adeq · demonstrate compliance with sc#3 and to require sc#2 to demonstrate compliance with sc#4...

20
ADEQ ARK A N S A S Department of Environmental Quality August 5,2013 Jeff Wagner Plant Manager EAKAS Arkansas Corporation P.O. Box 8 Wynne, AR 72396 Dear Mr. Wagner: The enclosed Permit No. 2053-AR-1 is your authority to construct, operate, and maintain the equipment and/or control apparatus as set forth in your application initially received on 5/14/2013. After considering the facts and requirements of A.C.A. §8-4-101 et seq., and implementing regulations, I have determined that Permit No. 2053-AR-1 for the construction, operation and maintenance of an air pollution control system for EAKAS Arkansas Corporation to be issued and effective on the date specified in the permit, unless a Commission review has been properly requested under Arkansas Department of Pollution Control & Ecology Commission's Administrative Procedures, Regulation 8, within thirty (30) days after service of this decision. The applicant or permittee and any other person submitting public comments on the record may request an adjudicatory hearing and Commission review of the final permitting decisions as provided under Chapter Six of Regulation No.8, Administrative Procedures, Arkansas Pollution Control and Ecology Commission. Such a request shall be in the form and manner required by Regulation 8.603, including filing a written Request for Hearing with the APC&E Commission Secretary at 101 E. Capitol Ave., Suite 205, Little Rock, Arkansas 72201. If you have any questions about filing the request, please call the Commission at 501-682-7890. Sincerely, Mike Bates Chief, Air Division Enclosure ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE / NORTH UTILE ROCK / ARKANSAS 72118-5317 / TELEPHONE 501-682-0744 / FAX 501-682-0880 www.adeq.state.ar.us

Upload: others

Post on 24-Jul-2020

0 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

ADEQARK A N S A SDepartment of Environmental Quality

August 5,2013

Jeff WagnerPlant ManagerEAKAS Arkansas CorporationP.O. Box 8Wynne, AR 72396

Dear Mr. Wagner:

The enclosed Permit No. 2053-AR-1 is your authority to construct, operate, and maintain theequipment and/or control apparatus as set forth in your application initially received on5/14/2013.

After considering the facts and requirements of A.C.A. §8-4-101 et seq., and implementingregulations, I have determined that Permit No. 2053-AR-1 for the construction, operation andmaintenance of an air pollution control system for EAKAS Arkansas Corporation to be issuedand effective on the date specified in the permit, unless a Commission review has been properlyrequested under Arkansas Department of Pollution Control & Ecology Commission'sAdministrative Procedures, Regulation 8, within thirty (30) days after service of this decision.

The applicant or permittee and any other person submitting public comments on the record mayrequest an adjudicatory hearing and Commission review of the final permitting decisions asprovided under Chapter Six of Regulation No.8, Administrative Procedures, Arkansas PollutionControl and Ecology Commission. Such a request shall be in the form and manner required byRegulation 8.603, including filing a written Request for Hearing with the APC&E CommissionSecretary at 101 E. Capitol Ave., Suite 205, Little Rock, Arkansas 72201. If you have anyquestions about filing the request, please call the Commission at 501-682-7890.

Sincerely,

~Mike BatesChief, Air Division

Enclosure

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY5301 NORTHSHORE DRIVE / NORTH UTILE ROCK / ARKANSAS 72118-5317 / TELEPHONE 501-682-0744 / FAX 501-682-0880

www.adeq.state.ar.us

Page 2: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

ADEQMINOR SOURCE

AIR PERMITPermit No. : 2053-AR-1

IS ISSUED TO:

EAKAS Arkansas Corporation2000 South Falls Blvd

Wynne, AR 72396Cross County

AFIN: 19-00233

THIS PERMIT IS THE ABOVE REFERENCED PERMITTEE'S AUTHORITY TOCONSTRUCT, MODIFY, OPERATE, AND/OR MAINTAIN THE EQUIPMENT AND/ORFACILITY IN THE MANNER AS SET FORTH IN THE DEPARTMENT'S MINOR SOURCEAIR PERMIT AND THE APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THEPROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT(ARK. CODE ANN. SEC. 8-4-101 ET SEQ.) AND THE REGULATIONS PROMULGATEDTHEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINEDHEREIN.

Signed:

Mike BatesChief, Air Division

August 5, 2013

Date

Page 3: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-1AFIN: 19-00233

Table of Contents

Section I: FACILITY INFORMATION 4Section II: INTRODUCTION 5

Summary of Permit Activity 5Process Description 5Regulations 6Total Allowable Emissions 6

Section III: PERMIT HISTORY 7Section IV: EMISSION UNIT INFORMATION 8Section V: INSIGNIFICANT ACTIVITIES 13Section VI: GENERAL CONDITIONS 14

2

Page 4: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-lAFIN: 19-00233

List of Acronyms and Abbreviations

A.C.A.

AFIN

CFR

CO

HAP

lb/hr

No.

NOx

PM

PM 10

S02

Tpy

UTM

VOC

Arkansas Code Annotated

ADEQ Facility Identification Number

Code of Federal Regulations

Carbon Monoxide

Hazardous Air Pollutant

Pound Per Hour

Number

Nitrogen Oxide

Particulate Matter

Particulate Matter Smaller Than Ten Microns

Sulfur Dioxide

Tons Per Year

Universal Transverse Mercator

Volatile Organic Compound

3

Page 5: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-lAFIN: 19-00233

Section I: FACILITY INFORMATION

PERMITTEE: EAKAS Arkansas Corporation

AFIN: 19-00233

PERMIT NUMBER: 2053-AR-l

FACILITY ADDRESS: 2000 South Falls BlvdWynne, AR 72396

MAILING ADDRESS: P.O. Box 8Wynne, AR 72396

COUNTY: Cross County

CONTACT NAME: Joe Harrald

CONTACT POSITION: Plant Manager

TELEPHONE NUMBER: 870-238-2603

REVIEWING ENGINEER: Patty Campbell, PE

UTM North South (Y):

UTM East West (X):

Zone 15: 3897048.28 m

Zone 15: 700794.10 m

4

Page 6: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-1AFIN: 19-00233

Section II: INTRODUCTION

Summary ofPennit Activity

Eakas Arkansas Corporation (Eakas) owns and operates an automotive interior and exterior trimmanufacturing facility. It is located at 2000 South Falls Boulevard, Wynne, Cross County,Arkansas 72396. This permitting action is necessary to increase Acetone usage (SN-13) from7,230 to 10,000 gallons maximum per rolling 12 months and increase Acetone emissions from20.0 to 33.2 tpy. The total permitted annual emission changes associated with this modificationare: 13.2 tpy (tons per year) Acetone.

Process Description

Eakas Arkansas Corporation owns and operates an automotive interior / exterior trimmanufacturing facility. Eakas Arkansas manufactures painted decorative, interior / exterior trimand other complex modular assemblies for the automotive industry.

The process starts with the various types ofthennoplastic pellets, which are injection moldedinto various shapes, inspected and placed onto paint fixtures or shipped without paint to thecustomer. Approximately one percent of the product may need to be primed prior to beingcoated with a two-component polyurethane basecoat and clearcoat coating. Ninety-nine percentof all painted parts are coated with basecoat and clearcoat only, prior to cure.

Eakas Arkansas currently has one Automatic Paint Booth (SN-01) and one Manual Paint Booth(SN-05) that parts pass through.

SN-01 Automatic Paint Booth air is supplied by a natural gas Air Make-up Unit (SN-07). Thepaint utilized in the operation will be mixed in an attached Paint Mix Room (SN-06). Once theparts are coated they will enter an Electric Curing Oven (SN-03) and then they are unloadedfrom the system. SN-06 and SN-07 vent through SN-01. This paint booth equipment is cleanedand flushed with Acetone or Flushing Thinner.

SN-05 Manual Paint Booth air is supplied by a natural gas Air Make-up Unit (SN-10). Parts arepainted and then put into a natural gas Curing Oven (SN-04). SN-10 vents through SN-05. Thispaint booth equipment is cleaned and flushed with Acetone or Flushing Thinner.

All paints fixtures are cleaned at Eakas Arkansas. This is done by burning excess paint from thesteel structure. The fixtures are placed in a Controlled Pyrolysis Cleaning Furnace (SN-11) thatis natural gas-fired.

Child parts are added, which are either molded in-house or are purchased from an outsidesupplier to make simple to complex modular assemblies that are packaged for pick-up by ourcustomers. Ajust-in-time philosophy is utilized throughout the facility.

5

Page 7: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-1AFIN: 19-00233

Eakas Arkansas also performs the following insignificant activities on site: Injection Molding ofparts, Hand polishing / sanding ofparts, Parts water wash machine, and Inspect / Destat (pre­moistened IPA wipes.

Regulations

The following table contains the regulations applicable to this permit.

Regulations

Arkansas Air Pollution Control Code, Regulation 18, effective June 18, 2010

Regulations of the Arkansas Plan of Implementation for Air Pollution Control,Regulation 19, effective November 18,2012

Total Allowable Emissions

The following table is a summary of emissions from the facility. This table, in itself, is not anenforceable condition of the permit.

TOTAL ALLOWABLE EMISSIONS

Emission RatesPollutant

lb/hr tpy

PM 0.3 0.5

PM 10 0.3 0.5

SOz 0.3 0.3

VOC 11.4 19.0

CO 1.0 3.7

NOx 1.1 4.3

Single HAP 1.0 1.0

Combined HAPs 3.0 3.0

Acetone 33.2 33.2

6

Page 8: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-lAFIN: 19-00233

Section III: PERMIT HISTORY

Permit 2053-AOP-RO was originally issued on February 9, 2004 to Eakas Arkansas. Totalallowable emissions were: 0.3 tpy PM/PMIO, 0.3 tpy S02, 247.9 tpy YOC, 1.3 tpy CO, 1.4 tpyNOx, 9.5 tpy Single HAPs, 22.5 tpy Combined HAPs, and 12.0 tpy acetone.

Permit 2053-AOP-Rl was issued on December 14,2006 to permit installation of a new air make­up heater (SN-I0) for the manual paint line and a controlled pyrolysis cleaning furnace (SN-ll).Additional acetone usage was requested. Additional source numbers (SN) were assigned toallow multiple emission points (vents/stacks) for already permitted equipment. Permittedemission increases were: 0.2 tpy PM, 0.2 tpy PM IO, 0.2 tpy S02, 0.2 tpy YOC, 1.0 tpy CO, 1.1tpy NOx and 8.00 tpy acetone.

Permit 2053-AOP-Rl was amended on January 18, 2007 to revise Specific Condition #1 todemonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4and #5. There was no change in overall emissions.

Permit 2053-A was issued to Eakas Arkansas Corporation on February 12, 2009. Thispermitting action is necessary to change from a Title Y to a minor source air permit, Annualpaints and coatings usage have been reduced from 10,000 to 7,800 gallons. SN-02 and SN-09were never installed and are being removed from the permit. Annual emission changes are: -0.2tpy PMIPMIO, -0.4 tpy S02, -229.3 tpy YOC, 0.4 tpy CO, 0.7 tpy NOx, -8.5 tpy Single HAP,and -19.5 tpy Combined HAPs.

7

Page 9: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-1AFIN: 19-00233

Section IV: EMISSION UNIT INFORMATION

Specific Conditions

1. The permittee shall not exceed the emission rates set forth in the following table.[Regulation 19 §19.501 et seq. and AC.A §8-4-203 as referenced by §8-4-304 and§8-4-311]

SN Description Pollutant lb/hr tpy

01 Automatic Paint Booth (2005)

05 Manual Paint Booth (2007) VOC 11.1 18.5

06 Paint Mixing Room (2005)

PM IO 0.1 0.1

Three Curing Ovens S02 0.1 0.103,04&12 VOC 0.1 0.1(0.2 MMBTU/hr each)

CO 0.1 0.3NOx 0.1 0.3

PM IO 0.1 0.3Three Make Up Air Heaters S02 0.1 0.1

07,08 & 10 (Natural gas, 2.8 MMBtu/hr VOC 0.1 0.3each) CO 0.8 3.2

NOx 0.9 3.8

Pyrolysis Furnace PM 10 0.1 0.1

(Natural gas, 0.35-0.50 S02 0.1 0.111 VOC 0.1 0.1MMBtu/hr)

CO 0.1 0.2(2005)NOx 0.1 0.2

02&09 Removed from permit.

2. The permittee shall not exceed the emission rates set forth in the following table.[Regulation 18 §18.801 and AC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

8

Page 10: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-lAFIN: 19-00233

SN Description Pollutant lb/hr tpy

01 Automatic Paint Booth (2005)

05 Manual Paint Booth (2007)Single HAP 1.0 1.0

Combined HAPs 3.0 3.0

06 Paint Mixing Room (2005)

13Annual Emissions Flushing

Acetone 33.2 33.2Solvents Facility-wide

03,04 & Three Curing OvensPM 0.1 0.1

12 (0.2 MMBTU/hr each)

07,08 &Three Make Up Air Heaters

10(Natural gas, 2.8 MMBtu/hr PM 0.1 0.3

ea)

Pyrolysis Furnace11 (Natural gas, 0.35-0.50 PM 0.1 0.1

MMBtu/hr) (2005)

3. Visible emissions may not exceed the limits specified in the following table of this permitas measured by EPA Reference Method 9. [A.c.A. §8-4-203 as referenced by §8-4-304and §8-4-311]

SN Limit Regulatory Citation

03,04,07,08, 10, 11, & 12 5% §18.501 and A.C.A.

4. The permittee shall not cause or permit the emission of air contaminants, including odorsor water vapor and including an air contaminant whose emission is not otherwiseprohibited by Regulation #18, if the emission of the air contaminant constitutes airpollution within the meaning of A.C.A. §8-4-303. [Regulation 18 §18.801 andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

5. The permittee shall not conduct operations in such a manner as to unnecessarily cause aircontaminants and other pollutants to become airborne. [Regulation 18 §18.901 andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-3l1]

6. The permittee shall not use any paint or coating that contains VOCs in excess of 2.22pounds per gallon. The permittee shall not use more than 5.0 gallons per hour of paints

9

Page 11: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-1AFIN: 19-00233

and/or coatings facility-wide. [Regulation 19 §19.705 and A.C.A. §8-4-203 as referencedby A.C.A. §8-4-304 and §8-4-311]

7. The permittee shall not use any paint or coating that contains Single HAP and CombinedHAPs in excess of 0.2 and 0.6 pounds per gallon, respectively. The permittee shall notuse more than 5.0 gallons per hour of paint and/or coatings facility-wide (as a monthlyaverage). [Regulation 18, §18.1004 and A.C.A. §8-4-203 as referenced by A.C.A.§8-4-304 and §8-4-31l]

8. The permittee shall not exceed a throughput of 10,000 gallons of Acetone at the facilityper rolling 12 month period. All equipment cleaning operations and thinner usage in thefacility are covered under a facility-wide "emissions bubble" (SN-13). [Regulation 19§19.705, Regulation 18 §18.1004, and A.c.A. §8-4-203 as referenced by A.C.A.§8-4-304 and §8-4-311]

9. The permittee shall not exceed 7,800 gallons of paints and coatings for the paintingoperations (SN-01, 05 & 06) per rolling 12 month period. [Regulation 19 §19.705 andA.c.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

10. The permittee shall maintain monthly records and calculations ofVOC emissions fromall paints and coatings, which demonstrate compliance with Specific Conditions #1 and#6. These records shall list chemicals by name and product number. These records shallindicate the amount of each VOC-containing material used in gallons, the respectiveVOC content of each gallon of material (pounds/gallon), and the resulting emissions fromthe usage of each material (pounds per month). A rolling twelve-month total and eachindividual month's data shall be maintained in a spreadsheet, database, or other well­organized format. The records and the MSDS records or other equivalent documentationshall be maintained on-site and made available to Department personnel upon request.The permittee shall update the records by the fifteenth day of the month following themonth to which the records pertain. [Regulation 19 §19.705 and A.C.A. §8-4-203 asreferenced by A.C.A. §8-4-304 and §8-4-311]

11. The permittee may use only the HAPs listed in the following table or any HAP that has aTLV greater than 9.091 mg/nr' as published by the American Conference ofGovernmental Industrial Hygienists (ACGIH) in the most current ACGIH handbook ofThreshold Limit Values (TLVs) and Biological Exposure Indices (BEIs). Compliancewith this limit is demonstrated by Specific Condition #9. [Regulation 18 §18.1004 andA.c.A. §8-4-203 as referenced by A.c.A. §8-4-304 and §8-4-311]

HAP Pollutant CAS Number

Xylene 1331-20-7

Toluene 108-10-1

10

Page 12: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-lAFIN: 19-00233

HAP Pollutant CAS Number

Ethyl Benzene 100-41-4

Cumene 98-82-8

Methyl Isobutyl Ketone 108-10-1

Any HAP with TLV 2: 9.091 rng/rrr' N/A

12. The permittee shall maintain monthly records and calculations of HAP and/or acetoneemissions from all paints, coatings, and solvents, which demonstrate compliance withSpecific Conditions #1, #2, #6 and #8. These records shall list HAPs by name andproduct number. These records shall be calculated as follows: [Regulation 18 §18.1004and AC.A §8-4-203 as referenced by AC.A §8-4-304 and §8-4-311]

a. For materials other than flushing solvents:i. Actual usages volume (gallon) ofVOC, HAP and/or acetone containing

material, as determined by inventory differences and purchases and11. Actual VOC, HAP and/or acetone content of material (pounds/gallon) as

determined by MSDS or other equivalent documentation.b. For Flushing Solvents (acetone) (SN-13):

i. Actual volume purchased and/or received in gallon ofVOC, HAP and/oracetone containing flushing solvents (SN-13)

Total weight flushing solvents received x weight fraction ofVOC, HAP,and/or acetone.

11. Actual VOC, HAP and/or acetone in flushing solvents (SN-13) recovered(not emitted) as determined byWeight spent flushing solvents shipped off site x 0.85 (non-solids) x weightfraction VQC, HAP and/or acetone.

13. Spent flushing solvents, acetone, shall not exceed 15% solids by weight. Compliancewith this limit is demonstrated by Specific Condition #llb. [Regulation 18 §18.1004 andAC.A §8-4-203 as referenced by AC.A §8-4-304 and §8-4-311]

14. The permittee shall maintain monthly records and calculations to demonstrate that spentflushing solvents, acetone, contain less than 15% solids by weight. The permittee shallmaintain a twelve month rolling total and each individual month's data on-site and madeavailable to Department personnel upon request. The permittee shall update the recordsby the fifteenth day of the month following the month to which the records pertain.[Regulation 18 §18.1004 and AC.A §8-4-203 as referenced by AC.A §8-4-304 and§8-4-311]

11

Page 13: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-lAFIN: 19-00233

15. The permittee shall use only pipeline quality gas as fuel for curing ovens SN-03, 04 and12; make-up air heaters SN-07, 08, and 10; and pyrolysis furnace SN-l1. The emissionshave been calculated at full load for continuous operation and no recordkeeping ofnatural gas is required. [Regulation 19 §19.705 and AC.A §8-4-203 as referenced byAC.A §8-4-304 and §8-4-311]

16. The permittee shall operate the afterburner chamber ofSN-ll between 1500 - 1650°Fwith residence times of Y:2 second or greater with a continuous temperature monitor.Temperature records shall be maintained on-site and shall be made available toDepartment personnel upon request. [Regulation 19 §19.705 and 40 CFR Part 52Subpart E]

12

Page 14: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-lAFIN: 19-00233

Section V: INSIGNIFICANT ACTIVITIES

The Department deems the following types of activities or emissions as insignificant on the basisof size, emission rate, production rate, or activity in accordance with Group A of theInsignificant Activities list found in Regulation 18 and 19 Appendix A. Insignificant activityemission determinations rely upon the information submitted by the permittee in an applicationdated August 4, 2008.

Description Category

Injection Molding ofParts (and mold release agents/cleaner) A-13

Hand Polishing/Sanding of Parts as necessary A-13

Parts Water Wash Machine (with detergent) A-13

Inspect / Destat (pre-moistened IPA wipes) A-13

13

Page 15: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-lAFIN: 19-00233

Section VI: GENERAL CONDITIONS

1. Any terms or conditions included in this permit that specify and reference ArkansasPollution Control & Ecology Commission Regulation 18 or the Arkansas Water and AirPollution Control Act (AC.A §8-4-101 et seq.) as the sole origin of and authority for theterms or conditions are not required under the Clean Air Act or any of its applicablerequirements, and are not federally enforceable under the Clean Air Act. ArkansasPollution Control & Ecology Commission Regulation 18 was adopted pursuant to theArkansas Water and Air Pollution Control Act (AC.A §8-4-101 et seq.). Any terms orconditions included in this permit that specify and reference Arkansas Pollution Control& Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution ControlAct (AC.A §8-4-101 et seq.) as the origin of and authority for the terms or conditionsare enforceable under this Arkansas statute.

2. This permit does not relieve the owner or operator of the equipment and/or the facilityfrom compliance with all applicable provisions of the Arkansas Water and Air PollutionControl Act and the regulations promulgated under the Act. [AC.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311]

3. The permittee shall notify the Department in writing within thirty (30) days aftercommencement of construction, completion of construction, first operation of equipmentand/or facility, and first attainment of the equipment and/or facility target production rate.[Regulation 19 §19.704 and/or AC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

4. Construction or modification must commence within eighteen (18) months from the dateof permit issuance. [Regulation 19 §19.41O(B) and/or Regulation 18 §18.309(B) andAC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

5. The permittee must keep records for five years to enable the Department to determinecompliance with the terms of this permit such as hours of operation, throughput, upsetconditions, and continuous monitoring data. The Department may use the records, at thediscretion of the Department, to determine compliance with the conditions ofthe permit.[Regulation 19 §19.705 and/or Regulation 18 §18.1004 and AC.A §8-4-203 asreferenced by §8-4-304 and §8-4-311]

6. A responsible official must certify any reports required by any condition contained in thispermit and submit any reports to the Department at the address below. [Regulation 19§19.705 and/or Regulation 18 §18.1004 and AC.A §8-4-203 as referenced by §8-4-304and §8-4-31l]

Arkansas Department of Environmental QualityAir DivisionATTN: Compliance Inspector Supervisor

14

Page 16: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-1AFIN: 19-00233

5301 Northshore DriveNorth Little Rock, AR 72118-5317

7. The permittee shall test any equipment scheduled for testing, unless stated in the SpecificConditions of this permit or by any federally regulated requirements, within the followingtime frames: (1) newly constructed or modified equipment within sixty (60) days ofachieving the maximum production rate, but no later than 180 days after initial start up ofthe permitted source or (2) existing equipment already operating according to the timeframes set forth by the Department. The permittee must notify the Department of thescheduled date of compliance testing at least fifteen (15) business days in advance ofsuch test. The permittee must submit compliance test results to the Department withinthirty (30) calendar days after the completion of testing. [Regulation 19 §19.702 and/orRegulation 18 §18.1002 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

8. The permittee shall provide: [Regulation 19 §19.702 and/or Regulation 18 §18.1002 andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

a. Sampling ports adequate for applicable test methods;b. Safe sampling platforms;c. Safe access to sampling platforms; andd. Utilities for sampling and testing equipment

9. The permittee shall operate equipment, control apparatus and emission monitoringequipment within their design limitations. The permittee shall maintain in goodcondition at all times equipment, control apparatus and emission monitoring equipment.[Regulation 19 §19.303 and/or Regulation 18 §18.1104 andA.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311]

10. If the permittee exceeds an emission limit established by this permit, the permittee will bedeemed in violation of said permit and will be subject to enforcement action. TheDepartment may forego enforcement action for emissions exceeding any limitsestablished by this permit provided the following requirements are met: [Regulation 19§19.601 and/or Regulation 18 §18.1101 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311]

a. The permittee demonstrates to the satisfaction of the Department that theemissions resulted from an equipment malfunction or upset and are not the resultof negligence or improper maintenance, and the permittee took all reasonablemeasures to immediately minimize or eliminate the excess emissions.

b. The permittee reports the occurrence or upset or breakdown of equipment (bytelephone, facsimile, or overnight delivery) to the Department by the end of thenext business day after the occurrence or the discovery of the occurrence.

c. The permittee must submit to the Department, within five business days after theoccurrence or the discovery of the occurrence, a full, written report of suchoccurrence, including a statement of all known causes and of the scheduling and

15

Page 17: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-lAFIN: 19-00233

nature of the actions to be taken to minimize or eliminate future occurrences,including, but not limited to, action to reduce the frequency of occurrence of suchconditions, to minimize the amount by which said limits are exceeded, and toreduce the length of time for which said limits are exceeded. If the information isincluded in the initial report, the information need not be submitted again.

11. The permittee shall allow representatives of the Department upon the presentation ofcredentials: [AC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

a. To enter upon the permittee's premises, or other premises under the control of thepermittee, where an air pollutant source is located or in which any records arerequired to be kept under the terms and conditions of this permit;

b. To have access to and copy any records required to be kept under the terms andconditions of this permit, or the Act;

c. To inspect any monitoring equipment or monitoring method required in thispermit;

d. To sample any emission of pollutants; ande. To perform an operation and maintenance inspection ofthe permitted source.

12. The Department issued this permit in reliance upon the statements and presentationsmade in the permit application. The Department has no responsibility for the adequacy orproper functioning of the equipment or control apparatus. [AC.A §8-4-203 asreferenced by §8-4-304 and §8-4-311]

13. The Department may revoke or modify this permit when, in the judgment of theDepartment, such revocation or modification is necessary to comply with the applicableprovisions of the Arkansas Water and Air Pollution Control Act and the regulationspromulgated the Arkansas Water and Air Pollution Control Act. [Regulation 19§19.410(A) and/or Regulation 18 §18.309(A) and A.C.A. §8-4-203 as referenced by §8­4-304 and §8-4-311]

14. This permit may be transferred. An applicant for a transfer must submit a written requestfor transfer of the permit on a form provided by the Department and submit the disclosurestatement required by Arkansas Code Annotated §8-1-1 06 at least thirty (30) days inadvance of the proposed transfer date. The permit will be automatically transferred to thenew permittee unless the Department denies the request to transfer within thirty (30) daysof the receipt of the disclosure statement. The Department may deny a transfer on thebasis of the information revealed in the disclosure statement or other investigation or,deliberate falsification or omission of relevant information. [Regulation 19 §19.407(B)and/or Regulation 18 §18.307(B) and AC.A §8-4-203 as referenced by §8-4-304 and §8­4-311]

15. This permit shall be available for inspection on the premises where the control apparatusis located. [A.C.A §8-4-203 as referenced by §8-4-304 and §8-4-3l1]

16

Page 18: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-lAFIN: 19-00233

16. This permit authorizes only those pollutant emitting activities addressed herein. [AC.A§8-4-203 as referenced by §8-4-304 and §8-4-311]

17. This permit supersedes and voids all previously issued air permits for this facility.[Regulation 18 and 19 and AC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

18. The permittee must pay all permit fees in accordance with the procedures established inRegulation No.9. [AC.A §8-1-105(c)]

19. The permittee may request in writing and at least 15 days in advance of the deadline, anextension to any testing, compliance or other dates in this permit, No such extensions areauthorized until the permittee receives written Department approval. The Departmentmay grant such a request, at its discretion in the following circumstances:

a. Such an extension does not violate a federal requirement;b. The pennittee demonstrates the need for the extension; andc. The permittee documents that all reasonable measures have been taken to meet

the current deadline and documents reasons it cannot be met.

[Regulation 18 §18.314(A), Regulation 19 §19.416(A), AC.A §8-4-203 as referenced by§8-4-304 and §8-4-311, and 40 CFR Part 52, Subpart E]

20. The pennittee may request in writing and at least 30 days in advance, temporaryemissions and/or testing that would otherwise exceed an emission rate, throughputrequirement, or other limit in this permit, No such activities are authorized until thepermittee receives written Department approval. Any such emissions shall be included inthe facilities total emissions and reported as such. The Department may grant such arequest, at its discretion under the following conditions:

a. Such a request does not violate a federal requirement;b. Such a request is temporary in nature;c. Such a request will not result in a condition of air pollution;d. The request contains such information necessary for the Department to evaluate

the request, including but not limited to, quantification of such emissions and thedate/time such emission will occur;

e. Such a request will result in increased emissions less than five tons of anyindividual criteria pollutant, one ton of any single HAP and 2.5 tons of totalHAPs; and

f. The permittee maintains records of the dates and results of such temporaryemissions/testing.

[Regulation 18 §18.314(B), Regulation 19 §19.416(B), AC.A §8-4-203 as referenced by§8-4-304 and §8-4-311, and 40 CFR Part 52, Subpart E]

17

Page 19: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

EAKAS Arkansas CorporationPermit #: 2053-AR-lAFIN: 19-00233

21. The permittee may request in writing and at least 30 days in advance, an alternativeto the specified monitoring in this permit, No such alternatives are authorized until thepermittee receives written Department approval. The Department may grant such arequest, at its discretion under the following conditions:

a. The request does not violate a federal requirement;b. The request provides an equivalent or greater degree of actual monitoring to the

current requirements; andc. Any such request, if approved, is incorporated in the next permit modification

application by the permittee.

[Regulation 18 §18.314(C), Regulation 19 §19.416(C), A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311, and 40 CFR Part 52, Subpart E]

18

Page 20: ADEQ · demonstrate compliance with SC#3 and to require SC#2 to demonstrate compliance with SC#4 and #5. There was no change in overall emissions. Permit 2053-Awas issued to Eakas

CERTIFICATE OF SERVICE

I, Pam Owen, hereby certify that a copy of this permit has been mailed by first class mail to

EY:YJof_-----:...A--:....=.:l)§I!S ± 2013.

~~ QuJen_--Pam Owen, AAII, Air Division