operating air permit - arkansas department of ... air permit pursuant to the regulations of the...

OPERATINGAIR PERMIT

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

Permit #: 268-AOP-R0

IS ISSUED TO:

Viskase Corporation2221 E. State Highway 198

Osceola, AR 72370Mississippi County

CSN:47-0115

THIS PERMIT AUTHORIZES THE ABOVE REFERENCED PERMITTEE TO INSTALL,OPERATE, AND MAINTAIN THE EQUIPMENT AND EMISSION UNITS DESCRIBED INTHE PERMIT APPLICATION AND ON THE FOLLOWING PAGES. THIS PERMIT ISVALID BETWEEN:

and

AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN.

Signed:

Keith A. Michaels Date

Viskase CorporationCSN: 47-0115Permit #:268-AOP-R0

2

SECTION I: INTRODUCTION

The process descriptions in Section I and elsewhere in this permit, are included for informationalpurposes only and do not include, contain, or create any limits, conditions, or provisionsapplicable to the facility or its operations.

Viskase Corporation operates a cellulose food casing plant located in Osceola, Arkansas. Production of cellulose food casings by the viscose process involves the reaction of a cellulosematerial, either cotton or wood pulp, with an aqueous sodium hydroxide solution. After an agingprocess, the alkali cellulose is reacted with carbon disulfide to form an intermediate compound,cellulose xanthate, which is subsequently dissolved in a dilute caustic solution to form a viscousfluid called “viscose”. After aging and filtering, the viscose is extruded into precision-sizedtubes which are passed through a series of acid baths where the cellulose is regenerated. Theextruded generated cellulose film is then purified, dried, reeled, and finished. Glycerine is addedas a plasticizer and humectant.

Emissions from the viscose process consist primarily of carbon disulfide and hydrogen sulfide. These gases occur during xanthation, coagulation, regeneration, and purification stages of theviscose process. Smaller amounts of carbon disulfide are also emitted during carbon disulfideunloading and transfer operations. Ammonia is released from the fibrous casing generationprocess and a small amount of glycerine emissions are released from dryer vents.

The Osceola facility operates two industrial on-site boilers (SN-02 and SN-03) with a combinedheat input of 100 million BTU/hr. These boilers generate steam for use in multiple productionoperations such as the acid bath evaporator systems, crystallizer, press water wash, glycerinehandling system, deaeration vacuum system, casing process dryers, and space heating. Theboilers are typically fired with natural gas but have the capability to fire No. 2 or No. 6 fuel oil.

A 340 horsepower emergency fire water pump (SN-05) is used in the event of a fire at theOsceola facility. Particulate matter, sulfur dioxide, nitrogen oxides, carbon monoxide,aldehydes, and unspecified volatile organic compounds are emitted during pump operation. Viskase also operates an on-site wastewater treatment plant to ensure wastewater is properlytreated prior to discharge to the Mississippi River. Calcium hydroxide is combined with thewater and fed as a lime slurry to neutralize process wastewater. The neutralized wastewater isequalized and clarified before being discharged. The lime is stored in a 150 ton silo equippedwith a baghouse (SN-04) which retains particulate emissions.

Other emissions from the facility include carbon disulfide fugitive emissions which occur duringunloading operations from tank cars or an intermodal portable tank into two (2) submergedstorage tanks; transfer of carbon disulfide from storage tanks to weigh scales; and weigh tankoperations. Several fuel oil, gasoline, raw material glycerine, and used oil storage tanks are also


3

present at the facility.

Specific pollutants were modeled and compared to the de minimis level for each specificpollutant to determine the impact on air quality. The results obtained did not exceed the levels ofsignificance for any of the modeled pollutants. A summary of facility wide emissions is providedin the following table. Specific emission unit information is located by the indicated crossreference pages.

Viskase is presently in compliance with the applicable requirements of the Arkansas AirPollution Control Code (Regulation 18) and the Arkansas State Implementation Plan for AirPollution Control (Regulation 19). Viskase proposes to comply with all applicable sections ofboth Regulations. Viskase also proposes to comply with all applicable sections of theRegulations of the Arkansas Operating Air Permit (Regulation 26) upon issuance of this permit.


4

EMISSION SUMMARY

SourceNo.

Description Pollutant Emission Rates CrossReference

Pagelb/hr tpy

Total Allowable Emissions PM10

SO2

VOCCONOX

TRS H2S* CS2*ammonia

sulfur oxidesaldehydes

9.5104.6

1.36.1

46.7254.056.0

238.89.00.70.2

39.8458.2

3.922.5

185.2954.0211.0901.631.01.70.4

SN-01 Viscose Process Vent TRS H2S* CS2*

ammonia

254.056.0

238.09.0

954.0211.0898.0

31.0

8

SN-02 Industrial BoilerNatural Gas

PM10

SO2

VOCCONOX

0.20.10.21.87.0

0.90.50.97.9

30.7

9

Industrial BoilerNo. 2 Fuel Oil

PM10

SO2

VOCCONOX

0.852.3

0.11.97.4

3.5229.1

0.58.4

32.5


PM10

SO2

VOCCONOX

4.351.7

0.11.7

18.1

18.8226.5

0.57.5

79.3


5

EMISSION SUMMARY

SourceNo.

Description Pollutant Emission Rate CrossReference

Page(s)lb/hr ton/yr

SN-03 Industrial BoilerNatural Gas

PM10

SO2

VOCCONOX

0.20.10.21.87.0

0.90.50.97.9

30.7

9


PM10

SO2

VOCCONOX

0.852.30.11.97.4

3.5229.1

0.58.4

32.5


PM10

SO2

VOCCONOX

4.351.70.11.7

18.1

18.8226.4

0.57.5

79.3

SN-04 Lime Silo PM10 0.1 0.3 12

SN-05 Emergency FireWater Pump

PM10sulfur oxides

VOCCONOX

aldehydes

0.80.70.92.3

10.50.2

5.72.1

26.40.41.71.9

13

SN-06 Carbon DisulfideFugitive Emissions

CS2* 0.8 3.6 14

CS2 is carbon disulfide.H2S is hydrogen sulfide.TRS is total reduced sulfur ( CS2 and H2S).* Carbon disulfide and hydrogen sulfide emissions are included in total TRS emissions. Note: Carbon disulfide is a VOC but has been included in TRS. For purposes of this table, the CS2 emissions areidentified on their own line, authorized independently, and accordingly are not included in the VOC information.


6

SECTION II: PERMIT HISTORY

The following facility permit history is provided for background informational purposes only,and does not include, contain, or create any limits, conditions, or provisions applicable to thefacility or its operations. It is a summary and does not purport to represent a complete orcomprehensive discussion of the facility’s entire permit history.

268-A was the first air permit issued to the facility on October 21, 1974. 268-A permitted theconstruction and operation of the Union Carbide Corporation cellulose food casing facility. Carbon disulfide and hydrogen sulfide emissions were limited to 175 pounds per hour and 26.2pounds per hour, respectively.

On February 25, 1988, air permit 268-AR-1 was issued to Viskase Corporation. This permit wasissued to record the change of ownership from Union Carbide Corporation to ViskaseCorporation. Emission estimates for carbon disulfide, hydrogen sulfide, sulfur dioxide, nitrogenoxides, particulate matter, and other products of combustion were identified in a relatedsummary report relative to permit application.

268-AR-2 was issued to Viskase on October 17, 1996. This permit modification allowed theOsceola facility to operate existing equipment at a capacity that reflected expected marketdemand. The permit additionally supplemented and updated information about existing sourcesat the facility.

268-AOP-R0 is the first operating permit issued to Viskase Corporation under Regulation 26. No physical changes in the method of operation at the facility occurred prompting this permitissuance. However, Viskase Corporation is including glycerine emissions which have not beenpreviously identified in other air permitting efforts.


SECTION III: EMISSION UNIT INFORMATION


8

SN-01 Viscose Process Vent

Source Description

Carbon disulfide and hydrogen sulfide are emitted during the xanthation, coagulation,regeneration, and purification stages of the viscose process. These gases are then vented to theatmosphere through the viscose process vent (144 foot stack). Smaller amounts of carbondisulfide are emitted during carbon disulfide unloading and transfer operations. Ammonia isreleased from the fibrous casing regeneration process. This source has been in operation at thefacility since 1976. There are no control devices associated with this source.

Production of the cellulose food casings involves the reaction of a cellulose material with anaqueous sodium hydroxide solution. After aging, the alkali cellulose is reacted with carbondisulfide to form an intermediate compound, cellulose xanthate, which is subsequently dissolvedin a dilute caustic solution to form a viscous fluid called “viscose”. After aging and filtering, theviscose is extruded into precision-sized tubes which are passed through a series of acid bathswhere the cellulose is regenerated. The extruded regenerated cellulose film is then purified,dried, reeled, and finished. Glycerine is added as a plasticizer and humectant.

Specific Conditions

1. Pursuant to §18.10 of the Arkansas Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the air contaminant emission rates set forth in the followingtable.

SN-# Pollutant lb/hr tpy Opacity

01 TRS* H2S CS2

ammonia

254.056.0

238.09.0

954.0211.0898.0

31.0

N/A

*TRS( total reduced sulfur) includes H2S and CS2

2. Pursuant to A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 and 40CFR 70.6, the permittee shall not consume in excess of 2.38 million pounds of CS2during any consecutive twelve month period.


9

3. Pursuant to §19.7 of Regulation 19, 40 CFR Part 52, Subpart E, the permittee shallmonitor and record the monthly amount of CS2 consumed at the facility, as determinedfrom weigh scales. These records shall be updated on a monthly basis, shall be kept onsite, and shall be provided to Department personnel upon request. Under normalconditions, operations at the facility are continuous, operating 24-hours per day yearround.


10

SN-02 and SN-03 Industrial Boilers

Source Description

The facility utilizes two industrial on-site boilers each with a heat input capacity of 50MMBTU/hr. The boilers generate steam for use in multiple production operations such as theacid bath evaporator systems, crystallizer, process water wash, glycerine handling system,deaeration vacuum system casing process dryers, and space heating. The boilers are currentlypermitted to operate under alternate operating scenarios. Scenario I represents natural gascombustion, Scenario II represents No. 2 Fuel Oil combustion, and Scenario III represents No. 6Fuel Oil combustion. The boilers are typically fired with natural gas. Both boilers have been inoperation at the facility since 1976. No control devices are associated with these sources.

Specific Conditions

4. Pursuant to §19.5 of the Regulations of the Arkansas State Implementation Plan for AirPollution Control (Regulation 19) and Part 52, Subpart E, the permittee shall not exceedthe emission rates set forth in the following table. Compliance with these limits shall bedemonstrated by compliance with the throughput limits.

SN-# Pollutant lb/hr ton/yr

02 Boiler #1: Natural Gas Combustion

PM10

SO2

VOCCONOX

0.20.10.21.87.0

0.90.50.97.9

30.7

02 Boiler #1: No. 2 Fuel Oil Combustion

PM10

SO2

VOCCONOX

0.852.3

0.11.97.4

3.5229.1

0.58.4

32.5


11

SN-# Pollutant lb/hr ton/yr


PM10

SO2

VOCCONOX

4.351.7

0.11.7

18.1

18.8226.5

0.57.5

79.3

03 Boiler #2: Natural Gas Combustion

PM10

SO2

VOCCONOX

0.20.10.21.87.0

0.90.50.97.9

30.7


PM10

SO2

VOCCONOX

0.852.3

0.11.97.4

3.5229.1

0.58.4

32.5


PM10

SO2

VOCCONOX

4.351.7

0.11.7

18.1

18.8226.4

0.57.5

79.3

5. Pursuant to §18.5 of Regulation 18, the permittee shall not exceed 20 percent opacityfrom SN-02 and SN-03. Compliance with the opacity limit may be demonstrated throughevidence that the source is burning natural gas or measurement by EPA ReferenceMethod 9.


12

6. Pursuant to §19.5 of Regulation 19 and Part 52, the permittee shall not exceed 1.0percent sulfur content in the No. 2 and No. 6 Fuel Oils used to fire the boilers. The sulfurcontent of the fuel oil used shall be verified by testing or vendor guarantees. Theserecords shall be available for Department review and submitted to the Department everysix months.

7. Pursuant to A.C.A §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, and 40CFR 70.6, when operating under Scenario II, No. 2 fuel oil usage shall be limited on amonthly basis to 548,000 gallons per month and shall not exceed the annual limit of6,576,000 gallons per any consecutive twelve (12) month period.

8. Pursuant to A.C.A §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, and 40CFR 70.6, when operating under Scenario III, No. 6 fuel oil usage shall be limited on amonthly basis to 490,000 gallons per month and shall not exceed the annual limit of5,800,000 gallons per any consecutive twelve (12) month period.

9. Pursuant to §19.7 of Regulation 19, the permittee shall maintain records whichdemonstrate compliance with the No. 2 and No. 6 fuel oil usage limits specified inSpecific Condition No. 7 and No. 8 and such records may be used by the Department forenforcement purposes. The records shall be updated on a monthly basis, shall be kept onsite, shall be provided to Department personnel upon request, and an annual total andeach individual month’s data shall be submitted in accordance with General Provision 7.

10. Pursuant to General Condition 17, the permittee shall contemporaneously with making a

change from one operating scenario to another, record in a log at the permitted facility arecord of the scenario under which the facility or source is operating.


13

SN-04 Lime Silo

Source Description

Viskase operates an on-site wastewater treatment plant to ensure wastewater is properly treatedprior to discharge into the Mississippi River. Calcium hydroxide is combined with water and fedas a lime slurry to neutralize process wastewater. The neutralized wastewater is equalized andclarified before being eventually discharged to the river. The lime is stored in a 150 ton siloequipped with a baghouse (SN-04). The baghouse has a manufacturer design efficiency rating of 99.7 percent efficient in retaining particulate matter. This silo has been in operation at thefacility since 1976

Specific Conditions

11. Pursuant to §19.5 of the Regulations of the Arkansas State Implementation Plan for AirPollution Control (Regulation 19) and Part 52,Subpart E, the permittee shall not exceedthe emission rates set forth in the following table.

Pollutant lb/hr tpy

PM/PM10 0.1 0.3

12. Pursuant to §18.5 of Regulation 18, the permittee shall not exceed 20 percent opacityfrom SN-04 as measured by EPA Reference Method 9.

13. Pursuant to §19.3(c) of Regulation 19, the permittee shall operate the baghouse withinthe design specifications and at all times when the equipment is in operation.


14

SN-05 Emergency Fire Water Pump

Source Description

A 340 horsepower emergency fire water pump will be used in the event of a fire at the facility. Particulate matter, sulfur dioxide, nitrogen oxides, carbon monoxide, aldehydes, and unspecifiedvolatile organic compounds are typically emitted during the operation of the pump. The pump isnormally tested one hour a week, fifty-two weeks a year. The pump is additionally periodicallyused as a source of water for other operations and maintenance activities at the facility.

Specific Conditions

14. Pursuant to §19.5 of the Regulations of the Arkansas State Implementation Plan for AirPollution Control (Regulation 19) and Part 52, the permittee shall not exceed theemission rates set forth in the following table.

Pollutant lb/hr ton/yr

COVOCNOX

AldehydesSulfur Oxides

PM10

2.30.9

10.50.20.70.8

5.72.1

26.40.41.71.9

15. Pursuant to §18.5 of Regulation 18, the permittee shall not exceed 20percent opacity from SN-05 as measured by EPA Reference Method 9.

16. Pursuant to §19.5 of Regulation 19, the hours of operation for SN-05shall not exceed 5000 hours during any consecutive twelve monthperiod.

17. Pursuant to §19.7 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shall maintain records which demonstrate compliancewith the limit set in Specific Condition 16. These records may be usedby the Department for enforcement purposes. The records shall be


15

updated on a monthly basis, shall be kept on site, and shall be provided toDepartment personnel upon request.


16

SN-06 Carbon Disulfide Fugitive EmissionsSN-06 Carbon Disulfide Fugitive EmissionsSN-06 Carbon Disulfide Fugitive EmissionsSN-06 Carbon Disulfide Fugitive Emissions

Source DescriptionSource DescriptionSource DescriptionSource Description

Carbon disulfide fugitive emissions occur due to unloading operations fromtank cars or an intermodal portable tank into two submerged storage tanks;transfer of carbon disulfide from storage tanks to weigh scales; and weigh tankoperations. Fugitive carbon disulfide emissions are also emitted from thefacility’s wastewater treatment activities.

Specific ConditionsSpecific ConditionsSpecific ConditionsSpecific Conditions

18. Pursuant to §19.5 of the Regulations of the Arkansas State Implementation Plan for AirPollution Control (Regulation 19) and Part 52, Subpart E, the permittee shall notexceed the emission rates at SN-6 set forth in the following table.

PollutantPollutantPollutantPollutant lb/hrlb/hrlb/hrlb/hr ton/yrton/yrton/yrton/yr

CS2 0.8 3.6


17

PLANTWIDE CONDITIONSPLANTWIDE CONDITIONSPLANTWIDE CONDITIONSPLANTWIDE CONDITIONS

1. Pursuant to §19.4(o) of Regulation 19, the Director shall be notified in writing withinthirty (30) days after construction has commenced, construction is complete, theequipment and/or facility is first placed in operation, and the equipment and/or facilityfirst reaches the target production rate.

2. Pursuant to §19.4(q) of Regulation 19, construction must commence within eighteen (18)months after the approval of the permit application. Records must be kept for two yearswhich will enable the Department to determine compliance with the terms of this permit--such as hours of operation, throughput, upset condition, and continuous monitoring data. The records may be used, at the discretion of the Department, to determine compliancewith the conditions of the permit.

3. Pursuant to §19.7 of Regulation 19, each emission point for which an emission testmethod is specified in this permit shall be tested in order to determine compliance withthe emission limitations contained herein within sixty (60) days of achieving themaximum production rate, but in no event later than 180 days after initial start-up of thepermitted source. The permittee shall notify the Department of the scheduled date ofcompliance testing at least fifteen (15) days in advance of such test. Compliance testresults shall be submitted to the Department within thirty (30) days after the completedtesting. The permittee shall provide:

(1) Sampling ports adequate for applicable test methods(2) Safe sampling platforms(3) Safe access to sampling platforms(4) Utilities for sampling and testing equipment

4. Pursuant to A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304, the equipment, controlapparatus and emission monitoring equipment shall be operated within their designlimitation and maintained in good condition at all times.

5. 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 the following specific conditions:

a. Regulation 19 - Compilation of Regulations of the Arkansas State ImplementationPlan for Air Pollution Control


18

b. Regulation 26 - Regulations of the Arkansas Operating Air Permit Program

c. The following requirements have been specifically identified as not applicable, based upon information submitted by the permittee in an application dated August 9, 1996.

Description of Non-ApplicableRegulations

Regulation Basis

New Source Performance Standardsfor Fossil-fuel fired Steam

Generators

40 CFR Part 60subpart D

The boilers have individual heatinput capacities less than 250

MMBtu/hr.

New Source Performance Standardsfor Industrial-Commercial-

Institutional Steam Generating Units

40 CFR Part 60subpart Db

The boilers were installed beforeJune 19, 1984, and have individualheat input capacities less than 100

MMBtu/hr.

New Source Performance Standardsfor Industrial-Commercial-

Institutional Steam Generating Units

40 CFR Part 60subpart Dc

The boilers were installed beforeJune 9, 1989.

NSPS for Storage Vessels forPetroleum Liquids

40 CFR Part 60subpart K

The stored liquids have a true vaporpressure less than 1.5 psia.

NSPS for Storage Vessels forPetroleum Liquids

40 CFR Part 60subpart Ka

The storage tanks were constructedprior to the effective date of May 18,

1978.

NSPS for Volatile Organic LiquidStorage Vessels

40 CFR Part 60subpart Kb

VOC storage tanks do not meet thestorage capacity applicability

requirement.

d. 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


19

Air Act.


20

SECTION IV: DE MINIMIS LISTSECTION IV: DE MINIMIS LISTSECTION IV: DE MINIMIS LISTSECTION IV: DE MINIMIS LIST

Pursuant to §26.3(d) of the Regulations of the Arkansas Operating Air Permit Program(Regulation 26), the following sources are below the de minimis emission levels. De minimisemission determinations rely upon the information submitted by the permittee in an applicationdated August 9, 1996.

* Emissions from laboratory equipment/vents used exclusively for routinechemical or physical analysis for quality control or environmental monitoring purposesprovided that the aggregate pollutant specific emissions from all suchequipment/vents considered insignificant do not exceed five tons per year and do not exceed anyhazardous air pollutant de minimis rate established pursuant to Section 112(g) of the federal CleanAir Act.* Glycerine and volatile organic chemical emissions from the dryer stack.* Chlorine cylinders* (1) 2000 gallon used oil tank* (2) 14,000 gallon raw material glycerine tanks* (5) fuel oil tanks- (1) 500 gallon gasoline tank, (1) 600 gallon tank, and (3)150,000 gallon tanks* (1) 500 gallon gasoline tank

Pursuant to §26.3(d) of Regulation 26, the following emission units, operations, or activities havebeen determined by the Department to be below the de minimis emission levels. Activitiesincluded in this list are allowable under this permit and need not be specifically identified.

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

2. Combustion emissions from propulsion of mobile sources and emissions from refuelingthese sources unless regulated by Title II and required to obtain a permit under Title V ofthe federal Clean Air Act, as amended. This does not include emissions from anytransportable units, such as temporary compressors or boilers. This does not includeemissions from loading racks or fueling operations covered under any applicable federalrequirements.

3. Air conditioning and heating units used for comfort that do not have applicable


1 Cleaning and painting activities qualify if they are not subject to VOC or HAP control requirements. Asphalt batchplant owners/operators must get a permit.

21

requirements under Title VI of the Act.

4. Ventilating units used for human comfort that do not exhaust air pollutants into theambient air from any manufacturing/industrial or commercial process.

5. Non-commercial food preparation or food preparation at restaurants, cafeterias, orcaterers, etc.

6. Consumer use of office equipment and products, not including commercial printers orbusinesses primarily involved in photographic reproduction.

7. Janitorial services and consumer use of janitorial products.

8. Internal combustion engines used for landscaping purposes.

9. Laundry activities, except for dry-cleaning and steam boilers.

10. Bathroom/toilet emissions.

11. Emergency (backup) electrical generators at residential locations.

12. Tobacco smoking rooms and areas.

13. Blacksmith forges.

14. Maintenance of grounds or buildings, including: lawn care, weed control, pest control,and water washing activities.

15. Repair, up-keep, maintenance, or construction activities not related to the sources’primary business activity, and not otherwise triggering a permit modification. This mayinclude, but is not limited to such activities as general repairs, cleaning, painting,welding, woodworking, plumbing, re-tarring roofs, installing insulation, paved/pavingparking lots, miscellaneous solvent use, application of refractory, or insulation, brazing,soldering, the use of adhesives, grinding, and cutting.1

16. Surface-coating equipment during miscellaneous maintenance and construction activities.


2"Moved by hand” means that it can be moved by one person without assistance of any motorized or non-motorizedvehicle, conveyance, or device.

3Brazing, soldering, and welding equipment, and cutting torches related to manufacturing and construction activitiesthat emit HAP metals are more appropriate for treatment as insignificant activities based on size or production thresholds. Brazing , soldering, and welding equipment, and cutting torches related directly to plant maintenance and upkeep and repair ormaintenance shop activities that emit HAP metals are treated as trivial and listed separately.

4Exemptions for storage tanks containing petroleum liquids or other volatile organic liquids are based on size andlimits including storage tank capacity and vapor pressure of liquids stored and are not appropriate for this list.

22

This activity specifically does not include any facility whose primary business activity issurface-coating or includes surface coating or products.

17. Portable electrical generators that can be “moved by hand” from one location to another.2

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

19. Brazing or soldering equipment related to manufacturing activities that do not result inemission of HAPs.3

20. Air Compressors and pneumatically operated equipment, including hand tools.

21. Batteries and battery charging stations, except at battery manufacturing plants.

22. Storage tanks, vessels, and containers holding or storing liquid substances that do notcontain any VOCs or HAPs.4

23. Containers of less than or equal to 5 gallons in capacity that do not emit any detectableVOCs or HAPs when closed. This includes filling, blending, or mixing of the contents ofsuch containers by a retailer.

24. Storage tanks, reservoirs, and pumping and handling equipment of any size containingsoaps, vegetable oils, grease, animal fat, and non-volatile aqueous salt solutions, providedappropriate lids and covers are used and appropriate odor control is achieved.

25. Equipment used to mix and package soaps, vegetable oil, grease, animal fat, and non-volatile aqueous salt solution, provided appropriate lids and covers are used andappropriate odor control is achieved.


23

26. Drop hammers or presses for forging or metalworking.

27. Equipment used exclusively to slaughter animals, but not including other equipment atslaughter-houses, such as rendering cookers, boilers, heating plants, incinerators, andelectrical power generating equipment.

28. Vents from continuous emission monitors and other analyzers.

29. Natural gas pressure regulator vents, excluding venting at oil and gas productionfacilities.

30. Hand-held applicator equipment for hot melt adhesives with no VOCs in the adhesive.

31. Equipment used for surface coating, painting, dipping, or spraying operations, containingless than 0.4 lb/gal VOCs, any hexavalent chromium, or that emit no more than 0.1 tpy ofall other HAPs.

32. Lasers used only on metals and other materials which do not emit HAPs in the process.

33. Consumer use of paper trimmers/binders.

34. Electric or steam-heated drying ovens and autoclaves, but not the emissions from thearticles or substances being processed in the ovens or autoclaves or the boiler deliveringthe steam.

35. Salt baths using non-volatile salts that do not result in emissions of any air pollutantcovered by this regulation.

36. Laser trimmers using dust collection to prevent fugitive emissions.

37. Bench-scale laboratory equipment used for physical or chemical analysis.

38. Routine calibration and maintenance of laboratory equipment or other analyticalinstruments.

39. Equipment used for quality control/assurance or inspection purposes, including samplingequipment used to withdraw materials for analysis.

40. Hydraulic and hydrostatic testing equipment.


24

41. Environmental chambers not using hazardous air pollutant gases.

42. Shock chambers, humidity chambers and solar simulators.

43. Fugitive emissions related to movement of passenger vehicles, provided the emissions arenot counted for applicability purposes and any required fugitive dust control plan or itsequivalent is submitted.

44. Process water filtration systems and demineralizers.

45. Demineralized water tanks and demineralizer vents.

46. Boiler water treatment operations, not including cooling towers.

47. Emissions from storage or use of water treatment chemicals, except for hazardous airpollutants or pollutants listed under regulations promulgated pursuant to Section 112(r) ofthe Act, for use in cooling towers, drinking water systems, and boiler water/feed systems.

48. Oxygen scavenging (de-aeration) of water.

49. Ozone generators.

50. Fire suppression systems.

51. Emergency road flares.

52. Steam vents and safety relief valves.

53. Steam leaks.

54. Steam cleaning operations.

55. Steam and microwave sterilizers.

56. Site assessment work to characterize waste disposal or remediation sites.

57. Miscellaneous additions or upgrades of instrumentation.

58. Emissions from combustion controllers or combustion shutoff devices.


25

59. Use of products for the purpose of maintaining motor vehicles operated by the facility,not including air cleaning units on such vehicles (i.e. antifreeze, fuel additives).

60. Stacks or vents to prevent escape of sanitary sewer gases through the plumbing traps.

61. Emissions from equipment lubricating systems (i.e. oil mist), not including storage tanks,unless otherwise exempt.

62. Residential wood heaters, cookstoves, or fireplaces.

63. Barbecue equipment or outdoor fireplaces used in conjunction with any residence orrecreation.

64. Log wetting areas and log fumes.

65. Periodic use of pressurized air for cleanup.

66. Solid waste dumpsters.

67. Emissions of wet lime from lime mud tanks, lime mud washers, lime mud piles, limemud filter and filtrate tanks, and lime mud slurry tanks.

68. Natural gas odoring activities unless the Department determines that a nuisance mayoccur.

69. Emissions from engine crankcase vents.

70. Storage tanks used for the temporary containment of materials resulting from anemergency reporting to an unanticipated release.

71. Equipment used exclusively to mill or grind coatings in roll grinding rebuilding, andmolding compounds where all materials charged are in paste form.

72. Mixers, blenders, roll mills, or calenders for rubber or plastic for which no materials inpowder form are added and in which no organic solvents, diluents, or thinners are used.

73. The storage, handling, and handling equipment for bark and wood residues not subject tofugitive dispersion offsite (this applies to equipment only).


26

74. Maintenance dredging of pulp and paper mill surface impoundments and ditchescontaining cellulosic and cellulosic derived biosolids and inorganic materials such aslime, ash, or sand.

75. Tall oil soap storage, skimming, and loading.

76. Water heaters used strictly for domestic (non-process) purposes.

77. Facility roads and parking areas, unless necessary to control offsite fugitive emissions.

78. Agricultural operations, including onsite grain storage.


27

SECTION V: GENERAL PROVISIONSSECTION V: GENERAL PROVISIONSSECTION V: GENERAL PROVISIONSSECTION V: GENERAL PROVISIONS

1. Pursuant to 40 C.F.R. 70.6(b)(2), any terms or conditions includedin this permit which specify and reference Arkansas Pollution Control& Ecology Commission Regulation 18 as the origin of and authorityfor the terms or conditions are not required under the Clean Air Actor any of its applicable requirements, and are not federallyenforceable under the Clean Air Act. Arkansas Pollution Control &Ecology Commission Regulation 18 was adopted pursuant to theArkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 etseq.). Any terms or conditions included in this permit which specifyand reference Arkansas Pollution Control & Ecology CommissionRegulation 18 as the origin of and authority for the terms orconditions are enforceable under this Arkansas statute.

2. Pursuant to 40 C.F.R. 70.6(a)(2) and §26.7 of the Regulations ofthe Arkansas Operating Air Permit Program (Regulation 26), thispermit shall be valid for a period of five (5) years beginning on thedate 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 tosubmit a complete application for permit renewal at least six (6)months prior to the date of permit expiration. Permit expirationterminates the permittee's right to operate unless a complete renewalapplication was submitted at least six (6) months prior to permitexpiration, in which case the existing permit shall remain in effectuntil the Department takes final action on the renewal application. The Department will not necessarily notify the permittee when thepermit 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 applicablerequirement of regulations promulgated under Title IV of the Act,both provisions are incorporated into the permit and shall be


28

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 shallinclude the following:

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

b. The date(s) analyses were performed;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 C.F.R. 70.6(a)(3)(ii)(B) and §26.7 of Regulation#26, records of all required monitoring data and supportinformation shall be retained for a period of at least 5 years fromthe date of the monitoring sample, measurement, report, orapplication. Support information includes all calibration andmaintenance records and all original strip-chart recordings forcontinuous monitoring instrumentation, and copies of all reportsrequired 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 6months. If no other reporting period has been established, the reportingperiod 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 shallcontain a full year of data. All instances of deviations from permitrequirements must be clearly identified in such reports. All requiredreports must be certified by a responsible official as defined in §26.2 ofRegulation #26 and must be sent to the address below.


29

Arkansas Department of Pollution Control and EcologyAir DivisionATTN: Compliance Inspector SupervisorPost Office Box 8913Little Rock, AR 72219

8. Pursuant to 40 C.F.R. 70.6(a)(3)(iii)(B), §26.7 of Regulation #26,and §19.6 of Regulation #19, all deviations from permit requirements,including those attributable to upset conditions as defined in the permitshall be reported to the Department. An initial report shall be made tothe Department within 24 hours of discovery of the occurrence. Theinitial 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, 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 additionto the information required by initial report a schedule of actions to betaken to eliminate future occurrences and/or to minimize the amount bywhich the permits limits are exceeded and to reduce the length of timefor which said limits are exceeded. If the permittee wishes, they maysubmit a full report in writing (by facsimile, overnight courier, or othermeans) within 24 hours of discovery of the occurrence and such reportwill serve as both the initial report and full report.


30

9. Pursuant to 40 C.F.R. 70.6(a)(5) and §26.7 of Regulation #26, andA.C.A.§8-4-203, as referenced by §8-4-304 and §8-4-311, if anyprovision of the permit or the application thereof to any person orcircumstance is held invalid, such invalidity shall not affect otherprovisions or applications hereof which can be given effect without theinvalid provision or application, and to this end, provisions of thisRegulation 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, thepermittee must comply with all conditions of this Part 70 permit. Anypermit noncompliance constitutes a violation of the Clean Air Act, asamended, 42 U.S.C. 7401, et seq. and is grounds for enforcement action;for permit termination, revocation and reissuance, or modification; or fordenial of a permit renewal application.

11. Pursuant to 40 C.F.R. 70.6(a)(6)(ii) and §26.7 of Regulation #26, itshall not be a defense for a permittee in an enforcement action that itwould have been necessary to halt or reduce the permitted activity inorder to maintain compliance with the conditions of this permit.

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, orterminated for cause. The filing of a request by the permittee for apermit modification, revocation and reissuance, or termination, or of anotification of planned changes or anticipated noncompliance does notstay any permit condition.

13. Pursuant to 40 C.F.R. 70.6(a)(6)(iv) and §26.7 of Regulation #26, thispermit does not convey any property rights of any sort, or any exclusiveprivilege.

14. Pursuant to 40 C.F.R. 70.6(a)(6)(v) and §26.7 of Regulation #26, thepermittee shall furnish to the Director, within the time specified by theDirector, any information that the Director may request in writing todetermine whether cause exists for modifying, revoking and reissuing, or


31

terminating the permit or to determine compliance with the permit.Upon request, the permittee shall also furnish to the Director copies ofrecords required to be kept by the permit. For information claimed to beconfidential, the permittee may be required to furnish such recordsdirectly 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, thepermittee shall pay all permit fees in accordance with the proceduresestablished in Regulation #9.

16. Pursuant to 40 C.F.R. 70.6(a)(8) and §26.7 of Regulation #26, nopermit revision shall be required, under any approved economicincentives, marketable permits, emissions trading and other similarprograms or processes for changes that are provided for elsewhere in thispermit.

17. Pursuant to 40 C.F.R. 70.6(a)(9)(i) and §26.7 of Regulation #26, ifthe permittee is allowed to operate under different operating scenarios,the permittee shall, contemporaneously with making a change from oneoperating scenario to another, record in a log at the permitted facility arecord 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 termsand conditions in this permit, including any provisions designed to limit asource's potential to emit, are enforceable by the Administrator andcitizens under the Act unless the Department has specifically designatedas not being federally enforceable under the Act any terms and conditionsincluded in the permit that are not required under the Act or under anyof its applicable requirements.

19. Pursuant to 40 C.F.R. 70.6(c)(1) and §26.7 of Regulation #26, anydocument (including reports) required by this permit shall contain acertification by a responsible official as defined in §26.2 of Regulation#26.


32

20. Pursuant to 40 C.F.R. 70.6(c)(2) and §26.7 of Regulation #26, thepermittee 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 recordsmust be kept under the conditions of this permit;

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

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

d. As authorized by the Act, sample or monitor at reasonable timessubstances or parameters for the purpose of assuring compliancewith this permit or applicable requirements.

21. Pursuant to 40 C.F.R. 70.6(c)(5) and §26.7 of Regulation #26, thepermittee shall submit a compliance certification with terms andconditions contained in the permit, including emission limitations,standards, or work practices. This compliance certification shall besubmitted annually and shall be submitted to the Administrator as wellas to the Department. All compliance certifications required by thispermit shall include the following:

a. The identification of each term or condition of the permit that isthe 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 themonitoring requirements of this permit; and

e. Such other facts as the Department may require elsewhere in thispermit or by §114(a)(3) and 504(b) of the Act.


33

22. Pursuant to §26.7 of Regulation #26, nothing in this permit shall alter or affectthe following:

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

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

c. The applicable requirements of the acid rain program, consistent with §408(a) of theAct; or

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


34

Title VI Provisions Title VI Provisions Title VI Provisions Title VI Provisions

1. The permittee shall comply with the standards for labeling of productsusing ozone depleting substances pursuant to 40 CFR Part 82, SubpartE:

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

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

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

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

2. The permittee shall comply with the standards for recycling andemissions 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, ordisposal must comply with the required practices pursuant to§82.156.

b. Equipment used during the maintenance, service, repair, ordisposal of appliances must comply with the standards forrecycling and recovery equipment pursuant to §82.158.

c. Persons performing maintenance, service repair, or disposal of


35

appliances must be certified by an approved techniciancertification program pursuant to §82.161.

d. Persons disposing of small appliances, MVACs, and MVAC-like

appliances must comply with record keeping requirementspursuant to §82.166. (“MVAC-like appliance” as defined at§82.152.)

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

f. Owners/operators of appliances normally containing 50 or morepounds of refrigerant must keep records of refrigerant purchasedand added to such appliances pursuant to §82.166.

3. If the permittee manufactures, transforms, imports, or exports aclass I or class II substance, the permittee is subject to allrequirements as specified in 40 CFR Part 82, Subpart A,Production and Consumption Controls.

4. If the permittee performs a service on motor (fleet) vehicles whenthis service involves ozone-depleting substance refrigerant in themotor vehicle air conditioner (MVAC), the permittee is subject toall the applicable requirements as specified in 40 CFR Part 82,Subpart B, Servicing of Motor Vehicle Air Conditioners.

The term “motor vehicle” as used in Subpart B does not include a vehiclein which final assembly of the vehicle has not been completed. The term“MVAC” as used in Subpart B does not include the air-tight sealedrefrigeration system used as refrigerated cargo, or system used onpassenger buses using HCFC-22 refrigerant.

5. The permittee shall be allowed to switch from any ozone-depletingsubstance to any alternative that is listed in the Significant New


36

Alternatives Program (SNAP) promulgated pursuant to 40 CFR Part82, Subpart G, Significant New Alternatives Policy Program.

.

APPENDIX AAPPENDIX AAPPENDIX AAPPENDIX A

APPENDIX BAPPENDIX BAPPENDIX BAPPENDIX B

APPENDIX CAPPENDIX CAPPENDIX CAPPENDIX C

APPENDIX DAPPENDIX DAPPENDIX DAPPENDIX D

Arkansas Department of Pollution Control and EcologyDivision of Air Pollution Control

DETERMINATION OF APPLICABILITY

Name & Location: Viskase Corporation, 2221 E. State Highway 198

Contact Name: E, H&S CoordinatorMailing Address: 2221 E. State Highway 198

City: Osceola State: Arkansas ZIP: 72730

Process Description__________________________Cellulose food casing manufacturer______________

CSN: 47-0115 Permit No.: 268-AOP-R0 Engineer: Maria Watts

Date(s) of DOA Attempts: ____________________, _________________

Applicable Programs: SIP _____, PSD _____, NSPS _____, NESHAPS _____, Non-Attainment _____, Air Code Only _____, Not Determinable_____

EMISSION SUMMARY TOTALS (TPY)Pollutant Existing Contemp. Contemp. Net Change Significant After

Decrease Increase Increase PermitPM/PM10 ___36.1__ _________ _________ __1.9____ 15 __39.8___SO2 ___459__ _________ _________ __-0.8___ 40 _458.2___VOC ___2.7___ _________ _________ __-0.8___ 40 __3.9____CO ___16.1__ _________ _________ __-0.8___ 100 _22.5____NOx ___159__ _________ _________ __-0.1___ 40 _185.2___TRS______ ___957__ _________ _________ __-3.0___ _________ _954.0____________ _________ _________ _________ _________ _________ _________Is facility on 28 list (100 TPY)? Yes _____ No __x___ Additional Information Required _____Facility is "Major Source" before permit? Yes __x___ No _____ Facility is "Major Source" after Permit? Yes __x___ No _____Major modification? Yes _____ No __x___ Not applicable _____ Will facility emit toxic emissions? Yes _____ No __x___Is the source within 10 km of a Class I area? Yes _____ No __x___ If yes, is maximum impact > 1Fg/m3 (24 hr)? Yes _____ No _____Is facility located in a non-attainment area? Yes _____ No _x____For PSD/Non-Attainment Review:

Monitoring Ambient Monitoring BACT/LEAR(Fg/m3-time) Impact Required

(Fg/m3) YES/NOPM/PM10 __________ __________ __________ __________SO2 __________ __________ __________ __________VOC __________ __________ __________ __________CO __________ __________ __________ __________NOx __________ __________ __________ __________Other __________ __________ __________ __________Limits required on hours of operation, feed rates, etc.? Yes _____ No _____

Route To: FELICIA INMANAdministration

AIR DIVISION

INVOICE REQUEST FORM

(1-94)

Facility Name & Address:Viskase Corporation2221 E. State Highway 198Osceola, Arkansas 72730

CSN: 47-0115 Permit No: 268-AOP-R0

Permit Description: (e.g. A = AIR CODE, S=SIP, H=NESHAP, P=PSD, N=NSPS)

Operating Permit -Regulation 26

Initial Fee Calculations:

TITLE V =$17.39*(TOTAL TPY REGULATED POLLUTANTS, EXCEPT CO)-LAST ANNUAL PAYMENT

=$17.39*1642-$16442 =$12112

Mod Fee Calculations:

TITLE V = 17.39*(TPY INCREASE PREDOMINANT POLLUTANT, EXCEPT CO)

F =

Fee Amount: $12,112.00

Engineer: Maria Watts

Date: October 5, 1996

JUSTIFICATION WORKSHEET

Specific Conditions (list applicable specific conditions) were included in Air Permit 268-AOP-R0 to complySpecific Conditions (list applicable specific conditions) were included in Air Permit 268-AOP-R0 to complySpecific Conditions (list applicable specific conditions) were included in Air Permit 268-AOP-R0 to complySpecific Conditions (list applicable specific conditions) were included in Air Permit 268-AOP-R0 to complywith: with: with: with:

1. New Source Performance Standard Subpart _______N/A____________1. New Source Performance Standard Subpart _______N/A____________1. New Source Performance Standard Subpart _______N/A____________1. New Source Performance Standard Subpart _______N/A____________

2. Prevention of Significant Deterioration Regulations N/A2. Prevention of Significant Deterioration Regulations N/A2. Prevention of Significant Deterioration Regulations N/A2. Prevention of Significant Deterioration Regulations N/A

3. NESHAPS N/A3. NESHAPS N/A3. NESHAPS N/A3. NESHAPS N/A

4. Compliance with SIP.4. Compliance with SIP.4. Compliance with SIP.4. Compliance with SIP.

5. Specific Conditions 1 through 16 were included in this permit to assure compliance with submitted5. Specific Conditions 1 through 16 were included in this permit to assure compliance with submitted5. Specific Conditions 1 through 16 were included in this permit to assure compliance with submitted5. Specific Conditions 1 through 16 were included in this permit to assure compliance with submitted operational descriptions and/or emission limits. operational descriptions and/or emission limits. operational descriptions and/or emission limits. operational descriptions and/or emission limits.

6. National Ambient Air Quality Standards (NAAQS) & Pulaski County Maintenance Regulations.6. National Ambient Air Quality Standards (NAAQS) & Pulaski County Maintenance Regulations.6. National Ambient Air Quality Standards (NAAQS) & Pulaski County Maintenance Regulations.6. National Ambient Air Quality Standards (NAAQS) & Pulaski County Maintenance Regulations.

SIP CHECKLISTSIP CHECKLISTSIP CHECKLISTSIP CHECKLIST

Facility Name: Facility Name: Facility Name: Facility Name: Viskase CorporationViskase CorporationViskase CorporationViskase Corporation

Permit No.: Permit No.: Permit No.: Permit No.: 268-AOP-R0268-AOP-R0268-AOP-R0268-AOP-R0 CSN: CSN: CSN: CSN: 47-011547-011547-011547-0115 Region: ______Region: ______Region: ______Region: ______

ADMINISTRATIVE SECTION

PRIOR TO ROUTING:PRIOR TO ROUTING:PRIOR TO ROUTING:PRIOR TO ROUTING: COMPLETEDCOMPLETEDCOMPLETEDCOMPLETED

1.1.1.1. Request invoice from Felicia (3 copies)Request invoice from Felicia (3 copies)Request invoice from Felicia (3 copies)Request invoice from Felicia (3 copies) ____________________________________

2.2.2.2. Type permit, stamp draftType permit, stamp draftType permit, stamp draftType permit, stamp draft ____________________________________

3.3.3.3. Type mailing listType mailing listType mailing listType mailing list ____________________________________

4.4.4.4. Type public notice letters to the following:Type public notice letters to the following:Type public notice letters to the following:Type public notice letters to the following:

a. Applicant - draft and final lettersa. Applicant - draft and final lettersa. Applicant - draft and final lettersa. Applicant - draft and final letters ____________________________________

b. Newspapers - local and statewide papersb. Newspapers - local and statewide papersb. Newspapers - local and statewide papersb. Newspapers - local and statewide papers ____________________________________

c. Depository/library - send certifiedc. Depository/library - send certifiedc. Depository/library - send certifiedc. Depository/library - send certified ____________________________________

d. Mayord. Mayord. Mayord. Mayor ____________________________________

e. County Judgee. County Judgee. County Judgee. County Judge ____________________________________

5.5.5.5. Route file to:Route file to:Route file to:Route file to: Program CoordinatorProgram CoordinatorProgram CoordinatorProgram Coordinator ____________________________________Testing/CEMS staffTesting/CEMS staffTesting/CEMS staffTesting/CEMS staffEnforcementEnforcementEnforcementEnforcementAir Division ChiefAir Division ChiefAir Division ChiefAir Division Chief

6.6.6.6. When file comes back to you, check to seeWhen file comes back to you, check to seeWhen file comes back to you, check to seeWhen file comes back to you, check to see ____________________________________if the proof of publication for the receiptif the proof of publication for the receiptif the proof of publication for the receiptif the proof of publication for the receipt

of application has been received.of application has been received.of application has been received.of application has been received.

7.7.7.7. After corrections have been made and the ChiefAfter corrections have been made and the ChiefAfter corrections have been made and the ChiefAfter corrections have been made and the Chief ____________________________________has signed the draft permit, make 10 copies ofhas signed the draft permit, make 10 copies ofhas signed the draft permit, make 10 copies ofhas signed the draft permit, make 10 copies ofthe public notice, 6 copies of the mailing list,the public notice, 6 copies of the mailing list,the public notice, 6 copies of the mailing list,the public notice, 6 copies of the mailing list,1 copy of the letters, type envelopes, and mail.1 copy of the letters, type envelopes, and mail.1 copy of the letters, type envelopes, and mail.1 copy of the letters, type envelopes, and mail.

8.8.8.8. Send a copy of the public notice and theSend a copy of the public notice and theSend a copy of the public notice and theSend a copy of the public notice and the ____________________________________mailing list to Rhonda Sharp.mailing list to Rhonda Sharp.mailing list to Rhonda Sharp.mailing list to Rhonda Sharp.

9.9.9.9. When the public comment period is up, the feeWhen the public comment period is up, the feeWhen the public comment period is up, the feeWhen the public comment period is up, the fee ____________________________________is paid, and the proofs of publication have beenis paid, and the proofs of publication have beenis paid, and the proofs of publication have beenis paid, and the proofs of publication have beenreceived, route to Air Division Chief forreceived, route to Air Division Chief forreceived, route to Air Division Chief forreceived, route to Air Division Chief forsignature. Make 6 copies of the permit and mail.signature. Make 6 copies of the permit and mail.signature. Make 6 copies of the permit and mail.signature. Make 6 copies of the permit and mail.Copies go to Enforcement, Testing/CEMS, Division Chief,Copies go to Enforcement, Testing/CEMS, Division Chief,Copies go to Enforcement, Testing/CEMS, Division Chief,Copies go to Enforcement, Testing/CEMS, Division Chief,and 3 to Permit Engineer (engineer, file, & summaryand 3 to Permit Engineer (engineer, file, & summaryand 3 to Permit Engineer (engineer, file, & summaryand 3 to Permit Engineer (engineer, file, & summarybook).book).book).book).

ENGINEERING SIP CHECKLISTENGINEERING SIP CHECKLISTENGINEERING SIP CHECKLISTENGINEERING SIP CHECKLIST

Facility Name:Facility Name:Facility Name:Facility Name: Viskase CorporationViskase CorporationViskase CorporationViskase Corporation

Permit No.: Permit No.: Permit No.: Permit No.: 268-AOP-R0268-AOP-R0268-AOP-R0268-AOP-R0 CSN: CSN: CSN: CSN: 47-011547-011547-011547-0115

Permit Package must contain the following prior to the DRAFT routing.Permit Package must contain the following prior to the DRAFT routing.Permit Package must contain the following prior to the DRAFT routing.Permit Package must contain the following prior to the DRAFT routing.

____ X__________ X__________ X__________ X______ Draft Permit

_____X__________X__________X__________X_____ Proof of publication of receipt of notice of application.... Please note that ten Please note that ten Please note that ten Please note that ten(10)(10)(10)(10) days must have elapsed from the date of this notice before a public notice days must have elapsed from the date of this notice before a public notice days must have elapsed from the date of this notice before a public notice days must have elapsed from the date of this notice before a public noticeon intent can be published.on intent can be published.on intent can be published.on intent can be published.

_____X__________X__________X__________X_____ DOA Form

_____X _________X _________X _________X ____ Fee Worksheet

_____X _________X _________X _________X ____ Technical Justification Worksheet

_____X _________X _________X _________X ____ Copy of Plot Plan for Local Inspector

The following must be received and placed in the permit package prior to The following must be received and placed in the permit package prior to The following must be received and placed in the permit package prior to The following must be received and placed in the permit package prior to FINAL routing. routing. routing. routing.

________________________________________ Proof of publication and payment of notice of intent to issue.

________________________________________ Fee Payment (Check PFAQ) (Check PFAQ) (Check PFAQ) (Check PFAQ)

________________________________________ 30 days have elapsed from the time of last publication of the public noticeof intent to issue.

________________________________________ All required attachments are enclosed (i.e. plot plan, area map, etc.)

Public Notice

Pursuant to Section 4(i) of the Arkansas Plan of Implementation for Air Pollution Control (SIP),Regulation 19, the Arkansas Department of Pollution Control and Ecology gives the followingnotice:

Viskase Corporation operates a cellulose food casing plant located in Osceola, Arkansas. Productionof cellulose food casings by the viscose process involves the reaction of a cellulose material, eithercotton or wood pulp, with an aqueous sodium hydroxide solution. Emissions from the viscoseprocess consist primarily of carbon disulfide and hydrogen sulfide. These gases occur duringxanthation, coagulation, regeneration, and purification stages of the viscose process. 268-AOP-R0is the first operating permit issued to Viskase Corporation under Regulation 26. No physical changesin the method of operation at the facility occurred prompting this permit issuance. However, ViskaseCorporation is including glycerine emissions which have not been previously identified in other airpermitting efforts.

The application has been reviewed by the staff of the Department and has received the Department'stentative approval subject to the terms of this notice.

Citizens wishing to examine the permit application and staff findings and recommendations may doso by contacting Rhonda Sharp. Citizens desiring technical information concerning the applicationor permit should contact Maria Watts. Both Rhonda Sharp and Maria Watts can be reached at theDepartment's central office, 8001 National Drive, Little Rock, 72219 (501) 682-0744.

Copies of the draft permit and permit application have been placed at the Blytheville Public Library,200 North Fifth, Blytheville, Arkansas 72315. This information may be reviewed during theDepartment's normal business hours. Interested or affected persons may also submit written comments on the proposal to the Departmentat the above address - Attention: Rhonda Sharp. In order to be considered, the comments must besubmitted within thirty (30) days of publication of this notice. Although the Department is notproposing to conduct a public hearing, one will be scheduled if significant comments on the permitprovisions are received. If a hearing is scheduled, adequate public notice will be given in thenewspaper 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 specialconditions in accordance with Part III of this Department's Administrative Procedures (Regulation#8).

Dated this

Randall Mathis

Director

operating air permit - arkansas department of ... air permit pursuant to the regulations of the...

Documents