operating air permit - arkansas department of … · cooper tire & rubber company, engineered...

OPERATINGAIR PERMIT

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

Permit #: 818-AOP-R2

IS ISSUED TO:

Cooper Tire & Rubber Company Engineered Products Division

166 Cooper DriveEl Dorado, AR 71730

Union CountyCSN: 70-0036

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

THE PERMIT APPLICATION AND ON THE FOLLOWING PAGES. THIS PERMIT ISVALID BETWEEN:

November 18, 1997 and November 17, 2002

AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN.

Signed:

Keith A. Michaels Modified Date

Cooper Tire & Rubber Company, Engineered Products DivisionPermit No. 818-AOP-R2CSN: 70-0036

2

SECTION I: FACILITY INFORMATION

PERMITTEE: Cooper Tire & Rubber CompanyCSN: 70-0036

PERMIT NUMBER: 818-AOP-R2

FACILITY ADDRESS: 166 Cooper DriveEl Dorado, Arkansas 71730

COUNTY: Union

CONTACT POSITION: Jason Johnson, Environmental CoordinatorTELEPHONE NUMBER: (870) 862-6441

REVIEWING ENGINEER: Melissa J. Blumenthal

UTM North-South (X): 3673.5 kmUTM East-West (Y): 536.3 km


3

SECTION II: INTRODUCTION

Cooper Tire & Rubber Company, Engineered Products Division (Cooper Tire) operates a moldedrubber products manufacturing facility in El Dorado, Arkansas. The molded rubber productsgenerally consist of specifically engineered rubber compounds bonded to metal carriers. Theseproducts are typically used for vehicle vibration control.

Process Description

Cooper Tire receives dry and liquid raw materials in both bulk and packaged forms. Dry materialsare stored inside the building. Carbon black is received in totes, bags, and supersacs. Three processoils are stored in bulk storage tanks in the east side of the building (SN-21). Fuel oil is stored in bulkstorage tanks on the southwest side of the building (SN-19 and SN-20). Solvents and cements arereceived and stored in drums. There are a total of six above ground storage tanks on site.

Rubber, carbon black, process oils, and miscellaneous dry ingredients are mixed in the BanburyMixer (SN-06). Carbon black is handled, weighed, and fed to the mixer in enclosed systems(SN-38). Dry ingredients are weighed to specified formulations and batched in the CompoundingArea (SN-14). The batches are then transported to the Banbury Mixer.

Carbon black and other dry ingredients generate dust at the opening to the mixer throat and the dropmill. Four dust collectors and a Mixing Area Vacuum System (SN-40) serve this operation. All ofthe dust collectors and the vacuum system discharge into filter rooms that provide additional filteringfor the discharged air. In addition, all mixing ventilation systems discharge into a filter room tocontrol any fugitive emissions that may result from this operation.

The mixed rubber is dropped from the Banbury Mixer onto a mill where it is milled to a specifiedwidth and thickness. Then, it is dipped in a de-tackifying solution, cooled, and layered onto skids(SN-39).

Some of the rubber is transported to the Pin Barrel Tuber (SN-34) where it is extruded in a specificform. The extruded form is cooled, dusted with a de-tackifier (zinc stearate), cut, and stored. Therubber pre-forms are used in the injection presses. The duster is connected to a dust collector.

Some of the rubber is transported to the Preformer Extruder (SN-35) where it is extruded in preformsfor use in conventional presses.


4

Some of the rubber is transported to the 6-inch Tuber (SN-16) where it is extruded in specific forms.The extruded form is dusted with a de-tackifier (talc), cooled, cut, and stored. This rubber is curedin the Autoclave (SN-27). The duster is connected to a dust collector.

Metal inserts for the molded rubber products are cleaned and undergo phosphate coating in theCaustic Cleaning/Phosphate Line (SN-32). Three heated tanks on the caustic line are equipped witha common roof exhaust. The acid tank is equipped with a fume scrubber and mist eliminator whichdischarges outside the building.

Solvents, adhesives, and coatings are mixed in the required proportions to form the adhesives andcoatings used on the metal inserts. The adhesives and coatings are stored and dispensed in theCement Storage and Mixing Room (SN-11).

Metal inserts are coated with adhesive coating in the Circular Paint Line (SN-01), Automatic PaintLine #1 (SN-02), Automatic Paint Line #2 (SN-03), Chain-on-Edge Paint Line (SN-08), and the DipUnits (SN-10 and SN-36). Each of the coating operations is equipped with exhausts that dischargeoutside the building.

The Pyrolytic Oven (SN-33) is used to clean Chain-on-Edge fixtures. The oven is fired with naturalgas and burns the dried adhesive off of the fixtures. The oven is equipped with an after-burner thatoperates at 1500 - 1650 deg. F. The after-burner exhausts outside the building.

Rubber and metal inserts are combined on the Conventional and Injection Presses (SN-26) toproduce molded rubber parts. A mold lubricant is applied to some molds. In addition, a coatingand/or a color code paint is applied to some cured products at the presses. Some cured parts are alsoground at the presses. Molds that become fouled through use are cleaned in the Mold Cleaner(SN-17). The Mold Cleaner is equipped with a dust collector that exhausts inside the building.

Some molded parts are transported to the Finishing Department where rubber flashing may beremoved in the Nitrogen Tumbler (SN-29) or the Nitrogen Deflasher (SN-30). This equipmentexhausts inside the building.

Finished products are inspected and stored in the warehouse prior to shipment to customers.

Steam is provided to the autoclave, the conventional presses, the caustic line, and the Circular PaintLine using two 500 horsepower boilers. The York Shipley Boiler (SN-25) is natural gas fired anduses No. 2 fuel oil as a backup fuel. The Sellers Boiler (SN-24) is only capable of firing natural gas.


5

Summary of Proposed Modifications

Cooper Tire has requested to increase the rubber processing limit on the Tubers and Extruders. TheBanbury Mixer and the Conventional and Injection Presses both have rubber processing limits of14,416 tons per twelve consecutive months. In order to provide maximum flexibility for plantoperations, Cooper Tire requested an identical limit for the Tubers and Extruders. The emissionscalculations for the Tubers and Extruders were based on processing 14,416 tons per year. Therefore,the requested change will not result in a change in permitted emissions.

Cooper Tire has requested to increase the toluene and ethylene glycol emissions limits for theSurface Coating Operations. Cooper Tire has found that the current limits do not provide the desiredplant operating flexibility. Cooper Tire requests that the toluene emission limit be increased from1.3 tons per year to 3.0 tons per year and that the ethylene glycol emission limit be increased from0.01 tons per year to 0.04 tons per year.

Cooper Tire is also installing some additional curing presses at the plant. These presses will be apart of the Conventional and Injection Presses source (SN-26). The operation of these presses doesnot require a change in the current rubber processing limit, mold lube/coating limit, color codingusage limit, or emission limits for the source.

The Department has made some additional changes to this permit. On February 15, 1999, revisedversions of Regulations #18 and #19 became effective. All of the regulatory citations in the permitwere modified to reflect the revised regulations.


6

Facility wide emissions are summarized in the following table. Specific emission unit informationis located at the indicated cross reference page.

CRITERIA POLLUTANTEMISSION SUMMARY

SourceNo.

Description Pollutant Emission Rates CrossReference

Pagelb/hr ton/year

Total Allowable EmissionsPM

PM10SO2

VOC CONOxLead

Phosphoric Acid Fumes

6.76.7

11.9203.5

9.212.85.620.1

19.319.351.3

310.639.855.70.820.4

N/A

Adhesive/Coating Application

01 Circular Paint Line PMPM10VOCLead

0.10.1

22.30.94

0.10.1- - - -

15

02 Automatic Paint Line #1 PMPM10VOCLead

1.21.2

45.51.77

2.42.4- -- -

15

03 Automatic Paint Line #2 PMPM10VOCLead

0.70.7

25.31.06

1.71.7- -- -

15

08 Chain-on-Edge Paint Line PMPM10SO2

VOCCO

NOXLead

0.20.20.1

32.00.20.3

0.55

0.50.50.1- -0.81.2- -

15



SourceNo.


Pagelb/hr ton/year

7

10 Dip Unit PMPM10VOCLead

0.50.5

15.60.65

0.70.7- -- -

15

11 Mixing and Storage Room VOCLead

- -1

- -1- -- -

15

36 Dip Unit PMPM10 VOCLead

0.50.5

15.60.65

0.70.7- -- -

15

01, 02, 03, 08, 10, 11, 36

VOCLead

- -- -

215.22

0.82215

Rubber Manufacturing

06 Banbury Mixer PMPM10VOC

0.20.21.1

0.40.43.4

20

16 6 Inch Tuber PMPM10VOC

0.10.10.2

0.10.1

0.6**

25

34 Pin Barrel Tuber PMPM10VOC

0.10.10.2

0.10.1

0.6**

25

35 Preformer Extruder PMPM10VOC

0.10.10.2

0.10.1

0.6**

25

26 Conventional and InjectionPresses

PMPM10VOC

0.10.1

43.2

0.40.4

86.4

38



SourceNo.


Pagelb/hr ton/year

8

28 Autoclave PMPM10VOC

0.10.10.1

0.40.40.3

42

Tanks

19 No. 2 Fuel Oil Storage Tank

VOC 0.3 0.1 32

20 No. 2 Fuel OilStorage Tank

VOC 0.3 0.1 32

21a Process Oil Tank VOC 0.1 0.1 32

21b Process Oil Tank VOC 0.1 0.1 32

21c Process Oil Tank VOC 0.1 0.1 32

22 Waste Oil Tank VOC 0.3 0.1 32

Boilers

24 Sellers Boiler PMPM10SO2

VOCCONOx

0.20.20.10.23.75.9

1.01.00.10.9

16.025.7

35

25 York Shipley Boiler PMPM10SO2

VOCCONOx

0.90.9

11.30.23.86.1

3.93.9

49.50.9

16.626.7

35

Other Sources

09 Mold Oven PMPM10VOC

0.10.10.1

0.40.40.4

23



SourceNo.


Pagelb/hr ton/year

9

14 Compounding Area PMPM10

0.10.1

0.40.4

24

17 Mold Cleaner PMPM10

0.10.1

0.40.4

31

32 Caustic Cleaning/Phosphate Line

Phosphoric Acid Fumes 0.1 0.4 44

33 Pyrolytic Oven PMPM10SO2

VOCCONOx

1.11.10.40.51.50.5

4.44.41.61.96.42.1

46

38 Carbon Black HandlingSystem and Weigh Hopper

PMPM10

0.10.1

0.40.4

48

39 Mixer Dip Mixing and DipTank

PMPM10

0.10.1

0.40.4

50

40 Mixing Area VacuumSystem

PMPM10

0.10.1

0.40.4

51

1Accounted for in adhesive/coating emissions at sources SN-01, SN-02, SN-03, SN-08, SN-10, and SN-36.2Total emissions for sources SN-01, SN-02, SN-03, SN-08, SN-10, SN-11, and SN-36.** Emissions are for SN-16, SN-34, and SN-35 combined.


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Overall non-criteria pollutant emissions are summarized in the following table. Specific hazardousair pollutant emission rates are identified in the specific emission unit information.

NON-CRITERIA POLLUTANTEMISSION SUMMARY

SourceNo.

Pollutant Emission Rates

lb/hr ton/year

Total AllowableEmissions

1,3 Butadiene 0.191 0.40

1,1 Dichloroethene (Vinylidene Chloride) 0.011 0.033

Acetophenone 3.291 6.48

Acrolein 0.034 0.07

Acrylonitrile 0.276 0.61

Aniline 0.035 0.08

Carbon Disulfide 8.855 17.68

Carbon Tetrachloride 0.711 0.053

Carbonyl Sulfide 3.468 6.86

Ethyl Benzene 24.881 20.75

Ethylene Glycol 0.24 0.46

Formaldehyde 1.36 0.7

Methylene Chloride 0.725 1.46

Methyl Ethyl Ketone (2-Butanone) 2.898 1.6

Methyl Isobutyl Ketone (4-Methyl 2-Pentanone) 128.642 82.23

n-Hexane 0.432 0.83

Nickel 0.009 0.01

Perchloroethylene (Tetrachloroethylene) 24.67 6.37

Phenol 0.023 0.05

Propylene Oxide 0.813 1.63

Styrene 0.629 1.27


NON-CRITERIA POLLUTANTEMISSION SUMMARY

SourceNo.

Pollutant Emission Rates

lb/hr ton/year

11

t-Butyl Methyl Ether 1.218 2.43

Toluene 50.761 4.18

Trichloroethylene 31.88 10.4

Xylene 111.986 93.93


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SECTION III: PERMIT HISTORY

The facility was originally permitted under Arkansas Regulation 19. The original permit, 818-A wasissued on November 10, 1987. The permit was modified and reissued as permit 818-AR-1 onSeptember 7, 1993.

Permit 818-AR-2 was issued on September 26, 1994, under Arkansas Regulation 19. Modificationsincluded a production increase and several changes in the manufacturing operation which includedreplacement of a dip unit with a new unit, routing particulate emissions from the 6-inch tuber to theWheelabrator dust collector, replacing the 8-inch hot feed tuber with a pin barrel tuber, andinstallation of a preformer extruder. Additionally several units were removed from service. Unitsremoved from service include two degreasers, a laboratory banbury mixer, fixture cleaning drumsand a rotocure operation.

Permit 818-AR-3 was issued on March 12, 1996, under Arkansas Regulation 19. Modificationsincluded a production increase and the ability to use new coating materials.

Cooper Tire’s first Title V operating permit, Permit #818-AOP-R0, was issued on November 18,1997. That modification permitted the installation of a new (second) dip unit (SN-36) and increasedthe overall adhesive/coating usage at the facility. Additionally, the VOC emission rates associatedwith the production of rubber were revised. The revised emission estimates were based on testingand emission factors developed by the Rubber Manufacturers Association. The modificationsresulted in an increase in permitted volatile organic compound (VOC) emissions of 46.7 tons peryear (tpy).

Cooper Tire’s second Title V operating permit, Permit #818-AOP-R1, was issued on January 15,1999. Cooper Tire replaced the existing Banbury Mixer (SN-06) and associated equipment with anew mixing system. This involved the construction of a new mixing building, the replacement ofthe mixer and the Compounding Area (SN-14), and the installation of a new Carbon Black HandlingSystem and Weigh Hopper, a new Mixer Dip Mixing and Dip Tank, and a new Mixing AreaVacuum System. The maximum annual rubber throughput on the new system is the same as theexisting Banbury Mixer.

These systems are served by new dust collection equipment, including a new secondary filtrationsystem. The mixing building ventilation system is also served by a filtration system. The existingmixer dust collector was removed. Improvements in dust collection efficiency and the addition ofthe secondary filtration system resulted in a decrease of particulate matter emissions. In addition,since the maximum throughput did not increase, the maximum annual VOC and HAP emissionswere unchanged.

The removal of the existing mixer dust collector affected the 6-inch Tuber and the Pin Barrel Tuber.These sources were connected to one of the new dust collectors.


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Cooper Tire also obtained revised physical data for several coatings and adhesives, and the plantlearned that several new materials will need to be introduced. As a result, there was a slight decreasein the maximum hourly VOC emission rates for each coating and adhesive application source, andan increase in the maximum hourly particulate matter emission rate for the Chain-on-Edge Paint Line(SN-08).

VOC emissions from the mold lube/coating had been omitted from the maximum VOC emission ratefor the Conventional and Injection Presses in past permit modifications. These emissions wereadded in this modification.

The following sources have been permanently removed from service through a permit modification:

Source Description

SN-04 Degreaser #1

SN-05 Degreaser #2

SN-07 Laboratory Banbury Mixer

SN-13 Fixture Cleaning Drums

SN-15 8 inch Tuber

SN-18 Wheelabrator

SN-23 Trichloroethylene Storage Tank

SN-27 Rotocure Operation


SECTION IV: EMISSION UNIT INFORMATION


15

Surface Coating OperationsSN-01, SN-02, SN-03, SN-08, SN-10, SN-11, SN-36

Source Description

Metal inserts are coated with adhesive coating in the Circular Paint Line (SN-01), the AutomaticPaint Line #1 (SN-02), the Automatic Paint Line #2 (SN-03), the Chain-on-Edge Paint Line (SN-08),and two dip units (SN-10 and SN-36). The Chain-on-Edge paint line uses a 1.0 million Btu per hournatural gas fired dryer. Adhesives are mixed in a cement mixing and storage room (SN-11).Emissions from the mixing and storage room are accounted for in the total emissions calculated forthe paint lines.

Specific Conditions

1. Pursuant to §19.501 et seq of the Regulations of the Arkansas Plan of Implementation for AirPollution Control, effective February 15, 1999 (Regulation #19) and 40 CFR Part 52Subpart E, the permittee shall not exceed the emission rates set forth in the following table.

The particulate matter emission rates are based on maximum capacity. The hourly VOC andlead emission rates are based on maximum capacity.

SN Pollutant lb/hr ton/year

01 PM10VOCLead

0.122.30.94

0.1**

02 PM10VOCLead

1.245.51.77

2.4**

03 PM10VOCLead

0.725.31.06

1.7**

08 PM10SO2

VOCCONOxLead

0.20.1

32.00.20.3

0.55

0.50.1*

0.81.2*

10 PM10VOCLead

0.515.60.65

0.7**

11 VOCLead

****

****



16

36 PM10VOCLead

0.515.60.65

0.7**

* Annual VOC and lead limit for listed sources established in Specific Condition #2. **Accounted for in total VOC emissions from SN-01, SN-02, SN-03, SN-08, SN-10, and SN-36.

2. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permitteeshall not exceed VOC emissions of 215.2 tons and lead emissions of 0.82 tons from sourcesSN-01, SN-02, SN-03, SN-08, SN-10, SN-11, and SN-36 during any consecutive twelvemonth period.

3. Pursuant to §19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shallmaintain records which demonstrate compliance with the emission limit set in SpecificCondition #2. These records may be used by the Department for enforcement purposes.Records shall be kept in a format equivalent to Attachment One. Records shall be updatedon a monthly basis, shall be kept on site, and shall be provided to Department personnel uponrequest. An annual total and each individual month’s data shall be submitted in accordancewith General Provision 7.

4. Pursuant to §18.801 of the Arkansas Air Pollution Control Code, effective February 15, 1999(Regulation #18), and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, thepermittee shall not exceed the emission rates set forth in the following table.

The particulate matter emission rates are based on maximum capacity. The hourly non-criteria pollutant emission rates are based on maximum capacity.


01 PMPerchloroethylene (Tetrachloroethylene)

Ethyl BenzeneXylene

Methyl Isobutyl KetoneFormaldehyde

TolueneTrichloroethylene

Methyl Ethyl Ketone (2-Butanone)Carbon Tetrachloride

0.13.593.44

15.4117.650.206.584.120.400.02

0.1***********



17


Ethyl BenzeneXylene




1.26.776.97

31.3834.590.37

16.937.780.750.26

2.4***********


Ethyl BenzeneXylene




0.74.063.90

17.4519.990.231.194.670.450.03

1.7***********


Ethyl BenzeneXylene




Ethylene Glycol

0.25.145.30

23.8426.280.28

12.875.910.570.200.04

0.5************


Ethyl BenzeneXylene


TrichloroethyleneMethyl Ethyl Ketone (2-Butanone)

TolueneCarbon Tetrachloride

0.52.512.58

11.6312.820.144.700.286.280.10

0.7***********



18

11 Perchloroethylene (Tetrachloroethylene)Ethyl Benzene

XyleneMethyl Isobutyl Ketone

FormaldehydeTrichloroethylene

Methyl Ethyl Ketone (2-Butanone)

** **


Ethyl BenzeneXylene


TrichloroethyleneMethyl Ethyl Ketone (2-Butanone)

TolueneCarbon Tetrachloride

0.52.512.58

11.6312.820.144.700.286.280.10

0.7***********

* Annual HAP limits for listed sources established in Specific Condition 5. **Accounted for in total HAP emissions from SN-01, SN-02, SN-03, SN-08, SN-10, and SN-36.

5. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not emit in excess of the following levels of HAPs from SN-01,SN-02, SN-03, SN-08, SN-10, and SN-36 during any consecutive twelve month period.

Hazardous Air PollutantAllowable Emission Level

(tons)

Perchloroethylene (Tetrachloroethylene) 6.2

Ethyl benzene 19.9

Xylene 92.7

Methyl Isobutyl Ketone 73.1

Formaldehyde 0.7

Toluene 3.0

Trichloroethylene 10.4

Methyl Ethyl Ketone (2-Butanone) 1.3

Carbon Tetrachloride 0.05

Ethylene Glycol 0.04


19

6. Pursuant to §18.1004 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall maintain records which demonstrate compliance with theemission limits set in Specific Condition #5. These records may be used by the Departmentfor enforcement purposes. Records shall be maintained in a format equivalent to AttachmentTwo. Records shall be updated on a monthly basis, shall be kept on site, and shall beprovided to Department personnel upon request. An annual total and each individualmonth’s data shall be submitted to the Department in accordance with General Provision 7.

7. Pursuant to §18.501 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed 5% opacity from sources SN-01, SN-02, SN-03,SN-08, SN-10, or SN-36 as measured by EPA Reference Method 9.

8. Pursuant to §18.1004 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall conduct weekly observations of the opacity from SN-01, SN-02, SN-03, SN-08, SN-10, and SN-36, and keep a record of these observations. If visibleemissions are detected, then the permittee shall conduct a 6-minute opacity reading inaccordance with EPA Reference Method 9. The results of these observations shall be kepton site and shall be made available to Department personnel upon request.


20

Banbury MixerSN-06

Source Description

Carbon black, “fillers,” curing agents, miscellaneous dry materials, rubber, and oil will be combinedin the Banbury Mixer in the required proportions for the desired rubber compound. Some minorcuring agents and other dry materials will be weighed at an operator compounding station at themixer. All solid materials will be loaded onto a charge conveyor that leads to the mixer or will becharged directly to the mixer via enclosed systems. Particulates will be released from the mixer,compounding station, charge conveyor, and drop mill. Two dust collectors will serve the mixer.One collector will serve the mixer charge door and ram chamber. The other dust collector will servethe compounding station, mixer drop gate, mixer dust seal hoods, and drop mill. Both dustcollectors will discharge to a filter room that will provide additional air filtering capacity prior todischarge to the atmosphere.

The emissions from SN-06 are discharged to Filter Room #2 where additional filtration is providedprior to discharge to the atmosphere. The emissions from SN-14 and SN-38 are also discharged toFilter Room #2. Since the emissions co-mingle in the filter room, it is not possible to observe theopacity of the emissions from each source individually. Instead, the Plantwide Conditions containan opacity limit and an observation requirement which applies to the discharge from Filter Room #2.

Specific Conditions

9. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permitteeshall not exceed the emission rates set forth in the following table. The emission rates areeffectively limited by Specific Condition #11.

Pollutant lb/hr ton/year

PM10 0.2 0.4

VOC 1.1 3.4

10. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates set forth in the following table.The emission rates are effectively limited by Specific Condition #11.


21


PM 0.2 0.4

1,1 Dichloroethene 0.001 0.003

1,3 Butadiene 0.002 0.01

2-Butanone (Methyl Ethyl Ketone) 0.028 0.09

4-Methyl-2-Pentanone (Methyl Isobutyl Ketone) 0.147 0.44


Acrolein 0.004 0.01


Aniline 0.002 0.01


Carbon Tetrachloride 0.001 0.003


Ethyl benzene 0.021 0.06


m,p Xylene 0.069 0.21

n-Hexane 0.052 0.16

o-Xylene 0.037 0.11

Phenol 0.003 0.01


Styrene 0.020 0.06



Toluene 0.111 0.33


22

11. Pursuant to §19.705 of Regulation #19, §18.1004 of Regulation #18, A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311, and 40 CFR 70.6, the permittee shall not exceed14,416 tons of rubber compound produced at the banbury mixer (SN-06) for any consecutivetwelve month period.

12. Pursuant to §19.705 of Regulation #19, 40 CFR Part 52 Subpart E, and §18.1004 ofRegulation #18, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permitteeshall maintain records which demonstrate compliance with the limit set in Specific Condition#11. These records may be used by the Department for enforcement purposes. The recordsshall be updated on a monthly basis, shall be kept on site, and shall be provided toDepartment personnel upon request. An annual total and each individual month’s data shallbe submitted in accordance with General Provision 7.


23

Mold OvenSN-09

Source Description

The electric mold oven is an intermittent operation. The mold oven is used to burn residue off ofmolds as necessary. Trace HAP emissions may be emitted. These emissions are assumed to bebelow the level of significance and are not addressed.

Specific Conditions

13. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permitteeshall not exceed the emission rates set forth in the following table. The emission rates arebased on maximum capacity.


PM10 0.1 0.4

VOC 0.1 0.4

14. Pursuant to §18.501 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed 5% opacity from SN-09 as measured by EPAReference Method 9.

15. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates set forth in the following table.The emission rates are based on maximum capacity.


PM 0.1 0.4

16. Pursuant to §18.1004 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall conduct weekly observations of the opacity from SN-09 andkeep a record of these observations. If visible emissions are detected, then the permitteeshall conduct a 6-minute opacity reading in accordance with EPA Reference Method 9. Theresults of these observations shall be kept on site and shall be made available to Departmentpersonnel upon request.


24

Compounding AreaSN-14

Source Description

“Fillers,” curing agents, and miscellaneous dry materials will be weighed and accumulated in batchesin the Compounding Area for subsequent presentation to the Banbury Mixer. Particulates will bereleased from this area as material bags are emptied, and materials are weighed and batched. Twodust collectors will serve this area. One collector will serve the materials storage bins. The otherdust collector will serve the compounding station. Both dust collectors will discharge to a filterroom that will provide additional air filtering capacity prior to discharge to the atmosphere.


Specific Conditions

17. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permitteeshall not exceed the emission rates set forth in the following table. These emissions arebased on maximum capacity.


PM10 0.1 0.4

18. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates set forth in the following table.These emissions are based on maximum capacity.


PM 0.1 0.4


25

Tubers and Extruders:6-Inch Tuber (Cold Feed), Pin Barrel Tuber, Preformer Extruder

SN-16, SN-34, SN-35

Source Description

Rubber is extruded from the Pin Barrel Tuber (SN-34) or the Preformer Extruder (SN-35), cooled,dusted, cut and stored. These rubber preforms are used in conventional and injection presses.Rubber and metal inserts are combined on the conventional and injection presses to produce moldedrubber parts.

Rubber from the 6-inch tuber (SN-16) is extruded, cured, cut, and stored. The extruded rubber iscured in the Autoclave. Some molded parts are transported to the finishing department where rubberflashing may be removed in the Nitrogen Tumbler or Nitrogen Deflasher.

Particulate emissions from these sources are routed to the baghouse which controls emissions fromthe Banbury Mixer (SN-06). The visible emissions from these sources will be limited by PlantwideConditions #6 and #7. Emissions of VOCs and HAPs are accounted for at the source.

Specific Conditions



16PM10 0.1 0.1

VOC 0.2 0.6**

34PM10 0.1 0.1

VOC 0.2 0.6**

35PM10 0.1 0.1

VOC 0.2 0.6**** Emission rate for SN-16, SN-34, and SN-35 combined.


26

20. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates at source SN-16 as set forth inthe following table. The emission rates are effectively limited by Specific Condition #24.


PM 0.1 0.1

1,3 Butadiene 0.003 **

2-Butanone (Methyl Ethyl Ketone) 0.02 **

4-Methyl-2-Pentanone (Methyl IsobutylKetone)

0.01 **

Acetophenone 0.04 **

Carbon Disulfide 0.07 **

Carbonyl Sulfide 0.06 **

Ethyl benzene 0.01 **

Methylene Chloride 0.06 **

m,p Xylene 0.04 **

n-Hexane 0.03 **

Nickel 0.003 **

o-Xylene 0.02 **

Propylene Oxide 0.01 **

Styrene 0.003 **

t-Butyl Methyl Ether 0.02 **

Perchloroethylene (Tetrachloroethylene) 0.01 **

Toluene 0.06 ****Total annual HAP Emissions provided in Specific Condition #23.


27



PM 0.1 0.1




0.01 **






m,p Xylene 0.04 **

n-Hexane 0.03 **

Nickel 0.003 **

o-Xylene 0.02 **


Styrene 0.003 **





28



PM 0.1 0.1




0.01 **






m,p Xylene 0.04 **

n-Hexane 0.03 **

Nickel 0.003 **

o-Xylene 0.02 **


Styrene 0.003 **





29

23. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the annual emission rates from sources SN-16,SN-34, and SN-35 as set forth in the following table. The emission rates are effectivelylimited by Specific Condition #24.

Pollutant ton/year

1,3 Butadiene 0.01

2-Butanone (Methyl Ethyl Ketone) 0.05

4-Methyl-2-Pentanone (Methyl Isobutyl Ketone) 0.04

Acetophenone 0.12

Carbon Disulfide 0.22

Carbonyl Sulfide 0.17

Ethyl benzene 0.03

Methylene Chloride 0.19

m,p Xylene 0.11

n-Hexane 0.08

Nickel 0.01

o-Xylene 0.06

Propylene Oxide 0.03

Styrene 0.01

t-Butyl Methyl Ether 0.06

Perchloroethylene (Tetrachloroethylene) 0.03

Toluene 0.18


30

24. Pursuant to §19.705 of Regulation #19, §18.1004 of Regulation #18, A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311, and 40 CFR 70.6, the permittee shall not process inexcess of 14,416 tons of rubber through the tubers and extruders (SN-16, SN-34 and SN-35)during any consecutive twelve month period. (The amount of rubber processed is alsolimited by Specific Conditions #11 and #51.)

25. Pursuant to §19.705 of Regulation #19, 40 CFR Part 52 Subpart E, §18.1004 of Regulation#18, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permittee shallmaintain records of rubber processed in the tubers and extruders which demonstratecompliance with the limit set in Specific Condition #24. These records may be used by theDepartment for enforcement purposes. The records shall be updated on a monthly basis,shall be kept on site, and shall be provided to Department personnel upon request. An annualtotal and each individual month’s data shall be submitted in accordance with GeneralProvision 7. (These records are also required to by Specific Conditions #12 and #52. Oneset of records may be used to demonstrate compliance with all three conditions.)


31

Mold CleanerSN-17

Source Description

Molds are cleaned using a blasting operation. This source operates intermittently and is controlledby a baghouse.

Specific Conditions

26. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permitteeshall not exceed the emission rates set forth in the following table. The emission rates arebased on maximum capacity.


PM10 0.1 0.4

27. Pursuant to §18.501 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed 5% opacity from SN-17 as measured by EPAReference Method 9.

28. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates set forth in the following table.The emission rates are based on maximum capacity.


PM 0.1 0.4

29. Pursuant to §18.1004 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall conduct weekly observations of the opacity from SN-17 andkeep a record of these observations. If visible emissions are detected, then the permitteeshall conduct a 6-minute opacity reading in accordance with EPA Reference Method 9. Theresults of these observations shall be kept on site and shall be made available to Departmentpersonnel upon request.


32

Storage TanksSN-19, SN-20, SN-21a, SN-21b, SN-21c, SN-22

Source Description

Six above ground storage tanks are located on site. Storage tanks contain No. 2 fuel oil (SN-19 andSN-20), waste oil (SN-22), and process oils (SN-21a, SN-21b and SN-21c).

SN-19 and SN-20 are not subject to regulation under NSPS Subpart K due to a vapor pressure lessthan 1.5 pounds per square inch absolute and, for SN-20, due to a capacity of less than 40,000gallons. SN-21a, SN-21b, SN-21c and SN-22 are not subject to regulation under NSPS Subpart Kbdue to a capacity less than 75 cubic meters (approximately 19,812.8 gallons). The following tablecontains the specifications of the six tanks.

SN Description Size (gal) Year

19 No. 2 Fuel Oil Storage Tank 50,000 1978

20 No. 2 Fuel Oil Storage Tank 12,500 1977

21a Process Oil Tank 10,000 1988

21b Process Oil Tank 10,000 1988

21c Process Oil Tank 10,000 1988

22 Waste Oil Tank 8,500 1990

Specific Conditions

30. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permitteeshall not exceed the emission rates set forth in the following table. The emission rates areeffectively limited by Specific Conditions #31, #33, #35, and #37.


19 VOC 0.3 <0.1

20 VOC 0.3 <0.1

21a VOC <0.1 <0.1

21b VOC <0.1 <0.1



33

21c VOC <0.1 <0.1

22 VOC 0.3 <0.1

31. Pursuant to §19.705 of Regulation #19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, and 40 CFR 70.6, the permittee shall not exceed a throughput of 1,310,400 gallonsNo. 2 fuel oil at SN-19 during any consecutive twelve month period.

32. Pursuant to §19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shallmaintain records of No. 2 fuel oil throughput which demonstrate compliance with the limitset in Specific Condition #31 and may be used by the Department for enforcement purposes.The records shall be updated on a monthly basis, shall be kept on site, and shall be providedto Department personnel upon request. An annual total and each individual month’s datashall be submitted in accordance with General Provision 7.

33. Pursuant to §19.705 of Regulation #19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, and 40 CFR 70.6, the permittee shall not exceed a throughput of 111,600 gallonsNo. 2 fuel oil at SN-20 during any consecutive twelve month period.

34. Pursuant to §19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shallmaintain records of No. 2 fuel oil throughput which demonstrate compliance with the limitset in Specific Condition #33 and may be used by the Department for enforcement purposes.The records shall be updated on a monthly basis, shall be kept on site, and shall be providedto Department personnel upon request. An annual total and each individual month’s datashall be submitted in accordance with General Provision 7.

35. Pursuant to §19.705 of Regulation #19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, and 40 CFR 70.6, the permittee shall not exceed a throughput of 36,000 gallonsof waste oil at SN-22 during any consecutive twelve month period.

36. Pursuant to §19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shallmaintain records of waste oil throughput which demonstrate compliance with the limit setin Specific Condition #35 and may be used by the Department for enforcement purposes.The records shall be updated on a monthly basis, shall be kept on site, and shall be providedto Department personnel upon request. An annual total and each individual month’s datashall be submitted in accordance with General Provision 7.


34

37. Pursuant to §19.705 of Regulation #19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311 and 40 CFR 70.6, the permittee shall not store any material other than process oilin the tanks which are sources SN-21a, SN-21b, and SN-21c.


35

BoilersSN-24, SN-25

Source Description

Steam is provided to the autoclave, conventional presses, the Circular Paint Line Dryer, and thecaustic line using a Sellers boiler (SN-24), with a heat input capacity of 20.9 mmBTU/hr, installedin 1972, and a York Shipley boiler (SN-25), with a heat input capacity of 20.9 mmBTU/hr, installedin 1974. The Sellers boiler is capable of firing natural gas only. The York Shipley boiler is capableof firing natural gas or No. 2 fuel oil. Emissions associated with the York Shipley boiler representthe worst case operating scenario.

Specific Conditions

38. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permitteeshall not exceed the emission rates set forth in the following table. The emission rates areeffectively limited by Specific Conditions #43, #44, and #45.


24 PM10 0.2 1.0

SO2 0.1 0.1

VOC 0.2 0.9

CO 3.7 16.0

NOx 5.9 25.7

25 PM10 0.9 3.9

SO2 11.3 49.5

VOC 0.2 0.9

CO 3.8 16.6

NOx 6.1 26.7

39. Pursuant to §19.503 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shallnot exceed 20% opacity from SN-25 as measured by EPA Reference Method 9, whilecombusting fuel oil.


36

40. Pursuant to §19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shallconduct weekly observations of the opacity from SN-25 when combusting fuel oil and keepa record of these observations. If visible emissions are detected, then the permittee shallconduct a 6-minute opacity reading in accordance with EPA Reference Method 9. Theresults of these observations shall be kept on site and shall be made available to Departmentpersonnel upon request.

41. Pursuant to §18.501 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed 5% opacity from SN-24 or SN-25 as measured byEPA Reference Method 9, while combusting natural gas. Compliance with the opacity limitfor SN-24 and SN-25 when combusting natural gas shall be met by compliance with SpecificCondition #43.

42. Pursuant to §18.801 et seq of Regulation #19 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. The emission rates are effectively limited by Specific Conditions #43 and #44.


24 PM 0.2 1.0

25 PM 0.9 3.9

43. Pursuant to §19.705 of Regulation #19, §18.1004 of Regulation #18, A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311, and 40 CFR 70.6, natural gas shall be the only fuelcombusted in SN-24.

44. Pursuant to §19.705 of Regulation #19, §18.1004 of Regulation #18, A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311, and 40 CFR 70.6, natural gas or fuel oil may becombusted in SN-25.

45. Pursuant to §19.705 of Regulation #19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, and 40 CFR 70.6, the permittee shall not use any fuel oil which has a sulfurcontent in excess of 0.5% in source SN-25.


37

46. Pursuant to §19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the sulfur content ofthe fuel oil shall be verified by testing or vendors’ guarantees. The permittee shall maintaina record of each fuel shipment and the associated sulfur content. This record shall beupdated with each shipment, kept on site, shall be made available to Department personnelupon request and may be used by the Department for enforcement purposes. This reportshall be submitted to the Department in accordance with General Provision #7.


38

Conventional and Injection PressesSN-26

Source Description

Rubber preforms from the tubers and extruders are combined with metal inserts at the conventionaland injection presses to form molded rubber parts. This source currently includes 26 conventionalpresses and 26 injection presses. Cooper Tire will be adding four additional presses.

Specific Conditions

47. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permitteeshall not exceed the emission rates at source SN-26 as set forth in the following table. Theemission rates are effectively limited by Specific Conditions #51, #53, #54, #56, and #58.


PM10 0.1 0.4

VOC 43.2 86.4

48. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates at source SN-26 as set forth inthe following table. The emission rates are effectively limited by Specific Conditions #51,#53, #54, #56, #57, and #58.


PM 0.1 0.4

Ethylene Glycol 0.2 0.42

1,1 Dichloroethene 0.01 0.03

1,3 Butadiene 0.17 0.37



4.31 8.64


Acrolein 0.03 0.06



39


Aniline 0.03 0.06





m,p Xylene 0.09 0.18

n-Hexane 0.22 0.45

o-Xylene 0.13 0.27

Phenol 0.02 0.04


Styrene 0.60 1.2



Toluene 0.19 0.37

49. Pursuant to §19.503 of Regulation #18 and 40 CFR Part 52 Subpart E, the permittee shallnot exceed 20% opacity from SN-26 as measured by EPA Reference Method 9.

50. Pursuant to §19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shallconduct weekly observations of the opacity from SN-26 and keep a record of theseobservations. If visible emissions are detected, then the permittee shall conduct a 6-minuteopacity reading in accordance with EPA Reference Method 9. The results of theseobservations shall be kept on site and shall be made available to Department personnel uponrequest.

51. Pursuant to §19.705 of Regulation #19, §18.1004 of Regulation #18, A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311, and 40 CFR 70.6, the permittee shall not exceed14,416 tons of rubber processed in the conventional and injection presses (SN-26) during any


40

consecutive twelve month period. (The amount of rubber processed is also limited bySpecific Conditions #11 and #24.)

52. Pursuant to §19.705 of Regulation #19, 40 CFR Part 52 Subpart E, §18.1004 of Regulation#18, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permittee shallmaintain records of amount of rubber processed on the conventional and injection presseswhich demonstrate compliance with the limit set in Specific Condition #51. These recordsmay be used by the Department for enforcement purposes. The records shall be updated ona monthly basis, shall be kept on site, and shall be provided to Department personnel uponrequest. An annual total and each individual month’s data shall be submitted in accordancewith General Provision 7. (These records are also required by Specific Conditions #12 and#25. One set of records may be used to demonstrate compliance all three conditions.)

53. Pursuant to §19.705 of Regulation #19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311 and 40 CFR 70.6, the permittee shall not use any mold lube/coating which containsmore than 8.34 pounds VOCs per gallon.

54. Pursuant to §19.705 of Regulation #19, #18.1004 of Regulation #18, A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311, and 40 CFR 70.6, the permittee shall not use in excessof 5,600 gallons of mold lube/coating at (SN-26) during any consecutive twelve monthperiod.

55. Pursuant to §19.705 of Regulation #19, 40 CFR Part 52 Subpart E, §18.1004 of Regulation#18, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permittee shallmaintain records of amount of mold lube/coating used which demonstrate compliance withthe limit set in Specific Condition #54. These records may be used by the Department forenforcement purposes. The records shall be updated on a monthly basis, shall be kept onsite, and shall be provided to Department personnel upon request. An annual total and eachindividual month’s data shall be submitted in accordance with General Provision 7.

56. Pursuant to §19.705 of Regulation #19, §18.1004 of Regulation #18, A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311, and 40 CFR 70.6, the permittee shall not use any colorcoding coating which contains more than 8.34 pounds VOCs per gallon.

57. Pursuant to §18.1004 of Regulation #18, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not use any color coding coating which contains more than 0.33pounds ethylene glycol per gallon.


41

58. Pursuant to §19.705 of Regulation #19, §18.1004 of Regulation #18, A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311, and 40 CFR 70.6, the permittee shall not use in excessof 2,500 gallons of color coding (SN-26) during any consecutive twelve month period.

59. Pursuant to §19.705 of Regulation #19, 40 CFR Part 52 Subpart E, §18.1004 of Regulation#18, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permittee shallmaintain records of amount of color coding used which demonstrate compliance with thelimit set in Specific Condition #58. These records may be used by the Department forenforcement purposes. The records shall be updated on a monthly basis, shall be kept onsite, and shall be provided to Department personnel upon request. An annual total and eachindividual month’s data shall be submitted in accordance with General Provision 7.


42

AutoclaveSN-28

Source Description

Rubber preforms from the tubers and extruders are cured in the autoclaves prior to being utilized inthe conventional and injection presses.

Specific Conditions



PM10 0.1 0.4

VOC 0.1 0.3



PM 0.1 0.4

1,3-Butadiene 0.01 0.01


4-Methyl-2-Pentanone (Methyl Isobutyl Ketone) 0.005 0.01

Aniline 0.003 0.01





m,p Xylene 0.09 0.19



43

n-Hexane 0.07 0.14

o-Xylene 0.05 0.10


Toluene 0.15 0.30

62. Pursuant to §19.503 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shallnot exceed 20% opacity from SN-28. Opacity shall be measured by EPA ReferenceMethod 9.

63. Pursuant to §19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shallconduct weekly observations of the opacity from SN-28 and keep a record of theseobservations. If visible emissions are detected, then the permittee shall conduct a 6-minuteopacity reading in accordance with EPA Reference Method 9. The results of theseobservations shall be kept on site and shall be made available to Department personnel uponrequest. The observations shall be made at the point of greatest opacity in that portion of theplume where condensed water vapor is not present.

64. Pursuant to §19.705 of Regulation #19, §18.1004 of Regulation #18, A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311 and 40 CFR 70.6, the permittee shall not exceed1,533,667 pounds of rubber processed in the autoclave (SN-28) during any consecutivetwelve month period.

65. Pursuant to §19.705 of Regulation #19, 40 CFR Part 52 Subpart E, §18.1004 of Regulation#18, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permittee shallmaintain records of rubber throughput through the autoclaves which demonstrate compliancewith the limit set in Specific Condition #64. These records may be used by the Departmentfor enforcement purposes. The records shall be updated on a monthly basis, shall be kept onsite, and shall be provided to Department personnel upon request. An annual total and eachindividual month’s data shall be submitted in accordance with General Provision 7.


44

Caustic Cleaning/Phosphate LineSN-32

Source Description

Metal inserts used to make the molded rubber products are cleaned and phosphate coated prior touse. The phosphoric acid tank on the caustic line is equipped with a fume scrubber and misteliminator.

Specific Conditions



Phosphoric AcidFumes

0.1 0.4

67. Pursuant to §19.503 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shallnot exceed 20% opacity from SN-32 as measured by EPA Reference Method 9.

68. Pursuant to §19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shallconduct weekly observations of the opacity from SN-32 and keep a record of theseobservations. If visible emissions are detected, then the permittee shall conduct a 6-minuteopacity reading in accordance with EPA Reference Method 9. The results of theseobservations shall be kept on site and shall be made available to Department personnel uponrequest.

69. Pursuant to §18.1104 of Regulation #18, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall maintain a water flow rate of 15 gallons per minute in thescrubber (SN-32).

70. Pursuant to §18.1104 of Regulation #18, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, phosphoric acid solution in the acid bath on the caustic cleaning/phosphate lineshall not exceed 15% phosphoric acid by volume.


45

71. Pursuant to §18.1004 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall maintain records to demonstrate compliance with SpecificCondition #70. This record shall be updated on a monthly basis, shall be kept on site, andshall be provided to Department personnel upon request. Each month’s individual data shallbe submitted in accordance with General Provision 7.


46

Pyrolytic OvenSN-33

Source Description

A Pyrolytic Oven is used to clean Chain-on-Edge fixtures. The oven burns adhesives off of thefixtures. The oven 0.40 MMBtu/hr and is natural gas fired. Emissions from the oven are controlledby an afterburner.

Specific Conditions

72. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permitteeshall not exceed the emission rates at source set forth in the following table. The emissionrates are effectively limited by Specific Conditions #75 and #76.


PM10 1.1 4.4

SO2 0.4 1.6

VOC 0.5 1.9

CO 1.5 6.4

NOx 0.5 2.1

73. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates at source set forth in thefollowing table. The emission rates are effectively limited by Specific Conditions #75 and#76.


PM 1.1 4.4

74. Pursuant to §19.503 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shallnot exceed 20% opacity from SN-33 as measured by EPA Reference Method 9. Compliancewith the opacity limit for SN-33 shall be met by compliance with Specific Condition #75.


47

75. Pursuant to §19.705 of Regulation #19, §18.1004 of Regulation #18, A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311, and 40 CFR 70.6, the pyrolytic oven shall be only befired by natural gas.

76. Pursuant to §19.705 of Regulation #19, §18.1004 of Regulation #18, A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311, and 40 CFR §70.6, the afterburner which controlsemissions from the pyrolytic oven shall be maintained as a minimum temperature of 1400degrees Fahrenheit at all times when the oven is operating.


48

Carbon Black Handling System and Weigh HopperSN-38

Source Description

Carbon black will be received in supersacs which will be connected to the Carbon Black HandlingSystem. The carbon black will be transported in this system to the Weigh Hopper where it isweighed in batches. At the proper time, the weighed carbon black will drop down the chute into themixer. The system, weigh hoppper, and chute vent to a dust collector. The dust collector dischargesto the filter room.


Specific Conditions



PM10 0.1 0.4



PM 0.1 0.4

79. Pursuant to §19.705 of Regulation #19, §18.1004 of Regulation #18, A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311, and 40 CFR 70.6, the permittee shall not exceed 4,380tons of carbon black processed in this area (SN-38) during any consecutive twelve monthperiod.


49

80. Pursuant to §19.705 of Regulation #19, 40 CFR Part 52 Subpart E, §18.1004 of Regulation#18, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permittee shallmaintain records of carbon black throughput through the Carbon Black Handling System andWeigh Hopper which demonstrate compliance with the limit set in Specific Condition #79.These records may be used by the Department for enforcement purposes. The records shallbe updated on a monthly basis, shall be kept on site, and shall be provided to Departmentpersonnel upon request. An annual total and each individual month’s data shall be submittedin accordance with General Provision 7.


50

Mixer Dip Mixing and Dip TankSN-39

Source Description

Mixed rubber will be dipped in a water-based de-tackifying solution and cooled. The dip mixingoperation will be served by the mixing building ventilation system which discharges to the filterroom. The dip tank will be equipped with a hood that exhausts directly to the filter room.

The emissions from SN-39 are discharged to Filter Rooms #1 and #3 where additional filtration isprovided prior to discharge to the atmosphere. The emissions from SN-40 are also discharged toFilter Room #1 and #3. Since the emissions co-mingle in the filter room, it is not possible to observethe opacity of the emissions from each source individually. Instead, the Plantwide Conditionscontain an opacity limit and an observation requirement which applies to the discharge from FilterRooms #1 and #3.

Specific Conditions



PM10 0.1 0.4



PM 0.1 0.4


51

Mixing Area Vacuum SystemSN-40

Source Description

The mixing area will be equipped with a vacuum system to facilitate clean up and containment ofdusty materials. The system will be equipped with a primary separator and a dust collector thatexhausts to the Filter Room.

The emissions from SN-40 are discharged to Filter Rooms #1 and #3 where additional filtration isprovided prior to discharge to the atmosphere. The emissions from SN-39 are also discharged toFilter Room #1 and #3. Since the emissions co-mingle in the filter room, it is not possible to observethe opacity of the emissions from each source individually. Instead, the Plantwide Conditionscontain an opacity limit and an observation requirement which applies to the discharge from FilterRooms #1 and #3.

Specific Conditions

83. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permitteeshall not exceed the emission rates set forth in the following table. The emissions are basedon maximum capacity.


PM10 0.1 0.4

84. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates set forth in the following table.The emissions are based on maximum capacity.


PM 0.1 0.4


52

SECTION V: COMPLIANCE PLAN AND SCHEDULE

Cooper Tire & Rubber Company, Engineered Products Division is in compliance with the applicableregulations cited in the permit application. Cooper Tire & Rubber Company, Engineered ProductsDivision will continue to operate in compliance with those identified regulatory provisions. Thefacility will examine and analyze future regulations that may apply and determine their applicabilitywith any necessary action taken on a timely basis.


53

SECTION VI. PLANTWIDE CONDITIONS

1. Pursuant to Section 19.704 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203as referenced by §8-4-304 and §8-4-311, the Director shall be notified in writing within thirty(30) days after construction has commenced, construction is complete, the equipment and/orfacility is first placed in operation, and the equipment and/or facility first reaches the targetproduction rate.

2. Pursuant to Section 19.410(B) of Regulation 19, 40 CFR Part 52, Subpart E, the Director maycancel all or part of this permit if the construction or modification authorized herein is notbegun within 18 months from the date of the permit issuance if the work involved in theconstruction or modification is suspended for a total of 18 months or more.

3. Pursuant to Section 19.702(E), 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as referencedby §8-4-304 and §8-4-311, each emission point for which an emission test method is specifiedin this permit shall be tested in order to determine compliance with the emission limitationscontained herein within sixty (60) days of achieving the maximum production rate, but in noevent later than 180 days after initial start-up of the permitted source. The permittee shallnotify the Department of the scheduled date of compliance testing at least fifteen (15) days inadvance of such test. Two copies of the compliance test results shall be submitted to theDepartment within thirty (30) days after the completed testing. 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 §19.303 of Regulation #19 and/or §18.1104 of Regulation #18, and A.C.A.§8-4-203 as referenced by A.C. A. §8-4-304 and §8-4-311, the equipment, control apparatusand emission monitoring equipment shall be operated within their design limitations andmaintained 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, thispermit subsumes and incorporates all previously issued air permits for this facility.

6. Pursuant to §18.801 of Regulation #18, the permittee shall not cause or permit the emissionof air contaminants, including odors or water vapor and including an air contaminant whoseemission is not otherwise prohibited by Regulation #18, if the emission of the air contaminantconstitutes air pollution within the meaning of A.C.A. §8-4-303.


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7. Pursuant to §18.901 of Regulation #18, the permittee shall not conduct operations in such amanner as to unnecessarily cause air contaminants and other pollutants from becomingairborne.

8. Pursuant to §18.501 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed 5% opacity from Filter Room #1 (SN-39 and SN-40discharge to this filter room). Opacity shall be measured by EPA Reference Method 9.

9. Pursuant to §18.1004 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall conduct weekly observations of the opacity from Filter Room #1and keep a record of these observations. If visible emissions are detected, then the permitteeshall conduct a 6-minute opacity reading in accordance with EPA Reference Method 9. Theresults of these observations shall be kept on site and shall be made available to Departmentpersonnel upon request.

10. Pursuant to §18.501 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed 5% opacity from Filter Room #2 (SN-06, SN-14, andSN-38 discharge to this filter room). Opacity shall be measured by EPA Reference Method 9.


12. Pursuant to §18.501 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed 5% opacity from Filter Room #3 (SN-39 and SN-40discharge to this filter room). Opacity shall be measured by EPA Reference Method 9.



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Title VI Provisions

14. 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 is stored or transported, allproducts containing a class I substance, and all products directly manufactured witha 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.

15. The permittee shall comply with the standards for recycling and emissions reduction pursuantto 40 CFR Part 82, Subpart F, excepts 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.)

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


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

16. 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 C.F.R. Part 82,Subpart A, Production and Consumption Controls.

17. 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 applicable requirementsas specified in 40 C.F.R. Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners.

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.

18. The permittee shall be allowed to switch from any ozone-depleting substance to anyalternative that is listed in the Significant New Alternatives Program (SNAP) promulgatedpursuant to 40 CFR Part 82, Subpart G, Significant New Alternatives Policy Program.


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SECTION VII: INSIGNIFICANT ACTIVITIES

Pursuant to §26.3(d) of Regulation 26, the following sources are insignificant activities.Insignificant and trivial activities will be allowable after approval and federal register noticepublication of a final list as part of the operating air permit program. Any activity for which a stateor federal applicable requirement applies is not insignificant even if this activity meets the criteriaof §3(d) of Regulation 26 or is listed below. Insignificant activity determinations rely upon theinformation submitted by the permittee in an application dated June 10, 1996.

1. Laboratory Equipment used for routine chemical or physical analysis.2. Nitrogen Tumbler3. Nitrogen Deflasher4. 5,500 Gallon Nitrogen Storage Tank.5. Cured Part Grinding

Pursuant to §26.3(d) of Regulation 26, the following emission units, operations, or activities havebeen determined by the Department to be insignificant activities. Activities included in this list areallowable under this permit and need not be specifically identified.

1. Combustion emissions from propulsion of mobile sources and emissions from refueling thesesources unless regulated by Title II and required to obtain a permit under Title V of thefederal Clean Air Act, as amended. This does not include emissions from any transportableunits, such as temporary compressors or boilers. This does not include emissions fromloading racks or fueling operations covered under any applicable federal requirements.

2. Air conditioning and heating units used for comfort that do not have applicable requirementsunder Title VI of the Act.

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

4. Non-commercial food preparation or food preparation at restaurants, cafeterias, or caterers,etc.

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

6. 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 batch plantowners/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-motorized vehicle,conveyance, or device.

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7. Internal combustion engines used for landscaping purposes.

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

9. Bathroom/toilet emissions.

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

11. Tobacco smoking rooms and areas.

12. Blacksmith forges.

13. Maintenance of grounds or buildings, including: lawn care, weed control, pest control, andwater washing activities.

14. Repair, up-keep, maintenance, or construction activities not related to the sources’ primarybusiness activity, and not otherwise triggering a permit modification. This may include, butis not limited to such activities as general repairs, cleaning, painting, welding, woodworking,plumbing, re-tarring roofs, installing insulation, paved/paving parking lots, miscellaneoussolvent use, application of refractory, or insulation, brazing, soldering, the use of adhesives,grinding, and cutting.1

15. Surface-coating equipment during miscellaneous maintenance and construction activities. Thisactivity specifically does not include any facility whose primary business activity is surface-coating or includes surface-coating or products.

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

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


3

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

4

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

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18. Brazing or soldering equipment related to manufacturing activities that do not result in emissionof HAPs.3

19. Air compressors and pneumatically operated equipment, including hand tools.

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

21. Storage tanks, vessels, and containers holding or storing liquid substances that do not containany VOCs or HAPs.4

22. Storage tanks, reservoirs, and pumping and handling equipment of any size containing soaps,vegetable oil, grease, animal fat, and no volatile aqueous salt solutions, provided appropriatelids and covers are used and appropriate odor control is achieved.

23. Equipment used to mix and package soaps, vegetable oil, grease, animal fat, and non-volatileaqueous salt solutions, provided appropriate lids and covers are used and appropriate odorcontrol is achieved.

24. Drop hammers or presses for forging or metalworking.

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

26. Vents from continuous emissions monitors and other analyzers.

27. Natural gas pressure regulator vents, excluding venting at oil and gas production facilities.

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


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

30. Consumer use of paper trimmers/binders.

31. Electric or steam-heated drying ovens and autoclaves, but not the emissions from the articlesor substances being processed in the ovens or autoclaves or the boilers delivering the steam.

32. Salt baths using non-volatile salts that do not result in emissions of any air pollutant coveredby this regulation.

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

34. Bench-scale laboratory equipment used for physical or chemical analysis not including labfume hoods or vents.

35. Routine calibration and maintenance of laboratory equipment or other analytical instruments.

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

37. Hydraulic and hydrostatic testing equipment.

38. Environmental chambers not using hazardous air pollutant gases.

39. Shock chambers, humidity chambers, and solar simulators.

40. Fugitive emissions related to movement of passenger vehicles, provided the emissions are notcounted for applicability purposes and any required fugitive dust control plan or its equivalentis submitted.

41. Process water filtration systems and demineralizers.

42. Demineralized water tanks and demineralizer vents.

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

44. Emissions from storage or use of water treatment chemicals, except for hazardous air pollutantsor pollutants listed under regulations promulgated pursuant to Section 112(r) of the Act, for usein cooling towers, drinking water systems, and boiler water/feed systems.


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

46. Ozone generators.

47. Fire suppression systems.

48. Emergency road flares.

49. Steam vents and safety relief valves.

50. Steam leaks.

51. Steam cleaning operations.

52. Steam and microwave sterilizers.

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

54. Miscellaneous additions or upgrades of instrumentation.

55. Emissions from combustion controllers or combustion shutoff devices but not combustion unitsitself.

56. Use of products for the purpose of maintaining motor vehicles operated by the facility, notincluding air cleaning units of such vehicles (i.e. antifreeze, fuel additives).

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

58. Emissions from equipment lubricating systems (i.e. oil mist), not including storage tanks, unlessotherwise exempt.

59. Residential wood heaters, cookstoves, or fireplaces.

60. Barbecue equipment or outdoor fireplaces used in connection with any residence or recreation.

61. Log wetting areas and log flumes.

62. Periodic use of pressurized air for cleanup.


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63. Solid waste dumpsters.

64. Emissions of wet lime from lime mud tanks, lime mud washers, lime mud piles, lime mud filterand filtrate tanks, and lime mud slurry tanks.

65. Natural gas odoring activities unless the Department determines that emissions constitute airpollution.

66. Emissions from engine crankcase vents.

67. Storage tanks used for the temporary containment of materials resulting from an emergencyreporting to an unanticipated release.

68. Equipment used exclusively to mill or grind coatings in roll grinding rebuilding, and moldingcompounds where all materials charged are in paste form.

69. Mixers, blenders, roll mills, or calendars for rubber or plastic for which no materials in powderform are added and in which no organic solvents, diluents, or thinners are used.

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

71. Maintenance dredging of pulp and paper mill surface impoundments and ditches containingcellulosic and cellulosic derived biosolids and inorganic materials such as lime, ash, or sand.

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

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

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

75. Agricultural operations, including onsite grain storage, not including IC engines or grainelevators.

76. The following natural gas and oil exploration production site equipment: separators,dehydration units, natural gas fired compressors, and pumping units. This does not includecompressors located on natural gas transmission pipelines.


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SECTION VIII: 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 the originof and authority for the terms or conditions are not required under the Clean Air Act or anyof its applicable requirements, and are not federally enforceable under the Clean Air Act.Arkansas Pollution Control & Ecology Commission Regulation #18 was adopted pursuantto the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.). Any termsor conditions included in this permit which specify and reference Arkansas Pollution Control& Ecology Commission Regulation #18 or the Arkansas Water and Air Pollution ControlAct (A.C.A. §8-4-101 et seq.) as the origin of and authority for the terms or conditions areenforceable under this Arkansas statute.

2. Pursuant to 40 C.F.R. 70.6(a)(2) and §26.7 of the Regulations of the Arkansas Operating AirPermit Program (Regulation 26), this permit shall be valid for a period of five (5) yearsbeginning 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 permit expiration.Permit expiration terminates the permittee's right to operate unless a complete renewalapplication was submitted at least six (6) months prior to permit expiration, in which casethe existing permit shall remain in effect until the Department takes final action on therenewal 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 applicablerequirement of the Clean Air Act, as amended, 42 U.S.C. 7401, et seq (Act) is more stringentthan an applicable requirement of regulations promulgated under Title IV of the Act, bothprovisions are incorporated into the permit and shall be enforceable by the Director orAdministrator.

5. Pursuant to 40 C.F.R. 70.6(a)(3)(ii)(A) and §26.7 of Regulation #26, records of monitoringinformation 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;


64

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 requiredmonitoring data and support information shall be retained for a period of at least 5 years fromthe date of the monitoring sample, measurement, report, or application. Support informationincludes all calibration and maintenance records and all original strip-chart recordings forcontinuous monitoring instrumentation, and copies of all reports required by this permit.

7. Pursuant to 40 C.F.R. 70.6(a)(3)(iii)(A) and §26.7 of Regulation #26, the permittee shallsubmit reports of all required monitoring every 6 months. All instances of deviations frompermit requirements must be clearly identified in such reports. All required reports must becertified by a responsible official as defined in §26.2 of Regulation #26 and must be sent tothe address below.

Arkansas Department of Pollution Control and EcologyAir DivisionATTN: Air EnforcementPost 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 conditionsas defined in the permit shall be reported to the Department. An initial report shall be madeto the Department by the next business day after discovery of the occurrence. The initialreport 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.


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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 length oftime for which said limits are exceeded. If the permittee wishes, they may submit a fullreport in writing (by facsimile, overnight courier, or other means) by the next business dayafter discovery 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), §26.7 of Regulation #26, and A.C.A. §8-4-203 asreferenced by A.C.A. §8-4-304 and §8-4-311, if any provision of the permit or theapplication thereof to any person or circumstance is held invalid, such invalidity shall notaffect other provisions or applications hereof which can be given effect without the invalidprovision or application, and to this end, provisions of this Regulation are declared to beseparable and severable.

10. Pursuant to 40 C.F.R. 70.6(a)(6)(i) and §26.7 of Regulation #26, the permittee must complywith all conditions of this Part 70 permit. Any permit noncompliance with applicablerequirements as defined in Regulation #26 constitutes a violation of the Clean Air Act, asamended, 42 U.S.C. § 7401, et seq. and is grounds for enforcement action; for permittermination, revocation and reissuance, or modification; or for denial of a permit renewalapplication. Any permit noncompliance with a state requirement constitutes a violation ofthe Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) and is alsogrounds for enforcement action; for permit termination, revocation and reissuance, ormodification; or for denial of a permit renewal application.

11. Pursuant to 40 C.F.R. 70.6(a)(6)(ii) and §26.7 of Regulation #26, it shall not be a defense fora permittee in an enforcement action that it would have been necessary to halt or reduce thepermitted activity in order 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 bemodified, revoked, reopened, and reissued, or terminated for cause. The filing of a requestby the permittee for a permit modification, revocation and reissuance, or termination, or ofa notification of planned changes or anticipated noncompliance does not stay any permitcondition.

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.


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14. Pursuant to 40 C.F.R. 70.6(a)(6)(v) and §26.7 of Regulation #26, the permittee shall furnishto the Director, within the time specified by the Director, any information that the Directormay request in writing to determine whether cause exists for modifying, revoking andreissuing, or terminating the permit or to determine compliance with the permit. Uponrequest, the permittee shall also furnish to the Director copies of records required to be keptby the permit. For information claimed to be confidential, the permittee may be required tofurnish such records directly to the Administrator along with a claim of confidentiality.

15. Pursuant to 40 C.F.R. 70.6(a)(7) and §26.7 of Regulation #26, the permittee shall pay 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 in thispermit.

17. Pursuant to 40 C.F.R. 70.6(a)(9)(i) and §26.7 of Regulation #26, if the permittee is allowedto operate under different operating scenarios, the permittee shall, contemporaneously withmaking a change from one operating scenario to another, record in a log at the permittedfacility a record of the scenario under which the facility or source is operating.

18. Pursuant to 40 C.F.R. 70.6(b) and §26.7 of Regulation #26, all terms and conditions in thispermit, 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 allow anauthorized representative of the Department, upon presentation of credentials, to perform thefollowing:

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;


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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 submit acompliance 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 the Department.All compliance certifications required by this permit shall include the following:

a. The identification of each term or condition of the permit that is the basis of 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 the following:

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

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

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

ATTACHMENT ONE

ATTACHMENT TWO

Route To: FELICIA INMANAdministration

AIR DIVISION

INVOICE REQUEST FORM

(9-96)

Facility Name & Address:Cooper Tire and Rubber Company, Engineered Products Division166 Cooper DriveEl Dorado, AR 71730

CSN: 70-0036 Permit No: 818-AOP-R2

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

Mod Fee Calculations:

Title V = 3333 (18.08)(TPY increase of each pollutant, except CO)

NOTE: Do Not double count HAPs and VOCs!!!No greater than 4000 tpy for each contaminant but not less than $1000

Fee Amount: $ 1000

Engineer: Melissa J. Blumenthal

Date: April 26, 1999

Public Notice

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

Cooper Tire and Rubber Company, Engineered Products Division, 166 Cooper Drive, El Dorado,Arkansas manufactures molded rubber products. This permit represents issuance of an initialTitle V operating permit, installation of a new dip unit, and updated emission calculations fromrubber manufacturing. Installation of the new dip unit and increased adhesive and coating usageresults in an increase in volatile organic compound emissions of 46.7 tons per year.

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

Citizens wishing to examine the permit application and staff findings and recommendations maydo so by contacting Rhonda Sharp. Citizens desiring technical information concerning theapplication or permit should contact Karen Ekse. Both Rhonda Sharp and Karen Ekse can bereached at the Department's central office, 8001 National Drive, Little Rock, (501) 682-0744.

The draft permit and permit application are available for copying at the above address. A copy ofthe draft permit has also been placed at the Barton Library, E. Fifth and N. Jefferson, El Dorado,Arkansas 71730. This information may be reviewed during normal business hours. Interested or affected persons may also submit written comments or request a hearing on theproposal to the Department at the above address - Attention: Rhonda Sharp. In order to beconsidered, the comments must be submitted within thirty (30) days of publication of this notice. Although the Department is not proposing to conduct a public hearing, one will be scheduled ifsignificant comments on the permit provisions are received. If a hearing is scheduled, adequatepublic notice will be given in the newspaper of largest circulation in the county in which thefacility 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) and Regulation #26.

Dated this

Randall Mathis Director

operating air permit - arkansas department of … · cooper tire & rubber company, engineered...

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