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OPERATINGAIR PERMIT

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

Permit #: 349-AOP-R0

IS ISSUED TO:

Frigidaire Home Products1 Poulan Drive

Nashville, AR 71852Howard CountyCSN: 31-0023

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

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SECTION I: FACILITY INFORMATION

PERMITTEE: Frigidaire Home ProductsCSN: 31-0023PERMIT NUMBER: 349-AOP-R0

FACILITY ADDRESS: 1 Poulan DriveNashville, AR 71852

COUNTY: Howard

CONTACT NAME: Jerry WilcoxTELEPHONE NUMBER: (870) 845-6817

REVIEWING ENGINEER: William E. Swafford, P.E.

UTM North-South (X): 3753.9 NorthUTM East-West (Y): 421.2 East

LATITUDE: 33° 55' 27" NorthLONGITUDE: 93° 51' 08" West

Frigidaire Home Products349-AOP-R031-0023

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SECTION II: INTRODUCTION

Frigidaire Home Products (“Frigidaire”), a division of White Consolidated Industries, Inc.(“WCI”), operates a manufacturing facility in Nashville, Howard County, Arkansas. The site isreferred to as the “Lawn and Garden Plant.” Prior to January 1997 the facility operated under thename of Poulan/Weed Eater Inc. (“Poulan”), a division of WCI. In January 1997 Poulan wasrestructured and the operator of the Lawn and Garden Plant became Frigidaire Home Products. Frigidaire manufactures a variety of gasoline powered lawn and garden equipment products atthis facility. These units include power-handle trimmers, edgers, blowers, and related equipment. The product line also includes a variety of gasoline powered chainsaws. The productionoperations at the facility are categorized under Standard Industrial Classification (SIC) code 3524(manufacture of lawn and garden equipment) and SIC code 3546 (manufacture of power-drivenhand tools). Carbon monoxide (CO) is the only major criteria pollutant emitted at this facility ofwhich over 99% is emitted from the engine test booths (SN-01).

Carbon monoxide (CO) is the only major criteria pollutant emitted at this facility of which over99% is emitted from the engine test booths (SN-01). Frigidaire anticipates increasing gasolineconsumption to 105,000 gallons per year by increasing production. By using the CO emissionfactors from the fifth edition of EPA Publication AP-42, Table 3.3-2, this consumption rateyields 406.3 tpy of CO. In the past the Department considered small engine exhaust from thisfacility exempt and the Department formalized this consideration August 9, 1994, in a letterstating that the air emissions generated during the testing of two-cycle engines were exemptfrom air permitting requirements. After further review both the facility and the Departmentconcur that these emissions require permitting. Considering the permit history and past andpresent production capabilities, the permitted rate of 406.3 tpy of CO does not represent asignificant increase for PSD purposes. This permit is not making any physical changes orchanges in the method of operation pursuant to PSD regulations.

The process of manufacturing gasoline powered lawn and garden tools begins with themachining of metal parts. The raw materials for parts fabrication are various types of castingswhich are purchased from outside vendors. The parts are machined to their final dimensions byconventional metal working equipment (lathes, drill presses, etc.). Mineral oil is used as alubricant during the machining operation. Mineral oil has a negligible vapor pressure. Therefore, the machining operations are considered insignificant air emission sources. Ventilation for this area is provided by the facility’s heating, ventilation, and air conditioning (HVAC) system.

Following the machining, most parts are deburred in a vibratory parts tumbling machine with an


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abrasive ceramic media and aqueous cleaning solution. The engine cylinders are deburred usingan electrochemical process. The engine cylinders are mounted on post and immersed in anelectrically conductive solution of sodium nitrite. An electrical current is applied and the burrsare dissolved in a process best described as a type of reverse plating.

After deburring, the fabricated metal components are washed in a non-volatile detergent solutionwith steam. No solvents are used during the cleaning process. Therefore, there are no significantemissions from the metal parts wash operation.

Engine cylinders are subjected to additional processing during the metal fabrication operations. After deburring, the cylinders are etched to inhibit corrosion during storage. The etchingoperation is a multi-process involving a combination of baths of caustic and acids with bothbaths followed by a hot water rinse. Finally, the cylinders are immersed in an acid stabilizer bathand then dried in the cylinder dry-off oven (SN-03). The etching operation is an insignificantsource for air emissions.

Some components of lawn and garden equipment require painting before assembly. Frigidaireutilizes a “powder paint” system for the coating of metal parts. The parts are heated in an ovenbefore being transferred to the painting machines. The hot parts are suspended in the paintmachines where an electrostatic charge is applied to the parts. The parts are sprayed with apowdered paint. The heat and electrostatic charge aids the powdered paint to adhere to the parts. The coated parts are then transferred to a curing oven where the parts are heated to a temperaturesufficient to cure the surface coating. The powder paint is a dry fine powder that contains noVOCs or HAPs. The paint machines are self contained and do not vent to the atmosphere. Air inthe paint room is circulated through particulate filters and is returned to the room. The powderpainting operation is not a source of air emissions.

The facility has a small nylon extruder for the fabrication of the plastic line used in weedtrimmers. The melted nylon does not contain any VOCs or HAPs and therefore is aninsignificant source for air emissions.

The Lawn and Garden Plant has six production lines for the assembly of the lawn and gardenproducts plus one dedicated line for the assembly of various gasoline powered chainsawproducts. In the assembly operation a variety of parts are assembled to produce the finalproducts. The various metal parts are fabricated on site, whereas the plastic parts (with theexception of trimmer line) are purchased from outside vendors. The assembly operation ismechanical in nature. Small quantities of lubricant are used during the assembly of the products. Air emissions from this operation are insignificant.


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At the end of each assembly line is a series of test booths (SN-01) to set up and test each engine. Each engine is fueled, started, and run for approximately two minutes at full throttle. After theengine has warmed up, a technician adjusts the carburetor and conducts a performance test. After testing, the fuel tank is emptied (degassed) by a vacuum system that returns the fuel to aportable thirty gallon dispensing tank.

Permit 349-AOP-R0 will be the first Title V operating permit issued to Frigidaire underRegulation #26 and it reestablishes the facility as a permitted source. A summary of facility wideemissions is provided in the following tables. Specific emission unit information is located bythe indicated cross reference pages.

EMISSION SUMMARY

SourceNo.

Description Pollutant Emission Rates CrossReference

Pagelb/hr tpy

Total Allowable Emissions

(All HAPs included in VOC total)

PM/PM10SO2

VOC CO NOx

Acetone

HAPsTolueneXylene

Ethyl BenzeneBenzene

FormaldehydeMEK

0.8 0.796.2

387.2 10.9 1.4

2.72.80.50.70.30.3

1.1 0.7

82.5 407.0

13.9 0.3

2.32.30.50.80.30.1


EMISSION SUMMARY

SourceNo.

Description Pollutant Emission Rates CrossReference

Pagelb/hr tpy

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01 Engine Test Booths PM/PM10SO2

VOCCONOX

HAPsTolueneXylene


Formaldehyde

0.7 0.6 13.9

387.0 10.1

2.12.00.50.70.3

0.7 0.6

14.6 406.3

10.6

2.22.10.50.80.3

10

02 Gasoline Storage Tanks VOC 0.4 1.6 13

03 Natural Gas CombustionEquipment (5 Units)(Total heat input - 7.41 MM BTU/hr)

PM/PM10SO2

VOCCONOX

0.10.10.10.20.8

0.40.10.20.73.3

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04 Product CleaningOperations

VOC(IsopropylAlcohol)

78.8 65.6 17

05 Touch-Up PaintingActivities

VOCAcetone

HAPsTolueneXyleneMEK

3.01.4

0.60.80.3

0.50.3

0.10.20.1

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SECTION III: PERMIT HISTORY

In 1976 the Beaird-Poulan Division of Emerson Electric Company began the construction of afacility in Nashville, Arkansas to manufacture 200,000 chainsaws annually. Beaird-PoulanDivision submitted an application on March 15, 1976, and Air Permit 349-A was issuedSeptember 24, 1976. The air permit covered one pound per hour emissions from two wet dustcollectors (rotoclones) which collected dust from the deburring of castings by chipping andsanding prior to machining. Fabric filters controlled the particulate emissions from a powdercoating operation.

At an undetermined date the facility was reorganized as the Poulan/Weed Eater, Inc. (“Poulan”). On January 1, 1987, Poulan was acquired by White Consolidated Industries, Inc. (“WCI”).

On October 21, 1988, Poulan submitted a letter stating that sources covered by Air Permit 349-Ahad been removed from service. The letter also contained a list of other sources at the facilityand gave justification as to why all these sources were exempt from notification and permittingrequirements. The letter also stated that the facility wanted to maintain the permit.

The Department answered Poulan’s letter on May 12, 1989, and stated that all of the additionsand changes described therein were minor or resulted in a reduction of emissions and therefore,there was no need for a formal modification to Permit 349-A at this time.

An Air Division inspector inspected the facility on September 6, 1990. His report included acopy of Poulan’s October 21, 1988, letter and the Department’s May 12, 1989, reply. Theinspector also made the following comments:

1. The facility had made large scale changes since the permit was issued in 1976.

2. The permit mentioned a production rate of 200,000 chainsaws per year. Thepresent rate is 200,000 small engines per month.

3. The facility was in compliance.

The next Air Division inspection was conducted on June 27, 1994. The Environmental Managerstated that no changes had been made since the last inspection. The Environmental Manager alsosaid that Poulan did not have any permitted sources and the sources listed in the permit were nolonger in service. If any operational changes are made, the Department will be notified. He alsowanted to keep the permit active. The inspector reported the facility in compliance.


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On June 24, 1994, Poulan submitted a letter requesting an official statement as to whether thetwo-cycle engine exhausts from the facility are exempt from Title V permitting requirements. The Department responded August 9, 1994, stating that the air emissions generated during the testing of two-cycle engines were exempt from air permitting requirements.

On September 1, 1994, the Department’s Permit Fee Coordinator submitted an invoice to Poulanfor the annual air permit fee. The Environmental Manager for Poulan replied on October 20,1994, with a letter stating that the original permitted source processes are discontinued andPoulan has not introduced any new processes which require permitting. He also included a copyof Poulan’s October 21, 1988, letter and the Department’s May 12, 1989, response. The letterstated that Poulan will not renew the permit by paying the permit fee. The Department voidedthe invoice.

However, Poulan’s parent company, WCI, subsequently decided that a conservativeinterpretation of the exemption language would not allow the emissions from the engine testbooths to be exempted from air permitting requirements. Poulan estimated that the Nashvillefacility’s potential-to-emit for carbon monoxide (CO) exceeded the 100 tons per year thresholdfor status as a Title V major source. As a result, in October 1996, Poulan submitted to theDepartment an initial “short form” application for a Title V Operating Permit for the NashvilleLawn and Garden Plant. As mentioned in the introduction, Poulan was restructured in January1997 and the name was changed to Frigidaire Home Products. Frigidaire Home Productssubmitted a full Title V application on March 10, 1997.


SECTION IV: EMISSION UNIT INFORMATION


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SN-01Engine Test Booths

Source Description

After assembly, all products are performance tested as part of Frigidaire’s Quality AssuranceProgram. Each of the seven production lines at the facility is equipped with a series of testbooths for this purpose. Each engine is fueled from a centralized day tank using a closed system. The engines are then started and run for approximately two minutes at full throttle. After theengine has warmed up, a technician adjusts the carburetor and conducts a performance test. Once tested, the excess fuel is removed (i.e., degassed) from the product by a vacuum system andstored in a day tank. A day tank is a portable 30 gallon fuel tank mounted on two dolly wheelsthat is used to fuel and degas the engines at the test booths. At the proposed production rate, amaximum of 105,000 gallons per year of gasoline will be combusted.

All engine test booths are equipped with exhaust hoods for venting of the gasoline combustionemissions. All the test booths on each production line is vented through one vent, therefore,there are seven test booth exhausts vented to the atmosphere. The seven vents are groupedtogether as a single source (SN-01). The VOC emissions from the associated fueling/degassingoperations at the test booths are also included in SC-01.

Frigidaire has the option of using either regular unleaded gasoline or reformulated, oxygenated,gasoline as a fuel in the engine test booths (SN-01). The reformulated gasoline contains fewerHAPs and is a cleaner burning fuel than regular unleaded gasoline. All emissions are higherwhen combusting regular unleaded gasoline. Therefore, all emission limits are based on thecombustion of regular unleaded gasoline in the test booths.

Specific Conditions

1. Pursuant to §19.5 of the Regulations of the Arkansas State Implementation Plan for AirPollution Control, effective July 1, 1997 (Regulation 19), and 40 CFR Part 52, Subpart E,the permittee shall not exceed the emission rates set forth in the following table. Compliance with the pounds per hour values will be demonstrated by Specific Condition#5. Compliance with the tons per year value will be demonstrated by Specific Condition#11.


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SN-# Pollutant lb/hr tpy

01 PM/PM10SO2

VOCCONOX

0.7 0.6 13.9387.0 10.1

0.7 0.6 14.6406.3 10.6

2. Pursuant to §18.8 of the Arkansas Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the total toxic emission rates at SN-01 set forth in thefollowing table. These HAPs are listed individually and are included in the total VOCs inthe above table. Acetaldehyde and propionaldehyde are emitted from this source at deminimis levels and therefore, are not listed in the table. Compliance with the pounds perhour values will be demonstrated by Specific Condition #5. Compliance with the tonsper year value will be demonstrated by Specific Condition #11.

Pollutant(Compounds)

Emission Rate

lb/hr tpy

TolueneXylene


Formaldehyde

2.12.00.50.70.3

2.22.10.50.80.3

3. Pursuant to §18.5 of Regulation 18 and 40 CFR Part 52, Subpart E, the permittee shallnot cause to be discharged to the atmosphere from the engine test booths gases whichexhibit an opacity greater than 5%.

4. Pursuant to §19.7 of Regulation 19 and 40 CFR Part 52, Subpart E, Frigidaire shallconduct weekly observations of the opacities from SN-01 and keep records of theseobservations. If visible emissions are detected, the permittee shall immediately conduct a6 minute opacity reading in accordance with EPA Reference Method #9. The results ofthese observations or readings shall be recorded in a log which shall be maintained on siteand made available to Department personnel upon request.

5. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311and 40 CFR 70.6,Frigidaire shall not combust more than fifty (50) gallons of gasoline per hour in the testbooths.


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6. Pursuant to §19.7 of Regulation 19 and 40 CFR Part 52, Subpart E, each week an hourlyrate of gasoline consumption shall be calculated by dividing the week’s quantity ofgasoline consumed by the hours of operation. Frigidaire shall maintain records of theweekly gasoline consumption, weekly hours of operation, and the weekly calculatedhourly rate of gasoline consumption. These records shall be kept on site and madeavailable to Department personnel upon request.

7. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, Frigidaire shallmaintain Material Safety Data Sheets (MSDS) for all gasolines to demonstratecompliance with Specific Condition #2.

8. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311 and 40 CFR 70.6,all gasoline shall be kept in closed containers and fueling and degassing of the enginesshall be done in a manner to minimize gasoline evaporation.

9. Pursuant to A.C.A.§8-4-203 as referenced by §8-4-304 and §8-4-311 and 40 CFR 70.6,Frigidaire shall not use any fuels in the engine test booths other than regular unleadedgasoline or reformulated gasoline.


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SN-02Gasoline Storage

Source Description

The facility has a 5,000 gallon above-ground gasoline storage tank located in a covered concreteblock enclosure. The tank currently in operation is a horizontal cylindrical fixed roof tank that isvented to the atmosphere. Frigidaire is considering replacing this tank with an 8,000 gallonhorizontal, fixed roof, pressurized tank.

VOC emissions from a vented tank occur from breathing losses and working losses. Breathinglosses result from the expansion and contraction of the tank contents during changes inbarometric pressure or temperature. Working losses occur when filling or emptying the tankduring use. The emissions are highest in a large vented tank. The calculated emissions in thispermit are calculated for an 8,000 gallon vented tank. These calculated emissions will covereither the proposed tank or the existing tank.

The storage tank is filled by tanker truck when necessary. The tank outlet is a service stationtype pump with hose and nozzle. The tank is used only to fill the 30 gallon day tanks which areused to fuel the product in the test booths. The fuel in the storage tank is not taxed and thereforeis not used to refuel plant vehicles. Facility vehicles are refueled at local service stations.

Both the present tank and the proposed tank are less than 40 cubic meters (10,566 gallons). Therefore, neither tank is subject to NSPS Subpart Kb.

The unleaded gasoline contains four HAPs according to the MSDS sheet. At the emission ratescalculated for the tank all the HAPs are below the de minimus level.

Specific Conditions

10. Pursuant to §19.5 of the Regulations of the Arkansas State Implementation Plan for AirPollution Control (Regulation 19), and 40 CFR Part 52, Subpart E, the permittee shall notexceed the emission rates set forth in the following table. Compliance with the emissionsfrom the gasoline storage tank was estimated using the TANKS2 software program.


02 VOC 0.4 1.6


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11. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311 and 40 CFR 70.6,Frigidaire shall not use or consume more than 105,000 gallons of gasoline in anyconsecutive twelve month period for the purpose of producing and testing small engines.

12. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311 and 40 CFR 70.6,the 5,000 gallon 2-cycle fuel storage tank shall be taken our of service and the day tankfilling equipment removed from the tank no later than 30 days after the new 8,000 gallontank is placed in service. Frigidaire may retain and store the tank on site. Frigidaire mustobtain an air permit modification before the tank can be used to store any pollutant.

13. Pursuant to §19.7 of Regulation 19 and 40 CFR Part 52, Subpart E, Frigidaire shallmaintain monthly and annual gasoline usage records which demonstrate compliance withthe limits listed in Specific Condition #11. A monthly report shall be prepared containingthe individual records for each of the last twelve months and the total of the twelvemonths. These records shall be kept on site and shall be made available to Departmentpersonnel upon request. A twelve consecutive month total and each month’s data shall besubmitted to the Department in accordance with General Provision #7, page 33.


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SN-03Natural Gas Combustion Equipment (5 Units)

Source Description

Frigidaire has five pieces of natural gas fired production equipment at this facility. Since they areall small units, a total heat input of 7.41 MM BTU/hr, they have been grouped together as onesource (SN-03). The emissions for these units have been calculated at their potential-to-emit(pte), or theoretical maximum, of 8,760 hours per year. Therefore, no record keeping of naturalgas usage will be required. Due to the size of the equipment, none are subject to any NSPSregulations. The five units are:

1. Boiler #1 1.26 MM BTU/hr

2. Boiler #2 1.67 MM BTU/hr

3 Cylinder Dry-Off Oven 0.48 MM BTU/hr

4. Preheat Oven 2.00 MM BTU/hr

5. Cure Oven 2.00 MM BTU/hr

The two test boilers supply heat for the various parts cleaning operations, the caustic and acidbaths, and the hot water rinse tanks. The cylinder dry-off oven follows the cylinder etchingoperation to prevent corrosion by insuring the cylinders are completely dry before storing. Thepreheat oven is the first step in the powder coating operation. The oven insures that the parts arecompletely dry but its primary function is to heat the parts to the proper temperature before thepowder coating is applied. The curing oven follows the powder coating application machinewhere it elevates the temperature to the curing point of the powder coating. Once cured andcooled, the painted parts are stored until required by the assembly department.

Specific Conditions

14. Pursuant to §19.5 of the Regulations of the Arkansas State Implementation Plan for AirPollution Control (Regulation 19) and 40 CFR Part 52, Subpart E, the permittee shall notexceed the emission rates set forth in the following table. The pounds per hour emissionrates in the following table are the potential to emit (pte) for all the pieces of equipment. The tpy rates are the pte rates times 8760 hours per year.


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03 PM/PM10SO2

VOCCONOX

0.10.10.10.20.8

0.40.10.20.73.3

15. Pursuant to §18.5 of Regulation 18 and 40 CFR Part 52, Subpart E, the permittee shallnot cause to be discharged to the atmosphere from any natural gas combusting equipmentgases which exhibit an opacity greater than 5%. Compliance with this condition can bedemonstrated by burning natural gas only.

16. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311 and 40 CFR 70.6,pipeline quality natural gas shall be the only fuel used in the permitted sources at thisfacility. The natural gas process equipment is permitted for their theoretical maximum orpotential to emit (pte). Therefore, no record keeping of natural gas usage is required.


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SN-04Product Cleaning Operation

Source Description

After performance testing in the engine test booths, the product is wiped down with isopropylalcohol in order to remove residual oil and grease from the testing activities. The solvent ismanually applied using spray bottles and/or wiping cloths. After cleaning, the finished product isallowed to air dry prior to touch-up painting and/or packaging. Product cleaning is performed atmultiple locations within the production building. The solvent evaporates into the plant’satmosphere and the emissions are exhausted via the plant’s general ventilation system. Themultiple cleaning stations are designated as one source (SN-04). At the production rateanticipated by Frigidaire, a maximum of 20,000 gallons per year of solvent will be utilized forcleaning and wipe-down of the finished product.

Specific Conditions

17. Pursuant to §19.5 of the Regulations of the Arkansas State Implementation Plan for AirPollution Control (Regulation 19), and 40 CFR Part 52, Subpart E, the permittee shall notexceed the emission rates set forth in the following table. Compliance with the poundsper hour values will be demonstrated by Specific Condition #19. Compliance with thetons per year value will be demonstrated by Specific Condition #21.


04 VOC 78.8 65.6

18. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311 and 40 CFR 70.6,Frigidaire may substitute any non-HAP cleaning solvent for isopropyl alcohol providedthe new material does not cause the facility to exceed the annual or hourly emissionlimitations for VOCs. Frigidaire must receive permission from the Department beforeusing any product cleaning solvent that contains a Hazardous Air Pollutant (HAP).

19. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311 and 40 CFR 70.6,Frigidaire shall not use or consume more than twelve (12) gallons of product cleaningsolvent per hour.

20. Pursuant to §19.7 of Regulation 19 and 40 CFR Part 52, Subpart E, each month an hourlyrate of product cleaning solvent usage shall be calculated by dividing the month’squantity of product cleaning solvent used by the hours of operation. Frigidaire shall


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maintain records of the monthly product cleaning solvent usage, monthly hours ofoperation, and the monthly calculated hourly rate of product cleaning solvent usage. These records shall be kept on site and made available to Department personnel uponrequest.

21. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311 and 40 CFR 70.6,Frigidaire shall not use or consume more than 20,000 gallons of product cleaning solventin any consecutive twelve month period.

22. Pursuant to §19.7 of Regulation 19 and 40 CFR Part 52, Subpart E, Frigidaire shallmaintain monthly and annual product cleaning solvent usage records which demonstratecompliance with the limits listed in Specific Condition #21. A monthly report shall beprepared containing the individual records for each of the last twelve months and the totalof the twelve months. These records shall be kept on site and shall be made available toDepartment personnel upon request. A twelve consecutive month total and each month’sdata shall be submitted to the Department in accordance with General Provision #7, page33.


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SN- 05Touch-Up Painting Activities

Source Description

Touch-up painting of the finished products is performed once the lawn and garden equipmentproducts and chain saws have been tested. The units are repainted on as-needed basis. Thepainted products are then allowed to air-dry prior to packing. When necessary, touch-up paintingis also performed during other stages of the production process. (The aerosol paints used byFrigidaire are various “Quick ‘N’ Easy” brand spray enamels or their equivalent.)

Touch-up painting is performed at multiple locations within the production building. The airemissions from these activities are exhausted via the facility’s ventilation system. The plant-wide VOC emissions from the touch-up painting activities are designated as Source SN-05. Atthe production rate anticipated, a maximum of 1,000 cans per year of aerosol spray paint may beused.

The above estimate of 1,000 cans per year is based upon the anticipated increase in productionand the quantity of touch-up spray cans used when the product was wet paint sprayed. Thesuperior quality of the powder coating finish has reduced the quantity of spray paint required.

Specific Conditions

23. Pursuant to §19.5 of the Regulations of the Arkansas State Implementation Plan for AirPollution Control (Regulation 19), and 40 CFR Part 52, Subpart E, the permittee shall notexceed the emission rates set forth in the following table. Compliance with the limits inthis table will be demonstrated by Specific Condition # 27.


05 VOC 3.0 0.5

24. Pursuant to §18.8 of the Arkansas Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the total toxic emission rates at SN-05 set forth in thefollowing table. These HAPs are listed individually and are included in the total VOCs inthe above table. Compliance with the limits in this table will be demonstrated by SpecificCondition # 27.

Pollutant(Compounds)

Emission Rate


20

lb/hr tpy

TolueneXylene

MEK (Methyl Ethyl Ketone)

0.60.80.3

0.20.10.1

25. Pursuant to §18.8 of the Arkansas Air Pollution Control Code (Regulation 18), thepermittee shall not exceed the acetone emission rates at SN-05 set forth in the followingtable. Acetone is neither a VOC nor a HAP but is classified as an air contaminate andtherefore it is regulated as such. It is not included in the VOC quantities. Compliancewith the limits in this table will be demonstrated by Specific Condition # 27.


05 Acetone 1.4 0.3

26. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, Material SafetyData Sheets (MSDS) for all paints, primers, and solvents shall be maintained on site andused to demonstrate compliance with Specific Conditions #24 and #25.

27. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311 and 40 CFR 70.6,Frigidaire shall not use or consume more than three aerosol cans per hour or more than1,000 aerosol cans of touch-up paint in any consecutive twelve month period.

28. Pursuant to §19.7 of Regulation 19 and 40 CFR Part 52, Subpart E, Frigidaire shallmaintain monthly and annual records of the number of cans of paint used at the facility. The records shall contain a monthly total of cans used and an annual running total of thenumber of cans used in the most recent twelve consecutive months of operation. Theserecords shall be maintained on site and be made available to ADPC&E personnel uponrequest. A twelve consecutive month total and each month’s data shall be submitted tothe Department in accordance with General Provision #7, page 33.


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SECTION V: PLANTWIDE 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 thispermit--such as hours of operation, throughput, upset condition, and continuousmonitoring data. The records may be used, at the discretion of the Department, todetermine compliance with 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 §19.3 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the equipment, control apparatus and emission monitoring equipment shall beoperated within their design limitations and maintained in good condition at all times.

5. 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.


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Permit Shield:

6. Compliance with the conditions of this permit shall be deemed compliance with allapplicable requirements, as of the date of permit issuance, included in and specificallyidentified in item A of this condition:

a. The following have been specifically identified as applicable requirements basedupon the information submitted by the permittee in an application dated March10, 1997.

Source No. Regulation Description

Facility Arkansas Regulation #19 Compilation of Regulations of the Arkansas StateImplementation Plan for Air Pollution Control

Facility Arkansas Regulation #26 Regulations of the Arkansas Operating Air Permits Program

b. The following requirements have been specifically identified as not applicablebased upon information submitted by the permittee in an application dated March10, 1997.

Source No. Regulation Description Basis for Determination

03 40 CFR Part 60,Subpart Dc

Standards for Small Industrial-Commercial-Institutional Steam Generating Units

The capacity of both steamgenerating units are less than10 million BTU/hr.

02 40 CFR Part 60,Subpart Kb

Standards of Performance for VolatileOrganic Liquid Storage Vessels (IncludingPetroleum Liquid Storage Vessels) forWhich Construction, Reconstruction, orModification Commenced after July 23,1984

Both the present tank and theproposed replacement tank areless than 40 cubic meters(10,566 gallons).

c. Nothing shall alter or affect the following:

Provisions of Section 303 of the Clean Air Act;

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

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


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

Title VI Provisions:

7. The permittee shall comply with the standards for labeling of products using ozone depletingsubstances pursuant to 40 CFR Part 82, Subpart E:

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

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

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

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

8. The permittee shall comply with the standards for recycling and emissions reduction pursuantto 40 CFR Part 82, Subpart F, except as provided for MVACs in Subpart B:

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

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

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

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


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

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

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

10. If the permittee performs a service on motor (fleet) vehicles when this service involvesozone-depleting substance refrigerant ( or regulated substitute substance) in the motorvehicle air conditioner (MVAC), the permittee is subject to all the applicablerequirements as specified in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle AirConditioners.

The term “motor vehicle” as used in Subpart B does not include a vehicle in which finalassembly of the vehicle has not been completed. The term “MVAC” as used in Subpart Bdoes not include the air-tight sealed refrigeration system used as refrigerated cargo, or thesystem used on passenger buses using HCFC-22 refrigerant.

11. The permittee shall be allowed to switch from any ozone-depleting substance to anyalternative that is listed in the Significant New Alternatives Program (SNAP)promulgated pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives PolicyProgram.


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SECTION VI: DE MINIMIS EMISSION SOURCES

Pursuant to §26.3(d) of Regulation 26, the following sources are below the de minimis emissionlevels. Insignificant and trivial activities will be allowable after approval and federal registernotice publication of a final list as part of the operating air permit program. Any activity forwhich a state or federal applicable requirement applies is not de mimimis, even if this activitymeets the criteria of §3(d) of Regulation 26 or is listed below. De minimis emissiondeterminations rely upon the information submitted by the permittee in an application datedMarch 10, 1997.

1. The fabrication of various metal parts including: the machining of magnesium andaluminum castings; the lubrication system for such equipment; and the storage adhandling of mineral oil for use as a lubricant during these operations.

2. The “deburring” of metal components in the three following operation: vibratorytumblers; electrochemical deburring units; and hand-filing.

3. Operation of the steam-washer units for the degreasing and cleaning of metalcomponents.

4. Operation of the etching process for engine cylinders, and the handling and the storage ofcaustic and acid solutions.

5. Operation of the powder paint system for surface coating of metal components. Thepowder paint systems are closed units and all excess powder paint is collected andrecycled.

6. Operation of the nylon-6 extruder for the manufacture of plastic line for weed trimmersand related product.

7. Small quantities of lubricants used during the assembly of product components.

8. The assembly, packaging, and warehousing of the product.

9. The storage, handling, and use of adhesives with negligible concentration of VOCs andHAPs in the formulation, and the operation of hand-held applicator equipment.

10. Storage tanks, vessels, and containers storing liquid substances (i.e., caustic and acidsolutions) which do not contain any VOCs or HAPs.


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11. Storage tanks, vessels, and containers storing liquid substances which contain VOCs orHAPs but which have negligible vapor pressures.

a. Hydraulic oil Tank, 2,000 gallons

b. Motor oil tank, 500 gallons

12. Operation of the portable “day tanks” for gasoline storage on the production line; theirassociated fuel transfer system; and the filling of the day tanks at the bulk storage tank.

13. Operation of the small parts wash units and the associated storage and handling ofmineral spirits.

Pursuant to §26.3(d) of Regulation 26, the following emission units, operations, or activities havebeen determined by the Department to be below the deminimis 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 one 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 applicablerequirements 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 or businesses primarily involved in photographic reproduction.

7. Janitorial services and consumer use of janitorial products.


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.

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

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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. 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.


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.

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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 oil, 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.

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.


29

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, has no hexavalent chromium, and emits no more than 0.1 tpyof all 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 delivering the 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.

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.


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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.

59. Use of products for the purpose of maintaining motor vehicles operated by the facility,not including air cleaning units or 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 residential orrecreational use.


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64. Log wetting areas and log flumes.

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 ADPC&E determines that a nuisance may occur.

69. Emissions from engine crankcase vents.

70. Storage tanks used for the temporary containment of materials resulting from anemergency reporting of 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).

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.


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SECTION VII: GENERAL PROVISIONS

1. Pursuant to 40 C.F.R. 70.6(b)(2), any terms or conditions included in this permit whichspecify and reference Arkansas Pollution Control & Ecology Commission Regulation 18or the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as thesole origin of and authority for the terms or conditions are not required under the CleanAir Act or any of its applicable requirements, and are not federally enforceable under theClean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 18 wasadopted pursuant to the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101et seq.). Any terms or conditions included in this permit which specify and referenceArkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Waterand Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as the origin of and authority forthe 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 OperatingAir 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 completeapplication for permit renewal at least six (6) months prior to the date of permitexpiration. Permit expiration terminates the permittee's right to operate unless a completerenewal application was submitted at least six (6) months prior to permit expiration, inwhich case the existing permit shall remain in effect until the Department takes finalaction on the renewal application. The Department will not necessarily notify thepermittee 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 applicablerequirement of the Clean Air Act, as amended, 42 U.S.C. 7401, et seq (Act) is morestringent than an applicable requirement of regulations promulgated under Title IV of theAct, both provisions are incorporated into the permit and shall be enforceable by theDirector or Administrator.

5. Pursuant to 40 C.F.R. 70.6(a)(3)(ii)(A) and §26.7 of Regulation #26, records ofmonitoring information required by this permit shall include the following:

a. The date, place as defined in this permit, and time of sampling or measurements; b. The date(s) analyses were performed;c. The company or entity that performed the analyses;d. The analytical techniques or methods used;


33

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 allrequired monitoring data and support information shall be retained for a period of at least5 years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all originalstrip-chart recordings for continuous 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 shallsubmit reports of all required monitoring as specified in Specific Conditions ?, ?, and ? every 6 months. The reporting period shall end on the last day of June and December ofeach year. The report shall be due within 30 days of the end of the reporting period. Eventhough 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 suchreports. 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 Pollution Control and EcologyAir DivisionATTN: Air Enforcement BranchPost 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 ofRegulation #19, all deviations from permit requirements, including those attributable toupset conditions as defined in the permit shall be reported to the Department. An initialreport shall be made to the Department within 24 hours of discovery of the occurrence. The initial report may be made by telephone and shall include:

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

occurs, d. The date and time the deviation started, e. The duration of the deviation, f. The average emissions during the deviation,g. The probable cause of such deviations,


34

h. Any corrective actions or preventive measures taken or being taken to prevent suchdeviations 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 ofdiscovery of the occurrence and shall include in addition to the information required byinitial report a schedule of actions to be taken to eliminate future occurrences and/or tominimize the amount by which the permits limits are exceeded and to reduce the lengthof time for which said limits are exceeded. If the permittee wishes, they may submit afull report in writing (by facsimile, overnight courier, or other means) within 24 hours ofdiscovery of the occurrence and such report will serve as both the initial report and fullreport.

9. Pursuant to 40 C.F.R. 70.6(a)(5) and §26.7 of Regulation #26, and A.C.A.§8-4-203, asreferenced by §8-4-304 and §8-4-311, if any provision of the permit or the applicationthereof to any person or circumstance is held invalid, such invalidity shall not affect otherprovisions or applications hereof which can be given effect without the invalid provisionor application, and to this end, provisions of this Regulation are declared to be separableand severable.

10. Pursuant to 40 C.F.R. 70.6(a)(6)(i) and §26.7 of Regulation #26, the permittee mustcomply with all conditions of this Part 70 permit. Any permit noncompliance withapplicable requirements as defined in Regulation #26 constitutes a violation of the CleanAir Act, as amended, 42 U.S.C. 7401, et seq. and is grounds for enforcement action; forpermit termination, revocation and reissuance, or modification; or for denial of a permitrenewal application. Any permit noncompliance with a state requirement constitutes aviolation 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 andreissuance, 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 defensefor a permittee in an enforcement action that it would have been necessary to halt orreduce the permitted activity in order to maintain compliance with the conditions of thispermit.

12. Pursuant to 40 C.F.R. 70.6(a)(6)(iii) and §26.7 of Regulation #26, this permit may bemodified, revoked, reopened, and reissued, or terminated for cause. The filing of arequest by the permittee for a permit modification, revocation and reissuance, ortermination, or of a notification of planned changes or anticipated noncompliance doesnot stay any permit condition.


35

13. Pursuant to 40 C.F.R. 70.6(a)(6)(iv) and §26.7 of Regulation #26, this permit does notconvey 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 shallfurnish to the Director, within the time specified by the Director, any information that theDirector may request in writing to determine whether cause exists for modifying,revoking and reissuing, or terminating the permit or to determine compliance with thepermit. Upon request, the permittee shall also furnish to the Director copies of recordsrequired to be kept by the permit. For information claimed to be confidential, thepermittee may be required to furnish such records directly to the Administrator along witha claim of confidentiality.

15. Pursuant to 40 C.F.R. 70.6(a)(7) and §26.7 of Regulation #26, the permittee shall pay allpermit 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 berequired, under any approved economic incentives, marketable permits, emissions tradingand other similar programs or processes for changes that are provided for elsewhere inthis permit.

17. Pursuant to 40 C.F.R. 70.6(a)(9)(i) and §26.7 of Regulation #26, if the permittee isallowed to operate under different operating scenarios, the permittee shall,contemporaneously with making a change from one operating scenario to another, recordin a log at the permitted facility a record of the scenario under which the facility or sourceis operating.

18. Pursuant to 40 C.F.R. 70.6(b) and §26.7 of Regulation #26, all terms and conditions inthis permit, including any provisions designed to limit a source's potential to emit, areenforceable by the Administrator and citizens under the Act unless the Department hasspecifically designated as not being federally enforceable under the Act any terms andconditions included in the permit that are not required under the Act or under any of itsapplicable requirements.

19. Pursuant to 40 C.F.R. 70.6(c)(1) and §26.7 of Regulation #26, any document (includingreports) required by this permit shall contain a certification by a responsible official asdefined 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 allowan authorized representative of the Department, upon presentation of credentials, toperform the following:


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

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

c. Inspect at reasonable times any facilities, equipment (including monitoring and airpollution control equipment), practices, or operations regulated or required under thispermit; and

d. As authorized by the Act, sample or monitor at reasonable times substances orparameters for the purpose of assuring compliance with this permit or applicablerequirements.

21. Pursuant to 40 C.F.R. 70.6(c)(5) and §26.7 of Regulation #26, the permittee shall submita compliance certification with terms and conditions contained in the permit, includingemission limitations, standards, or work practices. This compliance certification shall besubmitted annually and shall be submitted to the Administrator as well as to theDepartment. All compliance certifications required by this permit shall include thefollowing:

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

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

and over the reporting period established by the monitoring requirements of thispermit; and

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

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

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.


37

23 Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, this permitauthorizes only those pollutant emitting activities addressed herein.

APPENDIX A

Process Flow Diagrams

APPENDIX B

Area Map

APPENDIX C

Plot Plan

Route To: FELICIA INMANAdministration

AIR DIVISION

INVOICE REQUEST FORM

(9-96)

Facility Name & Address:Frigidaire Home Products1 Poulan DriveNashville, Arkansas71852

CSN: 31-0023 Permit No: 349-AOP-R0

Permit Description: Title V(e.g. A = AIR CODE, S=SIP, H=NESHAP, P=PSD, N=NSPS, T5= Title V)

Initial Fee Calculations:

Title V = 3333(17.89)(TPY each pollutant, except CO) - amount of last annual air permit fee

NOTE: Do Not double count HAPs and VOCs!!!No greater than 4000 tpy per pollutant or less than $1000

F = ($17.89)(1.1+0.7+80.9+3.9+0.3) = $1550.

Fee Amount: $1555.00

Engineer: William E. Swafford, P.E.Date:

Public Notice

Pursuant to the Arkansas Operating Air Permit Program (Regulation #26) Section 6(b), the Air Divisionof the Arkansas Department of Pollution Control and Ecology gives the following notice:

Frigidaire Home Products (“Frigidaire”), a division of White Consolidated Industries, Inc. (“WCI”),operates a manufacturing facility at 1 Poulan Drive in Nashville, Howard County, Arkansas. The site isreferred to as the “Lawn and Garden Plant.” Prior to January 1997 the facility operated under the nameof Poulan/Weed Eater Inc. (“Poulan”), a division of WCI. In January 1997 Poulan was restructured andthe operator of the Lawn and Garden Plant became Frigidaire Home Products. Frigidaire manufactures avariety of gasoline powered lawn and garden equipment products at this facility. These units includepower-handle trimmers, edgers, blowers, and related equipment. The product line also includes a varietyof gasoline powered chainsaws.

Carbon monoxide (CO) is the only major criteria pollutant emitted at this facility of which over 99% isemitted from the engine test booths (SN-01). At the time of submitting the application for this permit,Frigidaire was using 61,000 gallons of unleaded gasoline per year in the engine test booths. The presentCO emissions from the plant are 236.3 tons per year (tpy). Frigidaire anticipates increasing productionand gasoline consumption to 105,000 gallons per year. The above mentioned emission factor and thisconsumption rate yields 406.3 tpy of CO, an increase of 170.2 tpy.

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 do so bycontacting Rhonda Sharp, Information Officer. Citizens desiring technical information concerning theapplication or permit should contact William E. Swafford, engineer. Both Rhonda Sharp and William E.Swafford can be reached at the Department's central office, 8001 National Drive, Little Rock, 72209,telephone (501) 682-0744.

The draft permit and permit application are available for copying at the above address. A copy of thedraft permit has also been placed at the Hempstead County Public Library, Fifth and Elm Streets, Hope,Arkansas 71801. 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 tothe Department at the above address - Attention: Rhonda Sharp. In order to be considered, the commentsmust be submitted 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 the newspaperof 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 conditionsin accordance with Section 2.1 of the Arkansas Pollution Control and Ecology Commission’sAdministrative Procedures (Regulation #8) and Regulation #26.

Dated this

Randall Mathis Director

operating air permit - arkansas department of ... · pdf fileoperating air permit ... baths...

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