STATEMENT OF BASIS. NAICS Description: Soybean and Other Oilseed Processing NAICS Code:

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1 STATEMENT OF BASIS For the issuance of Draft Air Permit # 1427-AOP-R14 1. PERMITTING AUTHORITY: Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, Arkansas APPLICANT: Planters Cotton Oil Mill, Inc Planters Drive Pine Bluff, Arkansas PERMIT WRITER: Amanda Leamons 4. NAICS DESCRIPTION AND CODE: NAICS Description: Soybean and Other Oilseed Processing NAICS Code: ALL SUBMITTALS: Date of Application Type of Application (New, Renewal, Modification, Deminimis/Minor Mod, or Administrative Amendment) Short Description of Any Changes That Would Be Considered New or Modified s 1/29/2016 Renewal (with Mod) None 2/3/2016 Minor Mod Rotary Drum Filters #4 (SN-80) & #5 (SN-81) added to handle product and emissions from several existing sources. SN-74 ( Baghouse) removed. 6. REVIEWER S NOTES: Planters Cotton Oil Mill (Planters) is located at 2901 Planters Drive in Pine Bluff, Arkansas where it currently produces vegetable oil from cottonseed separation and solvent extraction (NAICS ). The facility s Title V Air Operating Permit is being modified and renewed with this permitting action. With this Title V renewal, a minor modification was approved on February 10, 2016 to allow the facility to install and operate Rotary Drum Filter #4 (SN-80) and Rotary Drum Filter #5 (SN-81). The two new rotary drum filters replaced the existing baghouse,

2 Page 2 of 2 SN-74. In addition, the facility was allowed to re-route Trash Beater #2 (SN-61) from Rotary Drum Filter #3 (SN-64) to Rotary Drum Filter #4 (SN-80). The baghouse, SN-74, was removed with this permit revision. Lastly, the requirements of 40 CFR Part 63, Subpart ZZZZ were updated and corrected for SN-79 and applicable requirements from 40 CFR Part 63, Subpart DDDDD (Boiler MACT) were added to the Specific Conditions for SN-44 and SN-45, natural gas fired boilers. The above mentioned changes along with updated emission factor information resulted in overall annual permitted emission limit decreases of 86.8 tons of PM and 3.0 tons of PM 10. All other permitted emissions remained unchanged with this permit renewal. 7. COMPLIANCE STATUS: The following summarizes the current compliance of the facility including active/pending enforcement actions and recent compliance activities and issues. Pending enforcement of March 2016 inspection findings: Failed to maintain calendar year totals & each month's data of hours it operated emergency generator (SN-79) for the last 7 months. Failed to maintain records showing weekly inspections of cyclones & filters had been conducted over the last 19 months. Failed to document if Visible s (VE) were detected during weekly observations on 38 sources. Failed to document if VEs were detected during daily observations on SN PSD APPLICABILITY: a) Did the facility undergo PSD review in this permit (i.e., BACT, Modeling, etc.)? N b) Is the facility categorized as a major source for PSD? Y Single pollutant 100 tpy and on the list of 28 or single pollutant 250 tpy and not on list If yes, explain why this permit modification is not PSD. s less than significant modification under PSD 9. SOURCE AND POLLUTANT SPECIFIC REGULATORY APPLICABILITY: Source Pollutant Regulation (NSPS, NESHAP or PSD) 44 & 45 NA* NSPS Dc SN-32, 42, 43, 46, and 56 Hexane NESHAP GGGG 79 HAPs NESHAP ZZZZ

3 Page 3 of 3 Source Pollutant Regulation (NSPS, NESHAP or PSD) 44 & 45 Filterable PM NESHAP DDDDD 10. EMISSION CHANGES AND FEE CALCULATION: See emission change and fee calculation spreadsheet in Appendix A. 11. AMBIENT AIR EVALUATIONS: a) Reserved. b) Non-Criteria Pollutants: The non-criteria pollutants listed below were evaluated. Based on Department procedures for review of non-criteria pollutants, emissions of all other non-criteria pollutants are below thresholds of concern. 1 st Tier Screening (PAER) Estimated hourly emissions from the following sources were compared to the Presumptively Acceptable Rate (PAER) for each compound. The Department has deemed the PAER to be the product, in lb/hr, of 0.11 and the Threshold Limit Value (mg/m 3 ), as listed by the American Conference of Governmental Industrial Hygienists (ACGIH). Pollutant TLV (mg/m 3 ) PAER (lb/hr) = 0.11 TLV Proposed lb/hr Acrolein Y Arsenic E-6 Y Beryllium E-7 Y Cadmium E-5 Y n-hexane N Lead E-5 Y Manganese E-5 Y Mercury E-5 Y POM Y Pass?

4 Page 4 of 4 2 nd Tier Screening (PAIL) AERMOD air dispersion modeling was performed on the estimated hourly emissions from the following sources, in order to predict ambient concentrations beyond the property boundary. The Presumptively Acceptable Impact Level (PAIL) for each compound has been deemed by the Department to be one one-hundredth of the Threshold Limit Value as listed by the ACGIH. Pollutant PAIL (μg/m 3 ) = 1/100 of Threshold Limit Value Modeled Concentration (μg/m 3 ) Pass? n-hexane Y c) H 2 S Modeling: 12. CALCULATIONS: SN & , & Factor Source 2012 Stack Test for PM 2012 Stack Test for PM Total PM stack test performed Dec Total PM stack test performed June 2005 Journal of Cotton Science 4: (2000), and AP- 42, 9.7 Journal of Cotton Science 4: (2000), and AP- 42, CFR 63, Subpart GGGG Factor (lb/ton, lb/hr, etc.) PM=0.2 lb/hr PM 10 = 0.03 lb/hr 15% of PM PM=0.1 lb/hr PM 10 =0.015 lb/hr 15% of PM PM=0.005gr/cf PM 10 =PM PM= gr/cf PM 10 =PM PM=0.04 gr/cf PM 40% of PM=0.016gr/cf PM=0.04 gr/cf PM 40% of PM=0.016gr/cf VOC, 0.5 gal/ton 2.83 lb/ton loss density=5.65 lb/gal Efficiency Comments *Based on 31.5% assignment. Assumes 100% lost at facility.

5 Page 5 of 5 SN 35 Factor Source Journal of Cotton Science 4: (2000), and AP- 42, AP AP-42, , 43, & & 45 Journal of Cotton Science 4: (2000) Factor (lb/ton, lb/hr, etc.) PM=0.04 gr/cf PM 40% of PM=0.016gr/cf lb PM /ton grain lb PM10 /ton grain Shipping: lb PM /ton lb PM10 /ton PM=0.04 gr/cf PM 40% of PM=0.016gr/cf Efficiency Comments 95% 160,000 tpy meal cyclone solvent lost VOC, 0.5 gal/ton --- AP-42, natural gas 7.6 lb PM10 /MMscf 0.6 lb SO2 /MMscf 5.5 lb VOC /MMscf 84 lb CO /MMscf 100 lb NOX /MMscf lb Pb /MMscf solvent lost VOC, 0.5gal/ton Testing 58, 59, 80, & 81 Testing 62 & 63 Testing 64 Testing 73 AP Testing (Nov 2012) 75 AP gr/cf PM gr/cf PM gr/cf PM gr/cf PM 10 PM=0.01 gr/cf PM 10 =0.1 lb/hr PM = gr/cf PM 10 = gr/cf lb PM /ton grain lb PM10 /ton grain PM=0.01 lb/hr PM 10 =0.02 lb/hr lb PM /ton grain lb PM10 /ton grain % None None *Based on 5.7% assignment. Assumes 100% lost at facility. Based upon maximum capacity. *Based on 51.3% assignment. Assumes 100% lost at facility Operate seed cooling fans at maximum capacity. This is a baghouse

6 Page 6 of 6 SN Factor Source 76 AP Factor (lb/ton, lb/hr, etc.) lb PM /1000 gal lb PM10 /1000 gal None Efficiency Comments Water flow rate = 3600 gal/min 77 &78 AP AP lb PM /ton grain lb PM10 /ton grain 85 hp CI RICE Max: 500 hr/yr 0.31 lb PM10 /MMBtu 0.29 lb SO2 / MMBtu 0.36 lb VOC / MMBtu 0.95 lb CO / MMBtu 4.41 lb NOx / MMBtu None None 94,500 tpy hulls 13. TESTING REQUIREMENTS: This permit does not require any testing of emission sources. 14. MONITORING OR CEMS: The permittee must monitor the following parameters with CEMS or other monitoring equipment (temperature, pressure differential, etc.) SN Parameter or Pollutant to be Monitored Method (CEM, Pressure Gauge, etc.) 79 Hours of operation Non-resettable hour meter 15. RECORDKEEPING REQUIREMENTS: Frequency continuous (when in operation) Report (Y/N) N The following are items (such as throughput, fuel usage, VOC content, etc.) that must be tracked and recorded. SN Recorded Item Permit Limit Frequency Facility Cottonseed throughput 350,000 tpy Yearly Y 32,42, 43, 46 & 56 Hexane make-up 44 & 45 Natural gas usage lb/gal (Normal Hexane) lb/gal (other Hexane) Monthly Report (Y/N) 175,000 gallon per year Yearly Y Operating boilers at maximum capacity Daily Y N

7 Page 7 of 7 SN Recorded Item Permit Limit Frequency OPACITY: Report (Y/N) Amount of fuel used NA monthly Y Tune-up for Gas 1 Units Hulls & Meal Throughput Hours of Operation (must identify emergency and non- emergency) Engine oil & filter changes Inspect air cleaner Inspect all hoses/belts See SC 54 & 59 annually Y 20,000 tons Monthly N 500 hr/yr Total (100 hr/yr for main. checks/testing 50hr of which can be nonemergency) Every 500hr or Annually Every 1,000 hr or Annually Replace as Necessary Every 500 hr or Annually Replace as Necessary SN Opacity Justification for limit 6-12, 18-28, 32, 42, 43, 47, 48-51, 56, 57, 73 5% 44 & 45 5% 13, 29, 30, 35, 38, 52, 58, 59, 62, 64, 80, & 81 Previous Permit & Dept. Guidance Previous Permit & Dept. Guidance Monthly When changed When inspected When inspected Y N N N Compliance Mechanism Weekly Observation Burn only Nat. Gas 10% Dept. Guidance Weekly Observation 37 20% Daily Observation 76 20% Weekly Observation 79 20% Annual Observation 17. DELETED CONDITIONS: Former SC Justification for removal SN-74 has been removed from service

8 Page 8 of GROUP A INSIGNIFICANT ACTIVITIES: Source Name Group A Category s (tpy) PM/PM 10 SO 2 VOC CO NO x Cottonseed Oil Tanks A HAPs Single Total Hexane Tanks (no vent) A-13 Miscella Tanks (no vent) A-13 Portable Loaders (SN-60) A Air Dryer for Pellet Cooler A-13 Cooker Cooling Air A-13 Clay Tanks (2) A Bulk Meal House A-13 Meal Conveyor to BMH A-13 Total A VOIDED, SUPERSEDED, OR SUBSUMED PERMITS: List all active permits voided/superseded/subsumed by the issuance of this permit. Permit # 1427-AOP-R13

9 APPENDIX A EMISSION CHANGES AND FEE CALCULATION

10 Fee Calculation for Major Source Facility Name: Planters Cotton Oil Mill, Inc. Permit Number: 1427-AOP-R14 AFIN: Revised $/ton factor Annual s (tpy) Permit Type Modification Permit Fee $ 1000 Minor Modification Fee $ 500 Minimum Modification Fee $ 1000 Renewal with Minor Modification $ 500 Check if Facility Holds an Active Minor Source or Minor Source General Permit If Hold Active Permit, Amt of Last Annual Air Permit Invoice $ 0 Total Permit Fee s (tpy) Initial Title V Permit Fee s (tpy) HAPs not included in VOC or PM: Air Contaminants: Chlorine, Hydrazine, HCl, HF, Methyl Chloroform, Methylene Chloride, Phosphine, Tetrachloroethylene, Titanium Tetrachloride All air contaminants are chargeable unless they are included in other totals (e.g., H2SO4 in condensible PM, H2S in TRS, etc.) Pollutant (tpy) Check if Old Permit New Permit Change in s Permit Fee s Annual s PM PM PM SO VOC CO NO X Lead

11 Pollutant (tpy) Check if Old Permit New Permit Change in s Permit Fee s Annual s Arsenic Beryllium Cadium Hexane Manganese Mercury Total other HAPs