operating air permit - adeq.state.ar.us

OPERATING AIR PERMIT

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

Permit #: 818-AOP-R5

Renewal #1

IS ISSUED TO:

Cooper-Standard Automotive Company Engineered Products Division

166 Cooper Drive El Dorado, AR 71730

Union County AFIN: 70-00036

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 AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Keith A. Michaels Date

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036

SECTION I: FACILITY INFORMATION PERMITTEE: Cooper-Standard Automotive Company AFIN: 70-00036 PERMIT NUMBER: 818-AOP-R5 FACILITY ADDRESS: 166 Cooper Drive El Dorado, Arkansas 71730 COUNTY: Union CONTACT POSITION: Stacy Thomas, Environmental Coordinator TELEPHONE NUMBER: (870) 862-6441 REVIEWING ENGINEER: David Triplett UTM North-South (X): 3673.5 km UTM East-West (Y): 536.3 km

2


SECTION II: INTRODUCTION Cooper-Standard Automotive Company, Engineered Products Division (Cooper) operates a molded rubber products manufacturing facility in El Dorado, Arkansas. The molded rubber products generally consist of specifically engineered rubber compounds bonded to metal inserts. These products are typically used for vehicle vibration, noise, and harshness control. This is the first renewal of the Title V Operating Air Permit for this facility.

Summary of Current Modification

This permit renewal also incorporates the following modifications: After issuance of permit No. 818-AOP-R4, Cooper discovered that it was unable to meet the 6.12 lb/gal VOC content limit for the primers, as applied. This 6.12 lb/gal limit was determined based on the assumption that Cooper would use a 75-25 primer-to-thinning solvent ratio at the facility. In order to meet operational specifications for primer viscosity, dry film thickness, and solids content, it was sometimes necessary for the facility to add additional solvent to the primer mixture, thus increasing the Aas applied@ VOC content above the 6.12 lb/gal permitted limit. Additionally, the facility has experienced some difficulty in demonstrating full compliance with limits based on an Aas applied@ standard. Based on these considerations, ADEQ has revised the previous BACT determination to allow for compliance demonstration through the tracking of the Aas supplied@ VOC contents of the primers, adhesives, and solvents used at the facility, with the additional requirements that the facility monitor the viscosity of the final primer/solvent and adhesive/solvent mixtures to ensure that the mixing occurs at acceptable levels. If too much solvent is added to either mixture (thus increasing the VOC content), it will be detected by means of the periodic viscosity monitoring conducted by the facility. The plantwide annual emission limitation for VOC from primer and adhesive application will remain unchanged at 302.8 tpy. Several sources have been determined to meet the Department=s Insignificant Activity criteria as outlined in Appendix A to Regulation 19. These sources have been removed from the Specific Conditions and listed in the Insignificant Activities List found in Section VII. The sources which have been reclassified are: SN-09, SN-13, SN-16, SN-34, SN-35, SN-17, SN-18, SN-21a, SN-21b, SN-21c, SN-32, SN-38, SN-39, and SN-40. Additionally, there are two other changes to this permit. SN-19, formerly used as a No. 2 Fuel Oil storage tank, has been removed from operation at the facility, and the emission limitations on the conventional and injection presses (SN-26) have been revised to correct an error made with

3

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 the issuance of Permit No. 818-AOP-R4. The correction of these emission calculations leads to increases in many of the annual HAP emission limitations at the source, as well as to the VOC emission limits. As a result of these permit changes, total annual VOC emission limits on the facility will increase by 5.8 tpy.

Process Description Cooper-Standard Automotive=s El Dorado, AR facility receives dry and liquid raw materials in both bulk and packaged forms. Dry materials are stored inside the building. Carbon black is received in totes, bags, and supersacs. Three process oils are stored in bulk storage tanks in the east side of the building (SN-21). Fuel oil is stored in a bulk storage tank on the southwest side of the building (SN-21a, 21b. & 21c). Solvents and cements are received and stored in drums. Rubber, carbon black, process oils, and miscellaneous dry ingredients are mixed in the Banbury Mixer (SN-06). Carbon black is handled, weighed, and fed to the mixer in enclosed systems (SN-38). Dry ingredients are weighed to specified formulations and batched in the Compounding Area (SN-14). The batches are then transported to the Banbury Mixer. Carbon black and other dry ingredients generate dust at the opening to the mixer throat and the drop mill. Three dust collectors and a Mixing Area Vacuum System (SN-40) serve this operation. All of the dust collectors and the vacuum system discharge into filter rooms that provide additional filtering for the discharged air. In addition, all mixing ventilation systems discharge into a filter room to control any fugitive emissions that may result from this operation. The mixed rubber is dropped from the Banbury Mixer onto a mill where it is milled to a specified width and thickness. Then, it is dipped in a de-tackifying solution, cooled, and layered onto skids (SN-39). Some of the rubber is transported to the Pin Barrel Tuber (SN-34) where it is extruded in a specific form. The extruded form is cooled, dusted with a de-tackifier (zinc stearate), cut, and stored. The rubber pre-forms are used in the injection presses. The duster is connected to a dust collector. Some of the rubber is transported to the Preformer Extruder (SN-35) where it is extruded in preforms for use in conventional presses. Extruded rubber from SN-34 and SN-35 may also be cured in the Autoclave (SN-27).

4

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 Some of the rubber is transported to the 6-Inch Tuber (SN-16) where it is extruded in specific forms. The extruded form is dusted with a de-tackifier (talc), cooled, cut, and stored. This rubber is cured in the Autoclave (SN-27). Extruded rubber from the 6-Inch Tuber (SN-16) may also be cured in the conventional and injection presses. Particulate emissions from the 6-Inch Tuber are routed to the baghouse which controls emissions from the Banbury Mixer (SN-06). Metal inserts can be cleaned by hitting them with metal shot in the Wheelabrator (SN-18). The particulate emissions from SN-18 are controlled by a control device inherent to the equipment design and then discharged inside the plant. Metal inserts for the molded rubber products are cleaned and undergo phosphate coating on the caustic cleaning/phosphate line (SN-32). Three heated tanks on the caustic line are equipped with a common roof exhaust. The acid tank is equipped with a fume scrubber and mist eliminator which discharges outside the building. Solvents, adhesives, and coatings are mixed in the required proportions to form the adhesives and coatings used on the metal inserts. The adhesives and coatings are stored and dispensed in the Cement Storage and Mixing Room (SN-11). Metal inserts are coated with adhesive coating in the Circular Paint Line (SN-01), Automatic Paint Line #1 (SN-02), Automatic Paint Line #2 (SN-03), Chain-on-Edge Paint Line #1 (SN-08), Chain-on-Edge Paint Line #2 (SN-41), Indexing Machine (SN-42), and the Dip Units (SN-10 and SN-36). Each of the coating operations is equipped with exhausts that discharge outside the building. The Pyrolytic Oven (SN-33) is used to clean Chain-on-Edge fixtures. The oven is fired with natural gas and burns the dried adhesive off of the fixtures. The oven is equipped with an after-burner that operates at 1500 - 1650 deg. F. The after-burner exhausts outside the building. Rubber and metal inserts are combined on the Conventional and Injection Presses (SN-26) to produce molded rubber parts. A mold lubricant is applied to some molds. In addition, a coating and/or a color code paint is applied to some cured products at the presses. Some cured parts are also ground at the presses. Molds that become fouled through use are cleaned in the Mold Cleaner (SN-17). The Mold Cleaner is equipped with a dust collector that exhausts inside the building. Finished products are inspected and stored in the warehouse prior to shipment to customers.

5

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 Steam is provided to the autoclave, the conventional presses, the caustic line, and the Circular Paint Line using two 500 horsepower boilers. The York Shipley Boiler (SN-25) is natural gas fired and uses No. 2 fuel oil as a backup fuel. The Sellers Boiler (SN-24) is only capable of firing natural gas.

Facility Emission Summary Facility wide emissions are summarized in the following table. Specific emission unit information is located at the indicated cross reference page.

CRITERIA POLLUTANT EMISSION SUMMARY

Emission Rates

Source

No.

Description

Pollutant

lb/hr

ton/year

Cross

Reference Page

Total Allowable Emissions

PM

PM10 SO2

VOC CO NOx

4.5 4.5

12.0 135.8 7.3 8.9

15.1 15.1 51.4 427.0 26.2 32.7

N/A

Adhesive/Coating Application

01

Circular Paint Line

PM

PM10 VOC

0.5 0.5 5.1

0.7 0.7

302.8**

17

02

Automatic Paint Line #1

PM

PM10 VOC

0.4 0.4

10.7

1.4 1.4 **

17

03

Automatic Paint Line #2

PM

PM10 VOC

0.4 0.4

10.7

1.4 1.4 **

17

08

Chain-on-Edge Paint Line #1

PM

PM10 SO2

VOC CO

NOX

0.1 0.1 0.1

14.6 0.1 0.1

0.1 0.1 0.1 ** 0.3 0.4

17

6



Emission Rates

Source

No.

Description

Pollutant

lb/hr

ton/year

Cross

Reference Page

41

Chain-on-Edge Paint Line #2

PM

PM10 SO2

VOC CO

NOX

0.1 0.1 0.1

14.6 0.1 0.1

0.1 0.1 0.1 ** 0.3 0.4

17

42

Indexing Machine

PM

PM10 VOC

0.1 0.1 5.9

0.2 0.2 **

17

10

Dip Unit #1

PM

PM10 VOC

0.2 0.2 5.8

0.7 0.7 **

17

11

Cement Mixing and

Storage Room

VOC

1.4

**

17

36

Dip Unit #2

PM

PM10 VOC

0.2 0.2 5.8

0.7 0.7 **

17

Rubber Manufacturing

06

Banbury Mixer

PM

PM10 VOC

0.1 0.1 1.1

0.4 0.4 4.4

22

26

Conventional and Injection

Presses

PM

PM10 VOC

0.1 0.1

58.9

0.4 0.4

116.7

28

28

Autoclave

PM

PM10 VOC

0.1 0.1 0.3

0.4 0.4 0.5

32

Boilers

24

Sellers Boiler

PM

PM10 SO2

0.2 0.2 0.1

0.3 0.3 0.1

25

7



Emission Rates

Source

No.

Description

Pollutant

lb/hr

ton/year

Cross

Reference Page

VOC CO NOx

0.2 1.8 2.1

0.2 2.6 3.1

25

York Shipley Boiler

PM

PM10 SO2

VOC CO NOx

0.9 0.9

11.3 0.2 3.8 6.1

3.9 3.9

49.5 0.5

16.6 26.7

25

Other Sources

32

Caustic Cleaning/ Phosphate Line

Phosphoric Acid Fumes

0.1

0.4

35

33

Pyrolytic Oven

PM

PM10 SO2

VOC CO NOx

1.1 1.1 0.4 0.5 1.5 0.5

4.4 4.4 1.6 1.9 6.4 2.1

37

**Total emissions for sources SN-01, SN-02, SN-03, SN-08, SN-10, SN-11, and SN-36, SN-41, and SN-42.

8

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 Overall non-criteria pollutant emissions are summarized in the following table. Specific hazardous air pollutant emission rates are identified in the specific emission unit information.

NON-CRITERIA POLLUTANT EMISSION SUMMARY

Emission Rates

Source

No.

Pollutant

lb/hr

ton/year

Acetaldehyde

0.11

0.21

Acetonitrile

0.01

0.01

Acetophenone

4.28

8.55

Acrolein

0.05

0.11

Acrylonitrile

0.35

0.79

Aniline

0.11

0.19

Benzene

0.08

0.15

Benzidine

0.04

0.09

Bis(2-ethylhexyl) phthalate

0.19

0.37

Bromoform

0.01

0.02

1,2 Butylene Oxide

0.03

0.12

1,3 Butadiene

0.27

0.52

Carbon Disulfide

17.79

32.75

Carbon Tetrachloride

8.79

17.4

Carbonyl Sulfide

4.42

9.05

Chloroethane

0.01

0.01

9



Emission Rates

Source

No.

Pollutant

lb/hr

ton/year

Chloroform 0.12 0.24

Chloromethane

0.08

0.17

Chromium Compounds

0.18

0.42

Cumene

0.06

0.14

Di-n-butylphthalate

0.10

0.20 1,1 Dichloroethene (Vinylidene Chloride)

0.11

0.21

1,4-Dioxane

0.01

0.01

Ethyl Benzene

7.29

31.59

Ethylene Glycol

0.31

0.55

Formaldehyde

0.03

0.12

Glycol Ethers

0.83

1.13

Hexachlorobutadiene

0.02

0.02

Isooctane

0.07

0.13

Isophorone

0.02

0.03

Manganese Compounds

0.02

0.10

Methylene Chloride

1.31

1.93

Methyl Ethyl Ketone (2-Butanone)

1.14

3.69

Methylene Diphenyl Diisocyanate

0.053

0.10

10



Emission Rates

Source

No.

Pollutant

lb/hr

ton/year

Methyl Isobutyl Ketone (4-Methyl 2-Pentanone)

32.06 126.52

n-Hexane

3.11

6.22

Naphthalene

0.05

0.13

Nickel

0.01

0.01

o-Cresol

0.06

0.25

o-Toluidene

0.05

0.10

Phenol

0.24

0.99


0.10

0.40

Propylene Oxide

1.05

2.14

Selenium Compounds

0.05

0.22

Styrene

0.83

1.67

t-Butyl Methyl Ether

1.56

3.19

Tetrachloroethylene

0.40

1.18

Toluene

20.62

89.28

1,1,1- Trichloroethane

3.43

6.78

Trichloroethylene

6.21

27.21

Xylene

30.20

130.77

11


SECTION III: PERMIT HISTORY The facility was originally permitted under Arkansas Regulation 19. The original permit, 818-A was issued on November 10, 1987. The permit was modified and reissued as permit 818-AR-1 on September 7, 1993. Permit 818-AR-2 was issued on September 26, 1994, under Arkansas Regulation 19. Modifications included a production increase and several changes in the manufacturing operation which included replacement of a dip unit with a new unit, routing particulate emissions from the 6-inch tuber to the Wheelabrator dust collector, replacing the 8-inch hot feed tuber with a pin barrel tuber, and installation of a preformer extruder. Additionally several units were removed from service. Units removed from service include two degreasers, a laboratory banbury mixer, fixture cleaning drums and a rotocure operation. Permit 818-AR-3 was issued on March 12, 1996, under Arkansas Regulation 19. Modifications included a production increase and the ability to use new coating materials. Cooper=s first Title V operating permit, Permit #818-AOP-R0, was issued on November 18, 1997. That modification permitted the installation of a new (second) dip unit (SN-36) and increased the overall adhesive/coating usage at the facility. Additionally, the VOC emission rates associated with the production of rubber were revised. The revised emission estimates were based on testing and emission factors developed by the Rubber Manufacturers Association. The modifications resulted in an increase in permitted volatile organic compound (VOC) emissions of 46.7 tons per year (tpy). Cooper=s second Title V operating permit, Permit #818-AOP-R1, was issued on January 15, 1999. Cooper replaced the existing Banbury Mixer (SN-06) and associated equipment with a new mixing system. This involved the construction of a new mixing building, the replacement of the mixer and the Compounding Area (SN-14), and the installation of a new Carbon Black Handling System and Weigh Hopper, a new Mixer Dip Mixing and Dip Tank, and a new Mixing Area Vacuum System. The maximum annual rubber throughput on the new system is the same as the existing Banbury Mixer. These systems are served by new dust collection equipment, including a new secondary filtration system. The mixing building ventilation system is also served by a filtration system. The existing mixer dust collector was removed. Improvements in dust collection efficiency and the addition of the secondary filtration system resulted in a decrease of particulate matter emissions. In addition, since the maximum throughput did not increase, the maximum annual VOC and HAP emissions were unchanged.

12

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 The removal of the existing mixer dust collector affected the 6-inch Tuber and the Pin Barrel Tuber. These sources were connected to one of the new dust collectors. Cooper also obtained revised physical data for several coatings and adhesives, and the plant learned that several new materials will need to be introduced. As a result, there was a slight decrease in the maximum hourly VOC emission rates for each coating and adhesive application source, and an increase in the maximum hourly particulate matter emission rate for the Chain-on-Edge Paint Line (SN-08). VOC emissions from the mold lube/coating had been omitted from the maximum VOC emission rate for the Conventional and Injection Presses in past permit modifications. These emissions were added in this modification. Permit #818-AOP-R2 was issued on July 26, 1999. Cooper requested to increase the rubber processing limit on the Tubers and Extruders. The Banbury Mixer and the Conventional and Injection Presses both have rubber processing limits of 14,416 tons per twelve consecutive months. In order to provide maximum flexibility for plant operations, Cooper requested an identical limit for the Tubers and Extruders. The emissions calculations for the Tubers and Extruders were based on processing 14,416 tons per year. Therefore, the requested change did not result in a change in permitted emissions. Cooper also requested to increase the toluene and ethylene glycol emissions limits for the Surface Coating Operations. Cooper found that the current limits do not provide the desired plant operating flexibility. Cooper requested that the toluene emission limit be increased from 1.3 tons per year to 3.0 tons per year and that the ethylene glycol emission limit be increased from 0.01 tons per year to 0.04 tons per year. Cooper also installed some additional curing presses at the plant. These presses are a part of the Conventional and Injection Presses source (SN-26). The operation of these presses did not require a change in the current rubber processing limit, mold lube/coating limit, color coding usage limit, or emission limits for the source. The following sources have been permanently removed from service through a permit modification:

13

Source

Description

SN-04

Degreaser #1

SN-05

Degreaser #2


Source

Description

SN-07 Laboratory Banbury Mixer SN-12

Coating Mixing Booth

SN-13

Fixture Cleaning Drums

SN-15

8 inch Tuber

SN-23

Trichloroethylene Storage Tank

SN-27

Rotocure Operation

SN-29

Nitrogen Tumbler

SN-30

Nitrogen Deflasher

SN-31

Nitrogen Storage Tank

Permit #818-AOP-R3 was issued on August 28, 2000. This modification authorized the use of new coating materials at the Surface Coating Operations portion of the plant. The permit also acknowledged new Hazardous Air Pollutant (HAP) content information recently issued for existing coating materials. Permit No. 818-AOP-R4 was issued on February 28, 2002. The purpose of this modification was to authorize the following changes: $ The installation of ten additional conventional and injection presses at SN-26, for a

total of 64 presses at SN-26. This modification did not involve an emission increase. $ The replacement of the Caustic Cleaning/Phosphate Line (SN-32), and the addition of a

Wheelabrator (SN-18) to clean metal parts. The only emission change with this modification was a 0.4 ton/yr increase in PM10.

$ The incorporation of a new surface coating material at various sources. This modification resulted in the following HAP emissions: 0.03 ton/yr ethylene glycol, and 0.02 ton/yr 1,2-butylene oxide.

$ The addition of an ink-jet spraying system to the permit=s list of insignificant activities.

$ The replacement, modification, or addition of selected units as follows: $

n inc

14


rease in rubber compound throughput at the

15


mixers, tubers, extruders, and presses, f

16


rom 14,416 ton/year to19,000 ton/year. thr

17


oughput increase at the Carbon Black Handl

18


ing System, from 4,380 ton/yr to 5,775 ton

19


/yr. n increase in rubber throughput at the

20


Autoclave from 1,533,667 lb/yr to 2,300,0

21


00 lb/yr. he replacement of the existing Ch

22


ain-on-Edge Paint Line, and the installati

23


on of an additional Chain-on-Edge Paint Li

24


ne. he installation of a new Indexing Machi

25


ne. he replacement of existing Dip Unit No.

26


2. he replacement of existing Automatic Pa

27


int Lines 1 and 2.

The final set of changes listed above result in a potential VOC increase of 218.0 ton/yr. This permitting action was therefore reviewed under the provisions of 40 CFR 52.21, Prevention of Significant Deterioration (PSD). The total permitted plantwide VOC increase was 112.2 ton/yr, due to emission bubble limits on selected sources. Below is a summary of the net emission increases associated with the issuance of Permit No. 818-AOP-R4.

Pollutant

Surface Coating

Equipment (ton/yr)

Process

Equipment (ton/yr)

Other

Equipment (ton/yr)

Boilers (ton/yr)

Total Net Change (ton/yr)

PSD

Significant Emission

Rate (ton/yr)

PSD

Applicability

PM

2.04

0.99

--

0.23

3.26

15

No

SO2

--

--

--

0.02

0.02

40

No

NOX

--

--

--

3.06

3.06

40

No

CO

--

--

--

2.57

2.57

100

No

VOC

153.3

61.7

2.80

0.17

218.0

40

Yes

28

Several control options were considered in the VOC BACT analysis. These options included the usage of water-based solvents and/or low-VOC solvents. Due to the particular need for very high-

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 strength metal-to-rubber bonding in the automotive industry, it was determined that the usage of such lower-VOC materials was not currently technically feasible at the Cooper facility. Add-on VOC controls with either full or partial enclosure of the new units was also considered, but ruled out as BACT due to the high dollar-per-ton cost of such control. ($5,899 per ton for partial enclosure). BACT for Cooper=s surface coating operations was therefore selected as the following:

OC content of the primer as applied

29


shall not exceed 6.12 pounds per gallon.

30


OC content of the adhesives as applied sha

31


ll not exceed 7.13 pounds per gallon.

he q

32


uantity of all coatings used for surface c

33


oating operations shall not exceed 721,824

34


pounds per year, based on a 12-month roll

35


ing total. This limit includes water-base

36


d and solvent-based top-coats, primers, an

37


d adhesives.

38


SECTION IV: EMISSION UNIT INFORMATION

39


Surface Coating Operations

SN-01, SN-02, SN-03, SN-08, SN-10, SN-11, SN-36, SN-41, SN-42

Source Description

Metal inserts are coated with top-coats, primers, and adhesives in the Circular Paint Line (SN-01), the Automatic Paint Line #1 (SN-02), the Automatic Paint Line #2 (SN-03), the Chain-on-Edge Paint Line #1 (SN-08), the Chain-on-Edge Paint Line #2 (SN-41), an Indexing Machine (SN-42) and two dip units (SN-10 and SN-36). The Chain-on-Edge paint lines each use an 0.8 million Btu per hour natural gas fired dryer. Coatings are mixed in a cement mixing and storage room (SN-11). Emissions from the mixing and storage room are accounted for in the total emissions calculated for the paint lines.

Specific Conditions 1. Pursuant to '19.501 et seq of the Regulations of the Arkansas Plan of Implementation for Air

Pollution Control, effective February 15, 1999 (Regulation #19) and 40 CFR Part 52 Subpart E, the permittee shall not exceed the emission rates set forth in the following table.

The particulate matter emission rates are based on the assumption that the coating with the highest solid content is used exclusively. The hourly VOC emission rates are based on the assumption that the coating with the highest VOC content is used exclusively.

SN

Pollutant

lb/hr

ton/year

01

PM10 VOC

0.5 5.1

0.7

302.8**

02

PM10 VOC

0.4 10.7

1.4 **

03

PM10 VOC

0.4 10.7

1.4 **

08

PM10 SO2

VOC CO NOx

0.1 0.1 14.6 0.1 0.1

0.1 0.1 ** 0.3 0.4

10

PM10 VOC

0.2 5.8

0.7 **

11

VOC

1.4

**

36

PM10 VOC

0.2 5.8

0.7 **

40


SN

Pollutant

lb/hr

ton/year

41 PM10 SO2

VOC CO NOx

0.1 0.1 14.6 0.1 0.1

0.1 0.1 ** 0.3 0.4

42

PM

PM10 VOC

0.1 0.1 5.9

0.2 0.2 **

**Total VOC emissions from SN-01, SN-02, SN-03, SN-08, SN-10, SN-11, SN-36, SN-41, and SN-42.

2. Pursuant to '19.501 et seq of Regulation #19 and 40 CFR 52.21, the permittee shall not

exceed combined VOC emissions of 302.8 tons from sources SN-01, SN-02, SN-03, SN-08, SN-10, SN-11, SN-36, SN-41, and SN-42 during any consecutive twelve month period.

3. Pursuant to '19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall

maintain records which demonstrate compliance with the emission limit set in Specific Condition #2. These records may be used by the Department for enforcement purposes. Records shall be kept in a spreadsheet, database, or other well-organized format. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel upon request. An annual total and each individual month=s data shall be submitted in accordance with General Provision 7.

4. Pursuant to '18.801 of the Arkansas Air Pollution Control Code, effective February 15, 1999

(Regulation #18), and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall not exceed the emission rates set forth in the following table. The particulate matter emission rates are based on the assumption that the coating with the highest solid content is used exclusively.

SN

Pollutant

lb/hr

ton/year

01

PM

0.5

0.7

02

PM

0.4

1.4

03

PM

0.4

1.4

08

PM

0.1

0.1

10

PM

0.2

0.7

36

PM

0.2

0.7

41

PM

0.1

0.1

41


SN

Pollutant

lb/hr

ton/year

42 PM 0.1 0.2

5. Pursuant to '18.801 of Regulation #18 and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall not exceed the emission rates set forth in the following table for SN-01, SN-02, SN-03, SN-08, SN-10, SN-11, SN-36, SN-41, and SN-42 combined. The hourly emission rates are based on the assumption that the coating with the highest non-criteria content is used exclusively.

Hazardous Air Pollutant

lb/hr

tons per twelve

consecutive months

1,2 Butylene Oxide

0.03

0.12

Chromium Compounds

0.17

0.40

Ethyl Benzene

7.14

31.3

Ethylene Glycol

0.10

0.13

Formaldehyde

0.03

0.12

Glycol Ethers

0.83

1.13

Manganese Compounds

0.013

0.10

Methyl Ethyl Ketone

0.56

2.47

Methylene Diphenyl Diisocyanate

0.053

0.10

Methyl Isobutyl Ketone

26.14

114.5

o-Cresol

0.06

0.25

Phenol

0.21

0.92

Selenium Compounds

0.05

0.22

Toluene

19.93

87.40

Tetrachloroethylene

0.17

0.72

Trichloroethylene

6.20

27.20

Xylene

29.50

129.10

42

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 6. Pursuant to '18.1004 of Regulation #18 and A.C.A. '8-4-203 as referenced by '8-4-304 and

'8-4-311, the permittee shall maintain records which demonstrate compliance with the annual emission limits set in Specific Condition #5. These records may be used by the Department for enforcement purposes. Records shall be maintained in a spreadsheet, database, or other well-organized format. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel upon request. An annual total and each individual month=s data shall be submitted to the Department in accordance with Plantwide Condition #17.

7. 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 permittee shall not exceed 5% opacity from sources SN-01, SN-02, SN-03, SN-08, SN-10, SN-11, SN-36, SN-41, or SN-42 as measured by EPA Reference Method 9.


'8-4-311, the permittee shall conduct weekly observations of the opacity from SN-01, SN-02, SN-03, SN-08, SN-10, SN-11, SN-36, SN-41, and SN-42, and keep a record of these observations. If visible emissions are detected, then the permittee shall conduct a 6-minute opacity reading in accordance with EPA Reference Method 9. The results of these observations shall be kept on site and shall be made available to Department personnel upon request.

9. Pursuant to '19.901 et seq of the Arkansas State Implementation Plan for Air Pollution

Control (Regulation 19) and 40 CFR Part 52 Subpart E, VOC content of primers, adhesives, and primer/adhesive thinning solvents, as supplied, shall not exceed the limits as listed in the following table. Compliance with this condition shall be demonstrated by compliance with Specific Condition #13.

Material

Maximum Allowable VOC

Content (lb/gal)

primers

5.9

primer thinning solvents

6.7

adhesives

7.1

adhesive thinning solvents

7.3

43

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 10. Pursuant to '19.901 et seq of the Arkansas State Implementation Plan for Air Pollution

Control (Regulation 19) and 40 CFR Part 52 Subpart E, all primer and/or adhesive mixes shall be maintained at or above a viscosity of 17 seconds as determined by the Zahn #2 cup method. Records of viscosity measurements shall be updated daily, maintained on-site for at least 30 days, and shall be made available to Department personnel upon request.

11. Pursuant to '19.901 et seq of the Arkansas State Implementation Plan for Air Pollution

Control (Regulation 19) and 40 CFR Part 52 Subpart E, the permittee shall develop and maintain work practice standards which outline the mixing process for the primers and adhesives used at the facility. These standards shall be updated as necessary, maintained on-site, and shall be made available to Department personnel upon request.

12. Pursuant to '19.303 of the Arkansas State Implementation Plan for Air Pollution Control

(Regulation 19) and 40 CFR 52.21, the quantity of all coatings used for surface coating operations shall not exceed 721,824 pounds per year, based upon a twelve-month rolling total. This limit includes water-based and solvent-based top-coats, primers, and adhesives.

13. Pursuant to '19.705 of Regulation #19, 40 CFR Part 52 Subpart E, and '18.1004 of

Regulation #18, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall maintain records which demonstrate compliance with the limits set forth in Specific Conditions 9 and 12. The records shall be updated on a monthly basis, kept on site, and made available to Department personnel upon request.

44


Banbury Mixer

SN-06

Source Description Carbon black, Afillers,@ curing agents, miscellaneous dry materials, rubber, and oil are combined in the Banbury Mixer in the required proportions for the desired rubber compound. Some minor curing agents and other dry materials are weighed at an operator compounding station at the mixer. All solid materials are loaded onto a charge conveyor that leads to the mixer or are charged directly to the mixer via enclosed systems. Particulates are released from the mixer, compounding station, charge conveyor, and drop mill. Two dust collectors serve the mixer. One collector serves the mixer charge door and ram chamber. The other dust collector serves the compounding station, mixer drop gate, mixer dust seal hoods, and drop mill. Both dust collectors discharge to a filter room that will provide additional air filtering capacity prior to discharge to the atmosphere. The emissions from SN-06 are discharged to Filter Room #2 where additional filtration is provided prior to discharge to the atmosphere. The emissions from SN-14 and SN-38 are also discharged to Filter Room #2. Since the emissions co-mingle in the filter room, it is not possible to observe the opacity of the emissions from each source individually. Instead, the Plantwide Conditions contain an opacity limit and an observation requirement which applies to the discharge from Filter Room #2. Specific Conditions 14. Pursuant to '19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee

shall not exceed the emission rates set forth in the following table. The emission rates are effectively limited by Specific Condition #16.

Pollutant

lb/hr

ton/year

PM10

0.1

0.4

VOC

1.1

4.4 15. Pursuant to '18.801 of Regulation #18 and A.C.A. '8-4-203 as referenced by '8-4-304 and

'8-4-311, the permittee shall not exceed the emission rates set forth in the following table. The emission rates are effectively limited by Specific Condition #16.

45


Pollutant

lb/hr

ton/year

PM

0.1

0.4

1,1 Dichloroethene

0.001

0.003

1,3 Butadiene

0.002

0.01

2-Butanone (Methyl Ethyl Ketone)

0.028

0.11

4-Methyl-2-Pentanone (Methyl

Isobutyl Ketone)

0.147

0.58

Acetaldehyde

0.003

0.01

Acetophenone

0.011

0.04

Acrolein

0.004

0.02

Acrylonitrile

0.056

0.22

Aniline

0.002

0.01

Benzene

0.003

0.01

Bis(2-Ethylhexyl)phthalate

0.003

0.01

Bromoform

0.001

0.01

Carbon Disulfide

0.135

0.53


0.001

0.01

Carbonyl Sulfide

0.108

0.43

Chromium Compounds

0.001

0.01

Cumene

0.015

0.06

1,1-Dichloroethene

0.001

0.01

Ethyl benzene

0.021

0.08

Isooctane

0.004

0.02

46


Pollutant

lb/hr

ton/year

Isophorone 0.003 0.01

Methylene Chloride

0.185

0.73

m,p Xylene

0.069

0.27

Naphthalene

0.001

0.01

n-Hexane

0.052

0.21

o-Xylene

0.037

0.15

o-Toluidine

0.001

0.01

Phenol

0.003

0.01

Propylene Oxide

0.033

0.13

Styrene

0.020

0.08


0.038

0.15

Tetrachloroethylene

0.020

0.08

Toluene

0.111

0.44

1,1,1-Trichloroethane

0.004

0.01 16. Pursuant to '19.705 of Regulation #19, '18.1004 of Regulation #18, A.C.A. '8-4-203 as

referenced by '8-4-304 and '8-4-311, and 40 CFR 70.6, the permittee shall not exceed 19,000 tons of rubber compound produced at the banbury mixer (SN-06) for any consecutive twelve month period. (The amount of rubber processed is also limited by Specific Conditions #27 and #52.)

47

17. Pursuant to '19.705 of Regulation #19, 40 CFR Part 52 Subpart E, and '18.1004 of Regulation #18, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall maintain records which demonstrate compliance with the limit set in Specific Condition #16. These records may be used by the Department for enforcement purposes. The records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel upon request. An annual total and each individual month=s data shall be submitted in accordance with Plantwide Condition #17. (These records are also required


by Specific Conditions #28 and #53. One set of records may be used to demonstrate compliance with all three conditions.)

48

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 Boilers SN-24, SN-25

Source Description Steam is provided to the autoclave, conventional presses, the Circular Paint Line Dryer, and the caustic line using a Sellers boiler (SN-24), with a heat input capacity of 20.9 mmBTU/hr, installed in 1972, and a York Shipley boiler (SN-25), with a heat input capacity of 20.9 mmBTU/hr, installed in 1974. The Sellers boiler is capable of firing natural gas only. The York Shipley boiler is capable of firing natural gas or No. 2 fuel oil. Emissions associated with the York Shipley boiler represent the worst case operating scenario. Specific Conditions 18. Pursuant to '19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee

shall not exceed the emission rates set forth in the following table. The emission rates are effectively limited by Specific Conditions #23 through #25.

SN

Pollutant

lb/hr

ton/year

PM10

0.2

0.3

SO2

0.1

0.1

VOC

0.2

0.2

CO

1.8

2.6

24

NOx

2.1

3.1

PM10

0.9

3.9

SO2

11.3

49.5

VOC

0.2

0.5

CO

3.8

16.6

25

NOx

6.1

26.7

19. Pursuant to '19.503 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall not

exceed 20% opacity from SN-25 as measured by EPA Reference Method 9, while combusting fuel oil.

49

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 20. Pursuant to '19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall

conduct weekly observations of the opacity from SN-25 when combusting fuel oil and keep a record of these observations. If visible emissions are detected, then the permittee shall conduct a 6-minute opacity reading in accordance with EPA Reference Method 9. The results of these observations shall be kept on site and shall be made available to Department personnel upon request.


'8-4-311, the permittee shall not exceed 5% opacity from SN-24 or SN-25 as measured by EPA Reference Method 9, while combusting natural gas. Compliance with the opacity limit for SN-24 and SN-25 when combusting natural gas shall be met by compliance with Specific Conditions #44 for SN-24 and the natural-gas portion of the restrictions in Specific Condition #46 for SN-25.

22. Pursuant to '18.801 et seq of Regulation #19 and A.C.A. '8-4-203 as referenced by

'8-4-304 and '8-4-311, the permittee shall not exceed the emission rates set forth in the following table. The emission rates are effectively limited by Specific Conditions #23 through #25.

SN

Pollutant

lb/hr

ton/year

24

PM

0.2

0.3

25

PM

0.9

3.9 23. Pursuant to '19.705 of Regulation #19, '18.1004 of Regulation #18, A.C.A. '8-4-203 as

referenced by '8-4-304 and '8-4-311, and 40 CFR 70.6, natural gas shall be the only fuel combusted in SN-24.

24. Pursuant to '19.705 of Regulation #19, '18.1004 of Regulation #18, A.C.A. '8-4-203 as

referenced by '8-4-304 and '8-4-311, and 40 CFR 70.6, natural gas or fuel oil may be combusted in SN-25.

25. 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 permittee shall not use any fuel oil which has a sulfur content in excess of 0.5% in source SN-25.

50

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 26. Pursuant to '19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the sulfur content of

the fuel oil shall be verified by testing or vendors= guarantees. The permittee shall maintain a record of each fuel shipment and the associated sulfur content. This record shall be updated with each shipment, kept on site, shall be made available to Department personnel upon request and may be used by the Department for enforcement purposes. This report shall be submitted to the Department in accordance with General Provision #7.

51


Conventional and Injection Presses

SN-26

Source Description Rubber preforms from the tubers and extruders are combined with metal inserts at the conventional and injection presses to form molded rubber parts. This source currently consists of 29 conventional and 31 injection presses. Specific Conditions 27. Pursuant to '19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee

shall not exceed the emission rates at source SN-26 as set forth in the following table. The emission rates are effectively limited by Specific Conditions #29, #31, #33, #34, #36, and #38.

Pollutant

lb/hr

ton/year

PM10

0.1

0.4

VOC

58.9


'8-4-311, the permittee shall not exceed the emission rates at source SN-26 as set forth in the following table. The emission rates are effectively limited by Specific Conditions #29, #31, #33, #34, #36, and #38.

Pollutant

lb/hr ton/year

PM

0.1

0.4

1,1-Dichloroethene

0.10

0.20

1,1,1-Trichloroethane

3.42

6.77

1,3 Butadiene

0.25

0.49


0.51

1.02

52


Pollutant

lb/hr

ton/year

53

4-Methyl-2-Pentanone (Methyl Isobutyl Ketone) 5.75 11.38

Acetaldehyde

0.10

0.19

Acetophenone

4.22

8.35

Acrolein

0.04

0.08

Acrylonitrile

0.29

0.57

Aniline

0.09

0.16

Benzene

0.05

0.11

Benzidine

0.04

0.09

bis(2-Ethylhexyl)phthalate

0.17

0.34

Carbon Disulfide

12.69

35.11


8.78

17.38

Carbonyl Sulfide

4.21

8.34

Chloroform

0.12

0.24

Chloromethane

0.07

0.15

Cumene

0.03

0.05

Di-n-butylphthalate

0.09

0.18

Ethyl benzene

0.05

0.10

Hexachlorobutadiene

0.01

0.01

Isooctane

0.05

0.09

Methylene Chloride

0.35

0.93

m,p Xylene

0.17

0.33

Naphthalene

0.04

0.08


Pollutant

lb/hr

ton/year

n-Hexane 2.88 5.69

o-Xylene

0.18

0.35

o-Toluidene

0.04

0.08

Propylene Oxide

1.00

1.98

Styrene

0.80

1.58


1.50

2.96

Tetrachloroethylene (Perchloroethlyene)

0.13

0.26

Toluene

0.38

0.75 29. Pursuant to '19.503 of Regulation #18 and 40 CFR Part 52 Subpart E, the permittee shall not

exceed 20% opacity from SN-26 as measured by EPA Reference Method 9. 30. Pursuant to '19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall

conduct weekly observations of the opacity from SN-26 and keep a record of these observations. If visible emissions are detected, then the permittee shall conduct a 6-minute opacity reading in accordance with EPA Reference Method 9. The results of these observations shall be kept on site and shall be made available to Department personnel upon request.


referenced by '8-4-304 and '8-4-311, and 40 CFR 70.6, the permittee shall not exceed 19,000 tons of rubber processed in the conventional and injection presses (SN-26) during any consecutive twelve month period. (The amount of rubber processed is also limited by Specific Condition #16)

32. Pursuant to '19.705 of Regulation #19, 40 CFR Part 52 Subpart E, '18.1004 of Regulation

#18, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall maintain records of amount of rubber processed on the conventional and injection presses which demonstrate compliance with the limit set in Specific Condition #52. These records may be used by the Department for enforcement purposes. The records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel upon request. An annual total and each individual month=s data shall be submitted in accordance

54


with Plantwide Condition #17. (These records are also required by Specific Conditions #16 and #27. One set of records may be used to demonstrate compliance all three conditions.)


'8-4-311 and 40 CFR 70.6, the permittee shall not use any mold lube/coating which contains more than 6.59 pounds VOCs per gallon.

34. Pursuant to '19.705 of Regulation #19, #18.1004 of Regulation #18, A.C.A. '8-4-203 as

referenced by '8-4-304 and '8-4-311, and 40 CFR 70.6, the permittee shall not use in excess of 5,600 gallons of mold lube/coating at (SN-26) during any consecutive twelve month period.


#18, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall maintain records of amount of mold lube/coating used which demonstrate compliance with the limit set in Specific Condition #55. These records may be used by the Department for enforcement purposes. The records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel upon request. An annual total and each individual month=s data shall be submitted in accordance with Plantwide Condition #17.


referenced by '8-4-304 and '8-4-311, and 40 CFR 70.6, the permittee shall not use any color coding coating which contains more than 8.34 pounds VOCs per gallon.


'8-4-311, the permittee shall not use any color coding coating which contains more than 0.33 pounds ethylene glycol per gallon.


referenced by '8-4-304 and '8-4-311, and 40 CFR 70.6, the permittee shall not use in excess of 2,500 gallons of color coding (SN-26) during any consecutive twelve month period.


#18, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall maintain records of amount of color coding used which demonstrate compliance with the limit set in Specific Condition #59. These records may be used by the Department for enforcement purposes. The records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel upon request. An annual total and each individual month=s data shall be submitted in accordance with Plantwide Condition #17.

55


Autoclave

SN-28

Source Description Some rubber preforms from the tubers and extruder are cured in the autoclave. Specific Conditions 40. Pursuant to '19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee

shall not exceed the emission rates set forth in the following table. The emission rates are effectively limited by Specific Condition #44.

Pollutant

lb/hr

ton/year

PM10

0.1

0.4

VOC

0.3


'8-4-311, the permittee shall not exceed the emission rates at source SN-28 as set forth in the following table. The emission rates are effectively limited by Specific Condition #44.

Pollutant

lb/hr

ton/year

PM

0.1

0.4

1,3 Butadiene

0.01

0.01


0.02

0.03 4-Methyl-2-Pentanone (Methyl Isobutyl Ketone)

0.01

0.01

Acetophenone

0.01

0.01

Aniline

0.01

0.01

Benzene

0.02

0.02

bis(2-Ethylhexyl)phthalate

0.01

0.01

56


Pollutant

lb/hr

ton/year

Carbon Disulfide

4.89

6.82

Carbonyl Sulfide

0.04

0.06

Ethyl benzene

0.06

0.08

Isooctane

0.01

0.01

Isophorone

0.01

0.01

Methylene Chloride

0.02

0.02

m,p Xylene

0.20

0.28

n-Hexane

0.15

0.21

o-Xylene

0.11

0.15

Tetrachloroethylene

0.06

0.08

Toluene

0.32

0.45


exceed 20% opacity from SN-28. Opacity shall be measured by EPA Reference Method 9. 43. Pursuant to '19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall

conduct weekly observations of the opacity from SN-28 and keep a record of these observations. If visible emissions are detected, then the permittee shall conduct a 6-minute opacity reading in accordance with EPA Reference Method 9. The results of these observations shall be kept on site and shall be made available to Department personnel upon request. The observations shall be made at the point of greatest opacity in that portion of the plume where condensed water vapor is not present.


referenced by '8-4-304 and '8-4-311 and 40 CFR 70.6, the permittee shall not exceed 2,300,000 pounds of rubber processed in the autoclave (SN-28) during any consecutive twelve month period.

57

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 45. Pursuant to '19.705 of Regulation #19, 40 CFR Part 52 Subpart E, '18.1004 of Regulation

#18, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall maintain records of rubber throughput through the autoclave which demonstrate compliance with the limit set in Specific Condition #65. These records may be used by the Department for enforcement purposes. The records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel upon request. An annual total and each individual month=s data shall be submitted in accordance with Plantwide Condition #17.

58

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 Caustic Cleaning/Phosphate Line SN-32

Source Description

Metal inserts for the molded rubber products are cleaned and undergo phosphate coating. Three heated tanks on the caustic line are equipped with a common roof exhaust. The acid tank is equipped with a fume scrubber and mist eliminator which discharges outside the building. Specific Conditions 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, the permittee shall not exceed the emission rates set forth in the following table. The emission rates are effectively limited by Specific Condition #75 and #76.

SN

Pollutant

lb/hr

ton/year

32


0.1

0.4


exceed 20% opacity from SN-32 as measured by EPA Reference Method 9. 48. Pursuant to '19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall

conduct weekly observations of the opacity from SN-32 and keep a record of these observations. If visible emissions are detected, then the permittee shall conduct a 6-minute opacity reading in accordance with EPA Reference Method 9. The results of these observations shall be kept on site and shall be made available to Department personnel upon request.


'8-4-311, the permittee shall maintain a water flow rate of 35 gallons per minute in the scrubber (SN-32).


'8-4-311, phosphoric acid solution in the acid bath on the caustic cleaning/phosphate line shall not exceed 15% phosphoric acid by volume.

59

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 51. Pursuant to '18.1004 of Regulation #18 and A.C.A. '8-4-203 as referenced by '8-4-304 and

'8-4-311, the permittee shall maintain records to demonstrate compliance with Specific Conditions #49 and #50. The records for water flow rate shall be updated once per shift, and the phosphoric acid percent records updated once per month. These records shall be kept on site, and shall be provided to Department personnel upon request. Each month=s individual data shall be submitted in accordance with Plantwide Condition #17.

Pyrolytic Oven SN-33

Source Description

60

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 A Pyrolytic Oven is used to clean Chain-on-Edge fixtures. The oven burns adhesives off of the fixtures. The oven is rated at 0.40 MMBtu/hr and is fired by natural gas. Emissions from the oven are controlled by an afterburner. Specific Conditions 52. Pursuant to '19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee

shall not exceed the emission rates at source set forth in the following table. The emission rates are effectively limited by Specific Conditions #48 and #50.

Pollutant

lb/hr

ton/year

PM10

1.1

4.4

SO2

0.4

1.6

VOC

0.5

1.9

CO

1.5

6.4

NOx

0.5


'8-4-311, the permittee shall not exceed the emission rates at source set forth in the following table. The emission rates are effectively limited by Specific Conditions #48 and #50.

Pollutant

lb/hr

ton/year

PM

1.1

4.4 54. Pursuant to '19.503 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall not

exceed 20% opacity from SN-33 as measured by EPA Reference Method 9. Compliance with the opacity limit for SN-33 shall be met by compliance with Specific Condition #81.


referenced by '8-4-304 and '8-4-311, and 40 CFR 70.6, the pyrolytic oven shall only be fired by natural gas.

61

Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 56. Pursuant to '19.705 of Regulation #19, '18.1004 of Regulation #18, A.C.A. '8-4-203 as

referenced by '8-4-304 and '8-4-311, and 40 CFR '70.6, the afterburner which controls emissions from the pyrolytic oven shall be maintained as a minimum temperature of 1400 degrees Fahrenheit at all times when the oven is operating.

62


SECTION V: COMPLIANCE PLAN AND SCHEDULE Cooper-Standard Automotive Company, Engineered Products Division is in compliance with the applicable regulations cited in the permit application. Cooper-Standard Automotive Company, Engineered Products Division 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.

63


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 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. 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.

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Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 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. 7. Pursuant to '18.801 of Regulation #18, the permittee shall not cause or permit the emission of

air contaminants, including odors or water vapor and including an air contaminant whose emission is not otherwise prohibited by Regulation #18, if the emission of the air contaminant constitutes air pollution within the meaning of A.C.A. '8-4-303.

8. Pursuant to '18.901 of Regulation #18, the permittee shall not conduct operations in such a

manner as to unnecessarily cause air contaminants and other pollutants from becoming airborne.


'8-4-311, the permittee shall not exceed 5% opacity from Filter Room #1 (SN-39 and SN-40 discharge to this filter room). Opacity shall be measured by EPA Reference Method 9.


'8-4-311, the permittee shall conduct weekly observations of the opacity from Filter Room #1 and keep a record of these observations. If visible emissions are detected, then the permittee shall conduct a 6-minute opacity reading in accordance with EPA Reference Method 9. The results of these observations shall be kept on site and shall be made available to Department personnel upon request.


'8-4-311, the permittee shall not exceed 5% opacity from Filter Room #2 (SN-06, SN-14, and SN-38 discharge to this filter room). Opacity shall be measured by EPA Reference Method 9.


'8-4-311, the permittee shall conduct weekly observations of the opacity from Filter Room #2 and keep a record of these observations. If visible emissions are detected, then the permittee shall conduct a 6-minute opacity reading in accordance with EPA Reference Method 9. The results of these observations shall be kept on site and shall be made available to Department personnel upon request.


'8-4-311, the permittee shall not exceed 5% opacity from Filter Room #3 (SN-39 and SN-40 discharge to this filter room). Opacity shall be measured by EPA Reference Method 9.


'8-4-311, the permittee shall conduct weekly observations of the opacity from Filter Room #3 and keep a record of these observations. If visible emissions are detected, then the permittee

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shall conduct a 6-minute opacity reading in accordance with EPA Reference Method 9. The results of these observations shall be kept on site and shall be made available to Department personnel upon request.


'8-4-311, the permittee shall not exceed 0.424 pounds of methylene diphenyl diisocyantate (MDI) usage during any 24-hour period.


'8-4-311, the permittee shall maintain records to demonstrate compliance with the methylene diphenyl diisocyanate limit in Plantwide Condition 15. These records shall be updated daily, kept on site, and made available to Department personnel upon request.

17. Pursuant to '19.705 of Regulation 19 and 40 CFR Part 52 Subpart E, the semi-annual reports

required by this permit shall be submitted to the Department at the address listed in General Provision #7 by July 31 and January 31 of each calendar year.

Title VI Provisions 18. 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.

19. 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.

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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.

20. 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.

21. 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.

22. 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.

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Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 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 May 16, 2002.

Description

Category

Laboratory Equipment used for routine chemical or

physical analysis

A-5

Cured Part Grinding

A-13

Sandblaster

A-13

Mold Oven (former SN-09)

A-13

Compounding Area (former SN-14)

A-13

6-inch Tuber (former SN-16)

A-13

Pin Barrel Tuber (former SN-34)

A-13

Preformer Extruder former SN-35)

A-13

Mold Cleaner (former SN-17)

A-13

Wheelabrator (former SN-18)

A-13

10,000 gal. process oil storage tanks (former SN-21a,

21b, 21c)

A-3

8,820 gal. waste oil storage tank (former SN-22)

A-3

Caustic Cleaning/Phosphate Line (former SN-32)

A-13

Carbon Black Handling System (former SN-38)

A-13

Mixer Dip Mixing and Dip Tank (former SN-39)

A-13

Mixing Area Vacuum System (former SN-40)

A-13

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Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 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.

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Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 SECTION VIII: GENERAL PROVISIONS 1. Pursuant to 40 C.F.R. 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 C.F.R. 70.6(a)(2) and '26.7 of the Regulations of the Arkansas Operating Air

Permit Program (Regulation 26), 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 '26.4 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 C.F.R. 70.6(a)(1)(ii) and '26.7 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 C.F.R. 70.6(a)(3)(ii)(A) and '26.7 of Regulation #26, records of monitoring

information required by this permit shall include the following:

i. The date, place as defined in this permit, and time of sampling or measurements; ii. The date(s) analyses were performed; iii. The company or entity that performed the analyses; iv. The analytical techniques or methods used; v. The results of such analyses; and vi. The operating conditions existing at the time of sampling or measurement.

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Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 6. Pursuant to 40 C.F.R. 70.6(a)(3)(ii)(B) and '26.7 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 C.F.R. 70.6(a)(3)(iii)(A) and '26.7 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 C.F.R. 70.6(a)(3)(iii)(B), '26.7 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 occurrence. The initial report may be made by telephone and shall include:

i. The facility name and location, ii. The process unit or emission source which is deviating from the permit limit, iii. The permit limit, including the identification of pollutants, from which deviation

occurs, iv. The date and time the deviation started, v. The duration of the deviation, vi. The average emissions during the deviation, vii. The probable cause of such deviations, viii. Any corrective actions or preventive measures taken or being taken to prevent such

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

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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 C.F.R. 70.6(a)(5) and '26.7 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 C.F.R. 70.6(a)(6)(i) and '26.7 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 C.F.R. 70.6(a)(6)(ii) and '26.7 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.

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Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 12. Pursuant to 40 C.F.R. 70.6(a)(6)(iii) and '26.7 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 termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition.

13. Pursuant to 40 C.F.R. 70.6(a)(6)(iv) and '26.7 of Regulation #26, this permit does not convey

any property rights of any sort, or any exclusive privilege. 14. Pursuant to 40 C.F.R. 70.6(a)(6)(v) and '26.7 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 C.F.R. 70.6(a)(7) and '26.7 of Regulation #26, the permittee shall pay all

permit fees in accordance with the procedures established in Regulation #9. 16. Pursuant to 40 C.F.R. 70.6(a)(8) and '26.7 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 C.F.R. 70.6(a)(9)(i) and '26.7 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 C.F.R. 70.6(b) and '26.7 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.

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Cooper-Standard Automotive Company, Engineered Products Division Permit No. 818-AOP-R5 AFIN: 70-00036 19. Pursuant to 40 C.F.R. 70.6(c)(1) and '26.7 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 C.F.R. 70.6(c)(2) and '26.7 of Regulation #26, the permittee shall allow an

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

i. 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;

ii. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;

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

iv. 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 C.F.R. 70.6(c)(5) and '26.7 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:

i. The identification of each term or condition of the permit that is the basis of the

certification; ii. The compliance status; iii. Whether compliance was continuous or intermittent; iv. 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

v. 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 '26.7 of Regulation #26, nothing in this permit shall alter or affect the following:

i. The provisions of Section 303 of the Act (emergency orders), including the authority of the Administrator under that section;

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ii. The liability of the permittee for any violation of applicable requirements prior to or at the time of permit issuance;

iii. The applicable requirements of the acid rain program, consistent with '408(a) of the Act; or

iv. 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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ATTACHMENT ONE

76

ATTACHMENT TWO

77

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: Cooper Tire & Rubber Company, Engineered Products Division (AFIN: 70-00036) operates a molded rubber products manufacturing facility located at 166 Cooper Drive in El Dorado, Arkansas. This first renewal of the Title V Operating Air Permit for this facility incorporates several modifications. Major changes include the re-evaluation of the VOC BACT limitation due to product specification requirements. Emission increases associated with this modification are: 5.8 tons per year (tpy) VOC, 17.38 tpy carbon tetrachloride, 8.61 tpy carbon disulfide, 5.10 tpy n-hexane, and 6.68 tpy 1,1,1-trichloroethane. Several other HAP emission rates have also increased by amounts ranging from 0.04 to 0.83 tpy. There are no increases in permitted production rates with this modification. The application has been reviewed by the staff of the Department and has 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 David Triplett, Engineer. Both Doug Szenher and David Triplett can be reached 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. A copy of the draft permit has also been placed at the Barton Library located at 200 East 5th Street in El Dorado, Union County, Arkansas 71730. This information may be reviewed 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. In order to be considered, the comments must be submitted within thirty (30) days of publication of this notice. Although the Department is not proposing to conduct a public hearing, one will be scheduled if significant comments on the permit provisions are received. If a hearing is scheduled, adequate public notice will be given in the newspaper of largest circulation in the county in which the facility in question is, or will be, located. The Director shall 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 Marcus C. Devine Director

operating air permit - adeq.state.ar.us

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