adeq minor source air permit · adeq minor source air permit permit #: 1621-ar-5 is issued to: ......

ADEQMINOR SOURCE

AIR PERMITPermit #: 1621-AR-5

IS ISSUED TO:

The Watkins Company11601 Otter Creek Road South

Mabelvale, AR 72103Pulaski CountyCSN: 60-1194

THIS PERMIT IS YOUR AUTHORITY TO CONSTRUCT, MODIFY, OPERATE, AND/ORMAINTAIN THE EQUIPMENT AND/OR FACILITY IN THE MANNER AS SET FORTH INTHE DEPARTMENT’S MINOR SOURCE AIR PERMIT AND YOUR APPLICATION. THISPERMIT IS ISSUED PURSUANT TO THE PROVISIONS OF THE ARKANSAS WATERAND AIR POLLUTION CONTROL ACT (ARK. CODE ANN. SEC. 8-4-101 ET SEQ.) ANDTHE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALLLIMITS AND CONDITIONS CONTAINED HEREIN.

Signed:

Keith A. Michaels Date

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SECTION I: FACILITY INFORMATION

PERMITTEE: The Watkins CompanyCSN: 60-1194PERMIT NUMBER: 1621-AR-5

FACILITY ADDRESS: 11601 Otter Creek Road SouthMabelvale, AR 72103

COUNTY: Pulaski

CONTACT POSITION: Diana Miles, V. P. of OperationsTELEPHONE NUMBER: (501) 217-4700/4701

REVIEWING ENGINEER: M. Lloyd Davis

UTM North-South (Y): Zone 15: 3843.63 kmUTM East-West (X): Zone 15: 554.08 km

The Watkins CompanyPermit #: 1621-AR-5CSN: 60-1194

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SECTION II: INTRODUCTION

Summary

The Watkins Company owns and operates a commercial printing business (SIC Code: 2752) locatedat 11601 Otter Creek Road South, Mabelvale, Arkansas 72103. Ink and paper constitute the primaryraw materials for the operation. Other raw materials include fountain solution, blanket wash, andgeneral cleaning solvents. Each press unit (SN-01 through SN-06) is considered an emission source,and consists of eight ink fountains, four printing units, one dryer and a chill roll. This modificationproposes to add a banner printer, designated as SN-15, to the facility, which will emit VOCs throughthe plant’s ventilation system. Total annual emission rates for VOCs will increase by 4.3 tpy to 91.4tpy.

Process Description

At each of the six existing press units (SN-01 to SN-06) and at the four proposed press units (SN-09to SN-12), a continuous paper web is fed to a printing unit where ink and fountain solution areapplied through a series of rolling cylinders. Volatiles from the fountain solution and miscellaneouscleaning solvents are partially fugitive and exhausted through the facility ventilation system. Eachpress source consists of a four (4) unit heat offset web press and the associated flotation dryer. Thepaper web passes through a flotation dryer where volatiles are driven off. These volatiles consistof the petroleum distillates that make up the ink vehicle, together with VOCs that are pulled in fromthe presses. The flotation dryers are natural gas fired recirculating hot air systems. The dryertemperature approaches 400EF. After drying, the web is routed over water cooled chill rolls wherethe temperature is reduced and the ink is set. After cooling, the web is passed through a folding unit.

The emissions from the new banner printer (SN-15) will be added with other emissions that are notdestroyed in the RTOs. The inks used on the Banner Printer cannot be utilized in the web pressoperation, and will be accounted for in separate recordkeeping. Ink usage for this new source islimited to 1,314 gallons on a 12 month rolling basis.

Air from the flotation dryers will be vented to the two RETOX 7.0 RTO 95 Regenerative OxidizerSystem (SN-07 and SN-13). The RTOs are twin bed systems with 95 percent VOC destructionefficiency. The process volume is 7,000 Scfm for each unit and the gas inlet temperature isestimated to be 350 EF. Each RTO has a limit of 27.3 lb/hr of combustible VOC. The solventcomposition tabulated for Watkins has been assumed by Adwest Technologies, the system provider,to have a solvent heat of combustion of 18,000 Btu/# net. The system uses natural gas as asupplemental fuel to maintain an operating temperature


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in the required range of 1500 to 1700EF. The initial RTO control device was installed at the Watkinsfacilityin mid-1998. In the event of a shut-down of one of the RTOs, a procedure has been established tosendthe exhausts from presses normally controlled by the shut down RTO into the remaining functionalRTO, if there is enough capacity to do so. Under normal conditions, a single RTO can only handlethe exhausts from 5-6 dryers, so failure of an RTO will probably require that some of thepresses/dryers will be bypassed directly to the atmosphere. The number of uncontrolledpresses/dryers that can be vented will be limited by the observed opacity of the exhaust gases, whichis a function of outside temperatures.

An incidental source (SN-08) at the Watkins facility consists of emissions from a dulling sprayapplied in the pre-press photography operations. The dulling spray is used to reduce the gloss offood objects prior to being photographed. The facility uses up to eight 11oz. cans per month. Thispermit also “bubbles”(SN-14) miscellaneous solvent emissions.


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Regulations

This facility is subject to regulation under the Arkansas Air Pollution Control Code (Regulation 18)and the State Plan of Implementation for Air Pollution Control (Regulation 19).

The following table is a summary of the facility’s total emissions.

TOTAL ALLOWABLE EMISSIONS

Pollutant Emission Rates

lb/hr tpy

PMPM10SO2

VOCCONOx

Ethylene GlycolEthylene Glycol n-Butyl Ether

n-Hexane

6.676.670.03192.00.562.6010.930.660.02

1.381.380.0891.42.4011.406.121.680.01


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SECTION III: PERMIT HISTORY

Permit # 1621-A was issued on May 18, 1995. It allowed PM emissions of 0.1 tpy, SO2 emissionsof 0.1 tpy, VOC emissions of 43.9 tpy, CO emissions of 0.1 tpy, and NOx emissions of 0.4 tpy.

Permit #1621-AR-1 was issued on May 16, 1996. It was a modification allowing increasedproduction with a corresponding increase in VOC emission to a total of 88.89 tpy.

Permit # 1621-AR-2 was issued on August 19, 1997. This modification allowed a change oflocation from the previous site, 6300 Old Jacksonville Highway, North Little Rock, to the currentlocation at 11601 Otter Creek Road South, Little Rock. It also allowed the addition of 8 new heatset units. Total emissions for the facility were now 1.2 tpy PM10, 0.6 tpy SO2, 88.9 tpy VOC, 1.8tpy CO, 6.0 tpy NOx, 3.0 tpy ethylene glycol, 3.6 tpy methylene chloride, 1.2 tpy methanol, 1.8 tpyethylene glycol n-butyl ether, 1.8 tpy propylene glycol methyl ether acetate, and 0.6 tpy of xylene.

Permit # 1621-AR-3 was issued on February 16, 2000. This modification added a RegenerativeRTO to control emissions from the presses, and increased production rates. Replacement of the inksused in the process reduced total HAP usage. HAP emissions were reduced to 7.6 tpy, withmethylene chloride almost completely eliminated.

Permit # 1621-AR-4 was issued on February 16, 2000, and proposed to add four new presses (SN-09through SN-12) and a second Regenerative Thermal Oxidizer (SN-13) to control the VOC emissionsfrom the new presses. Total VOC emissions declined from 89.4 tpy to 87.1 tpy, with HAPs at 7.81tpy.


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SECTION IV: EMISSION UNIT INFORMATION

Specific Conditions

1. Pursuant to §19.501 of the Regulations of the Arkansas Plan of Implementation for AirPollution Control, effective February 15, 1999 (Regulation 19) and A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311, the permittee shall not exceed the emission rates setforth in the following table.

SN Description Pollutant lb/hr tpy

01 to 06and

09 to 12

Ten (10) Offset WebPress/Flotation Dryers

“Bubbled” Fugitives andCombustion Gases

PM10SO2

VOCCONOx

6.62**0.02

169.13**0.472.20

1.160.0662.342.039.64

07and 13

Two (2) RegenerativeThermal Oxidizers

“Bubbled”

PM10SO2

VOCCONOx

0.050.015.490.090.40

0.220.0224.020.371.76

08 Pre-Press Operations VOC 0.05 0.21

14 Miscellaneous Sources“Bubbled”

VOC 16.33 0.50

15 Banner Printer VOC 1.0 4.3**Hourly emission rates from the Presses/Dryers include uncontrolled VOCs when one orboth of the RTOs are shut down for repairs. These uncontrolled emissions also include anestimated 6.35 lb/hr of condensed vapors present as an oil mist, and classified as particulates.

2. Pursuant to §18.801 of the Arkansas Air Pollution Control Code, effective February 15, 1999(Regulation 18) and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permitteeshall not exceed the emission rates set forth in the following table.


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SN Description Pollutant lb/hr tpy

01 to 06,09 to 12and 15

Ten (10) Offset WebPress/Flotation Dryers

“Bubbled” Fugitives andCombustion Gases

PMEthylene Glycol

Ethylene Glycol n-ButylEther

6.6210.930.66

1.166.121.68

07and 13

Two (2) RegenerativeThermal Oxidizers

“Bubbled”

PM 0.05 0.22

14 Miscellaneous Sources“Bubbled”

N-Hexane 0.02 0.01

3. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, visible emissionsshall not exceed the limits specified in the following table of this permit as measured by EPAReference Method 9.

SN Limit Reg. Citation

07 and 13 5% §18.501

4. Pursuant to §19.1004(H) of Regulation 19, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, visible emissions shall not exceed 20% as measured by EPA ReferenceMethod 9, from Presses/Dryers that bypass the Regenerative Thermal Oxidizers (RTOs).This temporary opacity limit is allowed only when one or both of the RTOs is shut down formaintenance or repairs. The provisions of General Condition #10 apply during any upsetcondition.

5. Pursuant to §18.801 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not cause or permit the emission of air contaminants, includingodors or water vapor and including an air contaminant whose emission is not otherwiseprohibited by Regulation #18, if the emission of the air contaminant constitutes air pollutionwithin the meaning of A.C.A. §8-4-303.

6. Pursuant to §18.901 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not conduct operations in such a manner as to unnecessarilycause air contaminants and other pollutants to become airborne.


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Offset Web Press/Flotation Dryers (SN-01 to SN-06 and SN-09 to SN-12)

7. Pursuant to §19.705 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the limits set forth in the following table for VOCcontent. The permittee shall maintain records which demonstrate compliance with theselimits. These records shall be updated for each new product. These records shall be kept onsite, and shall be made available to Department personnel upon request.

Product Maximum VOC Content

Web Press Inks 55% by weight

Fountain Solutions 0.77 lb/gal

Cleaning Compounds 100%

Ethylene Glycol 100%

Plate Cleaner 0.16 lb/gal

Flash Oil 100 %

Open Pocket Compound 2.2 lb/gal

Banner Printer Inks 100%

8. Pursuant to §18.1004 of Regulation 18 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, the permittee shall not exceed the limits set forth in the following tablefor HAP content. The permittee shall maintain records which demonstrate compliance withthese limits. These records shall be updated for each new product. These records shall bekept on site, and shall be made available to Department personnel upon request.


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Product MaximumHAP Content

TLVmg/m3

Fountain Solutions EGBE - 5% wtEthylene Glycol - 10% wt

DEG - 10% wt

97100NE

Ethylene Glycol 100% 100

Plate Cleaner EGBE - 3% wt 97

9. Pursuant to A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, the permitteeshall not exceed the HAP or VOC content limits given in Specific Conditions #7 and #8.Use of a product or solvent containing different components in amounts equal to or less thanthe HAP contents listed in the MSDS may be substituted provided that the ACGIHThreshold Limit Values, as listed on the current MSDS forms, or in the ACGIH handbookof Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs), of the newcomponents are equal to or higher than that given in Specific Condition #9. Thesesubstitution values shall be documented, maintained on site, and provided to Departmentpersonnel upon request and may be used by the Department for enforcement purposes.

10. Pursuant to §19.705 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall maintain records which demonstrate compliance with the tonsper year limit set in Specific Condition #1 for VOC usage from all sources. These recordsmay be used by the Department for enforcement purposes. These records shall be updatedno later than the fifteenth day of the month following the month which the records represent,shall be kept on site, and shall be made available to Department personnel upon request.

11. Pursuant to §18.1004 of Regulation 18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall maintain records which demonstrate compliance with the tonsper year limit set in Specific Condition #2 for HAP usage from all sources. These recordsmay be used by the Department for enforcement purposes. These records shall be updatedno later than the fifteenth day of the month following the month which the records represent,shall be kept on site, and shall be made available to Department personnel upon request.


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12. Pursuant to §19.705 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee may not change the design of the presses (SN-01 to SN-06 and SN-09 to SN-12) in a manner that would reduce the web retention and capture efficiencies usedto determine emission rates for this permit without obtaining any necessary permit revisions.

Regenerative Thermal Oxidizer (SN-07 and SN-13) Specific Conditions

13. Pursuant to §19.702 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall test one of the thermal oxidizers (SN-07 or SN-13) todetermine the VOC destruction rate, using EPA Method 18 or 25A. This test shall beperformed a minimum of once every five years. This test shall be performed with the unitoperating at or above 90% of its design capacity. This unit shall achieve a VOC destructionrate of not less than 95%. A written report of the results of the completed test shall besubmitted to the Department within 30 days of completion of the test.

14. Pursuant to §19.705 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the operating temperature of the inner combustion chambers of the thermaloxidizers shall be maintained within the design limits of 1500EF to 1700EF. (See AutomaticRETOX Twin Bed RTO Operation diagram in the Appendix.)

15. Pursuant to §19.705 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall maintain daily records of the operating temperature of the innercombustion chambers of the thermal oxidizers whenever emissions from the presses arerouted to one or both RTOs.

16. Pursuant to §19.705 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall maintain records of the time during operation of the pressesthat one or both of the RTOs controlling emissions from the presses fails to meet theminimum temperature requirements of Specific Condition #14 or is not functioning becauseof breakdown and/or maintenance. One hour of malfunction or shut-down for each unit shallbe considered a unit-hour, and a monthly record of total unit-hours of malfunction or shut-down shall be included. The reporting requirements of General Condition #10 shall applyto all such occasions. When over 316 unit-hours of malfunction or shut-down of the RTOshave accumulated in a 12 consecutive month period the permittee shall provide calculationsto demonstrate that total facility VOC emissions during the previous 12 consecutive monthshave not exceeded the 100 tpy threshold for a major source permit.


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Banner Printer (SN-15) Specific Conditions

17. Pursuant to §19.705 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permitteee shall not exceed 1,314 gallons of inks used at SN-15 in 12consecutive months. The permittee shall maintain records which demonstrate compliancewith these limits. These records shall be kept on site, and shall be made available toDepartment personnel upon request.


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SECTION V: INSIGNIFICANT ACTIVITIES

The following types of activities or emissions are deemed insignificant on the basis of size, emissionrate, production rate, or activity in accordance with Group A of the Insignificant Activities list foundin Regulation 18 and 19 Appendix A. Insignificant activity emission determinations rely upon theinformation submitted by the permittee in an application dated January 2, 2000.

Description Category

No Group A insignificant activities listed for the facility


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SECTION VI: GENERAL CONDITIONS

1. Any terms or conditions included in this permit which specify and reference ArkansasPollution Control & Ecology Commission Regulation 18 or the Arkansas Water and AirPollution Control Act (A.C.A. §8-4-101 et seq.) as the sole origin of and authority for theterms or conditions are not required under the Clean Air Act or any of its applicablerequirements, and are not federally enforceable under the Clean Air Act. Arkansas PollutionControl & Ecology Commission Regulation 18 was adopted pursuant to the Arkansas Waterand Air Pollution Control Act (A.C.A. §8-4-101 et seq.). Any terms or conditions includedin this permit which specify and reference Arkansas Pollution Control & EcologyCommission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A.§8-4-101 et seq.) as the origin of and authority for the terms or conditions are enforceableunder this Arkansas statute.

2. Pursuant to A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, this permitshall not relieve the owner or operator of the equipment and/or the facility from compliancewith all applicable provisions of the Arkansas Water and Air Pollution Control Act and theregulations promulgated thereunder.

3. Pursuant to §19.704 of the Regulations of the Arkansas Plan of Implementation for AirPollution Control (Regulation 19) and/or A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304and §8-4-311, the Department shall be notified in writing within thirty (30) days afterconstruction has commenced, construction is complete, the equipment and/or facility is firstplaced in operation, and the equipment and/or facility first reaches the target production rate.

4. Pursuant to §19.410(B) of Regulation 19 and/or §18.309(B) of the Arkansas Air PollutionControl Code (Regulation 18) and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and§8-4-311, construction or modification must commence within eighteen (18) months fromthe date of permit issuance.

5. Pursuant to §19.705 of Regulation 19 and/or §18.1004 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, records must be kept for fiveyears which will enable the Department to determine compliance with the terms of thispermit--such as hours of operation, throughput, upset conditions, and continuous monitoringdata. The records may be used, at the discretion of the Department, to determine compliancewith the conditions of the permit.


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6. Pursuant to §19.705 of Regulation 19 and/or §18.1004 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, any reports required by anycondition contained in this permit shall be certified by a responsible official and submittedto the Department at the address below.

Arkansas Department of Environmental QualityAir DivisionATTN: Compliance Inspector SupervisorPost Office Box 8913Little Rock, AR 72219

7. Pursuant to §19.702 of Regulation 19 and/or §18.1002 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, any equipment that is to be tested,unless stated in the Specific Conditions of this permit or by any federally regulatedrequirements, shall be tested with the following time frames: (1) Equipment to beconstructed or modified shall be tested within sixty (60) days of achieving the maximumproduction rate, but in no event later than 180 days after initial start-up of the permittedsource or (2) equipment already operating shall be tested according to the time frames setforth by the Department. The permittee shall notify the Department of the scheduled dateof compliance testing at least fifteen (15) days in advance of such test. Compliance testresults shall be submitted to the Department within thirty (30) days after the completedtesting.

8. Pursuant to §19.702 of Regulation 19 and/or §18.1002 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, the permittee shall provide:

a. Sampling ports adequate for applicable test methodsb. Safe sampling platforms c. Safe access to sampling platformsd. Utilities for sampling and testing equipment

9. Pursuant to §19.303 of Regulation 19 and/or §18.1104 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, the equipment, control apparatusand emission monitoring equipment shall be operated within their design limitations andmaintained in good condition at all times.


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10. Pursuant to §19.601 of Regulation 19 and/or §18.1101 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, if the permittee exceeds anemission limit established by this permit, they shall be deemed in violation of said permitand shall be subject to enforcement action. The Department may forego enforcement actionfor emissions exceeding any limits established by this permit provided the followingrequirements are met:

a. The permittee demonstrates to the satisfaction of the Department that the emissionsresulted from an equipment malfunction or upset and are not the result of negligenceor improper maintenance, and that all reasonable measures have been taken toimmediately minimize or eliminate the excess emissions.

b. The permittee reports the occurrence or upset or breakdown of equipment (bytelephone, facsimile, or overnight delivery) to the Department by the end of the nextbusiness day after the occurrence or the discovery of the occurrence.

c. The permittee shall submit to the Department, within five business days after theoccurrence or the discovery of the occurrence, a full, written report of suchoccurrence, including a statement of all known causes and of the scheduling andnature of the actions to be taken to minimize or eliminate future occurrences,including, but not limited to, action to reduce the frequency of occurrence of suchconditions, to minimize the amount by which said limits are exceeded, and to reducethe length of time for which said limits are exceeded. If the information is includedin the initial report, it need not be submitted again.

11. Pursuant to A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, the permitteeshall allow representatives of the Department upon the presentation of credentials:

a. To enter upon the permittee's premises, or other premises under the control of thepermittee, where an air pollutant source is located or in which any records arerequired to be kept under the terms and conditions of this permit

b. To have access to and copy any records required to be kept under the terms andconditions of this permit, or the Act

c. To inspect any monitoring equipment or monitoring method required in this permitd. To sample any emission of pollutantse. To perform an operation and maintenance inspection of the permitted source

12. Pursuant to A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, this permitis issued in reliance upon the statements and presentations made in the permit application.The Department has no responsibility for the adequacy or proper functioning of the


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equipment or control apparatus.


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13. Pursuant to §19.410(A) of Regulation 19 and/or §18.309(A) of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, this permit shall be subject torevocation or modification when, in the judgment of the Department, such revocation ormodification shall become necessary to comply with the applicable provisions of theArkansas Water and Air Pollution Control Act and the regulations promulgated thereunder.

14. Pursuant to §19.407(B) of Regulation 19 and/or §18.307(B) of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, this permit may be transferred.An applicant for a transfer shall submit a written request for transfer of the permit on a formprovided by the Department and submit the disclosure statement required by Arkansas CodeAnnotated §8-1-106 at least thirty (30) days in advance of the proposed transfer date. Thepermit will be automatically transferred to the new permittee unless the Department deniesthe request to transfer within thirty (30) days of the receipt of the disclosure statement. Atransfer may be denied on the basis of the information revealed in the disclosure statementor other investigation or, if there is deliberate falsification or omission of relevantinformation.

15. Pursuant to A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, this permitshall be available for inspection on the premises where the control apparatus is located.

16. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, this permit authorizesonly those pollutant emitting activities addressed herein.

17. Pursuant to Regulation 18 and 19 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, this permit supersedes and voids all previously issued air permits for this facility.

APPENDIX AUPSET CONDITION PROCEDURES

THE WATKINS COMPANY11601 Otter Creek Road South

Mabelvale, ArkansasPermit No. 1621-AR-5, CSN: 60-1194

UPSET CONDITION PROCEDURES

The Watkins Company has a single regenerative thermal oxidizer (RTO) at their facility (SN-07)and plans to install a second as part of this application (SN-13). In the event of an RTO failure, thesystem automatically vents the associated presses to atmosphere. Under normal conditions, fivepresses would be vented to each RTO. If one of the RTOs goes down, the five presses exhaustingto the RTO would automatically be exhausted through the dryer vents, bypassing the RTO. Theprocedures outlined below will be used in the event that one or both of the RTOs experiences afailure during production.

1. Upon discovery that one of the RTOs has failed, Watkins personnel will route as manypresses to the functioning RTO as possible. Watkins has determined that as many as six (6)presses may be routed to SN-07 and will determine the capacity of SN-13 after installation.

2. Watkins will immediately observe the opacity of the emissions at both the edge of thebuilding and at the perimeter of the property. Opacity observations will be performed by anindividual trained in EPA Method 9 Visual Opacity Observations and will be recorded onthe upset condition report.

3. Watkins will continue to observe the opacity of the emissions every morning (the coldesttime of the day) until the upset condition is corrected. Opacity observations will beperformed by an individual trained in EPA Method 9 Visual Opacity Observations. Opacitywill be recorded on the attached upset condition report.

4. If excess emissions are observed at the facility perimeter, the uncontrolled dryers will beshut down until the RTOs are back on line or until ambient conditions have changed suchthat excess emissions no longer exist.

5. Watkins will maintain a record of the time the presses operated during the upset conditionwithout benefit of the RTO. This information will be recorded as a percentage of down timeon monthly VOC and HAP emission reports. Emissions will be calculated without thedestruction factor for the RTOs during these periods.

6. Watkins will report the upset or breakdown of equipment by telephone, facsimile, orovernight delivery to the Department by the end of the next business day after theoccurrence.

7. Watkins will submit a full written report within five (5) business days of the occurrencesoutlining the information required by General Condition 10 of the permit.

APPENDIX BAutomatic RETOX Twin Bed RTO Operation diagram

APPENDIX B

Method of Calculating Total Facility VOCs Emitted for 12 Consecutive Months IncludingUncontrolled Emissions During RTO Malfunction or Shut-down.

Example #1: a) Presses and Flotation Dryers (SN-01 to 06 and SN-09 to 12) operate at 100% ofcapacity; b) RTOs are not functioning for 316 unit-hours during press operation.

Controlled Emissions: (62.34 tpy/10 Press/Dryer units) = 6.234 tpy/unit-year @ 100% capacity 24.02 tpy/2 RTOs = 24.02 tpy/17,520 unit-hours

Uncontrolled Emissions: 169.13 lb/hr uncontrolled = 84.57 lbs/unit-hour 2 units

SN-08 and SN-14 Emissions: 0.71 tpy (assumed constant)

Total Facility Emissions @ 100% capacity and 316 unit-hrs RTO shut-down:

Presses/Dryers: (6.234 tpy)(10 unit-years)(1.0 capacity) = 62.34tpy

RTOs functioning: (8760 hrs*2 RTOs - 316 hrs)/17,520 hrs * 24.02 tpy = 23.58tpy

Uncontrolled: (84.57 lbs)(316 unit-hours)/2000 lbs/ton = 13.36 tpySN-08 and SN-14 Emissions: 0.71 tpy

TOTAL 99.99 tpy

Example #2: a) Presses and Flotation Dryers (SN-01 to 06 and SN-09 to 12) operate at 90% ofcapacity and b) RTOs are not functioning for 500 unit-hours while the presses are operating.

Presses/Dryers: (6.234 tpy)(10 unit-years)(0.9 capacity) = 56.16 tpy

RTOs functioning: (8760 hrs*2 RTOs - 500 hrs)/17,520 hrs * 24.02 tpy = 23.33 tpyUncontrolled: (84.57 lbs)(500 unit-hours)/2000 lbs/ton = 21.14 tpySN-08 and SN-14 Emissions: 0.71 tpy

TOTAL 101.34 tpy

Example #3: a) Presses and Flotation Dryers (SN-01 to 06 and SN-09 to 12) operate at 80% ofcapacity and b) RTOs also are not functioning for 500 unit-hours while the presses are operating.

Presses/Dryers: (6.234 tpy)(10 unit-years)(0.8 capacity) = 48.87 tpy

RTOs functioning: (8760 hrs*2 RTOs - 500 hrs)/17,520 hrs * 24.02 tpy = 23.33tpy

Uncontrolled: (84.57 lbs)(500 unit-hours)/2000 lbs/ton = 21.14 tpySN-08 and SN-14 Emissions: 0.71 tpy

TOTAL 94.05 tpy

Public Notice

Not required for de minimis

(G:\Forms\PDS-Invoice-Request-Form.wpd)

Request for PDS InvoiceInvoice Number(assigned when invoice is printed)

PDS-

AFIN r 60-1194

Name(for confirmation only)

The Watkins Company

Invoice Type (pick one) r Initial Mod X Variance

Annual Renewal Interim Authority

Permit Number r 1621-AR-5

Media Code (A, S, U, W) r A

Fee Code r MS

Fee Description(for confirmation only)

Minor Source

Amount Due r(whole dollar amount only)

$400

Printed Comment(600 characters maximum)

Minimum fee

Note: The information below is for use by the requesting division; it will not print on the invoice.

Engineer Lloyd Davis

Paid? (yes/no) No

Check number

Comments

r Required data (See "g:\Misc\PDS_FeeCodes.wpd" for descriptions and discussions of fee codes)

Request submitted by: Lloyd Davis Date: January 23, 2002

adeq minor source air permit · adeq minor source air permit permit #: 1621-ar-5 is issued to: ......

Documents