adeq operating air permit · the gates rubber company permit #: 378-aop-r3 csn #: 04-0111...

ADEQ OPERATING AIR PERMIT Pursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation #26: Permit #: 378-AOP-R3 IS ISSUED TO: The Gates Rubber Company 1801 North Lincoln

Siloam Springs, AR 72761 Benton County

CSN: 04-0111 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: August 8, 2000 and August 7, 2005 AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Keith A. Michaels Date Modified

SECTION I: FACILITY INFORMATION

PERMITTEE: The Gates Rubber Company

CSN: 04-0111

PERMIT NUMBER: 378-AOP-R3

FACILITY ADDRESS: 1801 North Lincoln Siloam Springs, AR 72761

COUNTY: Benton

CONTACT POSITION: Environmental Coordinator - David Stever

TELEPHONE NUMBER: (479) 524-1236

FAX NUMBER: (479) 524-6394

REVIEWING ENGINEER: Paul Osmon

UTM North-South (X): 4006.8 km N

UTM East-West (Y): 363.2 km E

Zone 15

2

The Gates Rubber Company Permit #: 378-AOP-R3 CSN #: 04-0111

SECTION II: INTRODUCTION

Summary of Permit Activity Gates Rubber Company of 1801 North Lincoln Street, Siloam Springs, Benton County, Arkansas manufactures rubber belts. This permit has been modified to add five (5) vulcanizers to SN-09 - Rubber Autoclave Cure. It is a minor modification to Permit #378-AOP-R3. Rubber throughput through the Rubber Autoclave Cure will increase 3 percent with a corresponding increase in emissions from that emission source.

Process Description Cord used within the belts is manufactured in the Cord Treater area. In this process, stock synthetic cord is coated with several cement and latex coatings. Stock rubber is brought into the plant from outside sources, where it is mechanically and thermally treated to form thin layers of rubber sheeting. The sheeting, along with treated cord, is applied to a lathe type belt builder where an uncured rubber cylinder slab is produced. The rubber slab is transformed into power transmission belts following either a ABandless@ or a ABanded@ process. In the Bandless process, the slab is cured thermally as a complete unit within an autoclave type of device. Once cured, individual belts are machine cut from the slab and finished through grinding of the belt as per end use specifications. In the Banded process, the slab is cut into individual belts, with thin sheets of rubber wrapped around the belt prior to the curing process. Belt curing is completed either within an autoclave unit or through a step wise press curing process.

3


Regulations Gates Rubber Company is subject to regulation under the Arkansas Air Pollution Control Code (Regulation #18), the Regulations of the Arkansas Plan of Implementation for Air Pollution Control (Regulation #19), and the Regulations of the Arkansas Operating Air Permit Program (Regulation #26). The boilers at the facility are not subject to 40 CFR 60, Subpart Dc-Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units because the boilers were constructed prior to the applicability date and have not been modified or reconstructed since that date. The toluene storage tank is not subject to 40 CFR 60, Subpart K, Ka, or Kb because its capacity is smaller than the affected tank size. The cord treating operation is not subject to 40 CFR 60, Subpart VVV-Standards of Performance for Polymeric Coating of Supporting Substrates Facilities because the operation was constructed prior to that applicability date and has not been modified or constructed since that date. The following table is a summary of emissions from the facility. Specific conditions and emissions for each source can be found starting on the page cross referenced in the table. This table, in itself, is not an enforceable condition of the permit.

EMISSION SUMMARY

Emission Rates

SN

Description

Pollutant

lb/hr

tpy

Cross

ReferencePage

Total Allowable Emissions

HAPS*

PM

PM10 SO2

VOC CO NOx

Toluene* Carbon Disulfide

Tetrachloroethene* 2-Chloro-1,3-Butadiene*

73.9 73.9 43.1 154.73.5 13.7

119.0213.801.02 0.20 0.41

50.7 50.7 31.1 227.1 14.4 56.4

178.63 8.61 0.63 0.36 0.26

---

4


5

EMISSION SUMMARY

Emission

Rates

SN

Description

Pollutant

lb/hr

tpy

Cross

ReferencePage

bis(2-Ethylhexyl)phthalate

* Methylene Chloride

Hexane* Propylene Oxide*

1,3-Butadiene* Acetophenone* Acetaldehyde*

Nickel Phenol* Xylenes*

Carbonyl Sulfide Acrolein*

2-Butanone* Naphthalene*

Di-n-butyl phthalate*Chromium Methanol*

MDI Formaldehyde*

4-Methyl-2-Pentanone* Benzene* Cumene* Isooctane*

Ethyl Benzene* Aniline*

1,1,1-Trichloroethane*

o-Toluidine* Styrene* Carbon

Tetrachloride* Chloro methane*

11.913.03 0.21 0.20 3.09 0.12 0.01 0.09 0.41 1.59 0.06 0.27 0.06 0.04 0.03 0.98 7.47 2.30 0.93 0.12 0.08 0.07 0.05 0.03 0.16 0.03 0.01 0.01 0.01 0.01 0.39

7.43 11.21 0.14 0.13 1.94 0.06 0.04 0.05 0.25 1.01 0.03 0.17 0.05 0.04 0.03 0.60 20.62 0.60 0.58 0.07 0.05 0.04 0.03 0.02 0.09 0.02 0.01 0.01 0.01 0.01 0.20


EMISSION SUMMARY

Emission Rates

SN

Description

Pollutant

lb/hr

tpy

Cross

ReferencePage

Biphenyl* Chloroprene*

01

Boiler #1 (burning natural gas)

PM

PM10 SO2 VOC CO NOx

0.6 0.6 0.1 0.2 1.5 5.8

2.5 2.5 0.1 0.5 6.3 25.0

16

02

Boiler #2 (burning natural gas)

PM

PM10 SO2 VOC CO NOx

0.6 0.6 0.1 0.2 1.5 5.8

2.5 2.5 0.1 0.5 6.3 25.0

16

Boiler #1 and #2 (burning fuel oil)

PM

PM10 SO2 VOC CO NOx

---

1.0 1.0 31.0 0.2 2.2 8.8

16

01

Boiler #1 (burning fuel oil)

PM

PM10 SO2 VOC CO NOx

0.6 0.6 21.5 0.1 1.5 6.1

---

16

02

Boiler #2 (burning fuel oil)

PM

PM10 SO2 VOC CO NOx

0.6 0.6 21.5 0.1 1.5 6.1

---

16

6


EMISSION SUMMARY

Emission Rates

SN

Description

Pollutant

lb/hr

tpy

Cross

ReferencePage

03 Pre-Dip Hold Tank

VOC MDI

Toluene

16** 1.20**16.0**

8.8 0.66 8.76

19

04

Cement House Non-Point Source Emissions

VOC MDI

Toluene

52.6**0.16**52.56*

*

14.2 0.01 14.20

18

05

Latex Area Mix Vent

VOC

Formaldehyde Methanol

10.8**7.2** 3.6**

0.4 0.03 0.30

21

**The lb/ r emissions are actually lb/batch. h

06 Cord Treater Emissions

PM

PM10 SO2 VOC CO NOx

Formaldehyde Methanol

Chloroprene Toluene

MDI

0.2 0.2 0.1 98.8 0.5 1.5 1.70 0.68 0.39 88.73 7.22

0.6 0.6 0.1

156.5 1.8 6.4 0.80 0.30 0.20

135.09 19.95

23

07

Toluene Storage Tank

VOC

Toluene

8.2 8.2

0.1 0.1

26

08

Belt Builder Non-Point Source Emissions

VOC

Hexane Toluene

5.8 2.5 3.3

25.3 10.89 14.33

27

09

Rubber Autoclave Cure

VOC

Carbon Disulfide Acetophenone

Methylene Chloride Carbonyl Sulfide

13.9 8.90 2.92 2.44 1.24

8.9 5.57 1.82 1.52 0.77

29

7


EMISSION SUMMARY

Emission Rates

SN

Description

Pollutant

lb/hr

tpy

Cross

ReferencePage

4-Methyl-2-PentanoneToluene Xylene

2-Butanone Hexane Benzene Cumene

Isooctane Ethyl benzene

Aniline Phenol

Naphthalene 1,1,1-Trichloroethane

1,3-Butadiene Tetrachloroethene

o-Toluidine bis(2-

Ethylhexyl)phthalate Styrene Nickel

Di-n-butyl phthalate Carbon Tetrachloride

Chloro methane Biphenyl

0.83 0.29 0.31 0.21 0.20 0.12 0.08 0.07 0.05 0.03 0.03 0.03 0.02 0.02 0.02 0.02 0.01 0.01 0.01 0.01 0.01 0.01 0.01

0.52 0.18 0.19 0.13 0.12 0.07 0.05 0.04 0.03 0.02 0.02 0.02 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

10

Rubber Step Cure

VOC

Methylene Chloride Carbon Disulfide Carbonyl Sulfide

1,1,1-Trichloroethane 4-Methyl-2-Pentanone

Acetophenone Hexane Toluene

2-Butanone

4.2 9.11 1.64 0.29 0.14 0.10 0.05 0.03 0.03 0.02

2.7 5.69 1.02 0.18 0.08 0.06 0.03 0.02 0.02 0.01

31

8


EMISSION SUMMARY

Emission Rates

SN

Description

Pollutant

lb/hr

tpy

Cross

ReferencePage


o-Toluidine Xylene

0.02 0.01 0.01

0.01 0.01 0.01

SNs 11-13

PM

PM10 VOC

Toluene Carbon Disulfide Tetrachloroethene

2-Chloro-1,3-Butadiene

bis(2-Ethylhexyl)phthalate Methylene Chloride

Hexane Propylene Oxide

1,3-Butadiene Acetophenone Acetaldehyde

Nickel Phenol Xylene

Carbonyl Sulfide Acrolein

2-Butanone Naphthalene

Di-n-butyl phthalate Chromium

---

45.6 45.6 9.6 6.05 1.35 0.62 0.36 0.24 0.22 0.18 0.14 0.12 0.09 0.06 0.03 0.03 0.05 0.03 0.03 0.03 0.03 0.03 0.03

33

11

Belt Grinders

PM

PM10 VOC

Toluene Carbon Disulfide

24.5 24.5 4.4 3.15 0.71

---

33

9


EMISSION SUMMARY

Emission Rates

SN

Description

Pollutant

lb/hr

tpy

Cross

ReferencePage

Tetrachloroethene 2-Chloro-1,3-

Butadiene bis(2-

Ethylhexyl)phthalate Methylene Chloride







0.33 0.19 0.12 0.12 0.10 0.07 0.06 0.04 0.04 0.02 0.02 0.03 0.02 0.02 0.02 0.01 0.01 0.01

12

Belt Grinders

PM

PM10 VOC





1,3-Butadiene

23.4 23.4 5.0 3.15 0.71 0.33 0.19 0.12 0.12 0.10 0.07 0.06 0.04 0.04

---

33

10


EMISSION SUMMARY

Emission Rates

SN

Description

Pollutant

lb/hr

tpy

Cross

ReferencePage

Acetophenone Acetaldehyde





0.02 0.02 0.03 0.02 0.02 0.01 0.01 0.01 0.01

13

Belt Grinders

PM

PM10 VOC









24.6 24.6 5.3 3.30 0.74 0.34 0.20 0.13 0.12 0.10 0.07 0.06 0.04 0.04 0.02 0.02 0.03 0.02 0.02 0.02 0.01 0.01 0.01

----

33

11


EMISSION SUMMARY

Emission Rates

SN

Description

Pollutant

lb/hr

tpy

Cross

ReferencePage


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

12


SECTION III: PERMIT HISTORY Permit #378-A was the initial air permit for Gates Rubber Company. It was issued November 19, 1976, to allow the facility to build the plant in order to produce heavy duty and bandless AV@ belts. At that time, the facility permitted a gas fired boiler, cement mixing house exhaust, and a cord treating unit/catalytic incinerator. Non-specified emissions were permitted at 1 lb/hr. Nitrogen oxide emissions were limited to 5.0 lb/hr. Permit #378-AR-1 was issued September 9, 1978, to allow the facility to construct a second gas fired boiler. The boiler was permitted to burn natural gas and use #6 fuel oil as a backup. Permit #378-AR-2 was issued April 8, 1985, to permit a dust capture system and baghouse. The baghouse had been installed in 1984. All sources were assigned a 5% opacity limit. VOC was permitted at 0.2 lb/hr, hydrocarbons at 4.3 lb/hr, and particulate matter to 0.01 lb/hr. The two boilers were each limited at 40,800 ft3/hr maximum natural gas input. Permit #378-AR-3 was issued January 1, 1986, to permit 18 rubber grinders. Six control systems consisting of a cyclone separator and an electrostatic precipitator with prefilters were to be installed to collect the particulate. VOC was permitted at 4.5 lb/hr and particulate was permitted at 0.11 lb/hr. The two boilers were each limited at 40,800 ft3/hr maximum natural gas input. All sources had a 5% opacity limit. Permit #378-AR-4 was issued February 13, 1987, to permit the use of #6 fuel oil in the boilers with natural gas to be allowed as an alternate. The use of the boilers was limited by operating times, the use of 1% sulfur fuel, and emission limit of 100 tons of SO2 per year. The other permitted emissions remained the same. Opacity was changed to 10%. Permit #378-AR-5 was issued November 15, 1988, to permit the installation of 6 additional belt grinders. A cyclone and electrostatic precipitator with prefilters were installed to control particulate from the grinders. The permit was also revised to clarify emission limits and reporting requirements for the boilers. PM was permitted at 5.92 lb/hr, SO2 at 75.8 lb/hr, VOC at 4.5 lb/hr and NOX at 26.2 lb/hr. Permit #378-AR-6 was issued February 9, 1989, to permit the installation of 6 additional belt grinders. A cyclone and electrostatic precipitator with prefilters were installed to control particulate from the grinders. The testing method for fuel oil was revised. PM was permitted at 5.83 lb/hr, SO2 at 75.8 lb/hr, VOC at 4.5 lb/hr and NOX at 26.2 lb/hr. Permit #378-AR-7 was issued on June 29, 1990, to increase the number of belt grinders from 24 to 45. The allowable particulate emissions from the grinders was permitted at 0.7 tpy. No other emission changes were made.

13

The Gates Rubber Company Permit #: 378-AOP-R3 CSN #: 04-0111 Permit #378-AR-8 was issued on November 19, 1991, to permit the installation of 21 additional grinders and a latex mix tank. The permitted emissions from the facility were: particulate, 30.48 tpy; SO2, 3.64 tpy; NOX, 124.86 tpy; CO, 12.48 tpy; and VOC, 24.39 tpy.

Permit #378-AR-9 was issued on April 9, 1992, to allow the installation of three new grinders. The permitted emissions from the facility were: particulate, 30.49 tpy; SO2, 3.64 tpy; NOX, 124.86 tpy; CO, 12.48 tpy; and VOC, 24.39 tpy. Permit #378-AR-10 was issued on April 7, 1994, to permit fugitives and other previously unpermitted emissions at the facility. The permitted emissions from the facility were: PM, 26.58 tpy; SO2, 90.0 tpy; NOX, 88.40 tpy; CO, 12.20 tpy; other VOC, 1.96 tpy; Toluene, 45.30 tpy; Methanol, 0.02 tpy; MDI, 0.10 tpy; Formaldehyde, 0.03 tpy, and Hexane 11.40 tpy. Permit #378-AOP-R0 was issued on August 8, 2000, as the first operating permit for this facility as per the requirements of Regulation #26 (Title V) and the Clean Air Act. The facility is a major Title V source for both volatile organic compounds (VOCs) and hazardous air pollutants (HAPs). Under this permit, the facility increased throughput which increased production. Permit #378-AOP-R1 was issued August 27, 2001. It allowed the facility to increase the allowable throughput at the storage tank (SN-07) to 176,256 gallons of toluene. This increase debottlenecked the processes at SNs 03, 04 and 06; however, this higher throughput had already been permitted at SNs 03, 04 and 06, so there was no permitted increase at these sources. Also included in this modification was a minor modification which allowed the facility to move 2 belt grinders from SN-11 to SN-13. Additionally, Specific Condition numbers 49 and 50 of the previous permit were deleted because they were unnecessary for compliance demonstration. The total permitted increase in emissions at this facility due to the modifications was negligible. Permit No. 378-AOP-R2 was issued on November 8, 2001. This permit was modified to add one grinder to SN-13, Bubble Belt Grinders. The total permitted increase in emissions at this facility due to the modification was negligible.

SECTION IV: EMISSION UNIT INFORMATION

14


SNs 01, 02 Boiler=s #1 and #2

Source Description Boilers #1 and #2 are used to provide steam for thermal treatment in the rubber calendaring and belt curing processes. Boiler #1 (SN-01) is a 40.8 MMBTU/hr boiler. It was installed in1975 and brought on line in 1977. Boiler #2 (SN-02) is a 40.8 MMBtu/hr boiler. It was installed in 1978. They are both fueled by natural gas, but use fuel oil in the alternate operating scenario.

Specific Conditions

1. Pursuant to '19.501 of Regulation 19 et seq, and 40 CFR Part 52, Subpart E, this source shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the fuel limitations of this section.

15

SN

Pollutant

lb/hr

tpy

PM10

0.6

2.5

SO2

0.1

0.1

VOC

0.2

0.5

CO

1.5

6.3

01

NOX

5.8

25.0

PM10

0.6

2.5

SO2

0.1

0.1

VOC

0.2

0.5

CO

1.5

6.3

02

NOX

5.8

25.0

PM10

1.0

SO2

31.0

VOC

0.2

CO

2.2

01 and 02 (alternate scenario)

NOX

---

8.8

PM10

0.6

01

---


SN

Pollutant

lb/hr

tpy SO2 21.5

VOC

0.1

CO

1.5

(alternate scenario)

NOX

6.1

PM10

0.6

SO2

21.5

VOC

0.1

CO

1.5

02

(alternate scenario)

NOX

6.1

---

2. Pursuant to '18.501 of Regulation 18, and A.C.A. '8-4-203 as referenced by '8-4-304

and '8-4-311, the facility shall not exceed 5% opacity from this source while burning natural gas and 10% for fuel oil.

3. Pursuant to '19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, weekly

observations of the opacity from this source shall be conducted by personnel familiar with the facility=s visible emissions. The facility shall maintain personnel trained, but not necessarily certified, in EPA Reference Method 9. If visible emissions which appear to be in excess of the permitted opacity are detected, the facility shall immediately take action to identify the cause of the visible emissions, implement corrective action, and document that visible emissions did not appear to be in excess of the permitted opacity following the corrective action. The facility shall maintain records which contain the following items in order to demonstrate compliance with this specific condition. These records shall be updated weekly, kept on site, and made available to Department personnel upon request.

A. The date and time of the observation. B. If visible emissions which appeared to be above the permitted level were detected. C. If visible emissions which appeared to be above the permitted limit were detected, the

cause of the exceedance of the opacity limit, the corrective action taken, and if the visible emissions appeared to be below the permitted limit after the corrective action was taken.

D. The name of the person conducting the opacity observations. 16

The Gates Rubber Company Permit #: 378-AOP-R3 CSN #: 04-0111 4. 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 70.6, the boilers shall be fueled only by #2 fuel oil (0.5% sulfur) or natural gas.

5. 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 70.6, the throughput of #2 fuel oil shall be limited to 869,760 gallons per year.

6. Pursuant to '19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, records for the

sulfur content and annual fuel oil throughput shall be maintained on a twelve month rolling basis, updated monthly. Such records shall be submitted to the Department in accordance with General Condition #7.

17


SN-03, SN-04 Pre-Dip Hold Tanks, Cement House Non-Point Source Emissions

Source Description Pre-Dip (SN-03) is the toluene/isocyanate mixture used as the first dip when coating cords. The material is mixed on a batch basis and passes to the Pre-Dip holding tanks where it is pressurized with nitrogen and passed to the cord treater. A maximum of three batches of Pre-Dip is mixed per 24 hour period. Before the holding tanks are refilled, the tanks are vented for a ten minute period for a maximum of two times per 24 hour period. The short term emission rates are limited by the number of batches per day and ton per year emissions are limited by the amount of material that can be processed in the cord treater. SN-03 was installed in 1977. SN-04 is the non-point source emissions from mixing and dispensing Pre-Dip and Cement Compound in the Cement House. Cement Compound is a toluene and rubber stock mixture. Cement Compound is mixed on a batch basis in the Cement Mix tank and then dispensed into 150 gallon totes for use in the cord treater and belt building areas. Two batches of Cement Compound is mixed per day. SN-04 was constructed in 1977.

Specific Conditions 7. Pursuant to '19.501 of Regulation 19 et seq, and 40 CFR Part 52, Subpart E, this source

shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the pre-dip batch limits.

SN

Pollutant

lb/batch

tpy

03

VOC

16

8.8

04

VOC

52.6

14.2


and '8-4-311, this source shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the pre-dip batch limits.

18


SN

Pollutant lb/batch

tpy

MDI

1.20

0.66

03

Toluene

16.0

8.76

MDI

0.16

0.01

04

Toluene

52.56

14.20


'8-4-311, and 40 CFR 70.6, the facility is limited to producing three batches of pre-dip per day.

10. Pursuant to '19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the number of

batches per day shall be maintained on a daily basis, updated monthly, to be completed by the 15th day of the following month. Such records shall be submitted to the Department in accordance with General Condition #7.

19


SN-05 Latex Area Mix Vent

Source Description In this area, various components are mixed and water diluted in order to make latex used to coat cord. The initial mixing of formaldehyde mixture, sodium hydroxide, and resorcinol is a batch process. This material is reacted in the resin mix tank for approximately eight hours. Once reacted, the vessel is vented to the atmosphere. Liquids from the Resin Mix Tank are drained to two separate mix tanks where they are diluted with latex, dye, water, and mixed with Aquamix. The liquid is then pumped to another two tanks to be diluted with water to reach the product specification for use with the Cord Treater. In addition to the manufacture of latex, two lubes are mixed on a batch basis for use in the step cure and banded builder processes. These drums are then transferred to holding tanks in the banding and building sections of the facility for use. This source was installed in 1997.


shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the latex batch limits.

SN

Pollutant

lb/batch

tpy

05

VOC

10.8

0.4


and '8-4-311, compliance with these limits shall be demonstrated by compliance with the latex batch limits.

SN

Pollutant

lb/batch

tpy

Formaldehyd

e

7.2

0.03

05

Methanol

3.6

0.30

20



'8-4-311, and 40 CFR 70.6, the facility is limited to producing two batches of latex per day.

14. Pursuant to '19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the number of

batches per day shall be maintained on a daily basis, updated weekly. Such records shall be submitted to the Department in accordance with General Condition #7.

21


SN-06 Cord Treater Emissions

Source Description Within the Cord Treater area, synthetic cord procured from off-site is coated with various dips to form the treated cord material used within the belts. Synthetic cord is run through the pre-dip mixture and through the first zone of an oven to dry the cord coating. The cord then traverses through the latex mixture, through the second oven zone, through a second latex mixture dip, through a third oven zone and finally through the cement mixture before the cord is spooled for use in the belt building process. Emissions from Zones 1 and 4 of this source are controlled by a catalytic incinerator with a pre-burner and process blower. The overall control efficiency of the control equipment used for the calculations in the permit is 81% (90% capture and 90% efficiency). This equipment is fueled by natural gas. This source was installed in 1977.


shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the VOC recordkeeping, testing and monitoring requirements of the catalytic oxidizer, operating requirements of the catalytic incinerator and cord treater and the pre-dip limit of Specific Condition #9.

SN

Pollutant

lb/hr

tpy

PM10

0.2

0.6

SO2

0.1

0.1

VOC

98.8

156.5

CO

0.5

1.8

06

NOX

1.5

6.4


and '8-4-311, this source shall not exceed the emission rates set forth in the following

22


table. Compliance with these limits shall be demonstrated by compliance with the HAP recordkeeping, testing and monitoring requirements of the catalytic incinerator, operating requirements of the catalytic oxidizer and cord treater and the pre-dip limit of Specific Condition #9.

SN

Pollutant

lb/hr

tpy

Formaldehyd

e

1.70

0.80

Methanol

0.68

0.30

Chloroprene

0.39

0.20

Toluene

88.73

135.09

06

MDI

7.22

19.95


and '8-4-311, the facility shall not exceed 5% opacity from this source. Compliance shall be demonstrated by burning only natural gas.

18. Pursuant to '19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, records of the

monthly VOC emissions shall be recorded in the format of Table A in Appendix A. 19. Pursuant to '19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the VOC emission

rate tables shall be maintained on a twelve month rolling total, updated monthly. Such records shall be submitted to the Department in accordance with General Condition #7.


and '8-4-311, records of the monthly HAP emissions shall be recorded in the format of Table B in Appendix B.


and '8-4-311, the HAP emission rate tables shall be maintained on a twelve month rolling average, updated monthly. Such records shall be submitted to the Department in accordance with General Condition #7.

22. Pursuant to '19.702 of Regulation 19, and 40 CFR Part 52, Subpart E, the facility shall

test the catalytic oxidizer for VOC using EPA Reference Method 25A. The facility shall continue to test on the schedule that was initiated in Permit #378-AOP-R0. From these tests, a control efficiency shall be determined for the incinerator. A written report of the

23


results of the completed tests shall be furnished to the Department at the following address.

Arkansas Department of Environmental Quality Air Division ATTN.: Air Enforcement Post Office Box 8913 Little Rock, AR 72219

Testing for the catalytic incinerator shall be completed and reported every 5 years.

23. 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 operating range of the outlet gas temperature of the catalytic incinerator is to be determined during the compliance test. The outlet gas temperature must stay within this range during normal operation of the unit.


'8-4-311, and 40 CFR 70.6, the facility shall continuously monitor and record the combustion temperature of the catalytic incinerator while it is operating. During periods of maintenance on, or failure of, the continuous monitoring equipment, the facility shall manually measure and record the outlet temperature of the catalytic incinerator once per hour.


catalytic incinerator outlet temperature shall be kept on site and shall be submitted to the Department in accordance with General Condition #7.

26. 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 catalytic incinerator shall be kept in good working order, and shall be used whenever Zones 1 and 4 are being operated. The cord treater shall not be used when there is any equipment failure or shutdowns for maintenance on the catalytic incinerator. The facility shall report any equipment problems on the catalytic incinerator to ADEQ in accordance with ' 19.601.

24


SN-07 Toluene Storage Tank

Source Description This source is a 10,000 gallon tank that stores toluene for the mix dips, cements, and other bulk materials. It was installed in 1995.


shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the toluene limit of this section.

SN

Pollutant

lb/hr

tpy

07

VOC

8.2

0.1


and '8-4-311, this source shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the toluene limits of this section.

SN

Pollutant

lb/hr

tpy

07

Toluene

8.2

0.1


'8-4-311, and 40 CFR 70.6, the annual throughput of toluene at this source shall be limited to 176,256 gallons.

30. Pursuant to '19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the toluene

throughput amount shall be maintained on a twelve month rolling total, updated monthly. Such records shall be submitted to the Department in accordance with General Condition #7.

25


SN-08 Belt Builder Non-Point Source Emissions

Source Description A lathe (builder) is used to build the belts at the facility. Layers of calendar stock and treated cord are built-up on the builder to form a belt slab. Tackifiers, consisting of a mixture of toluene and hexane are applied between the different layers as needed. This source was installed in 1977.


shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the VOC recordkeeping of this section.

SN

Pollutant

lb/hr

tpy

08

VOC

5.8

25.3


and '8-4-311, this source shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the HAP recordkeeping of this section.

SN

Pollutant

lb/hr

tpy

Hexane

2.50

10.89

08

Toluene

3.30

14.33


monthly VOC emissions shall be recorded in the format of Table A in Appendix A. 34. Pursuant to '19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the VOC emission

rate tables shall be maintained on a twelve month rolling total, updated monthly. Such records shall be submitted to the Department in accordance with General Condition #7.

26



and '8-4-311, records of the monthly HAP emissions shall be recorded in the format of Table B in Appendix B.


and '8-4-311, the HAP emission rate tables shall be maintained on a twelve month rolling average, updated monthly. Such records shall be submitted to the Department in accordance with General Condition #7.

27


SN-09 Rubber Autoclave Cure

Source Description The kettle autoclaves may cure either complete slab stock directly from the builder (Bandless Belts) or the stock may be cut prior to placement on rings and then cured with autoclaves (Banded Belts). There are five (5) vulcanizers installed in the rubber autoclave cure. In the autoclave process, heat is applied via steam injection under pressure to cure the rubber to the proper consistency. During the curing process, certain volatile components of the rubber used to manufacture the belt are driven off as non-point source emissions. This source was installed in 1977.


shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the rubber limit of this section.

SN

Pollutant

lb/hr

tpy

09

VOC

13.9

8.9


and '8-4-311, this source shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the rubber limit of this section.

28

SN

Pollutant

lb/hr

tpy

Carbon Disulfide

8.90

5.57

Acetophenone

2.92

1.82

Methylene Chloride

2.44

1.52

Carbonyl Sulfide

1.24

0.77

4-Methyl-2-Pentanone

0.83

0.52

Toluene

0.29

0.18

09


SN

Pollutant

lb/hr

tpy Xylenes 0.31 0.19

2-Butanone

0.21

0.13

Hexane

0.20

0.12

Benzene

0.12

0.07

Cumene

0.08

0.05

Isooctane

0.07

0.04

Ethyl benzene

0.05

0.03

Aniline

0.03

0.02

Phenol

0.03

0.02

Naphthalene

0.03

0.02

1,1,1,-Trichloroethane

0.02

0.01

1,3-Butadiene

0.02

0.01

Tetrachloroethene

0.02

0.01

o-Toluidine

0.02

0.01

bis(2-

Ethylhexyl)phthalate

0.01

0.01

Styrene

0.01

0.01

Nickel

0.01

0.01

Di-n-butyl phthalate

0.01

0.01

Carbon Tetrachloride

0.01

0.01

Chloro methane

0.01

0.01

Biphenyl

0.01

0.01

39. Pursuant to '19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the twelve month

rolling total of rubber at this source shall be limited to 37,300,000 pounds of rubber. 40. Pursuant to '19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the rubber

throughput rate shall be maintained on a twelve month rolling total, updated monthly. Such records shall be submitted to the Department in accordance with General Condition #7.

29


30


SN-10 Rubber Step Cure

Source Description Some belts at the facility are cured in a step-wise press curing process called Step-Cure. This source was installed in 1977.


shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the rubber limit of this section.

SN

Pollutant

lb/hr

tpy

10

VOC

5.3

3.4


and '8-4-311, this source shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the rubber limit of this section.

SN

Pollutant

lb/hr

tpy

Methylene Chloride

9.11

5.69

Carbon Disulfide

2.72

1.69

Carbonyl Sulfide

0.29

0.18

1,1,1-Trichloroethane

0.14

0.08

4-Methyl-2-Pentanone

0.10

0.06

Acetophenone

0.05

0.03

Hexane

0.03

0.02

Toluene

0.03

0.02

2-Butanone

0.02

0.01

bis(2-


0.02

0.01

10

31


SN

Pollutant

lb/hr

tpy o-Toluidine 0.01 0.01

Xylenes

0.01

0.01

43. Pursuant to '19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the twelve month

rolling total of rubber at this source shall be limited to 36,300,000 pounds of rubber. 44. Pursuant to '19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the rubber

throughput rate shall be maintained on a twelve month rolling total, updated monthly. Such records shall be submitted to the Department in accordance with General Condition #7.

32


SNs 11, 12, 13 Belt Grinders

Source Description Belt profiles are completed through the grinding of belts with the grinding wheels on both a horizontal and vertical axis. The specific profile for a given belt depends upon the end use specification for that belt. Approximately 34% of the weight of the belt is ground off. These activities are completed in one of three production units at the facility. There are 28 belt grinders at SN-11. Emissions in this area are controlled by ten cyclones and ten electrostatic precipitators. There are 27 belt grinders at SN-12. Emissions in this area are controlled by eight cyclones and eight electrostatic precipitators. There are 16 belt grinders at SN-13. Emissions in this area are controlled by five cyclones and five electrostatic precipitators. All belt grinders were installed in 1985, except for one belt grinder installed at SN-13 in 2001.


shall not exceed the emission rates set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the rubber throughput limit of this section.

33

SN

Pollutant

lb/hr

tpy

PM10

24.5

11

VOC

4.4

PM10

23.4

12

VOC

5.0

PM10

24.6

13

VOC

5.3

---

Total

PM10 VOC

---

45.6 9.6

The Gates Rubber Company Permit #: 378-AOP-R3 CSN #: 04-0111 46. Pursuant to '18.801 of Regulation 18, and A.C.A. '8-4-203 as referenced by '8-4-304

and '8-4-311, this source shall not exceed the limits set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the rubber throughput limit of this section.

SN

Pollutant

lb/hr

tpy

PM

24.50

Toluene

3.15

Carbon Disulfide

0.71

Tetrachloroethene

0.33

2-Chloro-1,3-

Butadiene

0.19


0.12

Methylene Chloride

0.12

Hexane

0.10

Propylene Oxide

0.07

1,3-Butadiene

0.06

Acetophenone

0.04

Acetaldehyde

0.04

Nickel

0.02

Phenol

0.02

Xylenes

0.03

Carbonyl Sulfide

0.02

Acrolein

0.02

2-Butanone

0.02

Naphthalene

0.01


0.01

11

Chromium

0.01

---

34


SN

Pollutant

lb/hr

tpy

PM

23.4

Toluene

3.15

Carbon Disulfide

0.71

Tetrachloroethene

0.33


0.19

bis(2-


0.12

Methylene Chloride

0.12

Hexane

0.10

Propylene Oxide

0.07

1,3-Butadiene

0.06

Acetophenone

0.04

Acetaldehyde

0.04

Nickel

0.02

Phenol

0.02

Xylenes

0.03

Carbonyl Sulfide

0.02

Acrolein

0.02

2-Butanone

0.01

Naphthalene

0.01


0.01

12

Chromium

0.01

---

PM

24.60

Toluene

3.30

Carbon Disulfide

0.74

Tetrachloroethene

0.34

13

2-Chloro-1,3-

0.20

---

35


SN

Pollutant

lb/hr

tpy Butadiene

bis(2-


0.13

Methylene Chloride

0.12

Hexane

0.10

Propylene Oxide

0.07

1,3-Butadiene

0.06

Acetophenone

0.04

Acetaldehyde

0.04

Nickel

0.02

Phenol

0.02

Xylenes

0.03

Carbonyl Sulfide

0.02

Acrolein

0.02

2-Butanone

0.02

Naphthalene

0.01


0.01

Chromium

0.01

PM

45.6

Toluene

6.05

Carbon Disulfide

1.35

Tetrachloroethene

0.62


0.36

bis(2-


0.24

Methylene Chloride

0.22

Hexane

0.18

Tota

l

---

36


SN

Pollutant

lb/hr

tpy Propylene Oxide 0.14

1,3-Butadiene

0.12

Acetophenone

0.09

Acetaldehyde

0.06

Nickel

0.03

Phenol

0.03

Xylenes

0.05

Carbonyl Sulfide

0.03

Acrolein

0.03

2-Butanone

0.03

Naphthalene

0.03


0.03

Chromium

0.03


and '8-4-311, the facility shall not exceed 10% opacity from this source. 48. Pursuant to '18.501 of Regulation 18, and A.C.A. '8-4-203 as referenced by '8-4-304

and '8-4-311, weekly observations of the opacity from this source shall be conducted by personnel familiar with the facility=s visible emissions. The facility shall maintain personnel trained, but not necessarily certified, in EPA Reference Method 9. If visible emissions which would appear to be in excess of the permitted opacity are detected, the facility shall immediately take action to identify the cause of the visible emissions, implement corrective action, and document that visible emissions did not appear to be in excess of the permitted opacity following the corrective action. The facility shall maintain records which contain the following items in order to demonstrate compliance with this specific condition. These records shall be updated weekly, kept on site, and made available to Department personnel upon request.

A. The date and time of the observation. B. If visible emissions which appeared to be above the permitted level were detected. C. If visible emissions which appeared to be above the permitted limit were detected, the

37


cause of the exceedance of the opacity limit, the corrective action taken, and if the visible emissions appeared to be below the permitted limit after the corrective action was taken.

D. The name of the person conducting the opacity observations.

38


SECTION V: COMPLIANCE PLAN AND SCHEDULE The Gates Rubber Company is in compliance with the applicable regulations cited in the permit application. The Gates Rubber Company 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.

39


SECTION VI: PLANTWIDE CONDITIONS 1. Pursuant to '19.704 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 Director shall be notified in writing within thirty (30) days after construction has commenced, construction is complete, the equipment and/or facility is first placed in operation, and the equipment and/or facility first reaches the target production rate.

2. Pursuant to '19.410(B) of Regulation 19, 40 CFR Part 52, Subpart E, the Director may

cancel all or part of this permit if the construction or modification authorized herein is not begun within 18 months from the date of the permit issuance or if the work involved in the construction or modification is suspended for a total of 18 months or more.

3. Pursuant to '19.702 of Regulation 19 and/or '18.1002 of Regulation 18 and A.C.A.

'8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311, any equipment that is to be tested, unless stated in the Specific Conditions of this permit or by any federally regulated requirements, shall be tested with the following time frames: (1) Equipment to be constructed or modified shall be tested within sixty (60) days of achieving the maximum production rate, but in no event later than 180 days after initial start-up of the permitted source or (2) equipment already operating shall be tested according to the time frames set forth by the Department or within 180 days of permit issuance if no date is specified. The permittee shall notify the Department of the scheduled date of compliance testing at least fifteen (15) days in advance of such test. Compliance test results shall be submitted to the Department within thirty (30) days after the completed testing.

4. Pursuant to '19.702 of Regulation 19 and/or '18.1002 of Regulation 18 and A.C.A.

'8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311, the permittee shall provide:

a. Sampling ports adequate for applicable test methods b. Safe sampling platforms c. Safe access to sampling platforms d. Utilities for sampling and testing equipment

5. Pursuant to '19.303 of Regulation 19 and A.C.A. '8-4-203 as referenced by A.C.A.

'8-4-304 and '8-4-311, the equipment, control apparatus and emission monitoring equipment shall be operated within their design limitations and maintained in good condition at all times.

40

The Gates Rubber Company Permit #: 378-AOP-R3 CSN #: 04-0111 6. Pursuant to Regulation 26 and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311,

this permit subsumes and incorporates all previously issued air permits for this facility. Acid Rain (Title IV) 7. Pursuant to '26.701 of Regulation #26 and 40 CFR 70.6(a)(4), the permittee is prohibited

from causing any emissions which exceed any allowances that the source lawfully holds under Title IV of the Act or the regulations promulgated thereunder. No permit revision is required for increases in emissions that are authorized by allowances acquired pursuant to the acid rain program, provided that such increases do not require a permit revision under any other applicable requirement. This permit establishes no limit on the number of allowances held by the permittee. The source may not, however, use allowances as a defense to noncompliance with any other applicable requirement of this permit or the Act. Any such allowance shall be accounted for according to the procedures established in regulations promulgated under Title IV of the Act.

Title VI Provisions 8. The permittee shall comply with the standards for labeling of products using ozone

depleting substances pursuant to 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.

9. The permittee shall comply with the standards for recycling and emissions reduction

pursuant to 40 CFR Part 82, Subpart F, except as provided for MVACs in Subpart B:

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.

41


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. (AMVAC-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.

10. 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.

11. 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.

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.

12. The permittee shall be allowed to switch from any ozone-depleting substance to any

alternative that is listed in the Significant New Alternatives Program (SNAP) promulgated pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives Policy Program.

PERMIT SHIELD 13. 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 item A of this condition:

A. The following have been specifically identified as applicable requirements based

upon information submitted by the permittee in an application dated October 8, 1996.

42


SN

Regulation

Description

Facility

Arkansas Air Regulation 19

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

Facility

Arkansas Air Regulation 26

Regulations of the Arkansas Operating Air Permit Program

B. The following requirements have been specifically identified as not applicable,

based upon information submitted by the permittee in an application dated October 8, 1996.

Description of Regulation

Regulatory

Citation

Affected Source

Basis for Determination

Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units.

40 CFR 60 Subpart Dc

SN-01 SN-02

Installed prior to June 9, 1989 and has not been reconstructed or modified since that date.

Standards of Performance for Incinerators

40 CFR 60 Subpart E

SN-06

Does not burn solid waste.

Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978

40 CFR 60 Subpart K

SN-07

Capacity less than 40,000 gallons and the source was installed in 1995

Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984

40 CFR 60 Subpart Ka

SN-07

Capacity less than 40,000 gallons and the source was installed in 1995

Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984

40 CFR 60 Subpart Kb

SN-07

Capacity less than 40 m3

Standards of Performance for Polymeric Coating of Supporting Substrates Facilities

40 CFR 60

Subpart VVV

SN-06

Installed prior to April 30, 1987, and has not been reconstructed or modified since that date.

National Emission Standards for Hazardous Air Pollutants for Industrial Process Cooling Towers

40 CFR 63 Subpart Q

---

Cooling tower did not operate with chromium-based chemicals on or after September 8, 1994

National Emission Standards for Hazardous Air Pollutants for Halogenated Solvent Cleaning

40 CFR 63 Subpart T

Facility

No halogenated solvent cleaning material is used at the facility.

43


C. Nothing shall alter or affect the following:

Provisions of Section 303 of the Clean Air Act;

The liability of an owner or operator for any violation of applicable requirements prior to or at the time of permit issuance;

The applicable requirements of the acid rain program, consistent with Section 408(a) of the Clean Air Act; or

The ability of the EPA to obtain information under Section 114 of the Clean Air Act.

44

The Gates Rubber Company Permit #: 378-AOP-R3 CSN #: 04-0111 SECTION VII: INSIGNIFICANT ACTIVITIES Pursuant to '26.304 of Regulation 26, the following sources are insignificant activities. Any activity for which a state or federal applicable requirement applies is not insignificant even if this activity meets the criteria of '304 of Regulation 26 or is listed below. Insignificant activity determinations rely upon the information submitted by the permittee in an application dated October 8, 1996 and supplemental information.

Description

Category All air emissions resulting from the operation of the battery charging stations.

B-20

All air emissions resulting from the operation of mills and calendars used for rubber or plastic within the facility for which no materials in powder form are dded and in which no organic solvents, dilutants, or thinners are used. a

B-69

All emissions from the mobile printers used in the belt labeling processes because the facility has demonstrated that no enforceable permit conditions are necessary to insure compliance with any applicable law or regulation provided that the emissions are less than 5 tpy of any pollutant regulated under this regulation or less than 1 tpy of a single HAP or the emissions are less than 2.5 py of any combination of HAPs. t

A-13

All emissions from the grinding wheel cleaning process because the facility has demonstrated that no enforceable permit conditions are necessary to insure compliance with any applicable law or regulation provided that the emissions are less than 5 tpy of any pollutant regulated under this regulation or less than 1 tpy of a single HAP or the emissions are less than 2.5 tpy of any combination f HAPs. o

A-13

Natural gas space heaters used to provide area heating to the loading dock reas of the facility. a

B-2

Air conditioning and heating units used for comfort cooling and heating for the acility. f

B-2

All emissions from the Nubuild Process (gasless builder) which has mixers, blenders, roll mills, or calendars for rubber or plastic for which no materials in powder form are added and in which no organic solvents, diluents, or thinners re used. a

B-69

All emissions from the Cooling Tower because the facility has demonstrated that no enforceable permit conditions are necessary to insure compliance with any applicable law or regulation provided that the emissions are less than 5 tpy

A-13

45


of any pollutant regulated under this regulation or less than 1 tpy of a single AP or the emissions are less than 2.5 tpy of any combination of HAPs. H

Two (2) 500 gallon latex tanks because the storage tanks are less than 10,000 gallons and have a true vapor pressure less than 0.5 psia.

A-3

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

46

The Gates Rubber Company Permit #: 378-AOP-R3 CSN #: 04-0111 SECTION VIII: GENERAL PROVISIONS 1. Pursuant to 40 CFR 70.6(b)(2), any terms or conditions included in this permit which

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

2. Pursuant to 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, 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.

3. Pursuant to '26.406 of Regulation #26, it is the duty of the permittee to submit a

complete application for permit renewal at least six (6) months prior to the date of permit expiration. Permit expiration terminates the permittee's right to operate unless a complete renewal application was submitted at least six (6) months prior to permit expiration, in which case the existing permit shall 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.

4. Pursuant to 40 CFR 70.6(a)(1)(ii) and '26.701(A)(2) of Regulation #26, 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, both provisions are incorporated into the permit and shall be enforceable by the Director or Administrator.

5. Pursuant to 40 CFR 70.6(a)(3)(ii)(A) and '26.701(C)(2) of Regulation #26, records of

monitoring information required by this permit shall include the following:

a. The date, place as defined in this permit, and time of sampling or measurements;

b. The date(s) analyses were performed;

47


c. The company or entity that performed 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. Pursuant to 40 CFR 70.6(a)(3)(ii)(B) and '26.701(C)(2)(b) of Regulation #26, records of

all required monitoring data and support information shall be retained for a period of at least 5 years from the date of the monitoring sample, measurement, report, or 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.

7. Pursuant to 40 CFR 70.6(a)(3)(iii)(A) and '26.701(C)(3)(a) of Regulation #26, the

permittee shall submit reports of all required monitoring every 6 months. If no other reporting period has been established, the reporting period shall end on the last day of the anniversary month of this permit. The report shall be 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. All instances of deviations from permit requirements must be clearly identified in such reports. All required reports must be certified by a responsible official as defined in '26.2 of Regulation #26 and must be sent to the address below.

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

8. Pursuant to 40 CFR 70.6(a)(3)(iii)(B), '26.701(C)(3)(b) of Regulation #26, and '19.601

and 19.602 of Regulation #19, all deviations from permit requirements, including those attributable to upset conditions as defined in the permit shall be reported to the Department. An initial report shall be made 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 which is 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,

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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.

A full report shall be made in writing to the Department within five (5) business days of discovery of the occurrence and shall include, in addition to the information required by initial report, a schedule of actions to be taken to eliminate future occurrences and/or to minimize the amount by which the permits limits are exceeded and to reduce the length of time for which said limits are exceeded. If the permittee wishes, they 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 such report will serve as both the initial report and full report.

9. Pursuant to 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, if any provision of the permit or the application thereof to any person or circumstance is held invalid, such invalidity shall 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.

10. Pursuant to 40 CFR 70.6(a)(6)(i) and '26.701(F)(1) of Regulation #26, 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, or modification; or for denial of a permit renewal application. Any permit noncompliance with a state requirement constitutes a violation of the Arkansas Water and Air Pollution Control Act (A.C.A. '8-4-101 et seq.) and is also grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application.

11. Pursuant to 40 CFR 70.6(a)(6)(ii) and '26.701(F)(2) of Regulation #26, 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 in order to maintain compliance with the conditions of this permit.

12. Pursuant to 40 CFR 70.6(a)(6)(iii) and '26.701(F)(3) of Regulation #26, this permit may

be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or

49


termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition.

13. Pursuant to 40 CFR 70.6(a)(6)(iv) and '26.701(F)(4) of Regulation #26, this permit does

not convey any property rights of any sort, or any exclusive privilege. 14. Pursuant to 40 CFR 70.6(a)(6)(v) and '26.701(F)(5) of Regulation #26, the permittee

shall 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 shall also furnish to the Director copies of records required to be kept by the permit. For information claimed to be confidential, the permittee may be required to furnish such records directly to the Administrator along with a claim of confidentiality.

15. Pursuant to 40 CFR 70.6(a)(7) and '26.701(G) of Regulation #26, the permittee shall pay

all permit fees in accordance with the procedures established in Regulation #9. 16. Pursuant to 40 CFR 70.6(a)(8) and '26.701(H) of Regulation #26, no permit revision

shall be required, under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are provided for elsewhere in this permit.

17. Pursuant to 40 CFR 70.6(a)(9)(i) and '26.701(I)(1) of Regulation #26, if the permittee is

allowed to operate under different operating scenarios, the permittee shall, contemporaneously with making a change from one operating scenario to another, record in a log at the permitted facility a record of the scenario under which the facility or source is operating.

18. Pursuant to 40 CFR 70.6(b) and '26.702(A) and (B) of Regulation #26, all terms and

conditions in this permit, including any provisions designed to limit a source's potential to emit, are enforceable by the Administrator and citizens under the Act unless the Department has specifically designated as not being federally enforceable under the Act any terms and conditions included in the permit that are not required under the Act or under any of its applicable requirements.

50

The Gates Rubber Company Permit #: 378-AOP-R3 CSN #: 04-0111 19. Pursuant to 40 CFR 70.6(c)(1) and '26.703(A) of Regulation #26, any document

(including reports) required by this permit shall contain a certification by a responsible official as defined in '26.2 of Regulation #26.

20. Pursuant to 40 CFR 70.6(c)(2) and '26.703(B) of Regulation #26, the permittee shall

allow an authorized representative of the Department, upon presentation of credentials, to perform the following:

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 that must be kept 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 the purpose of assuring compliance with this permit or applicable requirements.

21. Pursuant to 40 CFR 70.6(c)(5) and '26.703(E)(3) of Regulation #26, the permittee shall

submit a compliance certification with terms and conditions contained in the permit, including emission limitations, standards, or work practices. This compliance certification shall be submitted annually and shall be submitted to the Administrator as well as to the Department. All compliance certifications required by this permit shall include the following:

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. Pursuant to '26.704(C) of Regulation #26, nothing in this permit shall alter or affect the

following:

51


a. The provisions of Section 303 of the Act (emergency orders), including the authority of 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. Pursuant to A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, this permit

authorizes only those pollutant emitting activities addressed herein.

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53

Appendix A

Sample VOC Recordkeeping SN-06 Cord Treater SN-08 Belt Builder


55

Source No Source Description For Month___________________ Year_______ Table A

VOC Emission Rate Calculations*

Column 1

Column 2 Column 3

Column 4

Column 5

Column 6

Column

7

Column 8

Column 9

Supplier

Name

Formulation

Type

MSDS #

Density

(lb/gallon)

VOC

Content (lb/gallon)

Amount

Used (gallon/mont

h)

%

Overall Control

Efficiency

VOC

Emissions (lb/month)

VOC

Emission (ton/month)

Total Emissions From Column 9 (tons)

Total Emissions From Previous 11 months (tons)

Total Annual Emissions (tpy) This month plus previous 11 months

*Emission rates are public information. Only the non-public factors used to determine the emissions can be kept confidential. It may be necessary to provide both a confidential and a non-confidential version of this to the Department for inspection. In accordance with Department policy, any

information requested to be kept confidential must be marked as such in red.

For calculations: Column 7 = Capture Efficiency X Control Efficiency = For SN-06 Cord Treater = 90% X 90% = 81% = 0% (no control) for SN-08 Belt Builder

Column 8 = Column 5 X Column 6 X [1- Column 7/100] Column 9 = Column 8 X ton/2000 lb

Appendix B

Sample HAP Recordkeeping SN-06 Cord Treater SN-08 Belt Builder

Source No Source Description For Month___________________ Year_______ Table B

VOC Emission Rate Calculations*

Column 1

Column 2 Column 3

Column 4

Column 5

Column 6

Column

7

Column 8

Column 9

Supplier

Name

Formulation

Type

MSDS #

Name of

HAP

HAP

Content (lb/gallon)

Amount

Used (gallon/mont

h)

%

Overall Control

Efficiency

HAP

Emissions (lb/month)

HAP

Emission (ton/month)

Total Emissions From Column 9 (tons)

Total Emissions From Previous 11 months (tons)

Total Annual Emissions (tpy) This month plus previous 11 months

*Emission rates are public information. Only the non-public factors used to determine the emissions can be kept confidential. It may be necessary to provide both a confidential and a non-confidential version of this to the Department for inspection. In accordance with Department policy, any information requested to be kept

confidential must be marked as such in red.

For calculations: Column 7 = Capture Efficiency X Control Efficiency = For SN-06 Cord Treater = 90% X 90% = 81% = 0% (no control) for SN-08 Belt Builder

Column 8 = Column 5 X Column 6 X [1- Column 7/100] Column 9 = Column 8 X ton/2000 lb

adeq operating air permit · the gates rubber company permit #: 378-aop-r3 csn #: 04-0111...

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