adeq operating air permit · 2019-12-30 · performance for volatile organic liquid storage vessels...

ADEQ OPERATING AIR PERMIT

Pursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation #26:

Permit #: 763-AOP-R5

Renewal #1

IS ISSUED TO: The Bryce Company, LLC

Searcy, AR 72143

White County AFIN: 73-00110

And

IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN

THIS PERMIT AUTHORIZES THE ABOVE REFERENCED PERMITTEE TO INSTALL, OPERATE, AND MAINTAIN THE EQUIPMENT AND EMISSION

UNITS DESCRIBED IN THE PERMIT APPLICATION AND ON THE FOLLOWING PAGES. THIS PERMIT IS VALID BETWEEN:

AND

IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN.

Signed:

Keith Michaels Date

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110

Table of Contents

Section I: FACILITY INFORMATION..................................................................................... 4

Section II: INTRODUCTION...................................................................................................... 5

Section III: PERMIT HISTORY............................................................................................... 11

Section IV: SPECIFIC CONDITONS ...................................................................................... 13

Section V: TEMPORARY SPECIFIC CONDITIONS ........................................................... 41

Section VI: COMPLIANCE PLAN AND SCHEDULE .......................................................... 52

Section VII: Plant Wide Conditions.......................................................................................... 53

Section VIII: Insignificant Activities......................................................................................... 57

Section IX: GENERAL PROVISIONS..................................................................................... 59

APPENDIX A................................................................................................................................ 1

2

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 Table 1 - List of Acronyms

A.C.A. Arkansas Code Annotated

CFR Code of Federal Regulations

CO Carbon Monoxide

CSN County Serial Number

HAP Hazardous Air Pollutant

Lb/hr Pound per hour

MVAC Motor Vehicle Air Conditioner

No. Number

NOx Nitrogen Oxide

PM Particulate matter

PM10 Particulate matter smaller than ten microns

SNAP Significant New Alternatives Program (SNAP)

SO2 Sulfur dioxide

SSM Startup, Shutdown, and Malfunction Plan

Tpy Ton per year

UTM Universal Transverse Mercator

VOC Volatile Organic Compound

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Section I: FACILITY INFORMATION

PERMITTEE: The Bryce Company, LLC

AFIN: 73-00110

PERMIT NUMBER: 763-AOP-R5

FACILITY ADDRESS: 450 South Benton Street

Searcy, AR 72143

MAILING ADDRESS 450 South Benton Street

Searcy, AR 72143

COUNTY: White

CONTACT POSITION: Teddy Townsend

TELEPHONE NUMBER: (501) 279-9675

REVIEWING ENGINEER: Melisha Griffin

UTM North - South (Y): Zone 15 3900.678

UTM East - West (X): Zone 15 617.095

4

MURPHY

Zone 15 [ Between 3650 & 4040]


Section II: INTRODUCTION

Summary of Permit Activity

Bryce Corporation (BC) owns and operates a flexible packaging manufacturing facility located at 450 South Benton Street in Searcy, Arkansas. This facility manufactures flexible packaging intended primarily for the salted snack food market. Bryce Corporation has emissions greater than 250 tons per year of volatile organic compounds (VOC) and, because of this, is defined as a major stationary source as defined in 40 CFR 52.21 (Prevention of Significant Deterioration (PSD) regulations). This facility is also subject to regulation under the Regulations of the Arkansas Operating Air Permit Program (Regulation #26) because it emits over 100 tons per year of VOCs. This facility is not subject to regulation under the National Emission Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 63.820 Subpart KK - National Emission Standards for the Printing and Publishing Industry because there are no significant HAP emissions from the printing process. The facility is subject to NSPS Subpart Kb -Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels).

As required by General Provision #3, the facility is submitting a request for a renewal of the existing Title V Air Operating permit. Bryce is also requesting a Minor Modification to the existing permit. The modification includes the installation of a solvent recovery system to lower spent solvent generated by the facility. The facility is replacing incinerators SN-10 and SN-11 with new incinerators, SN-32 and SN-31, respectively. The facility would also like to revise the permit to reflect that SN-01 and SN-20 are located within a total enclosure due to changes that were made after issuance of the original Title V permit and therefore are requesting a lower emission limit for these units. The facility is requesting to increase the maximum VOC content in the inks to 90%.

Process Description

The production processes conducted by The Bryce Company, LLC at the two South Benton Street addresses in Searcy, AR (400 & 500) are referred to as converting. That is The Bryce Company, LLC purchases plastic film, in roll form, from various film manufacturers and converts it into flexible packaging that is principally used by the manufacturers of salted snack foods.

The first step in the conversion process involves printing the required design on a particular film. Printing of the thin plastic film is performed on ten flexographic presses, each of which has been assigned a source number. Six of the presses are housed at 400 South Benton Street (Plant #2). Three presses, SN-02, SN-05 and SN-13 have the capability to print six colors while three presses SN-03, SN-04 and SN-06 have the capability to print eight colors. In Plant #5 at 500 South Benton there are two eight color presses SN-01 and SN-20 and three ten color press SN-24, SN-28, SN-29. In Plant #2 all six presses (SN-02, SN-03, SN-04, SN-05, SN-06, and SN-13) represent a source of VOC emissions that vent to the atmosphere through general building ventilation. However, in Plant #5 all five presses are contained within a permanent total

5

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 enclosure sending all emissions to incineration. All eleven presses (being of the same basic design in this respect) are equipped with a two-part natural gas fired ink-drying system. One part is known as the between color dryer, the other is known as the overhead dryer. Both dryers have a separate intake and exhaust system. The exhaust from both dryer systems on each press is ducted into an air pollution control device known as a catalytic incinerator. Two catalytic incinerators control the dryer systems on all six presses in Plant #2. The 21,500 SCFM incinerator, SN-32, controls the VOC emissions from the dryers of SN-02 and SN-06. SN-12, a 20,500 SCFM incinerator, controls the VOC emissions from the dryers of SN-03, SN-04, SN-05 and SN-13. The 21,500 SCFM incinerator, SN-31, controls the VOC exhaust emissions from SN-01, SN-20 and SN-21. SN-25, a 21,500 SCFM incinerator, controls the VOC emissions from the dryers of SN-24, SN-28 and SN-29.

Printing, of course, necessitates the use of inks. The inks utilized in this case are solvent based and are the origin of the VOC emissions. Three solvents or solvent blends are utilized to adjust the viscosity, color strength and dry time of the inks as they are applied. Bulk storage of these solvents is facilitated by a tank farm located at 400 South Benton Street, Plant #2. Located just behind Plant #2 is a tank farm consisting of three 10,000 gallons steel storage tanks each of which has been assigned a source number. SN-17 is divided into three compartments, SN-18 is a single compartment, and SN-19 is a dual compartment tank. A solvent blend is used in a very large quantity and is stored in SN-18. Normal propel acetate and normal propanol are stored in two of SN-17's compartments. One compartment of SN-17 contains naphtha, which is used in the laminators. Dirty Solvent (Hazardous Waste) is stored in one compartment of SN-19, while Clean Press solvent is stored in the other compartment. The Dirty Solvent is shipped to a properly permitted off-site TSD facility. Located just adjacent to Plant #5 is a tank farm consisting of one 16,100 gallons storage tank (SN-30). This tank has 6-compartments for the organic solvents needed to print the products.

Alone the printed film does not provide the stiffness, sealability or product protection the customer desires; so it must be laminated (bonded) to a second film. This part of the production process is accomplished on what is known as an extrusion laminator, i.e. SN-07, SN-08, SN-09, SN-21 and SN-22. An extrusion laminator creates a lamination by combining the printed film with an unprinted film utilizing a molten low-density polyethylene and polypropylene mixture. The polyethylene is purchased in the form of pellets, which are stored on-site in large silos with one silo at each production plant. Polypropylene is used in a much smaller quantity and is supplied in cardboard containers. A vacuum loading system, which feeds the throat of the device known as the extruder, draws the pellets into a mixer system. This device resembles a cylinder (barrel) with an auger (screw) that rotates in the center. The flights of the screw rotate in close tolerance to the walls of the barrel that is electrically heated progressively at higher and higher temperatures along its length, thereby melting and conveying the resin. The molten resin emerges at 6000F - 6100F from the extruder through a slit opening known as the die, such that a thin straight curtain of molten poly is created. The die opening is positioned such that it is just inches above and aligned with a water-cooled, high-pressure nip point. As long as the screw rotates and the temperature is maintained the molten curtain falls continuously into the nip point.

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Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 The nip is simply where a large cylindrical roller contacts rubber-coated roller and rotates against one another while pinched together hydraulically.

The process of lamination begins when the printed film is unwound from the unwind stand and passes through the primer deck. The primer deck applies a very light coating over the entire inked surface of the printed film (web), by a process known as direct gravure. The direct gravure coating method is best described as a metal roll called an anilox roll. The anilox roll is partially emerged in a pan filled with primer solution and has a doctor blade system to control the amount of solution transferred to the anilox. The surface of the anilox roller is pitted with many tiny depressions (or cells) and is rotating at a high rate of speed matching that of the film that moves between it and a rubber coated roller known as the impression roller (or primer nip roller). It is hydraulically actuated and functions by holding the film in contact with the anilox roller.

The primer that is used is a mixture of 95% water and polyethyleneamine. In most cases this mixture requires the addition of isopropanol to aid in the application. However, SN-22 does not use any isopropanol in the primer mixture. Once the primer is applied, the film passes through a primer oven to be dried. The primer oven operates by directing heated air, from the combustion of natural gas onto the primed surface and exhausting the combustion products along with the primer's vehicle to the atmosphere.

The printed and primed film passes out of the primer oven and over the surface of one of the rollers comprising the nip. From the other side an unprinted, sealable film unwinds from its stand and passes over the surface of the other roller in the nip. These two films along with the poly curtain pass through the nip sandwiching the poly curtain between the two films where it serves as an adhesive to hold the films together. This provides for the extra stiffness, tear resistance and added sealability that is required by the customer. Some packaging requires a greater sealability than others. So as a means of augmenting sealability, three of the laminators are equipped with what is known as a thermal strip deck (post coater). This post coating follows the "lamination" of the two films and is conducted on the same machine as part of the laminator. The thermal stripe solution is an ethylene vinyl acetate resin dispersed in naphtha. Both laminators at 400 South Benton (SN-07 and SN-08) and one laminator at 500 South Benton (SN-21) are equipped with this technology. The thermal stripe deck is a type of coating head that is comprised of a metal anilox roller rotating in a thermal stripe solution. The anilox has many tiny grooves that allows for the solution to be transferred to the anilox. A pressurized metal blade (doctor blade) comes into contact with the anilox roller and controls the amount of thermal stripe solution that remains on the anilox roller when it comes into contact with the film. The nip roller is comprised of individual hubs that have up to a ½" rubber strip that will come into contact with the film, pressing the film against the anilox roller transferring the thermal stripe solution to the film. The film then passes through the thermal stripe drying oven (post oven). The drying oven uses heated air from the combustion of natural gas and the heated air is then forced onto the treated surface. The exhaust from the products of combustion and the thermal stripe's vehicle are then vented to the atmosphere on SN-07 and SN-08. With SN-21 these products are vented to a catalytic incinerator, SN-31.

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Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 From here the film goes to the slitting department where when the film is slit, the thermal stripes end up bordering one edge of the packaging. The slitting operation transforms large laminated rolls into smaller rolls to be packaged and sent to the warehouse at 450 South Benton for transport to the customer.

Regulations

The following table contains the regulations applicable to this permit.

Table 2 - Regulations

Source No. Regulation Citations

All Arkansas Plan of Implementation for Air Pollution Control (Regulation #19)

All Arkansas Air Pollution Control Code (Regulation #18)

All Regulations of the Arkansas Operating Air Permit Program (Regulation #26)

30 NSPS Subpart Kb –Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels)

The following table is a summary of emissions from the facility. The following table contains cross-references to the pages containing specific conditions and emissions for each source. This table, in itself, is not an enforceable condition of the permit.

Table 3 – Emission Summary

Emission Summary

Emission Rates

Source No.

Description Pollutant lb/hr Tpy Cross Reference Page

PM 1.8 6.0

PM10 1.8 6.0

SO2 1.3 1.7

VOC 528.2 1126.9

CO 3.8 16.8

Total Allowable Emissions

NOx 13.6 55.8

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MURPHY

This section must contain any NSPS requirements and all sources that apply.


HAPs* None ----- ----- -----

Air Contaminants** None ----- ----- -----

02 Six Color Flexographic Printing Press

(P-14)

06 Eight Color Flexographic Printing Press

(P-21)

PM PM10 SO2 VOC CO

NOx

0.2 0.2 0.2 95.0 0.4 1.4

0.6 0.6 0.2

202.8 1.8 5.8

13


(P-04)


(P-15)

31 20,500 SCFM TEC Catalytic Incinerator

(I-02)

PM PM10 SO2 VOC CO NOx

0.2 0.2 0.1 16.6 0.5 2.0

0.9 0.9 0.1 42.7 2.2 9.6

15


(P-16)


(P-17)


(P-20)


(P-27)


0.4 0.4 0.4

173.3 0.8 2.8

1.2 1.2 0.4

306.6 3.6 11.6

19

07 Extrusion Laminator w/Thermal Strip (L-4)

08 Extrusion Laminator w/Thermal Strip

(L-11)


0.2 0.2 0.1

142.0 0.4 1.3

0.6 0.6 0.1

420.0 1.8 2.9

21

09 Extrusion Laminator (L-12)

22 Extrusion Laminator (L-08)


0.2 0.2 0.1 9.9 0.4 1.4

0.6 0.6 0.1 28.0 1.8 5.8

23

9


32 20,500 SCFM TEC Catalytic Incinerator

(I-01)


0.1 0.1 0.1 12.2 0.2 0.7

0.3 0.3 0.1 23.8 0.9 2.9

25

12

TEC System Incinerator (Incinerator #3)


0.1 0.1 0.1 20.3 0.2 0.7

0.3 0.3 0.5 34.9 0.9 2.9

27

24 Ten Color Flexographic Printing Press

(P-28)


(P-29)


(P-30)

25 TEC System Incinerator (Incinerator #4)


0.3 0.3 0.1 25.0 0.7 2.6

1.2 1.2 0.1 47.2 2.9 11.4

29

17 Storage Tank #1 (3 Compartment) VOC 3.8 0.2 33

18 Storage Tank #2 VOC 6.0 0.3 34


21 Extrusion Laminator

w/Thermal Strip (L-19)


0.1 0.1 0.1 6.1 0.2 0.7

0.3 0.3 0.1 18.1 0.9 2.9

36


33 Solvent Recovery Unit #1 VOC 5.0 1.0 40

*HAPs included in the VOC totals. Other HAPs are not included in any other totals unless specifically stated.

**Air Contaminants such as ammonia, acetone, and certain halogenated solvents are not VOCs or HAPs.

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Section III:PERMIT HISTORY

Air permit 763-A was the initial State Implementation Plan (SIP) permit for Bryce Corporation. The permit was issued on March 3, 1988 for the permitting of a flexible packaging manufacturing facility consisting of two flexographic printing presses and two laminators.

Air permit 763-AR-1 was issued to Bryce Corporation on June 6, 1988. The air permit was modified to incorporate the addition of an extrusion laminator and an emulsion laminator.

Air permit 763-AR-2 was issued to Bryce Corporation under a Prevention of Significant Deterioration review on January 23, 1990. The air permit was modified to incorporate the addition of one six color and one eight color flexographic printing press and to permit the emission rates for three laminators under the emission rate for one laminator.

Air permit 763-AR-3 was issued to Bryce Corporation under a Prevention of Significant Deterioration review on April 14, 1993. The air permit was modified to incorporate the addition of two eight color flexographic printing presses, an extrusion laminator, and the replacement of two existing older presses for more modern units. The permit was also modified to provide the installation of two catalytic incinerators to destroy VOC emissions.

Air permit 763-AR-4 was issued to Bryce Corporation on September 19, 1994. The air permit was modified to incorporate the addition of a six color flexographic printing press and three trim blowers for recycling solid waste.

Air permit 763-AR-5 was issued to Bryce Corporation on February 9, 1995. The air permit was modified to incorporate the addition of three 10,000 gallon above ground storage tanks.

Air permit 763-AR-6 was issued to Bryce Corporation on January 29, 1996. The air permit was modified to incorporate the addition of a new eight color flexographic printing press and to relocate a six color flexographic printing press.

Air permit 763-AR-7 was issued to Bryce Corporation on February 19, 1997. The air permit was modified to incorporate the addition of a new extrusion laminator.

Arkansas Operating air permit 763-AOP-R0 was issued to Bryce Corporation on March 6, 1998. This was the initial Title V operating permit issued to Bryce under Regulation 26. The facility modified the previous permit by the following methods.

1. The installation of a reconditioned flexographic press that caused an emissions increase of 76.6 tons per year of volatile organic compounds (VOC) which was greater than the 40 ton per year significance level for PSD permitting requirements. The flexographic press being removed for the installation of the reconditioned press represented an actual source-wide creditable contemporaneous emissions decrease of 44.0 tons per year of VOCs. The facility had no additional source-wide creditable contemporaneous emissions increases. Since the facility demonstrated a net emissions increase less than the

11


significance level of 40 tpy, the installation of the reconditioned flexographic press did not require a PSD review.

2. An old source number SN-08, which included three laminators, was divided up into two source numbers (SN-08 & SN-22).

3. The third laminator from the old SN-08 was removed from the facility. 4. And three source numbers (SN-14, SN-15, and SN-16) were removed from the permit.

These sources are enclosed in the buildings and have no emissions to the atmosphere.

Arkansas operating permit #763-AOP-R1 was issued to Bryce Corporation on September 3, 1998. The facility’s existing air permit was modified by the addition of a retro-fitted six color flexographic printing press which had the capability using water based inks for the printing operations. This addition resulted in an emissions increase of all the criteria pollutants including one hazardous air pollutant (HAP).

Arkansas operating permit #763-AOP-R2 was the second modification to Bryce Corporation’s initial operating permit. The facility’s existing air permit was modified by the addition of a ten color flexographic printing press (SN-24), the conversion of a six color flexographic printing press (SN-23) from water based inks back to solvent based inks, the addition of a new catalytic incinerator to control the VOC emissions from printing presses SN-23 and SN-24, the switch to a new thermal strip solution that no longer contains any hazardous air pollutants (HAP), and the addition of a total inclosure in Plant #5.

Arkansas operating permit #763-AOP-R3 was the third modification to Bryce Corporation’s initial operating permit. In this modification, the facility proposed to install two 1,500-gallon storage tanks. This modification resulted in an increase in VOC emissions of 0.20 lb/hr and 1.0 ton/yr.

Permit #763-AOP-R4 was issued on February 2, 2001. In this modification, the facility proposed to replace two 1,500 gallon double wall storage tanks (SN-26 & SN-27), that contain organic solvent for use at Plant #5, with one 16,100 gallon compartmentalized storage tank. This modification resulted in an increase in VOC emissions of 0.20 lb/hr and 1.0 ton/yr. The facility also planned to upgrade one of the oldest presses P-05 (SN-23) and add two state-of-the-art ten color printing presses (P-29, SN-28 & P-30, SN-29). This modification did not significantly increase emissions (the increase was 35.0 ton/yr) and provided the facility with equipment designed with updated features. In this replacement, P-29 and P-30 was installed in Plant #5 (500 South Benton). P-05 (SN-23) was retired and removed from operation.

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Section IV: SPECIFIC CONDITONS

SN- 02 and SN- 06 Descriptions Flexographic Printing Presses Controlled by Incinerator #1

Source SN-02 is a Kidder Stacy flexographic printing press which has the capability of using six colors in the printing operation. Sources SN-06 is Windholler & Hoercst flexographic printing press which has the capability of using eight colors in the printing operation. These presses are located in Plant #2. The VOC emissions from these sources are captured at a rate of 70% and directed to incinerator #1 (SN-32). The dryers used for the drying of the ink utilize natural gas for fuel. The burning of the natural gas serves as an additional source of emissions for these sources. The printing presses were both installed in 1989.

These emissions are those not captured by the control system.

These Specific Conditions take effect upon start-up of SN-31 and SN-32. (See Section V for Temporary Specific Conditions for this source).

Specific Conditions

1. The permit allows the following maximum combined emission rates for sources SN-02 and SN-06. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 4 and 5 and Plantwide Condition 7. [Regulation No. 19 §19.501 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E]

Table 4– Maximum Criteria Emission Rates

Pollutant Lb/hr Tpy

PM10 0.2 0.6

SO2 0.2 0.2

VOC 95.0 202.8

CO 0.4 1.8

NOX 1.4 5.8

2. The permittee shall not exceed the combined emission rates set forth in the following table for sources SN-02 and SN-06. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 4 and 5 and Plantwide Condition 7. [Regulation No. §18.801 effective February 15, 1999, and A. C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

Table 5 – Maximum Non-Criteria Emission Rates

13


Pollutant Lb/hr Tpy

PM 0.2 0.6

3. Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. Since the burning of natural gas produces only trace amounts of particular matter, compliance with this condition does not require any visual observations.

Table 6– Visible Emissions

SN Limit Regulatory Citation

02 5 Regulation No. 18 §18.501 effective February 15, 1999, and A. C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311


4. The permittee shall not use any flexographic ink with a greater VOC content than 90% by weight and a cutting solvent with a greater VOC content than 6.8 lb/gal. Compliance with this condition shall be demonstrated through compliance with Specific Condition 5. [Regulation No. 19 §19.705 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E]

5. The permittee shall maintain records of a material balance to show compliance with the annual VOC emission limits set in Specific Condition 1. This information may be used by the Department for enforcement purposes. Compliance shall be determined on a monthly basis by completing the material balance in Appendix A or by completing the material balance using a document equivalent to that in Appendix A. The monthly record shall also include a subtotal for all VOC emissions for the previous 12 months. These records shall be maintained on site and shall be provided to Department personnel upon request. The monthly reports shall also be submitted to the Department per General Provision 7 by the last day of the month after the reported month.

For the purposes of these reports, a 70% collection efficiency shall be assumed for all VOC emissions from ink and other materials used in production runs which are exhausted to the catalytic incinerator. [Regulation No. 19 §19.705 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E]

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Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 01, SN- 20 & SN- 31 Descriptions Flexographic Printing Presses and the TEC System Incinerator (Incinerator #2)

Source SN-01 is an eight color Kidder & Stacy flexographic printing press, while SN-20 is an eight-color Windholler & Hoercst flexographic printing press. SN-31 is a 22,500 SCFM Grace TEC System Catalytic Incinerator. These presses are located in Plant #5. One hundred percent (100%) of the VOC emissions from the presses are captured and directed to incinerator #4 (SN-31). The manufacturer has supplied a destruction efficiency of 95%. The dryers used for the drying of ink and the combustion of the VOCs in the incinerator utilizes natural gas for fuel. The burning of natural gas serves as an additional source of emissions for these sources. The printing presses were installed in 1997 and 1996 respectively. The incinerator will be constructed within eighteen months of permit issuance.


Specific Conditions

6. The permit allows the following maximum combined emission rates for sources SN-01, SN-20 and SN-31. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 9, 11, 12, 14, and 16. [Regulation No. 19 §19.501 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

Table 7 – Maximum Criteria Emission Rates

Pollutant lb/hr Tpy

PM10 0.2 0.9

SO2 0.1 0.1

VOC 16.6 42.7

CO 0.5 2.2

NOX 2.0 9.6

15


7. The permittee shall not exceed the combined emission rates set forth in the following table for sources SN-01, SN-20, and SN-31. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 9, 11, 12, 14, and 16. [Regulation No. §18.801 effective February 15, 1999, and A. C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311].


Pollutant Lb/hr Tpy

PM 0.2 0.9

8. Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. Compliance with this condition does not require any visual observations as long as the minimum combustion temperature requirement contained in Specific Condition 14 is maintained.

Table 9 – Visible Emissions



9. The permittee shall not:

a. use any flexographic ink with a greater VOC content than 90% by weight b. use any cutting solvent with a greater VOC content than 6.8 lb/gal.

[Regulation No. 19 §19.705 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E].

10. The permittee shall maintain records of a material balance to show compliance with the annual VOC emission limits set in Specific Condition 6 and Specific Condition 9. This material balance should include lbVOC/gal, amount of material used and any other information pertinent to demonstrate compliance. This information may be used by the Department for enforcement purposes. Compliance shall be determined on a monthly basis by completing the material balance in Appendix A or by completing the material balance using a document equivalent to that in Appendix A. The monthly record shall also include a subtotal for all VOC emissions for the previous 12 months. These records shall be maintained on site and shall be provided to Department personnel upon request. The monthly reports shall also be submitted to the Department per General Provision 7 by the last day of the month after the reported month.

For the purposes of these reports, a 100% collection efficiency shall be assumed for all VOC emissions from ink used in production runs. In addition, a 95% destruction efficiency shall

16


also be assumed for all VOC emissions emitted by the incinerator. [Regulation No. 19 §19.705 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E].

11. The permittee shall continuously operate SN-31 whenever the flexographic presses SN-01 and SN-20 are operating. Bypassing this control equipment when either press is running shall be considered a violation of this permit condition. [Regulation No. 19 §19.705 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E].

12. The permittee shall maintain the following operational parameters in order to continuously demonstrate compliance with the 100% capture efficiency used in the VOC emission calculations. These parameters are the defining criteria for a permanent total enclosure.

1. Any natural draft opening (NDO) shall be at least four equivalent opening diameters from each VOC emitting point. An “equivalent diameter” is the diameter of a circle that has the same area as the opening. The equation for an equivalent diameter (ED) is:

ED = 4*

area∏

For a circular NDO, this equation simply reduces to the diameter of the opening.

2. The total area of all NDO’s shall not exceed five percent of the surface area of the enclosure’s walls, floor, and ceiling.

3. The average face velocity (FV) of air through each NDO’s shall be at least 200 ft/min. The direction of air through all NDO’s shall be into the enclosure.

4. All access doors and windows whose areas are not included as NDO’s shall be closed during routine operation of the process.

[Regulation No. 19 §19.705 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E].

13. The permittee shall install and operate a pressure gauge which verifies the pressure differential across the total enclosure. A pressure differential of 0.007 inches of water will demonstrate compliance with the 200 ft/min face velocity requirement contained in Specific Condition 12. The pressure differential shall be monitored by means of a guage which measures the drop in air pressure. The gauge shall be monitored once every six months for a one-hour period. Readings shall be recorded during this one hour period every five minutes and presses operating at that time shall be noted. These records shall be maintained on site and shall be provided to Department personnel upon request. These reports shall also be submitted to the Department per General Provision 7 by the last day of the month after the

17


reported six month period. [Regulation No. 19 §19.703 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E].

14. The permittee shall maintain the inlet temperature of the incinerator at 600 ˚F. [Regulation No. 19 §19.705 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E].

15. The permittee shall continuously monitor and record once per hour or continuously (by strip chart) the inlet temperature to the incinerator to show compliance with Specific Condition 14. The permittee shall maintain these records on site and shall provide them to Department personnel upon request. [Regulation No. 19 §19.703 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E].

16. The permittee shall test, in accordance with EPA Reference Method 25A, the destruction efficiency of the catalytic incinerator (SN-31) in order to show compliance with a destruction efficiency of 95%. The test shall be performed in accordance with Plantwide Conditions 3 and 4. During this test, both printing presses (SN-01 and SN-20) shall be running solvent based inks and shall be operated within 10% of their capacity. The permittee shall give the Department written notification of the scheduled date of compliance testing at least fifteen calendar days in advance. [Regulation No. 19 §19.702 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E].

18

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 03, SN- 04, SN- 05, & SN- 13 Descriptions Flexographic Printing Presses Controlled by Incinerator #3

Sources SN-03, SN-04, SN-05, and SN-13 are Windholler & Hoercst flexographic printing presses which have the capability of utilizing eight colors in the printing operation. These presses are located in Plant #2. The VOC emissions from these sources are captured at a rate of 70% and directed to incinerator #3 (SN-12). The dryers used for the drying of the ink utilize natural gas for fuel. The burning of the natural gas serves as an additional source of emissions for these sources. The printing presses were installed in 1992, 1991, 1992, and 1996, respectively.

Specific Conditions

17. The permit allows the following maximum combined emission rates for sources SN-03, SN-04, SN-05 and SN-13. The permittee will demonstrate compliance with this condition by compliance with Specific Condition 20 and Plantwide Condition 7. [Regulation No. 19 §19.501 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E]


Pollutant Lb/hr Tpy

PM10 0.4 1.2

SO2 0.4 0.4

VOC 173.3 306.6

CO 0.8 3.6

NOX 2.8 11.6

18. The permittee shall not exceed the combined emission rates set forth in the following table for sources SN-03, SN-04, SN-05 and SN-13. The permittee will demonstrate compliance with this condition by compliance with Specific Condition 20 and Plantwide Condition 7. [Regulation No. §18.801 effective February 15, 1999, and A. C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]


Pollutant Lb/hr Tpy

PM 0.4 1.2

19

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 19. Visible emissions may not exceed the limits specified in the following table of this permit as

measured by EPA Reference Method 9. Since the burning of natural gas produces only trace amounts of particular matter, compliance with this condition does not require any visual observations.







20. The permittee shall not use any flexographic ink with a greater VOC content than 90% by weight and a cutting solvent with a greater VOC content than 6.8 lb/gal. Compliance with this condition shall be demonstrated through compliance with Specific Condition 21. [Regulation No. 19 §19.705 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E].


For the purposes of these reports, a 70% collection efficiency shall be assumed for all VOC emissions from ink used in production runs which are exhausted to the catalytic incinerator. All VOC emissions from inks which are vented to the atmosphere shall be recorded at 100% of the VOC content as stated on the Material Safety Data Sheets (MSDS). [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

20

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 07 and SN- 08 Descriptions Thermal Strip Equipped Extrusion Laminators

Sources SN-07 and SN-08 are extrusion laminators which are equipped with the capability of producing a thin thermal strip along the edges of the extruded film to increase the sealability of the packaging. These laminators are located in Plant #2. The VOC emissions from these sources are released directly to the indoor atmosphere of the building. The dryers used for the drying of the primer utilize natural gas for fuel. The burning of the natural gas serves as an additional source of emissions for these sources. The extrusion laminators were installed in 1976 and 1979, respectively.

Specific Conditions

22. The permit allows the following maximum combined emission rates for sources SN-07 and SN-08. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 26, 27 and 28 and Plantwide Condition 7. [Regulation No. 19 §19.501 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E]


Pollutant Lb/hr Tpy

PM10 0.2 0.6

SO2 0.1 0.1

VOC 142.0 420.0

CO 0.4 1.8

NOX 1.3 2.9

23. The permittee shall not exceed the combined emission rates set forth in the following table for sources SN-07 and SN-08. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 26, 27 and 28 and Plantwide Condition 7. [Regulation No. §18.801 effective February 15, 1999, and A. C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]


Pollutant Lb/hr Tpy

PM 0.2 0.6

21


24. Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9.



07 20 Regulation No. 19 §19.503 and 40 CFR Part 52, Subpart E


25. The permittee will conduct weekly observations of the opacity from sources Source No. SN-07 and SN-08, and keep a record of these observations. If the permittee detects visible emissions, then the permittee shall conduct a 6-minute opacity reading in accordance with EPA Reference Method #9. The permittee must immediately take action to identify and correct the cause of the visible emissions. After implementing the corrective action, the permittee must document the source complies with the visible emissions requirements. The permittee shall maintain records of the cause of any visible emissions and the corrective action taken. The permittee must keep the records onsite and make the records available to Department personnel upon request. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

26. The permittee shall not use any thermal strip solution with a greater VOC content than 70% by weight and a cutting solvent with a greater VOC content than 6.8 lb/gal. Compliance with this condition shall be demonstrated through compliance with Specific Condition 28. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

27. The permittee shall not use any thermal strip solution that contains any hazardous air pollutant (HAP). [Regulation No. 18 §18.1004 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

28. The permittee shall maintain records of a material balance to show compliance with the annual VOC emission limits set in Specific Condition 22. This information may be used by the Department for enforcement purposes. Compliance shall be determined on a monthly basis by completing the material balance in Appendix A or by completing the material balance using a document equivalent to that in Appendix A. The monthly record shall also include a subtotal for all VOC emissions for the previous 12 months. These records shall be maintained on site and shall be provided to Department personnel upon request. The monthly reports shall also be submitted to the Department per General Provision 7 by the last day of the month after the reported month. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

22

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 09 and SN- 22 Descriptions Extrusion Laminators without Thermal Strip Capability

Sources SN-09 and SN-22 are extrusion laminators which do not have thermal strip capability. These laminators are located in Plant #5. The VOC emissions from these sources are non-point source emissions exhausted outside the building. The dryers used for the drying of the primer utilize natural gas for fuel. The burning of the natural gas serves as an additional source of emissions for these sources. The extrusion laminators were installed in 1993 and 1988, respectively.

Specific Conditions


Table 16– Maximum Criteria Emission Rates SN- 023

Pollutant Lb/hr Tpy

PM10 0.2 0.6

SO2 0.1 0.1

VOC 9.9 28.0

CO 0.4 1.8

NOX 1.4 5.8


Table 17 – Maximum Non-Criteria Emission Rates SN- 023

Pollutant Lb/hr Tpy

PM 0.2 0.6

23


measured by EPA Reference Method 9.

Table 18– Visible Emissions SN- 023




32. The permittee will conduct weekly observations of the opacity from sources Source No. SN-09 and SN-22, and keep a record of these observations. If the permittee detects visible emissions, then the permittee shall conduct a 6-minute opacity reading in accordance with EPA Reference Method #9. The permittee must immediately take action to identify and correct the cause of the visible emissions. After implementing the corrective action, the permittee must document the source complies with the visible emissions requirements. The permittee shall maintain records of the cause of any visible emissions and the corrective action taken. The permittee must keep the records onsite and make the records available to Department personnel upon request. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

33. The permittee shall not use any primer solvent with a greater VOC content than 6.6 lb/gal. Compliance with this condition shall be demonstrated through compliance with Specific Condition 34. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

34. The permittee shall maintain records of a material balance to show compliance with the annual VOC emission limits set in Specific Condition 29. This information may be used by the Department for enforcement purposes. Compliance shall be determined on a monthly basis by completing the material balance in Appendix A or by completing the material balance using a document equivalent to that in Appendix A. The monthly record shall also include a subtotal for all VOC emissions for the previous 12 months. These records shall be maintained on site and shall be provided to Department personnel upon request. The monthly reports shall also be submitted to the Department per General Provision 7 by the last day of the month after the reported month. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

24

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 32 Description TEC System Incinerator (Incinerator #1)

Source SN-32 is a 22,500 SCFM Grace TEC System Catalytic Incinerator. VOC emissions from sources SN-02 and SN-06 are captured at a rate of 70% and routed to this incinerator for destruction. The manufacturer has supplied destruction efficiency of greater than 95%. This incinerator will be constructed within eighteen months of permit issuance.

Specific Conditions

35. The permit allows the following emission rates for source SN-32. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 39 and 41. [Regulation No. 19 §19.501 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E]


Pollutant Lb/hr Tpy

PM10 0.1 0.3

SO2 0.1 0.1

VOC 12.2 23.8

CO 0.2 0.9

NOX 0.7 2.9

36. The permittee shall not exceed the emission rates set forth in the following table for source SN-32. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 39 and 41. [Regulation No. §18.801 effective February 15, 1999, and A. C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]


Pollutant Lb/hr Tpy

PM 0.1 0.3

25






38. The permittee shall continuously operate SN-32 whenever the flexographic presses SN-02 or SN-06 are operating. Bypassing this control equipment when either press is running shall be considered a violation of this permit condition. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

39. The permittee shall maintain the inlet temperature of the incinerator at 600 ˚F. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

40. The permittee shall continuously monitor and record once per hour or continuously (by strip chart) the inlet temperature to the incinerator to show compliance with Specific Condition 39. The permittee shall maintain these records on site and shall provide them to Department personnel upon request. [Regulation No. 19 §19.703 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

41. The permittee shall test, in accordance with EPA Reference Method 25A, the destruction efficiency of this catalytic incinerator (SN-32) in order to show compliance with a destruction efficiency of 95%. The test shall be performed within one year from permit issuance and be conducted in accordance with Plantwide Conditions 3 and 4. During this test, both printing presses shall be running solvent based inks and shall be operated within 10% of their capacity. The permittee shall give the Department written notification of the scheduled date of compliance testing at least fifteen calendar days in advance. [Regulation No. 19 §19.702 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

26

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 12 Description TEC System Incinerator (Incinerator #3)

Source SN-12 is a 20,500 SCFM Grace TEC System Catalytic Incinerator. VOC emissions from sources SN-03, SN-04, SN-05, and SN-13 are captured at a rate of 70% and routed to this incinerator for destruction. A stack test performed in 1993 confirmed a destruction efficiency of 95%. This incinerator was installed in 1993.

Specific Conditions

42. The permit allows the following emission rates for source SN-12. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 46 and 48. [Regulation No. 19 §19.501 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E]


Pollutant Lb/hr Tpy

PM10 0.1 0.3

SO2 0.1 0.5

VOC 20.3 34.9

CO 0.2 0.9

NOX 0.7 2.9

43. The permittee shall not exceed the emission rates set forth in the following table for source SN-12. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 46 and 48. [Regulation No. §18.801 effective February 15, 1999, and A. C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]


Pollutant Lb/hr Tpy

PM 0.1 0.3


27





45. The permittee shall continuously operate SN-12 whenever the flexographic presses SN-03, SN-04, SN-05, and SN-13 are operating. Bypassing this control equipment when either press is running shall be considered a violation of this permit condition. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].


47. The permittee shall continuously monitor and record once per hour or continuously (by strip chart) the inlet temperature to the incinerator to show compliance with Specific Condition 46. The permittee shall maintain these records on site and shall provide them to Department personnel upon request. [Regulation No. 19 §19.703 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

48. The permittee shall test, in accordance with EPA Reference Method 25A, the destruction efficiency of this catalytic incinerator in order to show compliance with a destruction efficiency of 90%. The test shall be performed within two years from permit issuance and be conducted in accordance with Plantwide Conditions 3 and 4. During this test, both printing presses and the laminator shall be running solvent based inks and primers and shall be operated within 10% of their capacity. The permittee shall give the Department written notification of the scheduled date of compliance testing at least fifteen calendar days in advance. [Regulation No. 19 §19.702 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

28

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 24, SN- 28, SN- 29 & SN- 25 Descriptions Flexographic Printing Presses and the TEC System Incinerator (Incinerator #4)

Source SN-24, SN-28 and SN-29 are Windholler & Hoercst flexographic printing presses which have the capability of utilizing ten colors in the printing operation. Source SN-25 is a 21,000 SCFM Grace TEC System Catalytic Incinerator. These sources are located in Plant #5. One hundred percent (100%) of the VOC emissions from the presses are captured and directed to incinerator #4 (SN-25). A destruction efficiency of 95% has been supplied by the manufacturer. The dryers used for the drying of the ink and the combustion of the VOCs in the incinerator utilize natural gas for fuel. The burning of the natural gas serves as an additional source of emissions for these sources. The printing presses were installed in 1999, 2000 and 2001 respectively. The incinerator was installed in 1999.

Specific Conditions

49. The permit allows the following maximum combined emission rates for sources SN-24, SN-25, SN-28 and SN-29. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 52, 54, 55, 57 and 59. [Regulation No. 19 §19.501 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

Table 25 – Maximum Criteria Emission Rates

Pollutant Lb/hr Tpy

PM10 0.3 1.2

SO2 0.1 0.1

VOC 25.0 47.2

CO 0.7 2.9

NOX 2.6 11.4

50. The permittee shall not exceed the combined emission rates set forth in the following table for sources SN-24, SN-25, SN-28 and SN-29. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 52, 54, 55, 57 and 59. [Regulation No. §18.801 effective February 15, 1999, and A. C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311].


Pollutant Lb/hr Tpy

PM 0.3 1.2

29


measured by EPA Reference Method 9. Compliance with this condition does not require any visual observations as long as the minimum combustion temperature requirement contained in Specific Condition 57 is maintained.

Table 27 – Visible Emissions



52. The permittee shall not:

a. use any flexographic ink with a greater VOC content than 90% by weight b. use any cutting solvent with a greater VOC content than 6.8 lb/gal. c. exceed 39 tons of VOC per consecutive twelve month period from presses SN-28 and

SN-29 combined; The facility must maintain records of each individual press’s (SN-28 and SN-29) emissions to demonstrate compliance with this limit.

[Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

53. The permittee shall maintain records of a material balance to show compliance with the annual VOC emission limits set in Specific Condition 49 and Specific Condition 52. This material balance should include lbVOC/gal, amount of material used and any other information pertinent to demonstrate compliance. This information may be used by the Department for enforcement purposes. Compliance shall be determined on a monthly basis by completing the material balance in Appendix A or by completing the material balance using a document equivalent to that in Appendix A. The monthly record shall also include a subtotal for all VOC emissions for the previous 12 months. These records shall be maintained on site and shall be provided to Department personnel upon request. The monthly reports shall also be submitted to the Department per General Provision 7 by the last day of the month after the reported month.

For the purposes of these reports, a 100% collection efficiency shall be assumed for all VOC emissions from ink used in production runs. In addition, a 95% destruction efficiency shall also be assumed for all VOC emissions emitted by the incinerator. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

54. The permittee shall continuously operate SN-25 whenever the flexographic presses SN-23, SN-24, SN-28 and SN-29 are operating. Bypassing this control equipment when either press is running shall be considered a violation of this permit condition. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

30

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 55. The permittee shall maintain the following operational parameters in order to continuously

demonstrate compliance with the 100% capture efficiency used in the VOC emission calculations. These parameters are the defining criteria for a permanent total enclosure.

1. Any natural draft opening (NDO) shall be at least four equivalent opening diameters from each VOC emitting point. An “equivalent diameter” is the diameter of a circle that has the same area as the opening. The equation for an equivalent diameter (ED) is:

ED = 4*

area∏

For a circular NDO, this equation simply reduces to the diameter of the opening.

2. The total area of all NDO’s shall not exceed five percent of the surface area of the enclosure’s walls, floor, and ceiling.

3. The average face velocity (FV) of air through each NDO’s shall be at least 200 ft/min. The direction of air through all NDO’s shall be into the enclosure.

4. All access doors and windows whose areas are not included as NDO’s shall be closed during routine operation of the process.

[Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

56. The permittee shall install and operate a pressure gauge which verifies the pressure differential across the total enclosure. A pressure differential of 0.007 inches of water will demonstrate compliance with the 200 ft/min face velocity requirement contained in Specific Condition 55. The pressure differential shall be monitored by means of a guage which measures the drop in air pressure. The gauge shall be monitored once every six months for a one-hour period. Readings shall be recorded during this one hour period every five minutes and presses operating at that time shall be noted. These records shall be maintained on site and shall be provided to Department personnel upon request. These reports shall also be submitted to the Department per General Provision 7 by the last day of the month after the reported six month period. [Regulation No. 19 §19.703 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].


31

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 58. The permittee shall continuously monitor and record once per hour or continuously (by strip

chart) the inlet temperature to the incinerator to show compliance with Specific Condition 57. The permittee shall maintain these records on site and shall provide them to Department personnel upon request. [Regulation No. 19 §19.703 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

59. The permittee shall test, in accordance with EPA Reference Method 25A, the destruction efficiency of the catalytic incinerator (SN-25) in order to show compliance with a destruction efficiency of 95%. The test shall be performed in accordance with Plantwide Conditions 3 and 4. During this test, all four printing presses shall be running solvent based inks and shall be operated within 10% of their capacity. The permittee shall give the Department written notification of the scheduled date of compliance testing at least fifteen calendar days in advance. [Regulation No. 19 §19.702 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E].

32

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 17 Description Storage Tank #1 (3 Compartments)

Source SN-17 is a 10,000 gallon, horizontal, fixed roof, above ground storage tank with three compartments. The tank consists of two 2500 gallon compartments and a 5000 gallon compartment. The 2500 gallon compartments house normal propanol and normal propyl acetate while the 5000 gallon compartment holds VM&P Naptha. The tank was installed in 1994.

Specific Conditions

60. The permit allows the following emission rates for source SN-17. The permittee will demonstrate compliance with this condition by compliance with Specific Condition 61. [Regulation No. 19 §19.501 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E]


Pollutant Lb/hr Tpy

VOC 3.8 0.2

61. The permittee shall not exceed the following net throughput limits during any consecutive 12 month period. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E]


Compartment Size Solvent Net Throughput (gallons/12 consecutive months)

1 2500 Organic Solvent 90,000


3 5000 Organic Solovent 180,000

62. The permittee shall maintain records which demonstrate compliance with the limits set in Specific Condition 61 and may be used by the Department for enforcement purposes. Compliance shall be determined on a monthly basis by totaling the net throughput for the previous 12 months. Each 12 month total shall be available for inspection by the last day of the month after the reported 12 months. These records shall be maintained on site and shall be provided to Department personnel upon request. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

33

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 18 Description Storage Tank #2

Source SN-18 is a 10,000 gallon, horizontal, fixed roof, above ground storage tank. The tank houses ethyl alcohol used for cleaning and was installed in 1994.

Specific Conditions


Table 30– Maximum Criteria Emission Rates SN- 19

Pollutant Lb/hr Tpy

VOC 6.0 0.3

64. The permittee shall not exceed the net throughput limit of 360,000 gallons of organic solvent during any consecutive 12 month period. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].


34

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 19 Description Storage Tank #3 (2 Compartment)

Source SN-19 is a 10,000 gallon, horizontal, fixed roof, above ground storage tank with two compartments. The tank consists of a 6000 gallon compartment and a 4000 gallon compartment. The 6000 gallon compartment houses washed out and dilluted solvent born ink as hazardous waste while the 4000 gallon compartment holds distilled solvent. The tank was installed in 1994.

Specific Conditions



Pollutant Lb/hr Tpy

VOC 4.6 0.3

67. The permittee shall not exceed the net throughput limit of 240,000 gallons of solvent during any consecutive 12 month period. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].


35

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 21 Description Thermal Strip Equipped Extrusion Laminator

Source SN-21 is an extrusion laminator which is equipped with the capability of producing a thin thermal strip along the edges of the extruded film to increase the sealability of the packaging. This laminator is located in Plant #5. The VOC emissions from this source are captured at a rate of 70% and directed to incinerator #2 (SN-31). The dryers used for the drying of the primer utilize natural gas for fuel. The burning of the natural gas serves as an additional source of emissions for this source. The extrusion laminator was installed in 1997.


Specific Conditions

69. The permit allows the following emission rates for source SN-21. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 73 and 75 and Plantwide Condition 7. [Regulation No. 19 §19.501 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E]


Pollutant Lb/hr Tpy

PM10 0.1 0.3

SO2 0.1 0.1

VOC 6.1 18.1

CO 0.2 0.9

NOX 0.7 2.9

70. The permittee shall not exceed the emission rates set forth in the following table for source SN-21. The permittee will demonstrate compliance with this condition by compliance with Specific 73 and 75 and Plantwide Condition 7. [Regulation No. §18.801 effective February 15, 1999, and A. C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]


Pollutant Lb/hr Tpy

PM 0.1 0.3


36




21 20 Regulation No. §19.503 and 40 CFR Part 52, Subpart E

72. The permittee will conduct weekly observations of the opacity from sources Source No. SN-21, and keep a record of these observations. If the permittee detects visible emissions, then the permittee shall conduct a 6-minute opacity reading in accordance with EPA Reference Method #9. The permittee must immediately take action to identify and correct the cause of the visible emissions. After implementing the corrective action, the permittee must document the source complies with the visible emissions requirements. The permittee shall maintain records of the cause of any visible emissions and the corrective action taken. The permittee must keep the records onsite and make the records available to Department personnel upon request. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].


74. The permittee shall not use any thermal strip solution that contains any hazardous air pollutants (HAP). [Regulation No. 18 §18.1004 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

75. The permittee shall maintain records of a material balance to show compliance with the VOC emission limits set in Specific Condition 69. This information may be used by the Department for enforcement purposes. Compliance shall be determined on a monthly basis by completing the material balance in Appendix A or by completing the material balance using a document equivalent to that in Appendix A. The monthly record shall also include a subtotal for all annual VOC emissions for the previous 12 months. These records shall be maintained on site and shall be provided to Department personnel upon request. The monthly reports shall also be submitted to the Department per General Provision 7 by the last day of the month after the reported month.

For the purposes of these reports, a 70% collection efficiency shall be assumed for all VOC emissions from thermal strip solution and cutting solvent used in production runs which are exhausted to the catalytic incinerator. All VOC emissions from inks which are vented to the atmosphere shall be recorded at 100% of the VOC content as stated on the Material Safety Data Sheets (MSDS). [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

37

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 30 Description Storage Tank #4 (6 Compartment)

Source SN-30 is a 16,000 gallons horizontal above ground storage tank with six compartments. This tank houses solvents for cleaning and processing and was installed in 2000.

Specific Conditions

76. The permit allows the following emission rates for source SN-30. The permittee will demonstrate compliance with this condition by compliance with Specific Condition77. [Regulation No. 19 §19.501 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E]


Pollutant Lb/hr Tpy

VOC 8.4 1.0

77. The permittee shall not exceed the following net throughput limits during any consecutive 12 month period. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E]


Compartment Size Solvent Net Throughput (gallons/12 consecutive months)







78. The permittee shall maintain records which demonstrate compliance with the limit set in Specific condition 77 and may be used by the Department for enforcement purposes. Compliance shall be determined on a monthly basis by totaling the net throughput for the previous 12 months. Each 12 month total shall be available for inspection by the last day of the month after the reported 12 months. These records shall be maintained on site and shall be reported according to General Provisions 7. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

38

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 79. The permittee “shall keep readily accessible records showing the dimension of the storage

vessel and an analysis showing the capacity of the storage vessel [Regulation No. 19 §19.304 et seq. effective February 15, 1999, and 40 CFR Part , Subpart §60.116b(b)].

39

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 33 Description Solvent Distillation Unit #1

Source SN-33 is a solvent distillation and recovery unit with the capability of processing 20,000 gallons of dirty solvent per month. The unit consists of two small storage vessels and the distillation apparatus. The distillation unit is to be installed in 2003.

Specific Conditions



Pollutant Lb/hr Tpy

VOC 5.0 1.0

81. The permittee shall not process more than 240,000 gallons of solvent during any consecutive 12 month period. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E]

82. The permittee shall maintain records which demonstrate compliance with the limits set in Specific Condition 81 and may be used by the Department for enforcement purposes. Compliance shall be determined on a monthly basis by totaling the net throughput for the previous 12 months. Each 12 month total shall be available for inspection by the last day of the month after the reported 12 months. These records shall be maintained on site and shall be provided to Department personnel upon request. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E]

40


Section V:TEMPORARY SPECIFIC CONDITIONS

This section (Section V: Temporary Specific Conditions) only applies to sources SN-01, SN-20, SN-02, SN-06, SN-21, SN-10 and SN-11. All other sources not identified in this section must comply with the Specific Conditions listed in Section IV of this permit.

After the installation of SN-31 and SN-32, this section of the permit (Section V: Temporary Specific Conditions) is no longer valid, and all sources, including SN-01, SN-20, SN-02, SN-06, SN-21, SN-31 and SN-32, must comply with the Specific Conditions in Section IV of this permit. Sources SN-10 (Incinerator #1) and SN-11 (Incinerator #2) will be deleted.

In accordance with Plantwide Condition #2, the facility has eighteen months to complete construction of SN-31 and SN-32.

SN- 01 and SN- 20

Flexographic Printing Presses Controlled by Incinerator #2

Source SN-01 is a Kidder Stacy flexographic printing press and SN-20 is Windholler & Hoercst flexographic printing press which have the capability of utilizing eight colors in the printing operation. These presses are located in Plant #5. The VOC emissions from these sources are captured at a rate of 70% and directed to incinerator #2 (SN-11). The dryers used for the drying of the ink utilize natural gas for fuel. The burning of the natural gas serves as an additional source of emissions for these sources. The printing presses were installed in 1996 and 1997, respectively.

Specific Conditions

83. Pursuant to §19.501 et seq of the Regulations of the Arkansas State Implementation Plan for Air Pollution Control (Regulation 19) and 40 CFR Part 52, Subpart E, the permittee shall not exceed the combined emission rates set forth in the following table for sources SN-01 and SN-20. The pound per hour pollutant emission rates are based on the maximum capacity of the equipment and are also limited by Specific Condition 86. The ton per year pollutant emission rates are effectively limited by Specific Condition 87 and Plantwide Condition 7.

Pollutant lb/hr Tpy PM10 0.2 1.0

SO2 0.2 1.0

VOC 76.7 153.2

CO 0.3 1.4

NOx 0.9 3.8

41

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 84. Pursuant to §18.801 of the Arkansas Air Pollution Control Code (Regulation #18) effective

February 15, 1999, 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. The pound per hour pollutant emission rate is based on the maximum capacity of the equipment and is also limited by Specific Condition 86. The ton per year pollutant emission rates are effectively limited by Specific Condition 87 and Plantwide Condition 7.

Pollutant (for each source)

lb/hr Tpy

PM 0.2 1.0

85. Pursuant to §18.501 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, the permittee shall not exceed 5% opacity from sources SN-01 and SN-20 as measured by EPA Reference Method 9. Since the burning of natural gas produces only trace amounts of particulate matter, compliance with this condition does not require any visual observations.

86. Pursuant to §19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by A.C. A. §8-4-304 and §8-4-311, and 40 CFR Part 70.6, the permittee shall not use any flexographic ink with a greater VOC content than 70% by weight and a cutting solvent with a greater VOC content than 6.8 lb/gal. Compliance with this condition shall be demonstrated through compliance with Specific Condition 87.

87. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52 Subpart E, the permittee shall maintain records of a material balance to show compliance with the annual VOC emission limits set in Specific Condition 83. This information may be used by the Department for enforcement purposes. Compliance shall be determined on a monthly basis by completing the material balance in Appendix A. The monthly record shall also include a subtotal for all VOC emissions for the previous 12 months. These records shall be maintained on site and shall be provided to Department personnel upon request. The monthly reports shall also be submitted to the Department per General Provision 7 by the last day of the month after the reported month.

88. For the purposes of these reports, a 70% collection efficiency shall be assumed for all VOC emissions from ink used in production runs which are exhausted to the catalytic incinerator. All VOC emissions from inks which are vented to the atmosphere shall be recorded at 100% of the VOC content as stated on the Material Safety Data Sheets (MSDS).

42

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 02 and SN- 06 Descriptions Flexographic Printing Presses Controlled by Incinerator #1

Source SN-02 is a Kidder Stacy flexographic printing press which has the capability of using six colors in the printing operation. Sources SN-06 is Windholler & Hoercst flexographic printing press which has the capability of using eight colors in the printing operation. These presses are located in Plant #2. The VOC emissions from these sources are captured at a rate of 70% and directed to incinerator #1 (SN-10). The dryers used for the drying of the ink utilize natural gas for fuel. The burning of the natural gas serves as an additional source of emissions for these sources. The printing presses were both installed in 1989.

These emissions are those not captured by the control system.

Specific Conditions



Pollutant Lb/hr Tpy

PM10 0.2 1.0

SO2 0.2 1.0

VOC 82.8 202.8

CO 0.4 1.8

NOX 1.3 5.8



Pollutant Lb/hr Tpy

PM 0.2 1.0

91. Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. Since the burning of natural gas produces only trace

43


amounts of particular matter, compliance with this condition does not require any visual observations.





92. The permittee shall not use any flexographic ink with a greater VOC content than 90% by weight and a cutting solvent with a greater VOC content than 6.8 lb/gal. Compliance with this condition shall be demonstrated through compliance with Specific Condition 93. [Regulation No. 19 §19.705 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E]


For the purposes of these reports, a 70% collection efficiency shall be assumed for all VOC emissions from ink and other materials used in production runs which are exhausted to the catalytic incinerator. [Regulation No. 19 §19.705 et seq. effective February 15, 1999 and 40 CFR Part 52, Subpart E]

44

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 21 Description Thermal Strip Equipped Extrusion Laminator

Source SN-21 is an extrusion laminator which is equipped with the capability of producing a thin thermal strip along the edges of the extruded film to increase the sealability of the packaging. This laminator is located in Plant #5. The VOC emissions from this source are captured at a rate of 70% and directed to incinerator #2 (SN-11). The dryers used for the drying of the primer utilize natural gas for fuel. The burning of the natural gas serves as an additional source of emissions for this source. The extrusion laminator was installed in 1997.

Specific Conditions

94. The permit allows the following emission rates for source SN-21. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 98 and 100 and Plantwide Condition 7. [Regulation No. 19 §19.501 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E]


Pollutant Lb/hr Tpy

PM10 0.1 0.3

SO2 0.1 0.1

VOC 6.1 18.1

CO 0.2 0.9

NOX 0.7 2.9

95. The permittee shall not exceed the emission rates set forth in the following table for source SN-21. The permittee will demonstrate compliance with this condition by compliance with Specific Conditions 98 and 100 and Plantwide Condition 7. [Regulation No. §18.801 effective February 15, 1999, and A. C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]


Pollutant Lb/hr Tpy

PM 0.1 0.3

45





21 20 Regulation No. §19.503 and 40 CFR Part 52, Subpart E

97. The permittee will conduct weekly observations of the opacity from sources Source No. SN-21, and keep a record of these observations. If the permittee detects visible emissions, then the permittee shall conduct a 6-minute opacity reading in accordance with EPA Reference Method #9. The permittee must immediately take action to identify and correct the cause of the visible emissions. After implementing the corrective action, the permittee must document the source complies with the visible emissions requirements. The permittee shall maintain records of the cause of any visible emissions and the corrective action taken. The permittee must keep the records onsite and make the records available to Department personnel upon request. [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].


99. The permittee shall not use any thermal strip solution that contains any hazardous air pollutants (HAP). [Regulation No. 18 §18.1004 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

46


100. The permittee shall maintain records of a material balance to show compliance with the VOC emission limits set in Specific Condition 94. This information may be used by the Department for enforcement purposes. Compliance shall be determined on a monthly basis by completing the material balance in Appendix A or by completing the material balance using a document equivalent to that in Appendix A. The monthly record shall also include a subtotal for all annual VOC emissions for the previous 12 months. These records shall be maintained on site and shall be provided to Department personnel upon request. The monthly reports shall also be submitted to the Department per General Provision 7 by the last day of the month after the reported month.

For the purposes of these reports, a 70% collection efficiency shall be assumed for all VOC emissions from thermal strip solution and cutting solvent used in production runs which are exhausted to the catalytic incinerator. All VOC emissions from inks which are vented to the atmosphere shall be recorded at 100% of the VOC content as stated on the Material Safety Data Sheets (MSDS). [Regulation No. 19 §19.705 et seq. effective February 15, 1999, and 40 CFR Part 52, Subpart E].

47

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 SN- 10 TEC System Incinerator (Incinerator #1)

Source SN-10 is an 8500 SCFM Grace TEC System Catalytic Incinerator. VOC emissions from sources SN-02 and SN-06 are captured at a rate of 70% and routed to this incinerator for destruction.

Specific Conditions for SN-10

101. Pursuant to '19.501 et seq of the Regulations of the Arkansas State Implementation Plan for Air Pollution Control Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table for source SN-10. The pound per hour pollutant emission rates are based on the maximum capacity of the flexographic presses that are routed to this incinerator. The ton per year pollutant emission rates are effectively limited by Specific Conditions 105 and 107.

Pollutant Lb/hr Tpy PM10 0.1 0.5 SO2 0.1 0.5 VOC 2.8 7.2 CO 0.2 0.9 NOx 0.7 2.9

102. Pursuant to '18.801 of the Arkansas Air Pollution Control Code (Regulation #18) effective February 15, 1999, 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. The pound per hour pollutant emission rate is based on the maximum capacity of the flexographic presses that are routed to this incinerator. The ton per year pollutant emission rate is effectively limited by Specific Conditions 105 and 107.

Pollutant (for each source)

lb/hr Tpy

PM 0.1 0.5

103. Pursuant to '18.501 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, the permittee shall not exceed 5% opacity from source SN-10 as measured by EPA Reference Method 9. Compliance with this condition does not require any visual observations as long as the minimum combustion temperature requirement contained in Specific Condition 105 is maintained.

104. Pursuant to '19.705 of Regulation 19, A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, and 40 CFR Part 70.6, the permittee shall continuously operate SN-10 whenever the flexographic presses SN-02 or SN-06 are operating. Bypassing this control equipment when either press is running shall be considered a violation of this permit condition.

48

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 105. Pursuant to '19.705 of Regulation 19, A.C.A. '8-4-203 as referenced by A.C.A. '8-4-

304 and '8-4-311, and 40 CFR Part 70.6, the permittee shall maintain the inlet temperature of the incinerator at 600EF.

106. Pursuant to '19.703 of Regulation 19, 40 CFR Part 52 Subpart E, and A.C.A '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall continuously monitor and record once per hour or continuously (by strip chart) the inlet temperature to the incinerator to show compliance with Specific Condition 105. The permittee shall maintain these records on site and shall provide them to Department personnel upon request.

107. Pursuant to '19.702 of Regulation 19 and 40 CFR Part 52 Subpart E, the permittee shall test the destruction efficiency of this catalytic incinerator in order to show compliance with a destruction efficiency of 95%. The test shall be performed within one year from permit issuance and be conducted in accordance with Plantwide Condition 3. During this test, both printing presses shall be running solvent based inks and shall be operated within 10% of their capacity. The permittee shall give the Department written notification of the scheduled date of compliance testing at least fifteen calendar days in advance.

49


SN- 11 TEC System Incinerator (Incinerator #2)

Source SN-11 is an 11,500 SCFM Grace TEC System Catalytic Incinerator. VOC emissions from sources SN-01, SN-20, and SN-21 are captured at a rate of 70% and routed to this incinerator for destruction.

Specific Conditions for SN-11

108. Pursuant to '19.501 et seq of the Regulations of the Arkansas State Implementation Plan for Air Pollution Control Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table for source SN-11. The pound per hour pollutant emission rates are based on the maximum capacity of the equipment that is routed to this incinerator. The ton per year pollutant emission rates are effectively limited by Specific Conditions 112 and 114.

Pollutant lb/hr Tpy

PM10 0.2 0.9

SO2 0.1 0.5

VOC 18.3 36.9

CO 0.2 0.9

NOx 0.7 2.9

109. Pursuant to '18.801 of the Arkansas Air Pollution Control Code (Regulation #18) effective February 15, 1999, 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. The pound per hour pollutant emission rate is based on the maximum capacity of the equipment that is routed to this incinerator. The ton per year pollutant emission rate is effectively limited by Specific Conditions 112 and 114.

Pollutant

(for each source)

lb/hr Tpy

PM 0.2 0.9

50


110. Pursuant to '18.501 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, the permittee shall not exceed 5% opacity from source SN-11 as measured by EPA Reference Method 9. Compliance with this condition does not require any visual observations as long as the minimum combustion temperature requirement contained in Specific Condition 40 is maintained.

111. Pursuant to '19.705 of Regulation 19, A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, and 40 CFR Part 70.6, the permittee shall continuously operate SN-11 whenever the flexographic presses SN-01 or SN-20 or the laminator SN-21 are operating. Bypassing this control equipment when either press or laminator is running shall be considered a violation of this permit condition.

112. Pursuant to '19.705 of Regulation 19, A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311, and 40 CFR Part 70.6, the permittee shall maintain the inlet temperature of the incinerator at 600EF.

113. Pursuant to '19.703 of Regulation 19, 40 CFR Part 52 Subpart E, and A.C.A '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall continuously monitor and record once per hour or continuously (by strip chart) the inlet temperature to the incinerator to show compliance with Specific Condition 112. The permittee shall maintain these records on site and shall provide them to Department personnel upon request.

114. Pursuant to '19.702 of Regulation 19 and 40 CFR Part 52 Subpart E, the permittee shall test the destruction efficiency of this catalytic incinerator in order to show compliance with a destruction efficiency of 90%. The test shall be performed within two years from permit issuance and be conducted in accordance with Plantwide Condition 3. During this test, both printing presses and the laminator shall be running solvent based inks and primers and shall be operated within 10% of their capacity. The permittee shall give the Department written notification of the scheduled date of compliance testing at least fifteen calendar days in advance.

51


Section VI: COMPLIANCE PLAN AND SCHEDULE

The Bryce Company, LLC does not currently have an enforcement action. The Bryce Company, LLC will continue to operate in compliance with those identified regulatory provisions. The facility will examine and analyze future regulations that may apply and determine their applicability with any necessary action taken on a timely basis.

52

MURPHY

Insert a compliance plan and schedule if applicable


Section VII: Plant Wide Conditions

1. The permittee will notify the Director in writing within thirty (30) days after commencing construction, completing construction, first placing the equipment and/or facility in operation, and reaching the equipment and/or facility target production rate. [Regulation No. 19 '19.704, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

2. If the permittee fails to start construction within eighteen months or suspends construction for eighteen months or more, the Director may cancel all or part of this permit. [§19.410(B) of Regulation 19 and , 40 CFR Part 52, Subpart E]

3. The permittee must test any equipment scheduled for testing, unless stated in the Specific Conditions of this permit or by any federally regulated requirements, within the following time frames: (1) New Equipment or newly modified equipment within sixty (60) days of achieving the maximum production rate, but no later than 180 days after initial start-up of the permitted source or (2) operating equipment according to the time frames set forth by the Department or within 180 days of permit issuance if no date is specified. The permittee must notify the Department of the scheduled date of compliance testing at least fifteen (15) days in advance of such test. The permittee will submit the compliance test results to the Department within thirty (30) days after completing the testing. [Regulation 19 §19.702 and/or Regulation 18 §18.1002 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

4. The permittee must provide: [§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]

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.

5. The permittee must operate the equipment, control apparatus and emission monitoring equipment within the design limitations. The permittee will maintain the equipment in good condition at all times. [Regulation 19 §19.303 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

6. This permit subsumes and incorporates all previously issued air permits for this facility. [Regulation 26 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

7. The permittee shall use only natural gas as fuel for all dryers at the facility and shall not exceed the natural gas usage limit of 742,848,000 cubic feet per 12 consecutive months. [Regulation 19 §19.705 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

53

Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 8. The permittee shall not make any modifications without first modifying this permit. This

includes, but is not limited to, usage of any material containing HAPs not specifically listed in this permit. [Regulation 26 §26.10, Regulation 19 §19.2 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

Title VI Provisions

9. The permittee must comply with the standards for labeling of products using ozone depleting substances. [40 CFR Part 82, Subpart E]

a. All containers containing a class I or class II substance stored or transported, all products containing a class I substance, and all products directly manufactured with a class I substance must bear the required warning statement if it is being introduced to interstate commerce pursuant to §82.106.

b. The placement of the required warning statement must comply with the requirements pursuant to §82.108.

c. The form of the label bearing the required warning must comply with the requirements pursuant to §82.110.

d. No person may modify, remove, or interfere with the required warning statement except as described in §82.112.

10. The permittee must comply with the standards for recycling and emissions reduction, except as provided for MVACs in Subpart B. [40 CFR Part 82, Subpart F]

a. Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuant to §82.156.

b. Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to §82.158.

c. Persons performing maintenance, service repair, or disposal of appliances must be certified by an approved technician certification program pursuant to §82.161.

d. Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply with record keeping requirements pursuant to §82.166. (“MVAC-like appliance” as defined at §82.152.)

e. Persons owning commercial or industrial process refrigeration equipment must comply with leak repair requirements pursuant to §82.156.

f. Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursuant to §82.166.

11. If the permittee manufactures, transforms, destroys, imports, or exports a class I or class II substance, the permittee is subject to all requirements as specified in 40 CFR Part 82, Subpart A, Production and Consumption Controls.

12. If the permittee performs a service on motor (fleet) vehicles when this service involves ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the permittee is subject to all the applicable requirements as specified in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners.

54

MURPHY

Include this condition if the source is subject to a MACT. Delete this condition if no MACT applies.


The term Amotor vehicle@ as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed. The term AMVAC@ as used in Subpart B does not include the air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger buses using HCFC-22 refrigerant.

13. The permittee can switch from any ozone-depleting substance to any alternative listed in the Significant New Alternatives Program (SNAP) promulgated pursuant to 40 CFR Part 82, Subpart G, “Significant New Alternatives Policy Program.”

Permit Shield

14. Compliance with the conditions of this permit shall be deemed compliance with all applicable requirements, as of the date of permit issuance, included in and specifically identified in Table 7 - Applicable Regulations of this condition. The permit specifically identifies the following as applicable requirements based upon the information submitted by the permittee in an application dated September 4, 2002.

Table 44 - Applicable Regulations

Source No. Regulation Description

Facility Arkansas Regulation 19 Compilation of Regulations of the Arkansas State Implementation Plan for Air Pollution Control

Facility Arkansas Regulation 26 Regulations of the Arkansas Operating Air Permit Program.

The permit specifically identifies the following as inapplicable based upon information submitted by the permittee in an application dated September 4, 2002.

55


Table 45 - Inapplicable Regulations

Source No. Regulation Description

1 through 6, 14, 20, 23 and 24

40 CFR Part 63 Subpart KK

National Emission Standards for the Printing and Publishing Industry. The HAP emissions from the printing process are less than the major source applicability levels.

56


Section VIII: Insignificant Activities

The following sources are insignificant activities. Any activity that has a state or federal applicable requirement is a significant activity even if this activity meets the criteria of §304 of Regulation 26 or listed in the table below. Insignificant activity determinations rely upon the information submitted by the permittee in an application dated September 4, 2002.

Table 46 - Insignificant Activities

Description Category

Q.C. lab vent-a-hood A-13

Blenders for non-VOC containing plastic resin A-13

Ink Mixing Operation A-13

Ink Dump Station A-13

Welding and cutting equipment A-7

Natural gas-burning equipment with a design rate less than 1 million BTU per hour

A-1

Air conditioning and heating units used for comfort B-2

Janitorial products B-2

Lawn mowers, ground keeping activities, etc. B-13

Bathroom/toilet emissions B-9

Weed control/pest control B-13

General repairs, cleaning (buckets, pans, rollers), painting, grinding, cutting, etc.

B-14

Air compressors and pneumatically operated tools B-19

Battery and battery charging stations B-20

Storage tanks storing liquid substances containing no VOC or HAP’s

B-21

Natural gas pressure regulator vents B-27

57


Description Category

Portable hand operated brazing, soldering or welding equipment

B-28

Hand held equipment for buffing, polishing, cutting, drilling, sawing, grinding, turning or machining wood, metal or plastics.

A-13

Salt baths using non-volatile salts B-32

Ozone generators B-46

Products used to maintain motor vehicles B-56

Equipment lubricating systems B-58

Solid waste dumpsters B-63

Engine crankcase venting B-66

Roll grinding equipment B-68

Water heaters for domestic purposes B-73

Cold vat for cleaning purposes A-13

Slitting and Pack-Out A-13

Vulcanizers A-13

Bag Machine Operation A-13

Pursuant to §26.304 of Regulation 26, the Department determined the emission units, operations, or activities contained in Regulation 19, Appendix A, Group B, to be insignificant activities. Activities included in this list are allowable under this permit and need not be specifically identified.

58


Section IX:GENERAL PROVISIONS

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.[Pursuant to 40 CFR 70.6(b)(2)]

2. This permit shall be valid for a period of five (5) years beginning on the date this permit becomes effective and ending five (5) years later. [40 CFR 70.6(a)(2) and §26.701(B) of the Regulations of the Arkansas Operating Air Permit Program (Regulation 26), effective August 10, 2000]

3. The permittee must submit a complete application for permit renewal at least six (6) months before permit expiration. Permit expiration terminates the permittee’s right to operate unless the permittee submitted a complete renewal application at least six (6) months before permit expiration. If the permittee submits a complete application, the existing permit will remain in effect until the Department takes final action on the renewal application. The Department will not necessarily notify the permittee when the permit renewal application is due. [Regulation #26 §26.406]

4. Where an applicable requirement of the Clean Air Act, as amended, 42 U.S.C. 7401, et seq. (Act) is more stringent than an applicable requirement of regulations promulgated under Title IV of the Act, the permit incorporates both provisions into the permit, and the Director or the Administrator can enforce both provisions. [40 CFR 70.6(a)(1)(ii) and Regulation #26 §26.701(A)(2)]

5. The permittee must maintain the following records of monitoring information as required by this permit. [40 CFR 70.6(a)(3)(ii)(A) and Regulation #26 §26.701(C)(2)]

a. The date, place as defined in this permit, and time of sampling or measurements; b. The date(s) analyses performed; c. The company or entity performing the analyses; d. The analytical techniques or methods used; e. The results of such analyses; and f. The operating conditions existing at the time of sampling or measurement.

6. The permittee must retain the records of all required monitoring data and support information for at least 5 years from the date of the monitoring sample, measurement, report, or

59


application. Support information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. [40 CFR 70.6(a)(3)(ii)(B) and Regulation #26 §26.701(C)(2)(b)]

7. The permittee must submit reports of all required monitoring every 6 months. If the permit establishes no other reporting period, the reporting period will end on the last day of the anniversary month of this permit. The report is due within 30 days of the end of the reporting period. Even though the reports are due every six months, each report shall contain a full year of data. The report must clearly identify all instances of deviations from permit requirements. A responsible official as defined in Regulation #26 §26.2 must certify all required reports. The permittee will send the reports to the address below: [40 CFR 70.6(a)(3)(ii)(B) and §26.701(C)(2)(b)]

Arkansas Department of Environmental Quality Air Division ATTN: Compliance Inspector Supervisor Post Office Box 8913 Little Rock, AR 72219

8. The permittee will report to the Department all deviations from permit requirements, including those attributable to upset conditions as defined in the permit. The permittee will make an initial report to the Department by the next business day after the discovery of the occurrence. The initial report may be made by telephone and shall include:

a. The facility name and location b. The process unit or emission source deviating from the permit limit, c. The permit limit, including the identification of pollutants, from which deviation occurs, d. The date and time the deviation started, e. The duration of the deviation, f. The average emissions during the deviation, g. The probable cause of such deviations, h. Any corrective actions or preventive measures taken or being taken to prevent such

deviations in the future, and i. The name of the person submitting the report.

The permittee will make a full report in writing to the Department within five (5) business days of discovery of the occurrence. The report must include, in addition to the information required by the initial report, a schedule of actions taken or planned to eliminate future occurrences and/or to minimize the amount the permit’s limits were exceeded and to reduce the length of time the limits were exceeded. The permittee may submit a full report in writing (by facsimile, overnight courier, or other means) by the next business day after discovery of the occurrence, and the report will serve as both the initial report and full report. [40 CFR 70.6(a)(3)(iii)(B), Regulation #26 §26.701(C)(3)(b), Regulation #19 §19.601 and §19.602]

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Facility: The Bryce Company, LLC Permit No.: 763-AOP-R5 AFIN: 73-00110 9. If any provision of the permit or the application thereof to any person or circumstance is held

invalid, such invalidity will not affect other provisions or applications hereof which can be given effect without the invalid provision or application, and to this end, provisions of this Regulation are declared to be separable and severable. [40 CFR 70.6(a)(5) and §26.701(E) of Regulation #26, and A.C.A. §8-4-203, as referenced by §8-4-304 and §8-4-311]

10. The permittee must comply with all conditions of this Part 70 permit. Any permit noncompliance with applicable requirements as defined in Regulation #26 constitutes a violation of the Clean Air Act, as amended, 42 U.S.C. §7401, et seq. and is grounds for enforcement action; for permit termination, revocation and reissuance, for permit modification; or for denial of a permit renewal application. [40 CFR 70.6(a)(6)(i) and Regulation No. §26.701(F)(1)]

11. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity to maintain compliance with the conditions of this permit. [40 CFR 70.6(a)(6)(ii) and §26.701(F)(2)]

12. The Department may modify, revoke, reopen and reissue the permit or terminate the permit for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition. [40 CFR 70.6(a)(6)(iii) and Regulation #26 §26.701(F)(3)]

13. This permit does not convey any property rights of any sort, or any exclusive privilege. [40 CFR 70.6(a)(6)(iv) and Regulation #26 §26.701(F)(4)]

14. The permittee must furnish to the Director, within the time specified by the Director, any information that the Director may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the permittee must also furnish to the Director copies of records required by the permit. For information the permittee claims confidentiality, the Department may require the permittee to furnish such records directly to the Director along with a claim of confidentiality. [40 CFR 70.6(a)(6)(v) and Regulation #26 §26.701(F)(5)]

15. The permittee must pay all permit fees in accordance with the procedures established in Regulation #19. [40 CFR 70.6(a)(7) and Regulation #26 §26.701(G)]

16. No permit revision shall be required, under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes provided for elsewhere in this permit. [40 CFR 70.6(a)(8) and Regulation #26 §26.701(H)]

17. If the permit allows different operating scenarios, the permittee will, contemporaneously with making a change from one operating scenario to another, record in a log at the permitted

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facility a record of the operational scenario. [40 CFR 70.6(a)(9)(i) and Regulation #26 §26.701(I)(1)]

18. The Administrator and citizens may enforce under the Act all terms and conditions in this permit, including any provisions designed to limit a source’s potential to emit, unless the Department specifically designates terms and conditions of the permit as being federally unenforceable under the Act or under any of its applicable requirements. [40 CFR 70.6(b) and Regulation #26 §26.702(A) and (B)]

19. Any document (including reports) required by this permit must contain a certification by a responsible official as defined in Regulation #26 §26.2. [40 CFR 70.6(c)(1) and Regulation #26 §26.703(A)]

20. The permittee must allow an authorized representative of the Department, upon presentation of credentials, to perform the following: [40 CFR 70.6(c)(2) and Regulation #26 §26.703(B)]

a. Enter upon the permittee’s premises where the permitted source is located or emissions-related activity is conducted, or where records must be kept under the conditions of this permit;

b. Have access to and copy, at reasonable times, any records required under the conditions of this permit;

c. Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit; and

d. As authorized by the Act, sample or monitor at reasonable times substances or parameters for assuring compliance with this permit or applicable requirements.

21. The permittee will submit a compliance certification with the terms and conditions contained in the permit, including emission limitations, standards, or work practices. The permittee will submit the compliance certification annually. The permittee must also submit the compliance certification to the Administrator as well as to the Department. All compliance certifications required by this permit must include the following: [40 CFR 70.6(c)(5) and Regulation #26 §26.703(E)(3)]

a. The identification of each term or condition of the permit that is the basis of the certification;

b. The compliance status; c. Whether compliance was continuous or intermittent; d. The method(s) used for determining the compliance status of the source, currently and

over the reporting period established by the monitoring requirements of this permit; and e. Such other facts as the Department may require elsewhere in this permit or by §114(a)(3)

and §504(b) of the Act.

22. Nothing in this permit will alter or affect the following: [Regulation #26 §26.704(C)]

a. The provisions of Section 303 of the Act (emergency orders), including the authority of

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the Administrator under that section; b. The liability of the permittee for any violation of applicable requirements prior to or at

the time of permit issuance; c. The applicable requirements of the acid rain program, consistent with §408(a) of the Act

or, d. The ability of EPA to obtain information from a source pursuant to §114 of the Act.

23. This permit authorizes only those pollutant-emitting activities addressed in this permit. [A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

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APPENDIX A

Monthly VOC Inventory for the Month of __________ Year ________ SN-__________

1 2 3 4 5* 6 7 8 9*

Material MSDS # MaterialDensity (lb/gal)

Weight Percent Volatile

VOC Content (lb/gal)

Amount Used (gal)

Capture Efficiency (fraction)

Destruction Efficiency (fraction)

VOC Emissions (lb)

*Note: Col 5 = (Col 3 x Col 4). Col 9 = [Col 5 x Col 6] {uncontrolled sources (SN-07, 08, 09, & 22)}

Col 9 = [Col 5 x Col 6 x (1.0 - Col 7)] {partially controlled sources (SN-02, 03, 04, 05, 06, 13 & 21)} Col 9 = [Col 5 x Col 6 x (1.0 - Col 8)] {100% capture with 95% efficient incinerators (SN-01,20 & 31; 23, 24, 28, 29 &25)}

Calculate: Total VOC Emissions (tpy)=[Sum of Column 9 (lb/year)] * [(1 ton)/(2000 lb)] =


Request for PDS Invoice Invoice Number (assigned when invoice printed)

PDS-

AFIN r 73-00110 Name (for confirmation only)

The Bryce Company, LLC

Initial Mod Variance Invoice Type (pick one) r Annual Renewal X Interim

Authority

Permit Number r 763-AOP-R5 Media Code r A Fee Code or Pmt Type r T5 Fee Description (for confirmation only)

Title V

Amount Due r (whole dollar amount only)

$500

Printed Comment(600 characters maximum)

Included Minor Modification

Note: The information below is for use by the requesting division if desired; it will not print on the invoice. Engineer Melisha Griffin Paid? (yes/no) Check number Comments r Required data (See “g:\Misc\PDS_FeeCodes.wpd” for descriptions and discussions of fee codes) Request submitted by: Date:

2


3

Public Notice

Pursuant to the Arkansas Operating Air Permit Program (Regulation #26) Section 602, the Air Division of the Arkansas Department of Environmental Quality gives the following notice:

The Bryce Company, LLC (AFIN# 73-00110, Permit# 763-AOP-R5) owns and operates a flexible packaging manufacturing facility located at 450 South Benton Street in Searcy, Arkansas. The facility submitted a request for a renewal of the existing Title V Air Operating permit. Byrce also requested a Minor Modification to the existing permit. The modification includes the installation of a solvent recovery system to lower solvent generated by the facility. The facility is replacing incinerators SN-10 and SN-11 with new incinerators, SN-32 and SN-31, respectively. The facility would also revise the permit to reflect that SN-01 and SN-20 are located within a total enclosure due to changes that were made after issuance of the original Title V permit and therefore are requesting a lower emission limit for these units. The facility requested to increase the maximum VOC content in the inks to 90% with no increase in the ton per year of VOC emissions.

The staff of the Department reviewed the application, and the application received the Department’s tentative approval subject to the terms of this notice. Citizens wishing to examine the permit application and staff findings and recommendations may do so by contacting Doug Szenher, Public Affairs Supervisor. Citizens desiring technical information concerning the application or permit should contact Melisha Griffin, Engineer. Citizens can reach both Doug Szenher and Melisha Griffin at the Department’s central office, 8001 National Drive, Little Rock, Arkansas 72209, telephone: (501) 682-0744.

The draft permit and permit application are available for copying at the above address. The White County Public Library at 113 E. Pleasure Ave. in Searcy, Arkansas 72143 has a copy of the draft permit. Citizens may review this information during normal business hours. Interested or affected persons may also submit written comments or request a hearing on the proposal or the proposed modification, to the Department at the above address - Attention: Doug Szenher. For the Department to consider the comment, the interested or affected persons must submit written comments within thirty (30) days of publication of this notice. Although the Department is not proposing to conduct a public hearing, the Department will schedule and hold a hearing if the Department receives significant comments on the permit provisions. If the Department schedules a hearing, the Department will give adequate public notice in the newspaper of largest circulation in the county in which the facility in question is, or will be, located.

The Director will make a final decision to issue or deny this application or to impose special conditions in accordance with Section 2.1 of the Arkansas Pollution Control and Ecology Commission=s Administrative Procedures (Regulation #8) and Regulation #26.

Dated this


4

Marcus C. Devine Director

adeq operating air permit · 2019-12-30 · performance for volatile organic liquid storage vessels...

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