cc: Mr. Hal Grant Pace Industries, Inc. P.O. Box 309 Fayetteville, AR ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

Transcription

1 ADEQ ARK A N S A S Department of Environmental Quality August 12, 2011 Michael Bakaric Division President Pace Industries, Inc., Harrison Division P.O. Box 1198 Harrison, AR Re: Notice ofadministrative Amendment, Permit No.: 1001-AR-8 Dear Mr. Bakaric: Enclosed is Permit 1001-AR-8 completed in accordance with the provisions of Section of Regulation No. 19, Regulations a/the Arkansas Plan ofimplementation for Air Pollution Control. This permit amendment is necessary to add an electric heat treating oven to the Insignificant Activities List. Total permitted annual emission rate limits remain unchanged. Please place the revised permit in your files. Sincerely, Mike Bates Chief, Air Division pc Enclosure cc: Mr. Hal Grant Pace Industries, Inc. P.O. Box 309 Fayetteville, AR ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE I NORTH UTILE ROCKI ARKANSAS I TELEPHONE I FAX \A'H/I,,' r1rlon ctnta flr lie:.

2 ADEQ MINOR SOURCE AIR PERMIT Permit No.: 1001-AR-8 IS ISSUED TO: Pace Industries, Inc., Harrison Division 513 Highway North Bypass Harrison, AR Boone County THIS PERMIT IS THE ABOVE REFERENCED PERMITTEE'S AUTHORITY TO CONSTRUCT, MODIFY, OPERATE, AND/OR MAINTAIN THE EQUIPMENT AND/OR FACILITY IN THE MANNER AS SET FORTH IN THE DEPARTMENT'S MINOR SOURCE AIR PERMIT AND THE APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THE PROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT (ARK. CODE ANN. SEC ET SEQ.) AND THE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Mike Bates Chief, Air Division Date August 12, 2011

3 Table ofcontents Section I: FACILITY INFORMATION 4 Section II: INTRODUCTION 5 Summary ofpermit Activity 5 Process Description 5 Regulations 6 Total Allowable Emissions 6 Section III: PERMIT HISTORY 8 Section IV: EMISSION UNIT INFORMATION 10 Section V: INSIGNIFICANT ACTIVITIES 16 Section VI: GENERAL CONDITIONS 17 2

4 List ofacronyms and Abbreviations A.c.A. AFIN BH CFR CM CO HAP lb/hr No. NOx PM PM 10 S02 tpy UTM VOC Arkansas Code Annotated ADEQ Facility Identification Number Baghouse Code offederal Regulations Central Melt [furnace] 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

5 Permit#: 1001-AR-8 Section I: FACILITY INFORMATION PERMITTEE: Pace Industries, Inc., Harrison Division PERMIT NUMBER: 1001-AR-8 FACILITY ADDRESS: 513 Highway North Bypass Harrison, AR MAILING ADDRESS: P.O. Box 1198 Harrison, AR COUNTY: CONTACT NAME: CONTACT POSITION: Boone County Michael Bakaric Division President TELEPHONE NUMBER: REVIEWING ENGINEER: Patty Campbell, PE UTM North South (Y): Zone 15: m UTM East West (X): Zone 15: m 4

6 Section II: INTRODUCTION Summary of Permit Activity Pace Industries, Inc., Harrison Division (Pace) operates an aluminum and zinc die casting manufacturing facility (NAICS , ) located at 513 Highway 62/65 North Bypass, Harrison, Boone County, Arkansas This permit action is necessary to install an electric heat treating oven (la, A-13). There are no changes to the annual emissions. Process Description Pace - Harrison Division is a fabricator ofcustom high quality aluminum castings and is not a secondary aluminum production facility. Aluminum is melted in eight (8) reverberatory central melt (CM) furnaces (CM1, CM2, CM3, CM7 and CM9 through CM12) which are natural gasfired. Products ofnatural gas combustion and small amounts ofaluminum PM are emitted to the atmosphere. Reverberatory furnace emissions are based on an in-house 1997 stack test. Molten aluminum is transferred to holding furnaces which keep the aluminum in a liquid state prior to casting. The facility has 49 small holding furnaces. Eighteen (18) holding furnaces are natural gas-fired, Insignificant Activity (la), A-I. The gas-fired furnaces emit products ofcombustion as well as small amounts ofaluminum particulate. The remaining 31 holding furnaces (la, A 13) are electric and emit only a small amount of aluminum particulate matter. There is one electric heat treating furnace (la, A-B) for distressing ofmetal in parts and dies. CM1 through CM6, CM8, DC8 and DC12 have been removed from service. However, CM1, CM2 and CM3 source numbers were re-issued to newly installed furnaces with Permit #1001-AR-7, dated April 11,2011. Molten aluminum is transferred to die cast machines, where it is forced into water cooled dies. After the castings have cooled and solidified, they are trimmed by a hydraulic press. Trimmings are recycled to the central melt furnaces. Aluminum die cast parts arriving from the cast and trim areas are directed to the finishing area. The finishing area is being upgraded to incorporate robotic positioning during polishing operations. The finishing operation uses a fine grit aluminum oxide to polish select components. The castings are finished by shot blasting, sanding and/or drilling. The shot blaster has two high efficiency baghouses, BH1 and BH2, which exhaust outside. Baghouse BH3 supports an additional polishing operation within the finishing area. The finishing area has several small dust collectors which exhaust into the building and are not considered emission points. 5

7 Regulations The following table contains the regulations applicable to this permit. Regulations Arkansas Air Pollution Control Code, Regulation 18, effective June 18, 2010 Regulations ofthe Arkansas Plan ofimplementation for Air Pollution Control, Regulation 19, effective July 18, CFR Part 63 Subpart RRR - National Em ission Standards for Secondary Aluminum Production does not apply because Pace is 1) not a secondary AL production facility ( ); 2) not a major source ofhaps ( (e»; and 3) exempted by (f). 40 CFR Part 60 Subpart Q - Standards ofperformance/or Primary Zinc Smelters does not apply because Pace's zinc operation involves only melting operations. Refining, sintering or gases containing PM are not emitted from the zinc melting furnaces. Only natural gas combustion emissions are emitted. Total Allowable Emissions The following table is a summary of emissions from the facility. This table, in itself, is not an enforceable condition ofthe permit. TOTAL ALLOWABLE EMISSIONS Pollutant lb/hr Emission Rates tpy PM PM S VOC CO

8 TOTAL ALLOWABLE EMISSIONS Pollutant lb/hr Emission Rates tpy NO x Hydrogen Chloride (HCI)) Hydrogen Fluoride (HF)I I HCl and HF are not VOCs, HAPs only. 7

9 Section III: PERMIT HISTORY Permit # 1001-A was issued on May 18, 1990 as evidenced in a routine inspection report dated August 22, Permit # 100l-AR-l was issued on December 13, 1995 as a modification to allow the installation oftwo (2) central melt furnaces, five electric holding furnaces and one (1) shot blaster. This information was obtained from a routine inspection report dated January 24, Permit # 1001-AR-2 was issued as a modification to allow the installation ofa second baghouse to help control emissions from the shot blasting operations and for the installation ofa new central melt furnace. Several sources were designated as insignificant activities and an annual production limit was established. Permit # 1001-AR-3 was issued on March 17,2004 as a modification to allow the installation of an additional melt furnace to be identified as SN-CM9, and proposed to modify two natural gas holding furnaces (SN-DC8 and SN-DCI2), previously listed as insignificant emission sources, into melt furnaces for special alloys. This installation and modification will not cause an increase in permitted emissions since the current aluminum melt rate will remain unchanged. This permit was amended on 6/18/04 in order to make a change to the Insignificant Activities. Permit # 1001-AR-4 was issued on April 6, 2006 as a modification to allow the replacement of two large inefficient melt furnaces (CM 1 and CM6) and two holding/melt furnaces (DC8 and DCI0) with two smaller more efficient furnaces to be designated as SN-CMI0 (8.0 MMBtu/hr) & SN-CM11 (5.0 MMBTU/hr). The modification will not cause an increase in permitted emissions from the facility because the current permitted aluminum melt rate of 175,000 tpy will remain unchanged. Permit #100 l-ar-5 was issued on July 28, 2006 as a modification to allow installation ofa new natural gas fired central melt furnace, SN-CMI2, with heat input to the burner of 14.0 MMBtu/hr. This modification also includes increasing the natural gas heat input which includes changing the burners ofsn-cmi0 from 8.0 to 14.0 MMBtu/hr and SN-CMll from 5.0 to 15.0 MMBtu/hr. In addition an increase in the visible emission limits for all central melt furnaces (SN-CM2, 3, 5, 7, 8, 9, 10, 11 & 12) from 10% to 20% opacity as measured by EPA Reference Method 9. This increase in the opacity limit is in accordance with Regulation 19, (B)(2). Permit #1001-AR-5 was amended on May 19,2008 as L&P Aluminum Holdings, LLC formerly Pace Industries, Inc. This permit amendment allowed physical removal of CM3 and CM4, each a 5.0 MMBtu/hr natural gas-fired furnaces. There was no change in annual emissions because the permitted aluminum melt rate of 175,000 tons per year remained unchanged. Permit #1001-AR-6 was issued to Pace Industries - Harrison Division on August 30,2010. This permit action is necessary to: Retire an existing baghouse (BH 1) and replace with a used more efficient (99.90%) baghouse (BHl); Install a new 99.99% efficient baghouse (BH3) for 8

10 Permit #: IOOI-AR-8 aluminum Polishing Dust Collection; Remove Central Melt (CM) Furnaces #2, #5 and #8 from service; IA changes included the following: change existing, natural gas-fired crucible/holding furnaces total from twelve to seventeen (17) and add one (1) new 1.75 MMBtulhr natural gasfired Thermtronix furnace, all A-I; Clarify that all aluminum ingots, billets and logs processed shall be free ofany paints, coatings, or lubricants and refine recordkeeping of same; and Add a requirement to burn only pipeline quality natural gas as fuel at the facility. The total permitted annual emission rate limit changes associated with this modification include: -0.9 tons per year (tpy) PM and -0.9 tpy PM lo Permit #1001-AR-7 was issued to Pace Industries - Harrison Division on April 11,2011. This permit action was necessary to: 1. Install three reverberatory melt furnaces: 7000, 8000 and 4000 lb/hr (CMl through CM3, respectively, reissue ofthese source numbers); 2. Add ten electric Westomat dosing furnaces (la, A-13); 3. Correct CM7 input heat rating to be 22 MMBtulhr; and 4. Correct CM10 and CM 12 melt rates to be 6,000 lb/hr and input heat rating to be 12 MMBtu/hr each. There were no changes to annual emissions because the aluminum melt throughput limit at the furnaces did not change. 9

11 Section IV: EMISSION UNIT INFORMATION Specific Conditions 1. The permittee shall not exceed the emission rates set forth in the following table. Hourly particulate emissions from the central melt furnaces are based on stack tests. The permittee shall demonstrate compliance with this condition by operating at or less than maximum capacity. Annual emissions are based on the aluminum melt limitation as stated in Specific Condition #6. [Regulation et seq. and A.C.A as referenced by and ] SN Description Pollutant lb/hr tpy PM * S * 7,000 lb/hr Central Melt Furnace CM1 (natural gas, 14.0 MMBtulhr, VOC 1.1 * stack test emission factors) CO 0.2 * NOx 0.6 * PM * S * 8,000 lb/hr Central Melt Furnace CM2 (natural gas, 16.0 MMBtulhr, VOC stack test emission factors) 1.2 * CO 0.3 * NOx 0.7 * PM * S * 4,000 lb/hr Central Melt Furnace CM3 (natural gas, 8.0 MMBtulhr, VOC 0.6 * stack test emission factors) CO 0.2 * NOx 0.4 * CM7 8,000 lb/hr Central Melt Furnace PM * (natural gas, 5.0 MMBtulhr, stack S * 10

12 SN Description Pollutant lb/hr tpy test emission factors) VOC 2.5 * CO 0.5 * NOx 1.4 * PM * S * 2,000 lb/hr Central Melt Furnace CM9 (natural gas, 5.0 MMBtu/hr, stack VOC 0.4 * test emission factors) CO 0.1 * NOx 0.2 * PM * S * 7,000 lb/hr Central Melt Furnace CMI0 (natural gas, 14.0 MMBtu/hr, stack VOC 1.3 * test emission factors) CO 0.3 * NOx 0.7 * PM IO 0.7 * S * 4,000 lb/hr Central Melt Furnace CMll (natural gas, 15.0 MMBtu/hr, stack VOC 1.4 * test emission factors) CO 0.3 * NO x 0.8 * PM * CM12 7,000 lb/hr Central Melt Furnace S * (natural gas, 14.0 MMBtu/hr, stack test emission factors) VOC 1.3 * CO 0.3 * 11

13 SN Description Pollutant lb/hr tpy NO x 0.7 * PM *Total Annual Emissions S Eight Central Melt Furnaces (CM1-CM3, CM7 and CM9-12) VOC (based on 175,000 tons ofal per year, Internal Scrap, Clean AL, Flux & Silicon) CO NOx BH1 BH2 BH3 Shot Blaster Baghouse # 1 (99.90% efficient) Shot Blaster Baghouse # 2 (99.0% efficient) Aluminum Polishing Dust Baghouse #3 (99.99% efficient) PM PM PM The permittee shall not exceed the emission rates set forth in the following table. The permittee shall not exceed the emission rates set forth in the following table. Hourly emissions are based on stack tests. Annual emissions are based on the aluminum melt limitation as stated in Specific Condition #6. [Regulation and A.C.A as referenced by and ] SN Description Pollutant lb/hr tpy PM 0.5 ** 7,000 lb/hr Central Melt Furnace CM1 (natural gas, 14.0 MMBtulhr, ** HCI 0.21 stack test emission factors) ** HF 0.01 PM 0.5 8,000 lb/hr Central Melt Furnace CM2 (natural gas, 16.0 MMBtu/hr, HCI 0.24 stack test emission factors) HF 0.01 CM3 ** 4,000 lb/hr Central Melt Furnace PM 0.3 ** ** ** 12

14 SN Description Pollutant lb/hr tpy (natural gas, 8.0 MMBtulhr, ** HCl 0.12 stack test emission factors) ** HF 0.01 PM 1.2 ** 8,000 lb/hr Central Melt Furnace CM7 (natural gas, 5.0 MMBtu/hr, stack HCI 0.78 ** test emission factors) HF 0.03 ** PM 0.2 ** 2,000 lb/hr Central Melt Furnace CM9 (natural gas, 5.0 MMBtulhr, stack. HCI 0.10 ** test emission factors) HF 0.01 ** PM 0.6 ** 7,000 lb/hr Central Melt Furnace CMI0 (natural gas, 14.0 MMBtu/hr, stack HCI 0.40 ** test emission factors) HF 0.01 ** PM 0.7 ** 4,000 lb/hr Central Melt Furnace CMll (natural gas, 15.0 MMBtulhr, stack HCl 0.50 ** test emission factors) HF 0.01 ** PM 0.6 ** 7,000 lb/hr Central Melt Furnace CM12 (natural gas, 14.0 MMBtulhr, stack HCI 0.40 ** test emission factors) HF 0.01 ** **Total Annual Emissions PM Eight Central Melt Furnaces (CMI-CM3, CM7 and CM9-12) HCl (based on 175,000 tons ofal per year, Internal Scrap, Clean AL, Flux & Silicon) HF BHl Shot Blaster Baghouse #1 (99.90% efficient) PM

15 SN Description Pollutant lb/hr tpy BH2 BH3 Shot Blaster Baghouse # 2 (99.0% efficient) Aluminum Polishing Dust Baghouse #3 (99.99% efficient) PM PM Visible emissions may not exceed the limits specified in the following table ofthis permit as measured by EPA Reference Method 9. [A.C.A as referenced by and ] SN Limit Regulatory Citation CMl, CM2, CM3, CM7 and CM9-CMI2 20% (B)(2) BH 1, BH2 and BH3 10% and A.C.A. 4. The permittee shall not cause or permit the emission of air contaminants, including odors or water vapor and including an air contaminant whose emission is not otherwise prohibited by Regulation #18, ifthe emission ofthe air contaminant constitutes air pollution within the meaning of A.C.A [Regulation and A.C.A as referenced by and 8-4-3l1] 5. The permittee shall not conduct operations in such a manner as to unnecessarily cause air contaminants and other pollutants to become airborne. [Regulation and A.C.A as referenced by and ] 6. The permittee shall not process more than 175,000 tons of aluminum (AL) at the facility per consecutive l2-month period. The maximum annual melt rate of aluminum (175,000 tpy) shall include clean aluminum scrap, flux and silicon. [Regulation and A.C.A as referenced by and ] 7. The permittee shall only charge the melt furnaces with clean aluminum ingots, billets or logs and internally recycled clean aluminum scrap. All aluminum ingots, billets and logs processed shall be free of any paints, coatings, or lubricants. Oily aluminum scrap shall not be used to charge the melt furnaces. The permittee is not subject to 40 CFR Part 63, Subpart RRR. [Regulation , Regulation , and 40 CFR (f)] 8. The permittee shall maintain documentation (e.g., purchase orders, inspection notes on received billets or operator checklist) and monthly records which demonstrate compliance with Specific Conditions #6 and #7. The permittee shall update the records 14

16 by the fifteenth day of the month following the month to which the records pertain. A twelve month rolling total and each individual month's data shall be maintained on-site and made available to Department personnel upon request. [Regulation and A.C.A as referenced by and 8-4-3l1] 9. The permittee shall burn only pipeline quality natural gas as fuel at the facility. Combustion emissions from fuel burning process equipment have been calculated at full load for continuous operation and no recordkeeping ofnatural gas usage is required. [Regulation and A.C.A as referenced by and ] 15

17 Section V: INSIGNIFICANT ACTIVITIES The Department deems the following types ofactivities or emissions as insignificant on the basis ofsize, emission rate, production rate, or activity in accordance with Group A ofthe Insignificant Activities list found in Regulation 18 and 19 Appendix A. Insignificant activity emission determinations rely upon the information submitted by the permittee in an application dated July 29, Description Seventeen (17) natural gas fired Holding Furnaces: seven 0.2 MMBtulhr, six 0.4 MMBtu/hr, two 0.5 MMBtulhr and two 0.8 MMBtu/hr One Thermtronix natural gas-fired Holding Furnace, 1.75 MMBtu/hr Category A-I A-I Forty-one (41) electric Holding Furnaces A-13 Finishing Area Dust Collectors - not vented to atmosphere A-13 Die Lubricant Vaporization: water-based non-voc, non-hap mold release Lubricant. A-13 One (1) electric Heat Treating Oven, 0.66 MMBtu/hr A-13 16

18 Section VI: GENERAL CONDITIONS 1. Any terms or conditions included in this permit that specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A et seq.) as the sole origin ofand authority for the terms or conditions are not required under the Clean Air Act or any of its applicable requirements, and are not federally enforceable under the Clean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 18 was adopted pursuant to the Arkansas Water and Air Pollution Control Act (AC.A et seq.). Any terms or conditions included in this permit that specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A 8-4-lO1 et seq.) as the origin ofand authority for the terms or conditions are enforceable under this Arkansas statute. 2. This permit does not relieve the owner or operator of the equipment and/or the facility from compliance with all applicable provisions ofthe Arkansas Water and Air Pollution Control Act and the regulations promulgated under the Act. [A.C.A as referenced by and 8-4-3ll] 3. The permittee shall notify the Department in writing within thirty (30) days after commencement of construction, completion ofconstruction, first operation ofequipment and/or facility, and first attainment ofthe equipment and/or facility target production rate. [Regulation and/or AC.A as referenced by and 8-4-3ll] 4. Construction or modification must commence within eighteen (18) months from the date ofpermit issuance. [Regulation (B) and/or Regulation (B) and A.C.A as referenced by and 8-4-3l1] 5. The permittee must keep records for five years to enable the Department to determine compliance with the terms of this permit such as hours of operation, throughput, upset conditions, and continuous monitoring data. The Department may use the records, at the discretion of the Department, to determine compliance with the conditions of the permit. [Regulation and/or Regulation l004andA.C.A as referenced by and 8-4-3ll] 6. A responsible official must certify any reports required by any condition contained in this permit and submit any reports to the Department at the address below. [Regulation and/or Regulation and A.C.A as referenced by and ] Arkansas Department ofenvironmental Quality Air Division ATTN: Compliance Inspector Supervisor 17

19 5301 Northshore Drive North Little Rock, AR The permittee shall test any equipment scheduled for testing, unless stated in the Specific Conditions ofthis permit or by any federally regulated requirements, within the following time frames: (1) newly constructed or modified equipment within sixty (60) days of achieving the maximum production rate, but no later than 180 days after initial start up of the permitted source or (2) existing equipment already operating according to the time frames set forth by the Department. The permittee must notify the Department ofthe scheduled date ofcompliance testing at least fifteen (15) business days in advance of such test. The permittee must submit compliance test results to the Department within thirty (30) calendar days after the completion of testing. [Regulation and/or Regulation and A.C.A as referenced by and ] 8. The permittee shall provide: [Regulation and/or Regulation and A.C.A as referenced by and ] a. Sampling ports adequate for applicable test methods; b. Safe sampling platforms; c. Safe access to sampling platforms; and d. Utilities for sampling and testing equipment 9. The permittee shall operate equipment, control apparatus and emission monitoring equipment within their design limitations. The permittee shall maintain in good condition at all times equipment, control apparatus and emission monitoring equipment. [Regulation and/or Regulation and A.C.A as referenced by and ] 10. Ifthe permittee exceeds an emission limit established by this permit, the permittee will be deemed in violation ofsaid permit and will be subject to enforcement action. The Department may forego enforcement action for emissions exceeding any limits established by this permit provided the following requirements are met: [Regulation and/or Regulation Oland A.C.A as referenced by and I ] a. The permittee demonstrates to the satisfaction ofthe Department that the emissions resulted from an equipment malfunction or upset and are not the result ofnegligence or improper maintenance, and the permittee took all reasonable measures to immediately minimize or eliminate the excess emissions. b. The permittee reports the occurrence or upset or breakdown ofequipment (by telephone, facsimile, or overnight delivery) to the Department by the end ofthe next business day after the occurrence or the discovery ofthe occurrence. c. The permittee must submit to the Department, within five business days after the occurrence or the discovery ofthe occurrence, a full, written report of such occurrence, including a statement ofall known causes and ofthe scheduling and 18

20 Permit #: IOOI-AR-8 nature ofthe actions to be taken to minimize or eliminate future occurrences, including, but not limited to, action to reduce the frequency of occurrence ofsuch conditions, to minimize the amount by which said limits are exceeded, and to reduce the length oftime for which said limits are exceeded. Ifthe information is included in the initial report, the information need not be submitted again. I I. The permittee shall allow representatives ofthe Department upon the presentation of credentials: [A.C.A as referenced by and ] a. To enter upon the permittee's premises, or other premises under the control ofthe permittee, where an air pollutant source is located or in which any records are required to be kept under the terms and conditions ofthis permit; b. To have access to and copy any records required to be kept under the terms and conditions ofthis permit, or the Act; c. To inspect any monitoring equipment or monitoring method required in this permit; d. To sample any emission ofpollutants; and e. To perform an operation and maintenance inspection ofthe permitted source. 12. The Department issued this permit in reliance upon the statements and presentations made in the permit application. The Department has no responsibility for the adequacy or proper functioning of the equipment or control apparatus. [A.C.A as referenced by and ] 13. The Department may revoke or modify this permit when, in the judgment ofthe Department, such revocation or modification is necessary to comply with the applicable provisions ofthe Arkansas Water and Air Pollution Control Act and the regulations promulgated the Arkansas Water and Air Pollution Control Act. [Regulation IO(A) and/or Regulation (A) and A.C.A as referenced by and ] 14. This permit may be transferred. An applicant for a transfer must submit a written request for transfer ofthe permit on a form provided by the Department and submit the disclosure statement required by Arkansas Code Annotated at least thirty (30) days in advance ofthe proposed transfer date. The permit will be automatically transferred to the new permittee unless the Department denies the request to transfer within thirty (30) days ofthe receipt ofthe disclosure statement. The Department may deny a transfer on the basis ofthe information revealed in the disclosure statement or other investigation or, deliberate falsification or omission ofrelevant information. [Regulation (B) and/or Regulation (B) and A.C.A as referenced by and I] 15. This permit shall be available for inspection on the premises where the control apparatus is located. [A.C.A as referenced by and I 1] 19

21 16. This permit authorizes only those pollutant emitting activities addressed herein. [A.C.A as referenced by and ] 17. This permit supersedes and voids all previously issued air permits for this facility. [Regulation 18 and 19 and A.C.A as referenced by and ] 18. The permittee must pay all permit fees in accordance with the procedures established in Regulation No.9. [A.C.A (c)] 19. The permittee may request in writing and at least 15 days in advance ofthe deadline, an extension to any testing, compliance or other dates in this permit, No such extensions are authorized until the permittee receives written Department approval. The Department may grant such a request, at its discretion in the following circumstances: a. Such an extension does not violate a federal requirement; b. The permittee demonstrates the need for the extension; and c. The permittee documents that all reasonable measures have been taken to meet the current deadline and documents reasons it cannot be met. [Regulation (A), Regulation (A), A.C.A as referenced by and , and 40 CFR Part 52, Subpart E] 20. The permittee may request in writing and at least 30 days in advance, temporary emissions and/or testing that would otherwise exceed an emission rate, throughput requirement, or other limit in this permit. No such activities are authorized until the permittee receives written Department approval. Any such emissions shall be included in the facilities total emissions and reported as such. The Department may grant such a request, 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 ofair pollution; d. The request contains such information necessary for the Department to evaluate the request, including but not limited to, quantification ofsuch emissions and the date/time such emission will occur; e. Such a request will result in increased emissions less than five tons ofany individual criteria pollutant, one ton ofany single HAP and 2.5 tons oftotal HAPs; and f. The permittee maintains records ofthe dates and results ofsuch temporary emissions/testing. [Regulation (B), Regulation (B), A.C.A as referenced by and , and 40 CFR Part 52, Subpart E] 20

22 21. The permittee may request in writing and at least 30 days in advance, an alternative to the specified monitoring in this permit. No such alternatives are authorized until the permittee receives written Department approval. The Department may grant such a request, 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 ofactual monitoring to the current requirements; and c. Any such request, ifapproved, is incorporated in the next permit modification application by the permittee. [Regulation (C), Regulation (C), A.C.A as referenced by and , and 40 CFR Part 52, Subpart E] 21