adeq minor source air permit€¦ · adeq minor source air permit permit #: 1220 ... from the...

21
ADEQ MINOR SOURCE AIR PERMIT Permit #: 1220-AR-3 IS ISSUED TO: Gerber Products Company 4301 Harriet Lane Fort Smith, AR 72917 Sebastian County CSN: 66-0054 THIS PERMIT IS YOUR 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 YOUR APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THE PROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT (ARK. CODE ANN. SEC. 8-4-101 ET SEQ.) AND THE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed:

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Page 1: ADEQ MINOR SOURCE AIR PERMIT€¦ · ADEQ MINOR SOURCE AIR PERMIT Permit #: 1220 ... from the blending and gravity flaker unit operation is exhausted through a ... were: PM - 109.20

ADEQ

MINOR SOURCE AIR PERMIT

Permit #: 1220-AR-3 IS ISSUED TO: Gerber Products Company 4301 Harriet Lane

Fort Smith, AR 72917 Sebastian County

CSN: 66-0054 THIS PERMIT IS YOUR 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 YOUR APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THE PROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT (ARK. CODE ANN. SEC. 8-4-101 ET SEQ.) AND THE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed:

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Keith A. Michaels Date

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SECTION I: FACILITY INFORMATION

PERMITTEE: Gerber Products Company

CSN: 66-0054

PERMIT NUMBER: 1220-AR-3

FACILITY ADDRESS: 4301 Harriet Lane Fort Smith, AR 72917

COUNTY: Sebastian

CONTACT POSITION: SSE Manager - Michael Wish

TELEPHONE NUMBER: (501)784-5238

FAX NUMBER: (501)784-5201

REVIEWING ENGINEER: Paul Osmon

UTM North-South (Y): 3921.6 km

UTM East-West (X): 374.5 km

Zone 15

1 1

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054

SECTION II: INTRODUCTION

Summary Gerber Products Company operates a food processing facility located at 4301 Harriet Lane in Fort Smith. This permit modification is issued to modify the previous permit by making the following changes:

1. The facility will install an additional small boiler which will be used only when the facility is not operating the other boilers due to them being oversized for the process heat load requirements. The use of fuel oil as an alternate fuel during natural gas curtailments will also be removed from the permit.

2. The ink jet printing on packing will be reclassified as an insignificant activity.

3. Methyl Bromide usage and emission limits will no longer be listed in the permit.

The facility will no longer fumigate raw materials before utilizing them in the process.

4. The compliance assurance record keeping for particulates will be changed to

show that the cereal drying processes (SN-08A through SN-13B) are permitted at maximum capacity.

Process Description

Gerber manufactures and packages baby and toddler foods at their Fort Smith facility. These foods are divided into 1) Cereals and 2) Baby Foods. Baby food includes produce (including vegetable/meat blends), dry ingredients, and meats. Process descriptions for each of these two categories along with other process operations are provided. Cereal Manufacture Various grain flours and nutrients are weighed and dry blended. The blended ingredients are then conveyed to a slurry tank where water is added. The resultant slurry is preheated and then pumped through a heat exchanger bringing the temperature above 200EF. The slurry is then pumped to one of the facility's six steam heated drum dryers where it is dehydrated. Exhaust blowers from the dryers vent steam, moisture vapor and flour particulate matter to the atmosphere as SN-08A through SN-13B. The dried product is conveyed to flakers, gravity separators and finally to storage bins. This product is then conveyed to the filler where it is packaged in paper cartons. The cased product is

2

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054 then transported to the warehouse for subsequent shipment to customers. Cereal and flour dust from the blending and gravity flaker unit operation is exhausted through a Sly Model #145 Impinjet Scrubber on the roof to atmosphere as SN-07. Solid waste from the gravity separators is either recycled or routed to the Fort Smith landfill. On an annual basis, the Gerber Fort Smith cereal plant processes approximately 9000 tons of grain flours such as rice, wheat, corn, and oats, as well as vitamin and mineral supplemental nutrient ingredients, to manufacture 2,800,000 cases of eight ounce baby cereals. Baby Food Manufacture Over 110 varieties of baby food are manufactured at the Fort Smith facility. Annually, 11,506 tons of dry ingredients are used to manufacture 43,800,000 cases (dozens) of various baby food items in this process. Produce. Produce is brought from cool storage, pre-inspected, washed and (if need be) peeled in a lye bath or steam peelers. This produce is then rewashed and any remaining defects are removed by human inspectors. The produce is chopped and then blanched and softened in screw steamers. Moisture vapor is vented to atmosphere at the screw steamers and at the steam peelers. The heated produce particle size is reduced through a series of milling steps and the resultant puree is accumulated in formulation tanks. Dry Ingredients. If the formula requires other ingredients, these are weighed, blended, and milled before being combined with the produce ingredients. Dust from this process is collected and vented through a Sly Model #140 Impinjet scrubber, to atmosphere as SN-06. Meat. If the formula requires a meat ingredient, the meat is ground, precooked and milled to reduce particle size. This ingredient is then pumped to the formulation tanks. Moisture vapor is vented to atmosphere at the milling equipment used for meat. The combined ingredients are heated above 185EF, and then pumped to filling equipment which delivers the product into glass jars. The jars are capped and pressure cooked in retorts. After the commercial sterilization process is completed, the jars are cooled, labeled and cased. The cases are transported to a warehouse facility and remain there until shipped to customers. Other Process Operations Boilers. There currently are two natural gas boilers located at the facility, Boiler No. 1 (East, SN-01) and Boiler No. 2 (West, SN-02). The boilers provide steam for the Cereal and Baby Food Departments. One boiler (SN-02) is on-line nearly all the time, while the second boiler (SN-01), operates during periods of high steam loads. To maximize operational flexibility,

3

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054 Gerber operates sources SN-01 and SN-02 Aunder a bubble@ for a combined total of 15,330 boiler-hours per year. This provides operational flexibility without increasing total allowable emissions. A third boiler (SN-22) approximately one-fourth the size of the original boilers is being installed on this permit modification to operate during periods of low heat requirements when the other two boilers are not operating. Maintenance and Material Handling Activities. The facility has a maintenance shop. The welding operation (SN-05) has a fume hood which vents to atmosphere. Fume emissions are less than 0.01 lbs/hr and 0.1 tons/year, and are therefore considered negligible. Materials are transported between areas at the facility by forklift. Lead-acid batteries used to power the fork lifts are recharged at the facility. Fumes generated by the recharge process are vented to the atmosphere via fume hoods (SN-14 through SN-17). These sources were deleted from the first permit issued April 29, 1992. Ammonia Refrigeration System. The facility utilizes an ammonia-based refrigeration system to maintain proper temperature for various operational rooms, storage areas, and offices. Both systems use pressurized ammonia stored in a receiver located on the roof of the facility. Some operations and areas require a temperature of 55 degrees Fahrenheit (EF). For these operations, ammonia is supplied to a chiller. In the chiller, the ammonia refrigerant cools a glycol solution. The glycol solution is circulated to the various areas. The areas which utilize the glycol circulation system are finished goods storage, flour silos, dry ingredients storage and meat batching. Other areas require colder temperatures. For these areas, ammonia is circulated directly to the area and serves as the refrigerant in direct expansion heat exchanger coils. The liquid ammonia is converted to gaseous ammonia by absorbing heat from air circulated over coils to the temperature controlled rooms. The gaseous ammonia is then compressed and condensed and returned to the receiver. Two freezers are maintained between 32EF and 72 EF depending on temperature requirements. This would include cereal operations rooms, meat stick operations room, brine chiller in the smokehouse, produce storage, and liquid ingredient storage. The system has rated capacity of approximately 1500 tons of refrigeration (one ton of refrigeration = 12,000 BTU/hr). At any one time the entire system contains about 50,000 pounds of liquid ammonia. Efforts are on-going to reduce ammonia losses through improved repair techniques and new equipment installation; however, under normal operating conditions, about 30,000 pounds of ammonia per year is emitted due to minor leaks, valve repairs and compressor repairs. These fugitive emissions are designated SN-18. Natural Gas Compressor. A natural gas compressor supplies compressed air to various locations at the facility. The fuel consumption rating for the compressor is 20,800 BTU/min. Emissions from the natural gas compressor have been accounted for at SN-19.

4

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054 Carton Printing Operation. Palletized, precut, corrugated carton blanks are delivered to the printing area (SN-20) located in the Labeling and Casing Room. The company and product names are printed on these blanks through the use of water based flexographic inks and Hottendorf printers. After printing is complete, printed cartons are repalletized and stored in warehouse locations until used. This process is classified as an insignificant activity in this permit modification. Natural Gas Emergency Generator. A natural gas emergency generator (SN-21) will be used to provide emergency lighting during power outages. The fuel consumption at full load will be 683 cubic feet of natural gas per hour.

Regulations This facility is currently subject to regulation under the Arkansas Air Pollution Control Code (Regulation 18), and the Arkansas State Implementation Plan for Air Pollution Control (Regulation 19). The new small boiler (SN-22) is subject to New Source Performance Standard (NSPS), 40 CFR Part 60, Subpart Dc - Standards of Performance for Small Industrial - Commercial - Institutional Steam Generating Units. The two large boilers (SN-01 and SN-02) were installed in 1963 and are therefore not subject to New Source Performance Standard (NSPS), 40 CFR Part 60, Subpart Dc - Standards of Performance for Small Industrial - Commercial - Institutional Steam Generating Units. The following table is a summary of the facility=s total emissions.

TOTAL ALLOWABLE EMISSIONS

Emission Rates

Pollutant

lb/hr

tpy

PM

PM10 SO2 VOC CO NOx

Ammonia

4.2 4.2 0.5 0.9 6.8 26.5

---

11.7 11.7 0.6 3.0 22.4 89.4

17.5

5

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054

SECTION III: PERMIT HISTORY Permit No. 1220-A was issued to Gerber Products Company on April 19, 1992. Permit limits were: PM - 109.20 tpy, VOC - 4.28 tpy, NOx - 109.60 tpy, CO - 27.42 tpy, SO2 - 32.44 tpy, and Methyl Bromide - 10.95 tpy. Permit No. 1220-AR-1 was issued to Gerber Products Company on April 19, 1995. Permit limits were: PM10 - 86.5 tpy, VOC - 1.8 tpy, NOx - 63.5 tpy, CO - 16.0 tpy, SO2 - 0.7 tpy, Methyl Bromide - 9.2 tpy, and Ammonia - 17.5 tpy. Permit No. 1220-AR-2 was issued to Gerber Products Company on June 14, 1996. Permit limits were: PM10 - 12.3 tpy, VOC - 2.7 tpy, NOx - 92.1 tpy, CO - 23.6 tpy, SO2 - 16.2 tpy, Methyl Bromide - 9.9 tpy, and Ammonia - 17.5 tpy.

6

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054

SECTION IV: EMISSION UNIT INFORMATION

Specific Conditions

1. Pursuant to '19.501 et seq of the Regulations of the Arkansas Plan of Implementation for Air Pollution Control, effective February 15, 1999 (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 emission rates set forth in the following table. All sources are permitted at maximum capacity for both hourly and yearly emissions except for the yearly emission limits for the boilers. Yearly emissions for the boiler are based on 15,330 total combined hours operations for the boilers and emissions are limited by the fuel usage limits contained in Specific Condition No 9.

7

ADEQ

SN

Facility

SN

Description

Pollutant

lb/hr

tpy

01A

01A

Boiler No. 1

Natural Gas Fuel 82.5 MMBtu/hr Installed - 1963

PM10 SO2 VOC CO NOx

1.2 0.1 0.3 2.9 11.6

02A

02A

Boiler No. 2

Natural Gas Fuel 82.5 MMBtu/hr Installed - 1963

PM10 SO2 VOC CO NOx

1.2 0.1 0.3 2.9 11.6

22

21

Boiler No. 3

Natural Gas Fuel 21 MMBtu/hr

Installed - 2000

PM10 SO2 VOC CO NOx

0.2 0.1 0.1 0.8 3.0

8.7 0.4 1.8 22.2 88.6

03

03

Fumigation Area

Source deleted this permit

06

04

Sly Scrubber (Baby Food)

PM10

0.1

0.2

07

05

Sly Scrubber

(Cereal)

PM10

0.1

0.2

Drum Dryer No.1

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054

ADEQ

SN

Facility

SN

Description

Pollutant

lb/hr

tpy

08A 06 Blower No. 1 PM10 0.1 0.3

08B

07

Drum Dryer No. 1 Blower No. 2

PM10

0.1

0.1

09A

08

Drum Dryer No. 2

Blower No. 1

PM10

0.1

0.3

09B

09

Drum Dryer No. 2

Blower No. 2

PM10

0.1

0.1

10A

10

Drum Dryer No. 3

Blower No. 1

PM10

0.1

0.3

10B

11

Drum Dryer No. 3

Blower No. 2

PM10

0.1

0.1

11A

12

Drum Dryer No. 4

Blower No. 1

PM10

0.1

0.3

11B

13

Drum Dryer No. 4

Blower No. 2

PM10

0.1

0.1

12A

14

Drum Dryer No. 5

Blower No. 1

PM10

0.1

0.3

12B

15

Drum Dryer No. 5

Blower No. 2

PM10

0.1

0.1

13A

16

Drum Dryer No. 6

Blower No. 1

PM10

0.1

0.3

13B

17

Drum Dryer No. 6

Blower No. 2

PM10

0.1

0.1

19

19

Natural Gas Engine

Drive Air Compressor

PM10 SO2 VOC CO NOx

0.1 0.1 0.1 0.1 0.2

0.1 0.1 0.1 0.1 0.5

20

20

Ink Jet Carton Printing

See Insignificant Activities

8

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054

ADEQ

SN

Facility

SN

Description

Pollutant

lb/hr

tpy

21

22

Natural Gas Engine Driven Emergency

Generator

PM10 SO2 VOC CO NOx

0.1 0.1 0.1 0.1 0.1

0.1 0.1 0.1 0.1 0.3

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 permittee shall not exceed the emission rates set forth in the following table. All sources are permitted at maximum capacity for both hourly and yearly emissions except for the yearly emission limits for the boilers. Yearly emissions for the boiler are based on the limits contained in Specific Condition No 9.

ADEQ SN

Facility

SN

Description

Pollutant

lb/hr

tpy

01A

01A

Boiler No. 1

Natural Gas Fuel 82.5 MMBtu/hr Installed - 1963

PM

1.2

02A

02A

Boiler No. 2

Natural Gas Fuel 82.5 MMBtu/hr Installed - 1963

PM

1.2

22

21

Boiler No. 3

Natural Gas Fuel 21 MMBtu/hr

Installed - 2000

PM

0.2

8.7

03

03

Fumigation Area

Source deleted this permit

06

04

Sly Scrubber (Baby Food)

PM

0.1

0.2

07

05

Sly Scrubber

(Cereal)

PM

0.1

0.2

9

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054

10

ADEQ

SN

Facility

SN

Description

Pollutant

lb/hr

tpy

08A 06 Drum Dryer No.1 Blower No. 1

PM 0.1 0.3

08B

07

Drum Dryer No. 1

Blower No. 2

PM

0.1

0.1

09A

08

Drum Dryer No. 2

Blower No. 1

PM

0.1

0.3

09B

09

Drum Dryer No. 2

Blower No. 2

PM

0.1

0.1

10A

10

Drum Dryer No. 3

Blower No. 1

PM

0.1

0.3

10B

11

Drum Dryer No. 3

Blower No. 2

PM

0.1

0.1

11A

12

Drum Dryer No. 4

Blower No. 1

PM

0.1

0.3

11B

13

Drum Dryer No. 4

Blower No. 2

PM

0.1

0.1

12A

14

Drum Dryer No. 5

Blower No. 1

PM

0.1

0.3

12B

15

Drum Dryer No. 5

Blower No. 2

PM

0.1

0.1

13A

16

Drum Dryer No. 6

Blower No. 1

PM

0.1

0.3

13B

17

Drum Dryer No. 6

Blower No. 2

PM

0.1

0.1

18

18

Refrigeration System

Fugitives

Ammonia

C

17.5

19

19

Natural Gas Engine

Drive Air Compressor

PM

0.1

0.1

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054

ADEQ

SN

Facility

SN

Description

Pollutant

lb/hr

tpy

20 20 Ink Jet Carton Printing See Insignificant Activities

21

22

Natural Gas Engine Driven Emergency

Generator

PM

0.1

0.1

3. Pursuant to A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, visible emissions

shall not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9.

ADEQ SN

Limit

Regulatory

Citation

01 02 22

5%

'18.501

19 21

5%

'18.501

06 07

08A through

13B

5%

'18.501

4. 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, 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. '8-4-303.

5. 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 unnecessarily cause air contaminants and other pollutants to become airborne.

6. 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 not add more than 35,000 pounds per rolling 12 month

11

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054

period of makeup ammonia to the system. 7. 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 keep records of ammonia recharges. That is, the amount and date of ammonia recharge. Records shall be kept on site and made available to Department personnel upon request.

8. Pursuant to '18.1004 or Regulation 18 and A.C.A. '8-4-203 as referenced by '8-4-304

and '8-4-311, the permittee may only use inks in the printing process which contains no more than 0.4 lb/gal VOCs and no more than 0.1 tpy of all other HAPs.

Boilers 9. Pursuant to '19.705 of Regulation 19 and A.C.A. '8-4-203 as referenced by '8-4-304

and '8-4-311, fuel usages at the facility shall not exceed the limits listed in the following table:

Fuel

Facility Fuel Usage - Rolling 12 Month Total

Natural Gas

1,275,675,000 ft3 during any consecutive 12 month period

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 monthly records which demonstrate compliance with Specific Condition No. 9. Records shall be updated by the fifteenth day of the month following the month to which the records pertain. These records shall be kept on site, and shall be made available to Department personnel upon request.

11. Pursuant to '19.705 of Regulation 19 and 40 CFR 60, the permittee shall only use natural

gas or LP gas as fuel for the boilers unless this permit has been amended.

NSPS Requirements

12

12. Pursuant to '19.705 of Regulation 19 and 40 CFR 60, the permittee shall comply with all applicable provisions of New Source Performance Standards (NSPS), 40 CFR 60, Subpart Dc, at all times. The permittee shall record and maintain records of the amount of natural gas or LP gas combusted in each boiler subject to this subpart (SN-22) during each month.

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054 13. Pursuant to '19.705 of Regulation 19 and 40 CFR 60, the permittee is responsible for

other requirements listed in Subpart Dc that may affect the facility. All records required by Subpart Dc shall be maintained by the permittee for a period of two (2) years following the date of such record. A copy of Subpart Dc is attached to this permit as Appendix A.

13

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054

SECTION V: INSIGNIFICANT ACTIVITIES The following types of activities or emissions are deemed insignificant on the basis of size, emission rate, production rate, or activity in accordance with Group A of the 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 April 5, 2000.

Description

Category

Printing Operations (SN-20)

Group A9

Fork Lift Battery Recharging (SN-14 through SN-17)

Group B20

Maintenance Shop (SN-05)

Group B14

14

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054

SECTION VI: GENERAL CONDITIONS

1. Any terms or conditions included in this permit which specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A. '8-4-101 et seq.) as the sole origin of and 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 18 was adopted pursuant to the Arkansas Water and Air Pollution Control Act (A.C.A. '8-4-101 et seq.). Any terms or conditions included in this permit which specify and reference Arkansas Pollution Control & Ecology Commission 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 enforceable under 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 permit

shall not relieve the owner or operator of the equipment and/or the facility from compliance with all applicable provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated thereunder.

3. Pursuant to '19.704 of the Regulations of the Arkansas Plan of Implementation for Air

Pollution Control (Regulation 19) and/or A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311, the Department shall be notified in writing within thirty (30) days after construction has commenced, construction is complete, the equipment and/or facility is first placed 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

Pollution Control 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 from the 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 five years which will enable the Department to determine compliance with the terms of this permit--such as hours of operation, throughput, upset conditions, and continuous monitoring data. The records may be used, at the discretion of the Department, to determine compliance with the conditions of the permit.

15

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054 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 any condition contained in this permit shall be certified by a responsible official and submitted to the Department at the address below.

Arkansas Department of Environmental Quality Air Division ATTN: Compliance Inspector Supervisor Post Office Box 8913 Little 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 regulated requirements, shall be tested with the following time frames: (1) Equipment to be constructed or modified shall be tested within sixty (60) days of achieving the maximum production rate, but in no event later than 180 days after initial start-up of the permitted source or (2) equipment already operating shall be tested according to the time frames set forth by the Department. The permittee shall notify the Department of the scheduled date of compliance testing at least fifteen (15) days in advance of such test. Compliance test results shall be submitted to the Department within thirty (30) days after the completed testing.

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 methods b. Safe sampling platforms c. Safe access to sampling platforms d. 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 apparatus and emission monitoring equipment shall be operated within their design limitations and maintained in good condition at all times.

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054 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 an emission limit established by this permit, they shall be deemed in violation of said permit and shall 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:

a. The permittee demonstrates to the satisfaction of the Department that the

emissions resulted from an equipment malfunction or upset and are not the result of negligence or improper maintenance, and that all reasonable measures have been taken to immediately minimize or eliminate the excess emissions.

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

c. The permittee shall submit to the Department, within five business days after the occurrence or the discovery of the occurrence, a full, written report of such occurrence, including a statement of all known causes and of the scheduling and nature 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 such conditions, to minimize the amount by which said limits are exceeded, and to reduce the length of time for which said limits are exceeded. If the information is included in 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

permittee shall 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 the

permittee, where an air pollutant source is located or in which any records are required 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 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 of pollutants e. To perform an operation and maintenance inspection of the permitted source

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Gerber Products Co. Permit #: 1220-AR-3 CSN: 66-0054 12. Pursuant to A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311, this permit

is 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 equipment or control apparatus.

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 to revocation or modification when, in the judgment of the Department, such revocation or modification shall become necessary to comply with the applicable provisions of the Arkansas 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 form provided by the Department and submit the disclosure statement required by Arkansas Code Annotated '8-1-106 at least thirty (30) days in advance of the 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 of the receipt of the disclosure statement. A transfer may be denied on the basis of the information revealed in the disclosure statement or other investigation or, if there is deliberate falsification or omission of relevant information.

15. Pursuant to A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311, this permit

shall 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

authorizes only 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.

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APPENDIX A NSPS 40 CFR 60, Subpart Dc