ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

Transcription

1 ADEQ ARK A N S A S Department of Environmental Quality Jerry Gamer, Plant Manager 829 Highway 35 South Monticello, AR 7655 Dear Mr. Gamer: The enclosed Permit No AR-9 is your authority to construct, operate, and maintain the equipment and/or control apparatus as set forth in your application initially received on 7/20/2007. After considering the facts and requirements of A.C.A et seq., and implementing regulations, I have determined that Permit No AR-9 for the construction, operation and maintenance ofan air pollution control system for be issued and effective on the date specified in the permit, unless a Commission review has been properly requested under 2..4 ofregulation No.8, Arkansas Department ofpollution Control & Ecology Commission's Administrative Procedures, within thirty (30) days after service ofthis decision. All persons submitting written comments during this thirty (30) day period, and all other persons entitled to do so, may request an adjudicatory hearing and Commission review on whether the decision of the Director should be reversed or modified. Such a request shall be in the form and manner required by 2..4 ofregulation No.8. Sincerely, Mike Bates Chief, Air Division Enclosure ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 530 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS / TELEPHONE / FAX

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3 ADEQ MINOR SOURCE AIR PERMIT Permit No.: 742-AR-9 IS ISSUED TO: 829 Highway 35 South Monticello, AR 7655 Drew 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: --U~ Mike Bates Chief, Air Division Date

4 Permit #: 742-AR-9 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 9 Section V: INSIGNIFICANT ACTIVITIES 3 Section VI: GENERAL CONDITIONS 4 2

5 Permit #: 742-AR-9 List ofacronyms and Abbreviations A.C.A. AFIN CFR CO HAP lb/hr No. NO x PM PMIO 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

6 Pennit #: 742-AR-9 Section I: FACILITY INFORMATION PERMITTEE: PERMIT NUMBER: 742-AR-9 FACILITY ADDRESS: MAILING ADDRESS: 829 Highway 35 South Monticello, AR Highway 35 South Monticello, AR 7655 COUNTY: CONTACT POSITION: Drew Brad Gridley, General Manager TELEPHONE NUMBER: REVIEWING ENGINEER: Amanda Leamons UTM North UTM East South (Y): West (X): Zone 5: Zone 5:

7 Permit #: 742-AR-9 Section II: INTRODUCTION Summary ofpermit Activity (Hood) owns and operates a flexible packaging plant located at 829 Highway 35 South in Monticello, Drew County, Arkansas. With this de minimis modification, SN-47, Flexoline Press #5 will be removed from the permit since it is no longer in operation at the facility. In addition, Hood will be permitted for the installation ofa new tail end printing press, SN-50, Robinette I-color Press #8. Press #8 does not use varnish and does not have dryers and it will use the same water based inks as the other presses. The maximum potential emissions from the press are 9.2 tpy ofvoc and 0.95 tpy ofcombined HAPs. However, no permitted emissions will increase with this modification because Hood will continue to comply with the existing facility wide emissions limit for VOC and HAPs. Process Description The processes at this plant are the manufacture ofmulti-wall paper bags. The bags are formed and glued using printed or plain roll paper stock. The plant uses flexographic printing presses which apply water based inks and varnishes to print roll paper stock prior to converting the stock into multi-wall bags. The facility's converting operations use paper and plastic as the primary raw materials for the production ofits packaging products. Plastic film may be used as part ofpaper packaging construction when the bag requires additional barrier and/or strength properties. Graphics are applied to paper and plastic substrates by flexographic printing presses. A variety ofpaper multiwall bags are produced at the facility. The paper multiwall operation begins with large rolls ofbleached or natural Kraft paper. These rolls are mounted on flexographic printing presses (SN-33, SN-44 through SN-46, SN-48 through SN-50), printed with appropriate graphics, and may be coated with lacquer to improve the appearance. The printed paper (which is the outermost ply ofthe packaging) is rewound onto another roll and is moved to a "bag machine" (tuber or bottomer). The bag machine unrolls the printed stock and may combine it with other rolls ofpaper or plastic to form finished bags. The tail-end presses are attached to one end ofa tuber, and the printing and converting steps are done in one operation. Closures are sealed to the bag with starch based or hot melt adhesives. A small boiler (.0 MM Btu/hr) (insignificant activity) is used at the facility to supply heat to the starch based adhesive cookers and a number ofsmall radiant space heaters are used to heat the warehouse and production areas. The facility has based emissions ofnatural gas combustion at the rated capacity ofall gas fired sources. All natural gas combustion sources are considered insignificant activities. Therefore, natural gas usage records are not required. 5

8 Pennit #: 742-AR-9 Regulations The following table contains the regulations applicable to this pennit. Regulations Arkansas Air Pollution Control Code, Regulation 8, effective February 5, 999 Regulations ofthe Arkansas Plan of Implementation for Air Pollution Control, Regulation 9, effective October 5, 2007 This facility will not be subject to the requirements of40 CFR Part 63 Subpart KK - National Emission Standards for the Printing and Publishing Industry provided that the facility maintains its status as an area source ofhaps. Record keeping will be necessary in order to demonstrate that this facility remains below the major source thresholds for HAP emissions. The following table is a summary of emissions from the facility. This table, in itself, is not an enforceable condition ofthe pennit. Total Allowable Emissions TOTAL ALLOWABLE EMISSIONS Pollutant lb/hr Emission Rates tpy VOC Total HAP Single HAP

9 Permit #: 742-AR-9 Section III: PERMIT HISTORY Air Permit # 742-A was issued to Chase Bag Company on 2/29/84. Union Camp Corporation acquired Chase Bag Company and Air Permit #742-AR-l was issued on /27/94. Air Permit #742-AR-2 permitted the installation ofa Wolverine poly printing press and was issued on 5/7/94. Air Permit #742-AR-3, issued 7/25/95, permitted the installation ofa 4-color Lemo Printing Press (SN-29) and the elimination of a Wolverine Flexographic printing presses (SN-) and its associated dryer (SN-2). Air Permit #742-AR-4 was issued to the facility on March 2, 998. This permit modification was issued in response to the relocation of flexographic printing presses from an out-of-state facility. Four sources were removed from the plant to facilitate this relocation. They are the Kidder Flexographic Printing Press and its dryer (SN-3 and SN-4), the ADSP Block Bottom Polyethylene Bag Machine (SN-7), and a Corona Electrostatic Polyethylene Film Treater (SN 8). Five new sources were also added (SN-30 through SN-34). In the past, permit applications from Union Camp had overstated the emissions from the printing presses for paper. In this permit the emissions for these presses were more realistic. Ownership ofthe facility was transferred to the Monticello Flexible Packaging Plant on July 8, 999. Air Permit #724-AR-5 was issued to the facility on April 7, This modification was issued in order to allow for a plantwide VOC usage limit rather than individual limits on each individual source. A VHAP table was generated to limit hourly VHAP emissions from the facility. Several new presses were to be added (SN-35, 36, 37), and one press was removed (SN-5). Due to a change in plans for the facility, SN-36 and SN-37 were never actually installed at the facility. Air Permit #724-AR-6 was issued to the facility on October 27,2000. This modification was issued in order to allow for the addition ofseveral new lines to the facility as well as the removal ofseveral ofthe currently permitted lines. All ofthe plastic bag manufacturing processes were removed from the facility for relocation to other International Paper facilities. Seven presses were removed from the facility as a result ofthis change. Five ofthe presses were relocated to other J.P. facilities (SN-04/05, SN-27, SN-28, SN-29, and SN-37), and two presses and their associated dryers (SN-0/02 and SN-07/08) were retired from service. The paper bag manufacturing capabilities ofthe facility increased; however, due to the addition of3 new presses (SN-38, SN-39, and SN-40/4). Air Permit #724-AR-7 was issued to the facility on October 2,2003. The name ofthe facility was changed from FPD Acquisition, Inc. to Exopack on September 6, 200. This permit was the first bearing the new facility name. This modification was issued in order to allow for the 7

10 Pennit #: 742-AR-9 following changes at the facility. One existing printing press and associated dryer was removed from service at the facility (SN-3 and SN-32). Additionally, one new Flexoline four-color offline flexographic printing press and associated dryer was installed at the facility (SN-42 and SN 43). These changes allowed for more reliable printing potential at the facility. Pennitted VOC emissions from the facility remained unchanged. The new dryer had a slightly different emissions profile than the unit it replaced, which resulted in increases in CO and PM IO emissions of0. tpyeach, and a decrease in NO x emissions of0.3 tpy. Ownership ofthe facility was transferred to the on February 2, Air Pennit #724-AR-8 was issued to the facility on October 26, This permit was the first bearing the new facility name. This modification allowed the removal ofseven (SNs-09, 0, 30, 35, and 38-43) ofthe existing eight printing presses and the installation ofsix new printing presses (SNs-44 through 49) bringing the total ofpermitted printing presses to seven presses. Additionally, the natural gas dryer (.5 MMBTU/hr) for SN-33 (previously permitted as SN-34) and a new natural gas dryer for SN-44 will be added to the insignificant activities list. The modifications removed permitted annual emissions ofpmlpm IO, CO, S02, and NOx as well as reduced permitted emissions ofvoc by 0.7 tons. No permitted emission increases occured with this pennit modification. 8

11 Permit #: 742-AR-9 Section IV: EMISSION UNIT INFORMATION Specific Conditions. The permittee shall not exceed the emission rates set forth in the following table. [Regulation 9, 9.50 et seq., effective October 5, 2007 and A.C.A as referenced by A.C.A and 8-4-3] SN Description Pollutant Ib/hr tpy 33 Kidder Flexographic Printing Press #4 for Paper 44 Robinette 6-color Press # 45 Robinette 4-color Press # Converter Graphics 4-color Press #3 830 # W&H Bottomer 2- color Press #6 830 #2 W&H Bottomer 2- color Press #7 VOC* Robinette I-color Press #8 * Plantwlde annual limit for emissions from non-combustion sources. 2. The permittee shall not exceed the emission rates set forth in the following table. [Regulation 8, 8.80, effective February 5, 999, and A.C.A as referenced by A.C.A and 8-4-3] SN Description Pollutant Ib/hr tpy 33 Kidder Flexographic Printing Press #4 for Paper 44 Robinette 6-color Press # 45 Robinette 4-color Press # Converter Graphics 4-color Single HAP ** 9.5 Press #3 Total HAP ** # W&H Bottomer 2-color Press #6 830 #2 W&H Bottomer 2-color Press #7 50 Robinette I-color Press #8.. ** Based on TLV Table, the hourly emission rates must comply with SpecIfic CondItIOn 9. 9

12 Pennit #: 742-AR-9 3. Visible emissions may not exceed the limits specified in the following table ofthis pennit as measured by EPA Reference Method 9. [AC.A as referenced by AC.A and 8-4-3] SN Limit Regulatory Citation All sources 20% The pennittee shall not cause or pennit the emission ofair contaminants, including odors or water vapor and including an air contaminant whose emission is not otherwise prohibited by Regulation 8, ifthe emission ofthe air contaminant constitutes air pollution within the meaning ofac.a [Regulation 8, 8.80 and AC.A as referenced by A.C.A and 8-4-3] 5. The pennittee shall not conduct operations in such a manner as to unnecessarily cause air contaminants and other pollutants to become airborne. [Regulation 8, 8.90 and AC.A as referenced by AC.A and 8-4-3] 6. The pennittee shall not emit more than 9.5 tpy ofany single HAP or more than tpy ofany combination ofhaps from the facility during any consecutive 2-month period. Compliance with this condition will be demonstrated by compliance with Specific Condition. [Regulation 9, and 40 CFR ] 7. The pennittee shall not emit more than 96.6 tpy of VOC from non-combustion sources at the facility during any consecutive 2 month period. [Regulation 9, and A.C.A as referenced by A.C.A and 8-4-3] 8. The pennittee shall maintain monthly records which demonstrate compliance with Specific Condition 7. These records should track the monthly usage ofall inks, varnishes, solvents, and additives used at the facility, and include records that indicate the quantity and VOC content ofeach VOC containing material used at the facility during the previous month. These records shall be maintained in a spreadsheet, database, or other well organized fonnat. A twelve month rolling total and each individual month's data shall be kept on-site and be made available to Department personnel upon request. [Regulation 9, and AC.A as referenced by and 8-4-3] 9. The pennittee shall not exceed the Hazardous Air Pollutant (HAP) content limits set forth in the following table. Compliance with this condition will be demonstrated by compliance with Specific Conditions 0 and. The maximum emission rate pennitted 0

13 Permit #: 742-AR-9 in the table for each corresponding TLV is based on a factor of0. multiplied by the TLV to yield the Presumably Acceptable Emission Rate (PAER). [Regulation,8 8.80l and AC.A as referenced by and 8-4-3] MinimumTLV (mg/m 3 ) Maximum Rate (lblhr) MinimumTLV (mg/m 3 ) Maximum Rate (lblhr) The permittee shall maintain records ofthe ACGIH TLV values as listed on current MSDS forms, or in the most recently published ACGIH handbook ofthreshold Limit Values (TLVs) and Biological Exposure Indices (BEIs) for all inks and solvents used at the facility. The concentration ofeach HAP in weight percent and the TLV should be noted on these records. These records shall be maintained in a spreadsheet, database, or other well organized format. These records shall be kept on-site and made available to Department personnel upon request. [Regulation 8, and AC.A as referenced by and 8-4-3]. The permittee shah maintain records that demonstrate compliance with the limits set in Specific Condition 9 [i.e., the TLV Table], and that may be used by the Department for enforcement purposes. Compliance shah be determined by inspecting the ACGIH Threshold Limit Values (TLVs) as listed on current MSDS, or in the most recently published ACGIH handbook oftlvs and Biological Exposure Indices (BEIs) and properly noting on the monthly HAP records whether the material in question is compliant with the table contained in Specific Condition 9. The hourly maximum usage rate shall be demonstrated by keeping mass balances on record on a monthly basis of ah HAP containing materials in use that qualify under Specific Condition 9. Monthly HAP emissions shall be calculated by multiplying the individual HAP content for each HAP contained in each ink or solvent in weight percent by the usage ofthe HAP containing material during that month. The hourly emissions will be calculated by dividing the monthly material usage by the actual hours ofoperation for that month. These records shall be maintained in a spreadsheet, database, or other well organized format. A 2 month rohing total and each individual month's data shall be kept on site and made available to Department personnel upon request. [Regulation 8, and AC.A as referenced by and 8-4-3]

14 Pennit #: 742-AR-9 2. The pennittee may use all scrap VOCs and VHAPs that are drummed and shipped offsite to a proper disposal site as a credit towards the facility's VOC emissions. Only the VOC and VHAP portion ofthe shipment may be taken as a credit. Before a credit can be given the following conditions must be met. [Regulation 9, and AC.A as referenced by and 8-4-3] a. Representative samples shall be taken from 0% ofthe drums containing VOCs and VHAPs. The samples shall be tested for percentage ofvoc and VHAP content by weight and reported as such. The average ofthe samples shall be applied to all the VOC and VHAP containing drums in that shipment. Sampling data taken by the offsite disposal facility shall be accepted provided it meets the requirements ofthis condition. b. The sampling reports shall be maintained on site with the VOC and VHAP emissions records required by this pennit. These records shall be made available to Department personnel upon request. 3. If actual emissions ofvoc exceed 95.0 tpy during any consecutive 2-month period, then the pennittee shall demonstrate that the degree ofaccuracy ofthe calculations used to detennine emissions is sufficient to prove that the major source thresholds have not been exceeded. [Regulation 9, 9.405(B) and AC.A as referenced by and 8-4-3] 2

15 Pennit #: 742-AR-9 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 8 and 9 Appendix A. Insignificant activity emission detenninations rely upon the infonnation submitted by the pennittee in an application dated March 0, Description Category Hurst Boiler ( MMBtu/hr) (Fonnerly SN-26) A-I 2 Natural Gas Dryers for SN-33 (.5 & 0.8 MMBtu!hr) (Fonnerly SN-34) A-I 2 Natural Gas Dryers for SN-44 (.2 MMBtu!hr each) A-I 3

16 Permit #: 742-AR-9 Section VI: GENERAL CONDITIONS. Any terms or conditions included in this permit that specify and reference Arkansas Pollution Control & Ecology Commission Regulation 8 or the Arkansas Water and Air Pollution Control Act (AC.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 8 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 8 or the Arkansas Water and Air Pollution Control Act (AC.A 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. [AC.A as referenced by AC.A and 8-4-3] 3. The permittee will notify the Department in writing within thirty (30) days after commencement ofconstruction, completion ofconstruction, first operation ofequipment and/or facility, and first attainment of the equipment and/or facility target production rate. [Regulation 9, and/or AC.A as referenced by AC.A and 8-4-3] 4. Construction or modification must commence within eighteen (8) months from the date ofpermit issuance. [Regulation 9, 9.4 0(8) and/or Regulation 8, 8.309(8) and AC.A as referenced by A.C.A and 8-4-3] S. The permittee must keep records for five years to enable the Department to determine compliance with the terms of this 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 9, and/or Regulation 8, and AC.A as referenced by AC.A and 8-4-3] 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 9, and/or Regulation 8, and AC.A as referenced by AC.A and 8-4-3] Arkansas Department ofenvironmental Quality Air Division ATTN: Compliance Inspector Supervisor 530 Northshore Drive North Little Rock, AR 728 4

17 Permit #: 742-AR-9 7. The permittee will 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: () newly constructed or modified equipment within sixty (60) days of achieving the maximum production rate, but no later than 80 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 Departmentofthe scheduled date of compliance testing at least fifteen (5) days in advance of such test. The permittee must submit compliance test results to the Department within thirty (30) days after the completion oftesting. [Regulation 9, and/or Regulation 8, and AC.A as referenced by AC.A and 8-4-3] 8. The permittee will provide: [Regulation 9, and/or Regulation 8, and AC.A as referenced by AC.A and 8-4-3] a. Sampling ports adequate for applicable test methods b. Safe sampling platforms c. Safe access to sampling platforms d. Utilities for sampling and testing equipment 9. The permittee will operate equipment, control apparatus and emission monitoring equipment within their design limitations. The permittee will maintain in good condition at all times equipment, control apparatus and emission monitoring equipment. [Regulation 9, and/or Regulation 8, 8.04 and A.C.A as referenced by AC.A and 8-4-3l] 0. If the 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 9, 9.60 and/or Regulation 8, 8.0 and A.C.A as referenced by AC.A and 8-4-3l] 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 ofsuch occurrence, including a statement ofall known causes and ofthe scheduling and nature ofthe actions to be taken to minimize or eliminate future occurrences, including, but not limited to, action to reduce the frequency ofoccurrence ofsuch 5

18 Permit #: 742-AR-9 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.. The permittee shall allow representatives ofthe Department upon the presentation of credentials: [AC.A as referenced by AC.A 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 of this 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. 2. 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 AC.A and 8-4-3] 3. 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 of the Arkansas Water and Air Pollution Control Act and the regulations promulgated the Arkansas Water and Air Pollution Control Act. [Regulation 9, 9.4O(A) and/or Regulation 8, 8.309(A) and A.C.A as referenced by A.C.A and 8-4-3] 4. 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 '8 06 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 9, 9.407(B) and/or Regulation 8, 8.307(B) and AC.A as referenced by A.C.A and 8-4-3] 5. This permit shall be available for inspection on the premises where the control apparatus is located. [AC.A as referenced byac.a and 8-4-3ll] 6. This permit authorizes only those pollutant emitting activities addressed herein. [AC.A as referenced by A.C.A and 8-4-3ll] 6

19 Permit #: 742-AR-9 7. This permit supersedes and voids all previously issued air permits for this facility. [Regulation 8 and 9 and AC.A as referenced by A.C.A and 8-4 3] 8. The permittee must pay all permit fees in accordance with the procedures established in Regulation No.9. [AC.A 8--05(c)] 7

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21 CERTIFICATE OF SERVICE I, Cynthia Hook, hereby certify that a copy ofthis pennit has been mailed by first class mail to, 829 Highway 35 South, Monticello, AR, 7655, on _ Cynthia Hook, AAII, Air Division

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