesive use limit and a minimum destruction/removal efficiency (DRE) for the thermal oxidizer will maintain facility-wide emissions at levels that are lower than the Class II operating permit thresholds of >=2.5 tons of any individual HAP, and/or >=10.0 tons of total combined HAPs.
Section 6  -  Discussion of Proposed Permit Conditions, Monitoring, Reporting, Notification and Record Keeping Requirements
      The following conditions of the proposed permit contain monitoring, reporting, and record keeping requirements, a brief description of the condition is provided:
   6.01  -  General Conditions
      Conditions II through XXVIII are general conditions that are applicable to all sources receiving a construction permit.  There will not be an in-depth discussion of these requirements, except to note the following General Conditions specifically related to monitoring, reporting, notification, and record-keeping:
         	VI	 - 	Fees
         	XI	 -  - 	Annual Emission Reporting
         	XII(B)	 - 	Notification of Source Modifications
         	XIX(E)	 - 	`Credible Evidence Rule'
         	XX	 - 	Startup, Shutdown, and Malfunction (SSM) Provisions
         	XXV	 - 	Notification of Anticipated Startup
         	XXVI	 - 	Permit Maintenance Requirements
   6.02  -  Specific Conditions
      The following are specific conditions of the proposed construction permit:
         	XXVIII.	 -  	Specific Requirements for the Permitted Emission Units.  These conditions apply to all emission units not otherwise addressed in a Specific Condition of the proposed permit.
               (A)	Throughput Limits & Operating Requirements.
            	(1)	 - 	The requirements set forth under this condition have been established based on self-imposed conditions agreed upon by the owner/operator for the reasons described in Section 5.06 of this document.
            	(2)	 - 	The requirements set forth under this condition establish that the proposed source shall be constructed and operated in a manner that is consistent with that described in the approved application.  Any change in the method of operation that would impact emissions must be analyzed prior to implementation to determine any impact on potential to emit.
            	(3)-(4)	 - 	The requirements set forth under these conditions are intended to ensure that the units are operated in such a manner that their contributions to air pollution are minimized, and to incorporate any elections made in the approved application by reference.
               (B)	Emission Limits & Emission Control Requirements.
            	(1) & (5)	 - 	The requirements set forth under these conditions are incorporated as applicable requirements from Article 2, Section 20 of the LLCAPCPRS.  Specific emission limit(s) set forth in Condition XXVIII(B)(1) have been calculated using the methods and formulas established in Table 20-1 of Section 20.
            	(2)	 - 	The requirements set forth under this condition have been established based on self-imposed conditions agreed upon by the owner/operator for the reasons described in Section 5.06 of this document.
            	(3)	 - 	The emission control requirements set forth under this condition incorporate the self-imposed emission controls agreed upon by the owner/operator in the approved application.  The destruction/‌removal efficiency (DRE) of the thermal oxidizer required under this condition has been agreed upon as the minimum DRE that thermal oxidizer shall be capable of achieving.  Mapes anticipates that the thermal oxidizer will be capable of achieving and maintaining a minimum DRE that exceeds the minimum DRE required under this condition.  A combination of the thermal oxidizer emission control efficiency and limiting adhesive throughput, in concert with monthly adhesive tracking, will ensure that the emissions from the  source remain lower than the HAP `major source' thresholds, as well as the Class II operating permit thresholds.
            			The thermal oxidizer operation and maintenance requirements set forth under this condition will ensure the thermal oxidizer is operated in a manner that is consistent with the operating parameters utilized during the performance testing used to establish the DRE.
            	(4)	 - 	The emission capture system requirements for the adhesive laminating line enclosure are designed to ensure that the emission capture system is being properly operated and maintained, and to ensure the capture system meets the requirements of a `permanent total enclosure' as established in EPA Test Method 204 at all times during operation of the adhesive laminating line.  As a `permanent total enclosure', Mapes will be able to assume 100% capture efficiency for the enclosure.
            	(6)	 - 	The requirement set forth under this condition is incorporated as an applicable requirement from Article 2, Section 24 of the LLCAPCPRS.
                (C)	Monitoring Requirements.
            	(1)	 - 	This condition establishes the requirement to perform monthly visible emission observations to ensure compliance with the opacity limit set forth in Conditions XV(C) and XXVIII(B)(5) of the  permit.
             	(2)	 - 	The monitoring requirements set forth under this condition have been established as means to demonstrate ongoing compliance with the thermal oxidizer requirements established in Condition XXVIII(B)(3).  
            	(3)	 - 	The monitoring requirements set forth under this condition have been established as means to demonstrate ongoing compliance with the emission capture system requirements established in Condition XXVIII(B)(4).
            	(4)-(5)	 - 	These conditions establish the method by which the owner/operator shall demonstrate compliance with the emission limits set forth in Conditions XXVIII(B)(1) and XXVIII(B)(6).
            	(6)-(7)	 - 	The monitoring requirements set forth under these conditions are intended to ensure that the owner/operator maintains records that are adequate to ensure the source remains below the adhesive use limit established in Condition XXVIII(A)(1).
               (D)	Record Keeping Requirements.
            	(1)	 - 	The record keeping requirements set forth in this condition will ensure that the owner/operator keeps adequate records to demonstrate on-going compliance with the visible emission opacity limit and opacity monitoring requirements set forth in Conditions XXVIII(B)(5) and XXVIII(C)(1).
            	(2)	 - 	The record keeping requirements set forth in this condition will ensure that the owner/operator keeps adequate records to demonstrate compliance with the emission control requirements in  Conditions XXVIII(B)(3)-(4), and the associated monitoring requirements in Conditions XXVIII(C)(2)-(3).
            	(3)	 - 	The record keeping requirements set forth in this condition will ensure that the owner/operator keeps adequate records to demonstrate compliance with the emission calculation and monitoring requirements Conditions XXVIII(C)(4)-(5).
            	(4)	 - 	The record keeping requirements set forth in this condition will ensure that the owner/operator keeps adequate records to demonstrate compliance with the adhesive throughput calculation and monitoring requirements Conditions XXVIII(C)(6)-(7).
            	(5)	 - 	The record keeping requirements set forth in this condition will ensure that the owner/operator keeps adequate records to demonstrate compliance with the requirements established in Conditions XXVIII(A)(3)-(4).
            	(6)	 - 	The record keeping requirements set forth in this condition will allow Department staff to view records pertaining to VOC and HAP emissions in order to verify that emissions are being calculated properly, based on actual VOC and HAP content in the material(s) used at the source.
            	(7)	 - 	The record keeping requirements set forth in this condition will allow Department staff to verify the accuracy of natural gas combustion records for the purposes of ensuring accurate emission calculations for the annual emission inventory.
            	(8)	 - 	The record(s) required under this condition are required records under 40 CFR Part 63, Subpart A (NESHAP MACT General Provisions).  For the purposes of this condition, maintaining a copy of this `Statement of Basis' document on-site will satisfy this record keeping requirement, as this document describes the reason(s) that Federal Regulations for affected source categories do not apply to this source.
            	(9)-(10)	 - 	The requirements set forth under these conditions serve to ensure that all records contain the information necessary to verify compliance with the permit for a duration of at least 5 years.
               (E)	Reporting Requirements.
            	(1)	 - 	This condition requires the owner/operator to report emissions to the Department annually, as required by Condition XI.
            	(2)	 - 	This condition requires the owner/operator to notify the Department in the event of excess visible emissions.
            	(3)-(5)	 - 	These conditions serve to ensure that the Department is informed of any change in the adhesive product or product formulation that Mapes plans to use at this source.  These conditions require the owner/operator to analyze the potential change in emissions, and notify the Department accordingly based on any change in potential to emit.  This will allow the Department to analyze what impact, if any, the change in adhesive will have on the source's potential to emit, what modifications to the construction permit (if any) would be required to allow for such a change, or if the change would require the owner/operator to obtain an operating permit.
                (F)	Other Requirements.
            	(1)-(2)	 - 	These conditions serve to ensure that the Department is aware of any changes to the emission units, and to ensure that the owner/operator complies with all applicable requirements in a timely manner.
Section 7  -  Summary of Permit Conditions Enforceable by Agency
         (1)	LLCHD (Local)  -  All conditions indicated in this permit, with the exception of 40 CFR Part 82, as referenced under Condition I(C).
   (2)	EPA (Federal)  -  All conditions indicated in this permit with the exception of General Condition (Regulations) I(B).
Section 8  -  Compliance Assurance Monitoring
   Because Mapes Panels will not be a major source for any criteria or hazardous air pollutant, the requirements of 40 CFR Part 64 do not apply. 
Section 9  -  Pollution Prevention Opportunities
   The Department encourages Mapes to continually examine its operations for pollution prevention opportunities.  The Department's Technical Assistance Program can provide resources to aid the facility in exploring available pollution prevention options.
Section 10  -  Air Quality Program Recommendation
   The Department proposes approval of a Construction Permit for this facility.  Enforceable permit conditions have been provided in the draft permit.  A final determination on this permit will be made following the opportunity of the public to comment on the draft permit, and any comments received have been addressed.
Section 11  -  Public Participation
   The following notice is scheduled for publication in the July 30, 2018 edition of the Lincoln Journal Star, which is a newspaper of general circulation in Lancaster County, Nebraska.  This notice, along with the draft permit, statement of basis, and permit application will also be made available on the Lincoln-Lancaster County Health Department (LLCHD) Air Quality Program website at the following URL:
   http://lincoln.ne.gov/city/health/environ/Air/PubNot.htm 
                       NOTICE OF INTENT TO ISSUE PERMIT
              Lincoln-Lancaster County Health Department (LLCHD)
    In accordance with Article 2, Section 14 of the Lincoln-Lancaster County Air Pollution Control Program Regulations and Standards (LLCAPCPRS), the LLCHD gives notice of the preliminary determination to approve the following permitting action(s) for the source identified in item B (below).  The 30-day public comment period commences July 30, 2018 and ends on August 29, 2018.
       Proposed issuance of a minor New Source Review permit to construct/reconstruct/modify
    Issuance of the proposed permit allows for construction of the subject emission source within Federal, State and Local requirements.  Provided below are the name, address, and the North America Industry Classification System (NAICS) code(s) describing the nature of business at the subject emission source:
       Source Name:  Mapes Panels, LLC
       Source Location: 2929 Cornhusker Hwy., Lincoln, Lancaster County, Nebraska  68504.
       NAICS Codes: 332323 (Ornamental and Architectural Metal Work Manufacturing)
    This construction permit has been requested by the owner/operator to establish this source as an `area source' of hazardous air pollutants, and also to avoid applicability of `maximum achievable control technology' standards for hazardous air pollutants (also referred to as `MACT') set forth in 40 CFR Part 63, Subparts MMMM, PPPP, and QQQQ.  The combination of an adhesive use limit and a minimum destruction/removal efficiency (DRE) for the thermal oxidizer will also maintain facility-wide emissions at levels that are lower than the Class II operating permit thresholds of >=2.5 tons of any individual HAP, and/or >=10.0 tons of total combined HAPs
    The proposed construction permit will allow for emissions of the following regulated air pollutants in the associated quantities.  All quantities are in units of tons per year, or tpy.
        Particulate matter <10 micrometers in diameter (PM10)	0.04 tpy
        Particulate matter <2.5 micrometers in diameter (PM2.5)	0.04 tpy
        Oxides of Nitrogen (NOx)	0.51 tpy
        Oxides of Sulfur (SO2, SO3, and combinations thereof)	<0.01 tpy
        Volatile Organic Compounds (VOC)	5.24 tpy
        Carbon Monoxide	0.43 tpy
        Lead	<0.01 tpy
        Greatest Individual Hazardous Air Pollutant	2.49 tpy
        Total Combined Hazardous Air Pollutants	3.50 tpy
        Carbon Dioxide Equivalents	618.14 tpy
    The proposed permit, statement of basis, construction permit application, and a copy of this public notice document are available online at: http://lincoln.ne.gov, keyword search "air".  Those materials are also available for inspection during business hours at the office of the LLCHD at 3131 O Street, Lincoln, NE 68510.  Telephone inquiries regarding this public notice may be directed to the Air Quality Program at (402) 441-8040.  If alternate formats of materials are needed, please notify the Department by calling (402) 441-8040 or (402) 441-6284 for TDD users.
    Within the 30-day public comment period, any interested person, agency, or group may submit comments on the proposed permit(s), or request or petition the Director of the LLCHD for a public hearing in accordance with item G. below.  Comments on the proposed permit(s) may be mailed to the attention of the Air Quality Program Supervisor at the address provided in item E. above, or submitted via e-mail to health@lincoln.ne.gov using the subject line `Comment on Air Quality Permit'.  Individuals commenting via e-mail are asked to provide their home address and phone number for follow-up correspondence.  
    Requests for public hearing must be made in writing, and must state the nature of the issues to be raised and all arguments and factual grounds supporting their position.  If a public hearing is granted by the Director, the hearing will be advertised by public notice at least 30 days prior to its occurrence.

