DATE APPLICATION RECEIVED:	March 26, 2018

FACILITY DESCRIPTION
The facility is a textile manufacturing facility that produces woven and knitted fabric mainly for industrial uses. 

PROJECT DESCRIPTION
The facility is requesting removal of the existing National Emissions Standards for Hazardous Air Pollutants (NESHAPs) requirements for Subpart OOOO  -  Printing, Coating, and Dyeing of Fabric and Other Textiles from the current Title V operating permit. Based on information submitted by the facility, along with their operating permit renewal application, the facility is currently operating as a true minor source of Hazardous Air Pollutant (HAP) emissions, and therefore is no longer subject to the NESHAP requirements for a major source of HAP emissions. 

Originally Takata Resistant Systems Inc. (TRSI) was collocated with Highland Industries for permitting applicability determinations, TRSI was closed on February 7, 2006. HAP emissions from TRSI are shown in the following table, the emissions data is based on a modeling summary for the two collocated facilities dated February 6, 2007. The annual emissions are calculated based on 8760 hours of operation per year.

                                 Equipment ID
                                     MIBK
                                  (108-10-1)
                                    Toluene
                                  (108-88-3)
                                    Cumene
                                   (98-82-8)
                                 Ethylbenzene
                                  (100-41-4)
                                    Xylene
                                       
                                     lb/hr
                                      TPY
                                     lb/hr
                                      TPY
                                     lb/hr
                                      TPY
                                     lb/hr
                                      TPY
                                     lb/hr
                                      TPY
                           T19 - Primer Paint Booth
                                     1.753
                                     7.676
                                    26.697
                                    116.93
                                      --
                                      --
                                      --
                                      --
                                     24.69
                                    108.13
                          T20 - Top Coat Paint Booth
                                    10.303
                                    45.127
                                    17.555
                                    76.891
                                     0.04
                                     0.17
                                     2.32
                                     10.17
                                     14.80
                                    64.806
                               T22 - Drying Oven
                                     0.503
                                     2.201
                                     1.844
                                     8.076
                                     0.002
                                     0.01
                                     0.10
                                     0.424
                                     1.645
                                     7.205
                         Facility Total HAP emissions
                                    12.558
                                    55.004
                                    46.096
                                    201.90
                                     0.04
                                     0.17
                                     2.42
                                     10.59
                                     41.13
                                    180.14

The total HAP emissions from this facility are 447.8 TPY, which would classify this facility as a major source. At the time of this modeling summary Highland Industries would also be classified as a major source of HAPs, as total HAP emissions from the facility were 51.087 TPY.

As a part of the facility's current Title V renewal application, which was received September 29, 2017, the facility updated calculations to include information gathered from a review of all the Safety Data Sheets (SDS) for all the materials used at the facility. The facility wide emissions table shows the updated potential emission calculations that resulted from this review of all the materials in use at the facility. As a result of the updated emissions calculations, Highland Industries will no longer be a major source of HAPs or Criteria pollutants. As a result a State Operating Permit will be issued for the facility upon renewal of the operating permit. 

                            FACILITY WIDE EMISSIONS
                                   Pollutant
                            Uncontrolled Emissions
                         Controlled/Limited Emissions
                                       
                                      TPY
                                      TPY
                                      PM
                                      4.7
                                      --
                                     PM10
                                      4.2
                                      --
                                     PM2.5
                                      4.2
                                      --
                                      SO2
                                      0.7
                                      --
                                      NOx
                                     67.1
                                      --
                                      CO
                                     41.3
                                      --
                                      VOC
                                     14.2
                                      --
                                   Lead (Pb)
                                   2.34E-04
                                      --
                                  Total HAPs
                                     2.72
                                      --
                                 Highest HAP:
                            Hexane (CAS#: 110-54-3)
                                     0.884
                                      --
                        Arsenic & compounds (CAS#:
                                   9.93E-03
                                      --
                         Acetaldehyde (CAS#: 75-07-0)
                                   7.13E-06
                                      --
                           Acrolein (CAS#:107-02-8)
                                   8.44E-06
                                      --
                            Benzene (CAS#: 71-43-2)
                                   1.06E-03
                                      --
                           Beryllium & compounds
                                   5.63E-06
                                      --
                            Cadmium & compounds
                                   5.16E-04
                                      --
                          Chloroform (CAS#: 67-66-3)
                                   2.70E-02
                                      --
                             Chromium - All/Total
                                   6.56E-04
                                      --
                                  Chromium VI
                                   6.56E-04
                                      --
                               Cobalt compounds
                                   3.94E-05
                                      --
                            Cumene (CAS#: 98-82-8)
                                   2.75E-07
                                      --
                      Dichlorobenzene (CAS#: 19287-45-7)
                                   5.63E-04
                                      --
                        Dichloromethane (CAS#: 75-09-2)
                                   1.24E-02
                                      --
              Diethylene glycol monobutyl ether (CAS#: 111-46-6)
                                   8.40E-02
                                      --
                        Ethyl Acrylate (CAS#: 140-88-5)
                                   1.24E-01
                                      --
                        Ethyl Benzene (CAS#: 100-41-4)
                                   7.12E-05
                                      --
                         Fluoranthene (CAS#: 206-44-0)
                                   1.41E-06
                                      --
                           Fluorene (CAS#: 86-73-7)
                                   1.31E-06
                                      --
                         Formaldehyde (CAS#: 50-00-0)
                                   5.16E-01
                                      --
                            Hexane (CAS#: 110-54-3)
                                   8.44E-01
                                      --
                           Manganese & compounds
                                   1.78E-04
                                      --
                            Mercury & compounds
                                   1.22E-04
                                      --
                            Methanol (CAS#:67-56-1)
                                   3.86E-01
                                      --
                          Naphthalene (CAS#: 91-20-3)
                                   2.86E-04
                                      --
                            Nickel & compounds
                                   9.85E-04
                                      --
                         Phenanathrene (CAS#: 85-01-8)
                                   7.97E-06
                                      --
                              Selenium compounds
                                   4.88E-06
                                      --
                            Styrene (CAS#:100-42-5)
                                   5.82E-02
                                      --
                           Toluene (CAS#: 108-88-3)
                                   8.72E-02
                                      --
                                  Total POM 
                                   4.14E-05
                                      --
                        Vinyl Chloride (CAS#: 75-01-4)
                                   6.18E-03
                                      --

OPERATING PERMIT STATUS
This facility operates under Title V Operating Permit; issued on April 12, 2013; effective on July 1, 2013; expires on June 30, 2018.
The operating permit will be updated to the new permit template upon completion of the operating permit renewal. 

                        REGULATORY APPLICABILITY REVIEW
                                  Regulations
                   Comments/Periodic Monitoring Requirements
                            40 CFR 63 and 61-62.63
Subpart OOOO  -  National Emissions Standards For Hazardous Air Pollutant: Printing, Coating, and Dyeing of Fabrics and Other Textiles. 

The facility has multiple sources that are defined as affected sources under this regulation. The potential emissions from the facility now are below the major source thresholds for Hazardous Air Pollutants due to the closure of a collocated facility and removal of the spot cleaning operations at the facility. The facility is no longer considered a major source and therefore this Subpart no longer applies to this facility. 


                         AMBIENT AIR STANDARDS REVIEW
                                  Regulations
                   Comments/Periodic Monitoring Requirements
                                Standard No. 2
The facility has demonstrated with requirements of this Standard through modeling, see modeling summary dated May 11, 2018.
                               Standard No. 7.c
This facility is not subject to permitting under Prevention of Significant Deterioration (PSD), no modeling is required under this Standard.
                          Standard No. 8 (state only)
The facility emissions are in compliance with the requirements of this Standard see modeling summary dated May 11, 2018.

PUBLIC NOTICE
A public notice was not required for this permit.

SUMMARY AND CONCLUSIONS
It has been determined that this source, if operated in accordance with the submitted application, will meet all applicable requirements and emission standards.
