ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

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1 ADEQ ARK A N S A S Department of Environmental Quality August 3, 2009 Ted Smith President Acrilla Mining & Land Company - SEMCOA 9474 Highway 57 McIntyre, GA RE: Application for Registration AFIN: Registration No.: 2210-A-REG315 Dear Mr. Smith: The Department has reviewed your facility's application for registration for the facility located at 1 mile S. on Mt Olive Rd from intersection ofmt. Olive/W. Sardis, Bauxite in Saline County, Arkansas. The Department has detennined that the infonnation certified in the application fulfills the required criteria for registration as specified in Arkansas Air Pollution Control Code (Regulation 18), Section and other applicable regulations. Your registration number has been assigned as 2210-A-REG315. This registration is your authority to construct, operate, and maintain the equipment and/or control apparatus as set forth in your registration request received on July 7,2009. Acrilla Mining & Land Company - SEMCOA is required to update this registration should the facility operations or emissions change so that the current registration no longer reflects actual operations. Please maintain a copy ofthis letter and the application at the facility. Sincerely, #2~ Thomas Rheaume Pennit Branch Manager, Air Division c: Compliance Monitoring ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE / NORTH UTILE ROCK / ARKANSAS / TELEPHONE / FAX

2 ATOKA.. INC. Professional Engineering and Environmental Consulting Services June 25, 2009 Arkansas Department ofenvironmental Quality Air Permitting Section 5301 Northshore Drive North Little Rock, AR Subject: Request for Registration for AFIN# Dear Air Permitting Section: A mining operation in Saline County outside ofbauxite is presently open pit mining for bauxite, and is interested in operating a portable rock crusher in order to process the mined bauxite into a finer consistency. ATOKA has been hired to obtain an air permit or to register this portable rock crusher. This Registration submittal follows a letter sent to Phillip Murphy dated requesting a determination as to whether an air permit is required. A response was received dated requiring the facility to register. You will find the Registration application along with supporting documentation on the following pages. This mine is operated by the Southeast Minerals Corporation ofamerica (SEMCOA) with the land being leased from Alcoa. SEMCOA presently has two mining permits 0676-MN and 0677 MN and a General Stormwater Permit #ARR Interestingly, SEMCOA has two AFIN numbers and The rock crusher will be located at the large Alcoa ore shed where the bauxite will be stored after excavation. Alcoa's ore shed can be accessed offofeither S. Reynolds Road or W. Sardis Road, and is approximately 2.2 miles from SEMCOA's "Section 13 Mine" (0676-MN) and approximately 3.5 miles from SEMCOA's "Bertha Mine" (0677-MN). Since the rock crusher is portable, SEMCOA would like to be able to move the crusher from the ore shed to the mines as necessary. Bauxite ore is mined from SEMCOA's surrounding open pit mines and brought to Alcoa's ore shed for storage. Crushing will take place on a temporary basis in a cyclic process. Bauxite will be stock piled until there is enough ore to be crushed. For example, ore may be stock piled for 3 months, the crusher operated for 3 weeks, and the cycle repeats. The ore is sold after crushing. There is no other processing of the ore at this facility. This facility is not subject to 40 CFR 60 Subpart LL, "Standards ofperformance for Metallic Mineral Processing Plants" because the facility does not meet Subpart LL's definition ofa "Metallic Mineral Processing Plant." This facility does not produce metallic mineral concentrates from ore, as per the definition in Subpart LL. Furthermore, as per Subpart LL the definition of "metallic mineral concentrate" means, "a material containing metallic compounds in concentrations higher than naturally occurring ore..." This facility is mining and crushing raw "naturally occurring" bauxite ore into a finer consistency for sale to their customers. This facility is also not subject to 40 CFR 60 Subpart 000 "Standards ofperformance for Nonmetallic Mineral Processing Plants" because at its best the portable crusher at SEMCOA's facility has a maximum capacity of 100 tons/hr which is less than the minimum 150 tons/hr as Corporate Office: 2695 Airport Road, Hot Springs, AR Fax: kchitwood@atokainc.com

3 ATOKA, Inc. Page 2 per 40 CFR 60 Subpart 000, (c)(2). The emission calculations have been included in an Excel spreadsheet; however, the Excel file will be included on a CD so that the formulas can be seen in the spreadsheets digital format. There are two emission sources included in the calculations: the crushing process, and the 400HP diesel engine on the crusher. All values are below the requirements for a minor source permit, but a value of20 tons/yr for PM indicates the need to register. You will also notice that I used the high-moisture ore emission factors in the AP-42 Table since the bauxite is wet when it is mined as well as the use ofa water spray by the dust suppression system in the crusher. Thank you for your assistance, and ifyou have any questions, please give me a call at the number shown below. Thank you, ~ Kevin Chitwood Engineer Corporate Office: 2695 Airport Road, Hot Springs, AR Fax: kchitwood@atokainc.com

4 ADEQ Arkansas Department ofenvironmental Quality AIR DIVISION REGISTRATION FOR FACILITIES REGULATION March 2009

5 REGISTRATION FORM AFlN I DATE I FACILITYPIIYSICAL LOCATION Facility Name Arcilla Mining & Land Company I Physical Address or Location Physical City 1 mile south on Mt. Olive Rd. from intersection ofmt. Olive / W. Sardis Bauxite Physical Zip UTMZone 15 IUTM Easting UTM Northing (nearest meter) (nearest meter) NAICS Code NAICS Description Bauxite Mining and/or Beneficiating FACILITY AIR CONTACT Contact First Name Contact Last Name Contact Position Ted Smith President Contact Mailing Address 9474 Highway 57 Contact Mailing City McIntyre Contact Mailing State GA Contact Mailing Zip Contact Phone # Contact FAX Contact Address tsmith@arcillamining.com INVOICE MAILING ADDRESS Organization Name Invoice Contact First Name Invoice Contact Last Name Southeast Mineral Corporation ofamerica (SEMCOA) Ted Smith Mailing Address 9474 Highway 57 Invoice Mailing State GA Invoice Mailing Zip Invoice Contact Phone Invoice Contact FAX

6 1. Organization Status ofapplicant Please check the box which appropriately describes the legal organization ofthe applicant. Solely Owned Proprietorship 0 Corporation ~ Limited Partnership General Partnership 0 OTHER: 0 Please Specify: I 2. Ifthe applicant is a corporation, indicate ifit is a domestic (Arkansas) corporation or a foreign (chartered outside ofarkansas) corporation. Domestic D Foreign [8] 3. Ifthe applicant is a corporation, is it currently registered to do business with the Arkansas Secretary of State? Yes [8] NoD 4. Registration Information New Facility 0 IExisting Facility ~ Existing Facility with an Air Permit D List Current Permit No. The permit will be voided with this registration. Modification of Current Registration List Current Registration No. D 5. Attach a briefdescription ofthe facility, processes and sources ofair pollution emissions. 6. What are the estimated total actual emissions from this facility? 1 0 Pollutant Tons/year PM 20 PM IO 9.15 S VOC 0.17 CO 0.45 NOx 2.07 Single HAP* Combination HAP* HAP* - Hazardous AIr Pollutant 7. Attach an explanation ofhow the emissions estimate was determined e.g. AP-42, test information, etc. 8. Has a Disclosure Statement been submitted to the Department previously? Yes [8] No D (Ifno, please attach a disclosure statement) 9. Do you wish to be added the Air Permits Newsletter list? Yes D No [8] Ifyes, list the addressees) you wish to use: (or you can usatairpermits@adeq.state.ar.us with "subscribe" (no quotation marks) in the subject box. 10. The registration requires an annual fee of$200. The Department will send an invoice when the annual fee is due. Submit this Registration to: Arkansas Department ofenvironmental Quality Air Permitting Section 5301 Northshore Drive North Little Rock, AR 72118

7 CERTIFICATION OF APPLICATION "'Responsible Official" means one of the jcillowing: I ) For a corporation: a president. secretary, treasurer, or vice-president of the corporation in charge ofa principal busim:ss function. or any other person who perfonns similar policy or decision-making functions fell' the corporation. or a duly authorized representative of such person if the representative is responsible fllr the overall operation ofone or more manulacturing, production, or operating facilities applying for or subject to a permit and either: :\) the hteilities employ more than 250 persons or have gross annual sales or expenditures exceeding $25 million (in second quarter 1990 dollars); or B) the delegation of authority to such representative is approved in advance by the permitting authority,.2) FlJr a par1nership or soh: proprietorship: a general partner or the proprietor. respectively; 3) For a municipality, State. Federal. or other public agency: either a principal executive officer or ranking elected official. For the purposes of this part, a principal executive officer of a Federal agency includes the chief ext:cutive oflicer having responsibility for the overall operations ofa principal geographic unit ofthe agt:ncy (e.g.. a Regional Administrator of EPA}. I certit)' under penalty of law that this application and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry ofthe person or persons who manage the system, orthose persons directly responsible for gathering the information, the information submitted is, to the best ofmy knowledge and belief: true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility offine and imprisonment for knowing violations. rcd Smith ----_._ " -----_ _--_._ rypcd'printcd name of responsible offlcial President Title ;;;~::~-,=_=:::_=.========D=a=t=e=7=/=2=/=O:==9===========:1

8 .. " SEMCOA Rock Crusher Air Emission Calculations Crushing Activity Annual Crushing Average Portable Rock Rate Rate Operating Hours Crusher's Diesel (tons/hr) (tons/yr) per Year Engine Horsepower 60 20, Crushing AP-42 Emission Factor Efficiency Pollutant Table (%) (tons/yr) PM PM lo Diesel Engine on Portable Crusher AP-42 Emission Factor Table (Ib/hp-hr) Pollutant (tonsfyr) NOx CO SOx PM lo VOC I HAPs Benzene Toluene Xylenes l,3-butadiene 2.737E E-05 Formaldehyde Acetaldehyde Acrolein 6.475E E-05 Napthalene 5.936E E-05 TOTAL HAPs

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