STATEMENT OF BASIS. NAICS Description: All Other Miscellaneous Chemical Product and Preparation Manufacturing NAICS Code:

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1 STATEMENT OF BASIS For the issuance of Draft Air Permit # 0196-AR-9 1. PERMITTING AUTHORITY: Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, Arkansas APPLICANT: Halliburton Energy Services, Inc Darby Lane Malvern, Arkansas PERMIT WRITER: Joseph Hurt 4. NAICS DESCRIPTION AND CODE: NAICS Description: All Other Miscellaneous Chemical Product and Preparation Manufacturing NAICS Code: SUBMITTALS: Date of Application Type of Application (New, Renewal, Modification, Deminimis/Minor Mod, or Administrative Amendment) 8/4/2014 De Minimis with 1 part denied and processed as a modification Short Description of Any Changes That Would Be Considered New or Modified Emissions Increasing duratone line capacity from 13,900 tpy to 19,272 tpy. New Sources: Lignite bulk storage silo (SN-18) Clay bulk storage silo (SN-19) 15,000 gallon Amine storage tank (SN-20) 4.5 MMBtu/hr Scott Dryer (SN-21) 1.0 MMBtu/hr hammer mill dryer (SN-22) Hammer Mill (SN-23) Rework bag dump (SN-26)

2 Page 2 of 8 6. REVIEWER S NOTES: With this modification, Halliburton requested: 1. Removal of the opacity requirements for SN Replace existing bulk bag dump stations for lignite and clay with negative air vacuum systems. The lignite bulk system silo (SN-18) and clay bulk system silo (SN-19) are each controlled with a fabric filter. 3. Replace the existing 4.5 MMBtu/hr duratone circuit dryer with a new natural gasfired Scott Dryer (SN-21). The exhaust from the dryer will be ducted to a dust collector and then routed to the thermal oxidizer (SN-16). 4. Replace the existing mill in the duratone circuit with a new hammer mill system (SN- 23), which is also heated with a 1.0 MMBtu/hr natural gas-fired heater (SN-22). Exhaust from the hammer mill will be ducted to a dust collector and then routed to the thermal oxidizer (SN-16). 5. The wastewater ponds (SN-14) will be closed and covered. Wastewater will be routed to the wastewater tanks (insignificant activity) and trucked off-site. 6. Replace the 12,000 gallon Amine storage tank (SN-15) with a 15,000 gallon Amine storage tank (SN-20). 7. Increase the duratone line capacity from 13,900 tpy to 19,272 tpy. 8. Add a rework bag dump (SN-26). During the review of the De Minimis application, it was discovered that the Product Packaging Duratone Circuit (SN-12), which was previously listed as an insignificant activity, is actually subject to 40 CFR Part 60, Subpart OOO. Therefore, this source cannot be an insignificant activity, and has been moved from the insignificant activities to a permitted source. The permitted emission increases include 0.8 tpy of PM/PM 10, 0.1 tpy of SO 2, 7.2 tpy of VOC, 0.03 tpy of HAP, 0.02 tpy of Methyl Chloride, and 0.01 tpy of Benzyl Chloride. The permitted emission decreases include 1.2 tpy of CO and 0.8 tpy of NO x. 7. COMPLIANCE STATUS: The following summarizes the current compliance of the facility including active/pending enforcement actions and recent compliance activities and issues. The facility was last inspected on August 21, No compliance issues were noted.

3 Page 3 of 8 8. 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? N 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. 9. SOURCE AND POLLUTANT SPECIFIC REGULATORY APPLICABILITY: Source Pollutant Regulation (NSPS, NESHAP or PSD) 10, 11, 12, 13, 16, 19, 23, & 26 PM 40 CFR Part 60, Subpart OOO 17 VOC, CO, NO x, and PM 40 CFR Part 60, Subpart IIII 10. EMISSION CHANGES AND FEE CALCULATION: See emission change and fee calculation spreadsheet in Appendix A. 11. NAAQS EVALUATIONS AND NON-CRITERIA POLLUTANTS: a) NAAQS: This permit decision did not involve an Arkansas Department of Pollution Control & Ecology Regulation 19, Chapter 9 permit (PSD) requiring dispersion modeling. 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 Emission 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).

4 Page 4 of 8 Pollutant TLV (mg/m 3 ) PAER (lb/hr) = 0.11 TLV Proposed lb/hr Methyl Chloride Y Benzyl Chloride Y 12. CALCULATIONS: SN Emission Factor Source Emission Factor Control Equipment Control Equipment Efficiency Pass? Comments Tanks 4.0 N/A Based on throughput 10 AP lb/ton 11 AP lb/ton 12 AP-42, Chapter 11.24, Table lb/ton: 0.12 PM/PM 10 Enclosed inside a building 90% Emission factor from AP-42 Table Emission factor from AP-42 Table ,272 tpy of Duratone product 13 AP lb/ton Emission factor from AP-42 Table Radian report of April 14 testing 1998, shows that 95% 95% IPA (VOC) of IPA is biodegraded biodegrades and 5% is evaporated into the atmosphere. 15 Tanks 4.0 N/A Based on throughput 16 AP-42 Natural Gas Section 1.4 IPA Combustion Section 1.5 lb/mmbtu: CO NO x PM/PM SO VOC lb/mgal: 1.9 CO 14 NO x 0.4 PM/PM 10 Thermal Oxidizer 98% Includes Duratone Circuit Scott Dryer (3.0 MMBtu/hr) & Extruder Circuit Rotary Dryers (2.4 MMBtu/hr)

5 Page 5 of 8 SN Emission Factor Source NSPS Limit AP-42 AP-42, Chapter 11.26, Table Emission Factor g/kw-hr: 4.0 NO x 5.0 CO 4.0 VOC 0.3 PM/PM 10 lb/mmbtu: 0.29 SO 2 lb/1000 lb: PM/PM 10 Control Equipment Control Equipment Efficiency None -- None TANKS 4.09b 0.05 lb/hr VOC None AP-42, Chapter 11.26, Table AP-42, Chapter 11.24, Table lb/1000 lb: PM/PM 10 lb/ton: 0.12 PM/PM 10 Dust Collector Enclosed inside a building -- 90% Comments 500 hour per year limit 139 BHp fire pump engine 5,250,000 lb of clay during any 12-month period 15,000 gallon Amine storage tank Max fill rate = 4,960 gal/hr 19,272 tons during any 12-month period. Emissions routed through the thermal oxidizer (SN-16) 50 bags per shift at 50 pounds per bag. 3 shifts per day 13. TESTING REQUIREMENTS: The permit requires testing of the following sources. SN Pollutants Test Method Test Interval Justification 16 VOC 25A Annually 10, 11, 12, 13, 19, 23, & 26 Verify proper continuing operation of RTOs Opacity 9 Annually To verify NSPS limits

6 Page 6 of 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.) Frequency Report (Y/N) N/A 15. RECORDKEEPING REQUIREMENTS: The following are items (such as throughput, fuel usage, VOC content, etc.) that must be tracked and recorded. SN Recorded Item Permit Limit Frequency Report (Y/N) Facility Production at 19,272 tons per consecutive Duratone 12-month period Monthly N Facility Production at 15,800 per consecutive 12- Extruder month period Monthly N Tanks Methyl chloride % Benzyl chloride % 17 Hours of operation 19 Clay receipts 16. OPACITY: 0.03% by wt 0.08% by wt 500 hours per 12-month period If more than 100 hours during any calendar year, the permittee must verify that the engine still qualifies as an emergency engine 5,250,000 pounds per 12- month period Per inspection of MSDS kept onsite Monthly As needed Monthly N N N N SN Opacity Justification for limit 10, 11, 12, 13, 19, 23, & 26 10% NSPS Subpart OOO 16 7% NSPS Subpart OOO 17 20% Department guidance Compliance Mechanism Design limits & Annual Method 9 Proper control operation & Annual Method 9 Upon inspection if operating

7 Page 7 of DELETED CONDITIONS: Former SC 16 & 19 Justification for removal Opacity compliance mechanisms for emergency generators at minor sources facilities are not required per Department guidance. 18. GROUP A INSIGNIFICANT ACTIVITIES: Source Name Group A Category Emissions (tpy) PM/PM 10 SO 2 VOC CO NO x HAPs Single Natural gas boiler (4.2 MMBtu/hr) Natural gas water heater (2.4 MMBtu/hr) Scott Dryer (3.0 MMBtu/hr) Hammermill Heater (1.0 MMBtu/hr) A-1 s ,000 gallon Nonylphenol storage tank gallon Diesel storage tank A-3 s ,000 gallon Caustic soda storage tank Lab Hoods gallon Specialty chemical storage tank Unpaved roads 13 Wastewater Tanks (3 tanks with 17,000 gallon capacity, each) Primary Wastewater Tanks (2 tanks with 42,000 gallon capacity, each) PM 0.47 PM

8 Page 8 of 8 Source Name Secondary Wastewater Tanks (2 tanks with 7,000 gallon capacity, each) Lignite Bulk Storage Silo (SN-18) A-13 s Group A Category Emissions (tpy) PM/PM 10 SO 2 VOC CO NO x 1.92 PM 0.52 PM HAPs Single VOIDED, SUPERSEDED, OR SUBSUMED PERMITS: List all active permits voided/superseded/subsumed by the issuance of this permit. Permit # 0196-AR-8

9 APPENDIX A EMISSION CHANGES AND FEE CALCULATION

10 Fee Calculation for Minor Source Facility Name: Halliburton Energy Services, Inc. Permit Number: 0196-AR-9 Revised Old Permit New Permit $/ton factor Permit Predominant Air Contaminant Minimum Fee $ 400 Net Predominant Air Contaminant Increase 7.2 Minimum Initial Fee $ 500 Permit Fee $ 400 Check if Administrative Amendment Annual Chargeable Emissions (tpy) 80.2 Pollutant (tpy) Old Permit New Permit Change PM PM SO VOC CO NO X HAP Methyl Chloride Benzyl Chloride

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

STATEMENT OF BASIS. NAICS Description: Soybean and Other Oilseed Processing NAICS Code: 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 72118-5317