ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

Transcription

1 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 Dear Mr. Wagner: The enclosed Permit No 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 et seq., and implementing regulations, I have determined that Permit No AR-1 for the construction, operation and maintenance ofan 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 ofpollution 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 ofthe final permitting decisions as provided under Chapter Six ofregulation 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 Ifyou have any questions about filing the request, please call the Commission at Sincerely, ~ Mike Bates Chief, Air Division Enclosure ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE / NORTH UTILE ROCK / ARKANSAS / TELEPHONE / FAX

2 ADEQ MINOR SOURCE AIR PERMIT Permit No. : 2053-AR-1 IS ISSUED TO: EAKAS Arkansas Corporation 2000 South Falls Blvd Wynne, AR Cross 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 ETSEQ.) AND THE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Mike Bates Chief, Air Division August 5, 2013 Date

3 Permit #: 2053-AR-1 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 7 Section IV: EMISSION UNIT INFORMATION 8 Section V: INSIGNIFICANT ACTIVITIES 13 Section VI: GENERAL CONDITIONS 14 2

4 List ofacronyms 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 offederal 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

5 Section I: FACILITY INFORMATION PERMITTEE: EAKAS Arkansas Corporation PERMIT NUMBER: 2053-AR-l FACILITY ADDRESS: 2000 South Falls Blvd Wynne, AR MAILING ADDRESS: P.O. Box 8 Wynne, AR COUNTY: CONTACT NAME: CONTACT POSITION: Cross County Joe Harrald Plant Manager TELEPHONE NUMBER: REVIEWING ENGINEER: Patty Campbell, PE UTM North South (Y): Zone 15: m UTM East West (X): Zone 15: m 4

6 Permit #: 2053-AR-1 Section II: INTRODUCTION Summary ofpennit Activity Eakas Arkansas Corporation (Eakas) owns and operates an automotive interior and exterior trim manufacturing facility. It is located at 2000 South Falls Boulevard, Wynne, Cross County, Arkansas This permitting action is necessary to increase Acetone usage (SN-13) from 7,230 to 10,000 gallons maximum per rolling 12 months and increase Acetone emissions from 20.0 to 33.2 tpy. The total permitted annual emission changes associated with this modification are: 13.2 tpy (tons per year) Acetone. Process Description Eakas Arkansas Corporation owns and operates an automotive interior / exterior trim manufacturing facility. Eakas Arkansas manufactures painted decorative, interior / exterior trim and other complex modular assemblies for the automotive industry. The process starts with the various types ofthennoplastic pellets, which are injection molded into various shapes, inspected and placed onto paint fixtures or shipped without paint to the customer. Approximately one percent ofthe product may need to be primed prior to being coated with a two-component polyurethane basecoat and clearcoat coating. Ninety-nine percent ofall 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). The paint utilized in the operation will be mixed in an attached Paint Mix Room (SN-06). Once the parts are coated they will enter an Electric Curing Oven (SN-03) and then they are unloaded from the system. SN-06 and SN-07 vent through SN-01. This paint booth equipment is cleaned and 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 are painted and then put into a natural gas Curing Oven (SN-04). SN-10 vents through SN-05. This paint 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 the steel structure. The fixtures are placed in a Controlled Pyrolysis Cleaning Furnace (SN-11) that is natural gas-fired. Child parts are added, which are either molded in-house or are purchased from an outside supplier to make simple to complex modular assemblies that are packaged for pick-up by our customers. Ajust-in-time philosophy is utilized throughout the facility. 5

7 Permit #: 2053-AR-1 Eakas Arkansas also performs the following insignificant activities on site: Injection Molding of parts, 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 ofthe Arkansas Plan ofimplementation for Air Pollution Control, Regulation 19, effective November 18,2012 Total Allowable Emissions The following table is a summary ofemissions 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 SOz VOC CO NOx Single HAP Combined HAPs Acetone

8 Section III: PERMIT HISTORY Permit 2053-AOP-RO was originally issued on February 9, 2004 to Eakas Arkansas. Total allowable emissions were: 0.3 tpy PM/PMIO, 0.3 tpy S02, tpy YOC, 1.3 tpy CO, 1.4 tpy NOx, 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 ofa 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 to allow multiple emission points (vents/stacks) for already permitted equipment. Permitted emission increases were: 0.2 tpy PM, 0.2 tpy PM IO, 0.2 tpy S02, 0.2 tpy YOC, 1.0 tpy CO, 1.1 tpy NOx and 8.00 tpy acetone. Permit 2053-AOP-Rl was amended on January 18, 2007 to revise Specific Condition #1 to 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-A was issued to Eakas Arkansas Corporation on February 12, This permitting action is necessary to change from a Title Y to a minor source air permit, Annual paints and coatings usage have been reduced from 10,000 to 7,800 gallons. SN-02 and SN-09 were never installed and are being removed from the permit. Annual emission changes are: -0.2 tpy PMIPMIO, -0.4 tpy S02, tpy YOC, 0.4 tpy CO, 0.7 tpy NOx, -8.5 tpy Single HAP, and tpy Combined HAPs. 7

9 Permit #: 2053-AR-1 Section IV: EMISSION UNIT INFORMATION Specific Conditions 1. The permittee shall not exceed the emission rates set forth in the following table. [Regulation et seq. and AC.A as referenced by and ] SN Description Pollutant lb/hr tpy 01 Automatic Paint Booth (2005) 05 Manual Paint Booth (2007) VOC Paint Mixing Room (2005) PM IO S Three Curing Ovens 03,04&12 VOC (0.2 MMBTU/hr each) CO NO x PM IO Three Make Up Air Heaters S ,08 & 10 (Natural gas, 2.8 MMBtu/hr VOC each) CO NOx PM Pyrolysis Furnace 0.1 S (Natural gas, VOC 0.1 MMBtu/hr) 0.1 CO 0.1 (2005) 0.2 NO x &09 Removed from permit. 2. The permittee shall not exceed the emission rates set forth in the following table. [Regulation and AC.A as referenced by and ] 8

10 SN Description Pollutant lb/hr tpy 01 Automatic Paint Booth (2005) 05 Manual Paint Booth (2007) 06 Paint Mixing Room (2005) Single HAP Combined HAPs Annual Emissions Flushing Solvents Facility-wide Acetone ,04 & Three Curing Ovens 12 (0.2 MMBTU/hr each) PM ,08 & 10 Three Make Up Air Heaters (Natural gas, 2.8 MMBtu/hr PM ea) Pyrolysis Furnace 11 (Natural gas, PM MMBtu/hr) (2005) 3. Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. [A.c.A as referenced by and ] SN Limit Regulatory Citation 03,04,07,08, 10, 11, & 12 5% and A.C.A. 4. The permittee shall not cause or permit the emission ofair contaminants, including odors or water vapor and including an air contaminant whose emission is not otherwise prohibited by Regulation #18, if the emission of the air contaminant constitutes air pollution within the meaning of A.C.A [Regulation and A.C.A as referenced by and ] 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 8-4-3l1] 6. The permittee shall not use any paint or coating that contains VOCs in excess of2.22 pounds per gallon. The permittee shall not use more than 5.0 gallons per hour ofpaints 9

11 Permit #: 2053-AR-1 and/or coatings facility-wide. [Regulation and A.C.A as referenced by A.C.A and ] 7. The permittee shall not use any paint or coating that contains Single HAP and Combined HAPs in excess of 0.2 and 0.6 pounds per gallon, respectively. The permittee shall not use more than 5.0 gallons per hour ofpaint and/or coatings facility-wide (as a monthly average). [Regulation 18, and A.C.A as referenced by A.C.A and l] 8. The permittee shall not exceed a throughput of10,000 gallons ofacetone at the facility per rolling 12 month period. All equipment cleaning operations and thinner usage in the facility are covered under a facility-wide "emissions bubble" (SN-13). [Regulation , Regulation , and A.c.A as referenced by A.C.A and ] 9. The permittee shall not exceed 7,800 gallons ofpaints and coatings for the painting operations (SN-01, 05 & 06) per rolling 12 month period. [Regulation and A.c.A as referenced by A.C.A and ] 10. The permittee shall maintain monthly records and calculations ofvoc emissions from all paints and coatings, which demonstrate compliance with Specific Conditions #1 and #6. These records shall list chemicals by name and product number. These records shall indicate the amount of each VOC-containing material used in gallons, the respective VOC content of each gallon of material (pounds/gallon), and the resulting emissions from the usage of each material (pounds per month). A rolling twelve-month total and each individual month's data shall be maintained in a spreadsheet, database, or other wellorganized format. The records and the MSDS records or other equivalent documentation shall 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 the month to which the records pertain. [Regulation and A.C.A as referenced by A.C.A and ] 11. The permittee may use only the HAPs listed in the following table or any HAP that has a TLV greater than mg/nr' as published by the American Conference of Governmental Industrial Hygienists (ACGIH) in the most current ACGIH handbook of Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs). Compliance with this limit is demonstrated by Specific Condition #9. [Regulation and A.c.A as referenced by A.c.A and ] HAP Pollutant CAS Number Xylene Toluene

12 HAP Pollutant CAS Number Ethyl Benzene Cumene Methyl Isobutyl Ketone Any HAP with TLV 2: rng/rrr' N/A 12. The permittee shall maintain monthly records and calculations ofhap and/or acetone emissions from all paints, coatings, and solvents, which demonstrate compliance with Specific Conditions #1, #2, #6 and #8. These records shall list HAPs by name and product number. These records shall be calculated as follows: [Regulation and AC.A as referenced by AC.A and ] 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 and 11. Actual VOC, HAP and/or acetone content ofmaterial (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/or acetone 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 by Weight spent flushing solvents shipped off site x 0.85 (non-solids) x weight fraction VQC, HAP and/or acetone. 13. Spent flushing solvents, acetone, shall not exceed 15% solids by weight. Compliance with this limit is demonstrated by Specific Condition #llb. [Regulation and AC.A as referenced by AC.A and ] 14. The permittee shall maintain monthly records and calculations to demonstrate that spent flushing solvents, acetone, contain less than 15% solids by weight. The permittee shall maintain a twelve month rolling total and each individual month's data on-site and made available to Department personnel upon request. The permittee shall update the records by the fifteenth day ofthe month following the month to which the records pertain. [Regulation and AC.A as referenced by AC.A and ] 11

13 15. The permittee shall use only pipeline quality gas as fuel for curing ovens SN-03, 04 and 12; make-up air heaters SN-07, 08, and 10; and pyrolysis furnace SN-l1. The emissions have been calculated at full load for continuous operation and no recordkeeping of natural gas is required. [Regulation and AC.A as referenced by AC.A and ] 16. The permittee shall operate the afterburner chamber ofsn-ll between F with 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 to Department personnel upon request. [Regulation and 40 CFR Part 52 Subpart E] 12

14 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 August 4, Description Category Injection Molding ofparts (and mold release agents/cleaner) A-13 Hand Polishing/Sanding ofparts as necessary A-13 Parts Water Wash Machine (with detergent) A-13 Inspect / Destat (pre-moistened IPA wipes) A-13 13

15 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 (AC.A et seq.) as the sole origin of and authority for the terms or conditions are not required under the Clean Air Act or any ofits 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 (AC.A et seq.) as the origin of and authority for the terms or conditions are enforceable under this Arkansas statute. 2. This permit does not relieve the owner or operator ofthe 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. [AC.A as referenced by and ] 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/orac.a as referenced by and ] 4. Construction or modification must commence within eighteen (18) months from the date ofpermit issuance. [Regulation O(B) and/or Regulation (B) and AC.A as referenced by and ] 5. The permittee must keep records for five years to enable the Department to determine compliance with the terms ofthis permit such as hours ofoperation, throughput, upset conditions, and continuous monitoring data. The Department may use the records, at the discretion ofthe Department, to determine compliance with the conditions ofthe permit. [Regulation and/or Regulation and AC.A as referenced by and ] 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 AC.A as referenced by and l] Arkansas Department ofenvironmental Quality Air Division ATTN: Compliance Inspector Supervisor 14

16 Permit #: 2053-AR Northshore Drive North Little Rock, AR The permittee shall test any equipment scheduled for testing, unless stated in the Specific Conditions of this 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 anda.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 and A.C.A as referenced by and ] 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 of the 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 15

17 nature ofthe actions to be taken to minimize or eliminate future occurrences, including, but not limited to, action to reduce the frequency ofoccurrence 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. 11. The permittee shall allow representatives ofthe Department upon the presentation of credentials: [AC.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 ofthe equipment or control apparatus. [AC.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 (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 AC.A as referenced by and ] 15. This permit shall be available for inspection on the premises where the control apparatus is located. [A.C.A as referenced by and 8-4-3l1] 16

18 16. This permit authorizes only those pollutant emitting activities addressed herein. [AC.A as referenced by and ] 17. This permit supersedes and voids all previously issued air permits for this facility. [Regulation 18 and 19 and AC.A as referenced by and ] 18. The permittee must pay all permit fees in accordance with the procedures established in Regulation No.9. [AC.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 pennittee 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), AC.A as referenced by and , and 40 CFR Part 52, Subpart E] 20. The pennittee 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 of such 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), AC.A as referenced by and , and 40 CFR Part 52, Subpart E] 17

19 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] 18

20 CERTIFICATE OF SERVICE I, Pam Owen, hereby certify that a copy ofthis permit has been mailed by first class mail to EY:YJ of_-----:...a--:...=.:l) I!S ± ~~ QuJen_-- Pam Owen, AAII, Air Division