operating air permit - arkansas department of ... · gates rubber company permit #: 378-aop-r2 csn:...

OPERATINGAIR PERMIT

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

Permit #: 378-AOP-R2

IS ISSUED TO:

Gates Rubber Company1801 North Lincoln

Siloam Springs, AR 72761Benton CountyCSN: 04-0111

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:

August 8, 2000 and August 7, 2005

AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN.

Signed:

Keith A. Michaels Date Modified

2

SECTION I: FACILITY INFORMATION

Facility: Gates Rubber CompanyCSN: 04-0111PERMIT NUMBER: 378-AOP-R2

FACILITY ADDRESS: 1801 North LincolnSiloam Springs, AR 72761

COUNTY: Benton

CONTACT POSITION: David SteverTELEPHONE NUMBER: (501) 524-8164

REVIEWING ENGINEER: Nancy Spencer Rogers

UTM North-South (X): 4006.8UTM East-West (Y): 363.2

Gates Rubber CompanyPermit #: 378-AOP-R2CSN: 04-0111

3

SECTION II: INTRODUCTION

Summary of Permit Activity

Gates Rubber Company of 1801 North Lincoln Street, Siloam Springs, Benton County, Arkansasmanufactures rubber belts. This permit has been modified to add one grinder to SN-13, BubbleBelt Grinders. It is a minor modification to Permit #378-AOP-R1. The total permitted increasein emissions at this facility due to the modification is negligible.

Process Description

Cord used within the belts is manufactured in the Cord Treater area. In this process, stocksynthetic cord is coated with several cement and latex coatings.

Stock rubber is brought into the plant from outside sources, where it is mechanically andthermally treated to form thin layers of rubber sheeting. The sheeting along with treated cord isapplied to a lathe type belt builder where an uncured rubber cylinder slab is produced.

The rubber slab is transformed into power transmission belts following either a “Bandless” or a“Banded” process.

In the Bandless process, the slab is cured thermally as a complete unit within an autoclave type ofdevice. Once cured, individual belts are machine cut from the slab and finished through grindingof the belt as per end use specifications.

In the Banded process, the slab is cut into individual belts, with thin sheets of rubber wrappedaround the belt prior to the curing process. Belt curing is completed either within an autoclaveunit or through a step wise press curing process.


4

Regulations

Gates Rubber Company is subject to regulation under the Arkansas Air Pollution Control Code(Regulation #18), the Regulations of the Arkansas Plan of Implementation for Air PollutionControl (Regulation #19), and the Regulations of the Arkansas Operating Air Permit Program(Regulation #26).

The boilers at the facility are not subject to 40 CFR 60, Subpart Dc-Standards of Performancefor Small Industrial-Commercial-Institutional Steam Generating Units because the boilers wereconstructed prior to the applicability date and have not been modified or reconstructed since thatdate.

The toluene storage tank is not subject to 40 CFR 60, Subpart K, Ka, or Kb because its capacityis smaller than the affected tank size.

The cord treating operation is not subject to 40 CFR 60, Subpart VVV-Standards of Performancefor Polymeric Coating of Supporting Substrates Facilities because the operation was constructedprior to that applicability date and has not been modified or constructed since that date.

Summary

The following table is a summary of emissions from the facility. Specific conditions and emissions for each source can be found starting on the page cross referenced in the followingtable.


5

EMISSION SUMMARY

SN Description Pollutant Emission Rates CrossReference

Pagelb/hr tpy

Total Allowable Emissions

HAPS*

PMPM10SO2

VOC CO NOx

Toluene*Carbon Disulfide

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

bis(2-Ethylhexyl)phthalate*Methylene Chloride

Hexane*Propylene Oxide*

1,3-Butadiene*Acetophenone*Acetaldehyde*

NickelPhenol*Xylenes*

Carbonyl SulfideAcrolein*

2-Butanone*Naphthalene*

Di-n-butyl phthalate*ChromiumMethanol*

MDIFormaldehyde*

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

Isooctane*Ethyl Benzene*

Aniline*1,1,1-Trichloroethane*

o-Toluidine*Styrene*

Carbon Tetrachloride*Chloro methane*

Biphenyl*Chloroprene*

73.973.943.1

154.63.5

13.7119.0213.801.020.200.41

11.913.030.210.203.090.120.010.090.411.590.060.270.060.040.030.987.472.300.930.120.080.070.050.030.160.030.010.010.010.010.39

50.750.731.1

226.814.456.4

178.638.610.630.360.267.43

11.210.140.131.940.060.040.050.251.010.030.170.050.040.030.60

20.620.600.580.070.050.040.030.020.090.020.010.010.010.010.20

---


EMISSION SUMMARY


Pagelb/hr tpy

6

01 Boiler #1(burning natural gas)

PMPM10SO2

VOC CO NOx

0.60.60.10.21.55.8

2.52.50.10.56.3

25.0

15

02 Boiler #2(burning natural gas)

PMPM10SO2

VOC CO NOx

0.60.60.10.21.55.8

2.52.50.10.56.3

25.0

15

Boiler #1 and #2(burning fuel oil)

PMPM10SO2

VOC CO NOx

--- 1.01.0

31.00.22.28.8

15

01 Boiler #1(burning fuel oil)

PMPM10SO2

VOC CO NOx

0.60.6

21.50.11.56.1

--- 15

02 Boiler #2(burning fuel oil)

PMPM10SO2

VOC CO NOx

0.60.6

21.50.11.56.1

--- 15

03 Pre-Dip Hold Tank VOCMDI

Toluene

16**1.20**16.0**

8.80.668.76

18

04 Cement House Non-Point SourceEmissions

VOCMDI

Toluene

52.6**0.16**

52.56**

14.20.01

14.20

18

05 Latex Area Mix Vent VOCFormaldehyde

Methanol

10.8**7.2**3.6**

0.40.030.30

20

**The lb/hr emissions are actually lb/batch.


EMISSION SUMMARY


Pagelb/hr tpy

7

06 Cord Treater Emissions PMPM10SO2

VOC CO NOx

FormaldehydeMethanol

ChloropreneToluene

MDI

0.20.20.1

98.80.51.5

1.700.680.39

88.737.22

0.60.60.1

156.51.86.4

0.800.300.20

135.0919.95

22

07 Toluene Storage Tank VOCToluene

8.28.2

0.10.1

25

08 Belt Builder Non-Point SourceEmissions

VOCHexane Toluene

5.82.53.3

25.310.8914.33

26

09 Rubber Autoclave Cure VOCCarbon Disulfide

AcetophenoneMethylene Chloride

Carbonyl Sulfide4-Methyl-2-Pentanone

TolueneXylene

2-ButanoneHexaneBenzeneCumeneIsooctane

Ethyl benzeneAnilinePhenol

Naphthalene1,1,1-Trichloroethane

1,3-ButadieneTetrachloroethene

o-Toluidinebis(2-Ethylhexyl)phthalate

StyreneNickel

Di-n-butyl phthalateCarbon Tetrachloride

Chloro methaneBiphenyl

13.88.902.922.441.240.830.290.310.210.200.120.080.070.050.030.030.030.020.020.020.020.010.010.010.010.010.010.01

8.65.571.821.520.770.520.180.190.130.120.070.050.040.030.020.020.020.010.010.010.010.010.010.010.010.010.010.01

28


EMISSION SUMMARY


Pagelb/hr tpy

8

10 Rubber Step Cure VOCMethylene Chloride

Carbon DisulfideCarbonyl Sulfide

1,1,1-Trichloroethane4-Methyl-2-Pentanone

AcetophenoneHexaneToluene

2-Butanonebis(2-Ethylhexyl)phthalate

o-ToluidineXylene

4.29.111.640.290.140.100.050.030.030.020.020.010.01

2.75.691.020.180.080.060.030.020.020.010.010.010.01

30

SN’s 11-13 PMPM10VOC

TolueneCarbon DisulfideTetrachloroethene

2-Chloro-1,3-Butadienebis(2-Ethylhexyl)phthalate

Methylene ChlorideHexane

Propylene Oxide1,3-ButadieneAcetophenoneAcetaldehyde

NickelPhenolXylene

Carbonyl SulfideAcrolein

2-ButanoneNaphthalene

Di-n-butyl phthalateChromium

--- 45.645.69.6

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

32


EMISSION SUMMARY


Pagelb/hr tpy

9

11 Belt Grinders PMPM10VOC





NickelPhenolXylene




24.524.54.4

3.150.710.330.190.120.120.100.070.060.040.040.020.020.030.020.020.020.010.010.01

--- 32






NickelPhenolXylene


23.423.45.0

3.150.710.330.190.120.120.100.070.060.040.040.020.020.030.020.02

--- 33

12Cont.

Belt Grinders-Continued 2-ButanoneNaphthalene


0.010.010.010.01

--- 32


EMISSION SUMMARY


Pagelb/hr tpy

10






NickelPhenolXylene




24.624.65.3

3.300.740.340.200.130.120.100.070.060.040.040.020.020.030.020.020.020.010.010.01

---- 33

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


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SECTION III: PERMIT HISTORY

Permit #378-A was the initial air permit for Gates Rubber Company. It was issuedNovember 19, 1976, to allow the facility to build the plant in order to produce heavy duty andbandless “V” belts. At that time the facility permitted a gas fired boiler, cement mixing houseexhaust, and a cord treating unit/catalytic incinerator. Non-specified emissions were permitted at1 lb/hr. Nitrogen oxide emissions were limited to 5.0 lb/hr.

Permit #378-AR-1 was issued September 9, 1978, to allow the facility to construct a second gasfired boiler. The boiler was permitted to burn natural gas and use #6 fuel oil as a backup.

Permit #378-AR-2 was issued April 8, 1985, to permit a dust capture system and baghouse. Thebaghouse had been installed in 1984. All sources were assigned a 5% opacity limit. VOC waspermitted at 0.2 lb/hr, hydrocarbons at 4.3 lb/hr, and particulate matter to 0.01 lb/hr. The twoboilers were each limited at 40,800 ft3/hr maximum natural gas input.

Permit #378-AR-3 was issued January 1, 1986, to permit 18 rubber grinders. Six control systemsconsisting of a cyclone separator and an electrostatic precipitator with prefilters were to beinstalled to collect the particulate. VOC was permitted at 4.5 lb/hr and particulate was permittedat 0.11 lb/hr. The two boilers were each limited at 40,800 ft3/hr maximum natural gas input. Allsources had a 5% opacity limit.

Permit #378-AR-4 was issued February 13, 1987, to permit the use of #6 fuel oil in the boilerswith natural gas to be allowed as an alternate. The use of the boilers was limited by operatingtimes, the use of 1% sulfur fuel, and emission limit of 100 tons of SO2 per year. The otherpermitted emissions remained the same. Opacity was changed to 10%.

Permit #378-AR-5 was issued November 15, 1988, to permit the installation of 6 additional beltgrinders. A cyclone and electrostatic precipitator with prefilters were installed to controlparticulate from the grinders. The permit was also revised to clarify emission limits andreporting requirements for the boilers. PM was permitted at 5.92 lb/hr, SO2 at 75.8 lb/hr, VOC at4.5 lb/hr and NOX at 26.2 lb/hr.

Permit #378-AR-6 was issued February 9, 1989, to permit the installation of 6 additional beltgrinders. A cyclone and electrostatic precipitator with prefilters were installed to controlparticulate from the grinders. The testing method for fuel oil was revised. PM was permitted at5.83 lb/hr, SO2 at 75.8 lb/hr, VOC at 4.5 lb/hr and NOX at 26.2 lb/hr.

Permit #378-AR-7 was issued on June 29, 1990, to increase the number of belt grinders from 24to 45. The allowable particulate emissions from the grinders was permitted at 0.7 tpy. No otheremission changes were made.


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

Permit #378-AR-9 was issued on April 9, 1992, to allow the installation of three new grinders. The permitted emissions from the facility were: particulate, 30.49 tpy; SO2, 3.64 tpy; NOX,124.86 tpy; CO, 12.48 tpy; and VOC, 24.39 tpy.

Permit #378-AR-10 was issued on April 7, 1994, to permit fugitives and other previouslyunpermitted emissions at the facility. The permitted emissions from the facility were: PM,26.58 tpy; SO2, 90.0 tpy; NOX, 88.40 tpy; CO, 12.20 tpy; other VOC, 1.96 tpy; Toluene, 45.30tpy; Methanol, 0.02 tpy; MDI, 0.10 tpy; Formaldehyde, 0.03 tpy, and Hexane 11.40 tpy.

Permit #378-AOP-R0 was issued on August 8, 2000, as the first operating permit for this facilityas per the requirements of Regulation #26 (Title V) and the Clean Air Act. The facility is amajor Title V source for both volatile organic compounds (VOCs) and hazardous air pollutants(HAPs). Under this permit, the facility increased throughput which increased production.

Permit #378-AOP-R1 was issued August 27, 2001. It allowed the facility to increase theallowable throughput at the storage tank (SN-07) to 176,256 gallons of toluene. This increasedebottlenecked the processes at SN’s 03, 04 and 06; however, this higher throughput had alreadybeen permitted at SN’s 03, 04 and 06 so there was no permitted increase at these sources. Alsoincluded in this modification was a minor modification which allowed the facility to move 2 beltgrinders from SN-11 to SN-13. Additionally, Specific Condition number’s 49 and 50 of theprevious permit were deleted because they were unnecessary for compliance demonstration. Thetotal permitted increase in emissions at this facility due to the modifications was negligible.


SECTION IV: EMISSION UNIT INFORMATION


14

SN’s 01, 02Boiler’s #1 and #2

Source Description

Boilers #1 and #2 are used to provide steam for thermal treatment in the rubber calendaring andbelt curing processes. Boiler #1 (SN-01) is a 40.8 MMBTU/hr boiler. It was installed in1975and brought on line in 1977. Boiler #2 (SN-02) is a 40.8 MMBtu/hr boiler. It was installed in1978. They are both fueled by natural gas, but use fuel oil in the alternate operating scenario.

Specific Conditions

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

SN Pollutant lb/hr tpy

01 PM10 0.6 2.5

SO2 0.1 0.1

VOC 0.2 0.5

CO 1.5 6.3

NOX 5.8 25.0

02 PM10 0.6 2.5

SO2 0.1 0.1

VOC 0.2 0.5

CO 1.5 6.3

NOX 5.8 25.0

01 and 02(alternatescenario)

PM10 --- 1.0

SO2 31.0

VOC 0.2

CO 2.2

NOX 8.8

01(alternatescenario)

PM10 0.6 ---

SO2 21.5

VOC 0.1

CO 1.5

NOX 6.1



15

02(alternatescenario)

PM10 0.6 ---

SO2 21.5

VOC 0.1

CO 1.5

NOX 6.1

2. Pursuant to §18.501 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the facility shall not exceed 5% opacity from this source while burningnatural gas and 10% for fuel oil.

3. Pursuant to §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, weeklyobservations of the opacity from this source shall be conducted by personnel familiar withthe facility’s visible emissions. The facility shall maintain personnel trained, but notnecessarily certified in EPA Reference Method 9. If visible emissions which appear to bein excess of the permitted opacity are detected, the facility shall immediately take actionto identify the cause of the visible emissions, implement corrective action, and documentthat visible emissions did not appear to be in excess of the permitted opacity followingthe corrective action. The facility shall maintain records which contain the followingitems in order to demonstrate compliance with this specific condition. These recordsshall be updated weekly, kept on site, and made available to Department personnel uponrequest.

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

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

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

4. Pursuant to §19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, and 40 CFR 70.6, the boilers shall be fueled only by #2 fuel oil (0.5% sulfur) ornatural gas.

5. Pursuant to §19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, and 40 CFR 70.6, the throughput of #2 fuel oil shall be limited to 869,760gallons per year.


16

6. Pursuant to §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, records for thesulfur content and annual fuel oil throughput shall be maintained on a twelve monthrolling basis, updated monthly. Such records shall be submitted to the Department inaccordance with General Condition #7.


17

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

Source Description

Pre-Dip (SN-03) is the toluene/isocyanate mixture used as the first dip when coating cords. Thematerial is mixed on a batch basis and passes to the Pre-Dip holding tanks where it is pressurizedwith nitrogen and passed to the cord treater. A maximum of three batches of Pre-Dip is mixedper 24 hour period. Before the holding tanks are refilled, the tanks are vented for a ten minuteperiod for a maximum of two times per 24 hour period. The short term emission rates are limitedby the number of batches per day and ton per year emissions are limited by the amount ofmaterial that can be processed in the cord treater.

SN-03 was installed in 1977.

SN-04 is the non-point source emissions from mixing and dispensing Pre-Dip and CementCompound in the Cement House. Cement Compound is a toluene and rubber stock mixture. Cement Compound is mixed on a batch basis in the Cement Mix tank and then dispensed into150 gallon totes for use in the cord treater and belt building areas. Two batches of CementCompound is mixed per day.

SN-04 was constructed in 1977.

Specific Conditions

7. Pursuant to §19.501 of Regulation 19 et seq, and 40 CFR Part 52, Subpart E, this sourceshall not exceed the emission rates set forth in the following table. Compliance withthese limits shall be demonstrated by compliance with the pre-dip batch limits.

SN Pollutant lb/batch tpy

03 VOC 16 8.8

04 VOC 52.6 14.2

8. Pursuant to §18.801 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, this source shall not exceed the emission rates set forth in the followingtable. Compliance with these limits shall be demonstrated by compliance with the pre-dip batch limits.


03 MDI 1.20 0.66

Toluene 16.0 8.76



18

04 MDI 0.16 0.01

Toluene 52.56 14.20

9. 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 facility is limited to producing three batches of pre-dipper day.

10. Pursuant to §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the number ofbatches per day shall be maintained on a daily basis, updated monthly, to be completed bythe 15th day of the following month. Such records shall be submitted to the Departmentin accordance with General Condition #7.


19

SN-05 Latex Area Mix Vent

Source Description

In this area, various components are mixed and water diluted in order to make latex used to coatcord. The initial mixing of formaldehyde mixture, sodium hydroxide, and resorcinol is a batchprocess. This material is reacted in the resin mix tank for approximately eight hours. Oncereacted, the vessel is vented to the atmosphere. Liquids from the Resin Mix Tank are drained totwo separate mix tanks where they are diluted with latex, dye, water, and mixed with Aquamix. The liquid is then pumped to another two tanks to be diluted with water to reach the productspecification for use with the Cord Treater.

In addition to the manufacture of latex, two lubes are mixed on a batch basis for use in the stepcure and banded builder processes. These drums are then transferred to holding tanks in thebanding and building sections of the facility for use.

This source was installed in 1997.

Specific Conditions

11. Pursuant to §19.501 of Regulation 19 et seq, and 40 CFR Part 52, Subpart E, this sourceshall not exceed the emission rates set forth in the following table. Compliance withthese limits shall be demonstrated by compliance with the latex batch limits.


05 VOC 10.8 0.4

12. Pursuant to §18.801 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, compliance with these limits shall be demonstrated by compliance with thelatex batch limits.


05 Formaldehyde 7.2 0.03

Methanol 3.6 0.30

13. 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 facility is limited to producing two batches of latex perday.


20

14. Pursuant to §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the number ofbatches per day shall be maintained on a daily basis, updated weekly. Such records shallbe submitted to the Department in accordance with General Condition #7.


21

SN-06 Cord Treater Emissions

Source Description

Within the Cord Treater area, synthetic cord procured from off-site is coated with various dips toform the treated cord material used within the belts.

Synthetic cord is run through the pre-dip mixture and through the first zone of an oven to dry thecord coating. The cord then traverses through the latex mixture, through the second oven zone,through a second latex mixture dip, through a third oven zone and finally through the cementmixture before the cord is spooled for use in the belt building process.

Emissions from Zones 1 and 4 of this source are controlled by a catalytic incinerator with apre-burner and process blower. The overall control efficiency of the control equipment used forthe calculations in the permit is 81% (90% capture and 90% efficiency). This equipment isfueled by natural gas.


Specific Conditions

15. Pursuant to §19.501 of Regulation 19 et seq, and 40 CFR Part 52, Subpart E, this sourceshall not exceed the emission rates set forth in the following table. Compliance withthese limits shall be demonstrated by compliance with the VOC recordkeeping, testingand monitoring requirements of the catalytic oxidizer, operating requirements of thecatalytic incinerator and cord treater and the pre-dip limit of Specific Condition #9.


06 PM10 0.2 0.6

SO2 0.1 0.1

VOC 98.8 156.5

CO 0.5 1.8

NOX 1.5 6.4

16. Pursuant to §18.801 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, this source shall not exceed the emission rates set forth in the followingtable. Compliance with these limits shall be demonstrated by compliance with the HAPrecordkeeping, testing and monitoring requirements of the catalytic incinerator, operatingrequirements of the catalytic oxidizer and cord treater and the pre-dip limit of SpecificCondition #9.


22


06 Formaldehyde 1.70 0.80

Methanol 0.68 0.30

Chloroprene 0.39 0.20

Toluene 88.73 135.09

MDI 7.22 19.95

17. Pursuant to §18.501 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the facility shall not exceed 5% opacity from this source. Complianceshall be demonstrated by burning only natural gas.

18. Pursuant to §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, records of themonthly VOC emissions shall be recorded in the format of Table A in Appendix A.

19. Pursuant to §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the VOC emissionrate tables shall be maintained on a twelve month rolling total, updated monthly. Suchrecords shall be submitted to the Department in accordance with General Condition #7.

20. Pursuant to §18.1004 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, records of the monthly HAP emissions shall be recorded in the format ofTable B in Appendix B.

21. Pursuant to §18.1004 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the HAP emission rate tables shall be maintained on a twelve monthrolling average, updated monthly. Such records shall be submitted to the Department inaccordance with General Condition #7.

22. Pursuant to §19.702 of Regulation 19, and 40 CFR Part 52, Subpart E, the facility shalltest the catalytic oxidizer for VOC using EPA Reference Method 25A. The facility shallcontinue to test on the schedule that was initiated in Permit #378-AOP-R0. From thesetests, a control efficiency shall be determined for the incinerator. A written report of theresults of the completed tests shall be furnished to the Department at the followingaddress.

Arkansas Department of Environmental QualityAir DivisionATTN.: Air EnforcementPost Office Box 8913Little Rock, AR 72219


23

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

23. Pursuant to §19.703 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A. §8- 4-203as referenced by §8-4-304 and §8-4-311, the operating range of the outlet gas temperatureof the catalytic incinerator is to be determined during the compliance test. The outlet gastemperature must stay within this range during normal operation of the unit.

24. 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 facility shall continuously monitor and record thecombustion temperature of the catalytic incinerator while it is operating. During periodsof maintenance on, or failure of, the continuous monitoring equipment, the facility shallmanually measure and record the outlet temperature of the catalytic incinerator once perhour.

25. Pursuant to §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, records of the catalytic incinerator outlet temperature shall be kept on site and shall be submitted to theDepartment in accordance with General Condition #7.

26. Pursuant to §19.703 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A. §8- 4-203as referenced by §8-4-304 and §8-4-311, the catalytic incinerator shall be kept in goodworking order, and shall be used whenever Zones 1 and 4 are being operated. The cordtreater shall not be used when there is any equipment failure or shutdowns formaintenance on the catalytic incinerator. The facility shall report any equipmentproblems on the catalytic incinerator to ADEQ in accordance with § 19.601.


24

SN-07 Toluene Storage Tank

Source Description

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

Specific Conditions

27. Pursuant to §19.501 of Regulation 19 et seq, and 40 CFR Part 52, Subpart E, this sourceshall not exceed the emission rates set forth in the following table. Compliance withthese limits shall be demonstrated by compliance with the toluene limit of this section.


07 VOC 8.2 0.1

28. Pursuant to §18.801 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, this source shall not exceed the emission rates set forth in the followingtable. Compliance with these limits shall be demonstrated by compliance with the toluenelimits of this section.


07 Toluene 8.2 0.1

29. 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 annual throughput of toluene at this source shall belimited to 176,256 gallons.

30. Pursuant to §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the toluenethroughput amount shall be maintained on a twelve month rolling total, updated monthly. Such records shall be submitted to the Department in accordance with General Condition#7.


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SN-08 Belt Builder Non-Point Source Emissions

Source Description

A lathe (builder) is used to build the belts at the facility. Layers of calendar stock and treatedcord are built-up on the builder to form a belt slab. Tackifiers, consisting of a mixture of tolueneand hexane are applied between the different layers as needed.


Specific Conditions

31. Pursuant to §19.501 of Regulation 19 et seq, and 40 CFR Part 52, Subpart E, this sourceshall not exceed the emission rates set forth in the following table. Compliance withthese limits shall be demonstrated by compliance with the VOC recordkeeping of thissection.


08 VOC 5.8 25.3

32. Pursuant to §18.801 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, this source shall not exceed the emission rates set forth in the followingtable. Compliance with these limits shall be demonstrated by compliance with the HAPrecordkeeping of this section.


08 Hexane 2.50 10.89

Toluene 3.30 14.33

33. Pursuant to §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, records of themonthly VOC emissions shall be recorded in the format of Table A in Appendix A.

34. Pursuant to §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the VOC emissionrate tables shall be maintained on a twelve month rolling total, updated monthly. Suchrecords shall be submitted to the Department in accordance with General Condition #7.

35. Pursuant to §18.1004 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, records of the monthly HAP emissions shall be recorded in the format ofTable B in Appendix B.


26

36. Pursuant to §18.1004 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the HAP emission rate tables shall be maintained on a twelve monthrolling average, updated monthly. Such records shall be submitted to the Department inaccordance with General Condition #7.


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SN-09 Rubber Autoclave Cure

Source Description

The kettle autoclaves may cure either complete slab stock directly from the builder (BandlessBelts) or the stock may be cut prior to placement on rings and then cured with autoclaves(Banded Belts).

In the autoclave process, heat is applied via steam injection under pressure to cure the rubber tothe proper consistency. During the curing process certain volatile components of the rubber usedto manufacture the belt are driven off as non-point source emissions.


Specific Conditions

37. Pursuant to §19.501 of Regulation 19 et seq, and 40 CFR Part 52, Subpart E, this sourceshall not exceed the emission rates set forth in the following table. Compliance withthese limits shall be demonstrated by compliance with the rubber limit of this section.


09 VOC 13.8 8.6

38. Pursuant to §18.801 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, this source shall not exceed the emission rates set forth in the followingtable. Compliance with these limits shall be demonstrated by compliance with the rubberlimit of this section.


09 Carbon Disulfide 8.90 5.57

Acetophenone 2.92 1.82

Methylene Chloride 2.44 1.52

Carbonyl Sulfide 1.24 0.77

4-Methyl-2-Pentanone 0.83 0.52

Toluene 0.29 0.18

Xylenes 0.31 0.19

2-Butanone 0.21 0.13

Hexane 0.20 0.12



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Benzene 0.12 0.07

Cumene 0.08 0.05

Isooctane 0.07 0.04

Ethyl benzene 0.05 0.03

Aniline 0.03 0.02

Phenol 0.03 0.02

Naphthalene 0.03 0.02

1,1,1,-Trichloroethane 0.02 0.01

1,3-Butadiene 0.02 0.01

Tetrachloroethene 0.02 0.01

o-Toluidine 0.02 0.01

bis(2-Ethylhexyl)phthalate 0.01 0.01

Styrene 0.01 0.01

Nickel 0.01 0.01

Di-n-butyl phthalate 0.01 0.01

Carbon Tetrachloride 0.01 0.01

Chloro methane 0.01 0.01

Biphenyl 0.01 0.01

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

40. Pursuant to §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the rubberthroughput rate shall be maintained on a twelve month rolling total, updated monthly. Such records shall be submitted to the Department in accordance with General Condition#7.


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SN-10 Rubber Step Cure

Source Description

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

Specific Conditions

41. Pursuant to §19.501 of Regulation 19 et seq, and 40 CFR Part 52, Subpart E, this sourceshall not exceed the emission rates set forth in the following table. Compliance withthese limits shall be demonstrated by compliance with the rubber limit of this section.


10 VOC 5.3 3.4

42. Pursuant to §18.801 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, this source shall not exceed the emission rates set forth in the followingtable. Compliance with these limits shall be demonstrated by compliance with the rubberlimit of this section.


10 Methylene Chloride 9.11 5.69

Carbon Disulfide 2.72 1.69

Carbonyl Sulfide 0.29 0.18

1,1,1-Trichloroethane 0.14 0.08

4-Methyl-2-Pentanone 0.10 0.06

Acetophenone 0.05 0.03

Hexane 0.03 0.02

Toluene 0.03 0.02

2-Butanone 0.02 0.01

bis(2-Ethylhexyl)phthalate 0.02 0.01

o-Toluidine 0.01 0.01

Xylenes 0.01 0.01

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


30

44. Pursuant to §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, the rubberthroughput rate shall be maintained on a twelve month rolling total, updated monthly. Such records shall be submitted to the Department in accordance with General Condition#7.


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SN’s 11, 12, 13 Belt Grinders

Source Description

Belt profiles are completed through the grinding of belts with the grinding wheels on both ahorizontal and vertical axis. The specific profile for a given belt depends upon the end usespecification for that belt. Approximately 34% of the weight of the belt is ground off. Theseactivities are completed in one of three production units at the facility.

There are 28 belt grinders at SN-11. Emissions in this area are controlled by ten cyclones and tenelectrostatic precipitators.

There are 27 belt grinders at SN-12. Emissions in this area are controlled by eight cyclones andeight electrostatic precipitators.

There are 16 belt grinders at SN-13. Emissions in this area are controlled by five cyclones andfive electrostatic precipitators.

All belt grinders were installed in 1985, except for one belt grinder installed at SN-13 in 2001.

Specific Conditions

45. Pursuant to §19.501 of Regulation 19 et seq, and 40 CFR Part 52, Subpart E, this sourceshall not exceed the emission rates set forth in the following table. Compliance withthese limits shall be demonstrated by compliance with the rubber throughput limit of thissection.


11 PM10 24.5 ---

VOC 4.4

12 PM10 23.4

VOC 5.0

13 PM10 24.6

VOC 5.3

Total PM10VOC

--- 45.69.6


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46. Pursuant to §18.801 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, this source shall not exceed the limits set forth in the following table. Compliance with these limits shall be demonstrated by compliance with the rubberthroughput limit of this section.


11 PM 24.50 ---

Toluene 3.15Carbon Disulfide 0.71Tetrachloroethene 0.33

2-Chloro-1,3-Butadiene 0.19bis(2-Ethylhexyl)phthalate 0.12

Methylene Chloride 0.12Hexane 0.10

Propylene Oxide 0.071,3-Butadiene 0.06Acetophenone 0.04Acetaldehyde 0.04

Nickel 0.02Phenol 0.02Xylenes 0.03

Carbonyl Sulfide 0.02Acrolein 0.02

2-Butanone 0.02Naphthalene 0.01

Di-n-butyl phthalate 0.01Chromium 0.01

12 PM 23.4 ---






33






13 PM 24.60 ---











34

Total PM --- 45.6 Toluene 6.05

Carbon Disulfide 1.35 Tetrachloroethene 0.62

2-Chloro-1,3-Butadiene 0.36 bis(2-Ethylhexyl)phthalate 0.24

Methylene Chloride 0.22 Hexane 0.18

Propylene Oxide 0.14 1,3-Butadiene 0.12 Acetophenone 0.09 Acetaldehyde 0.06

Nickel 0.03 Phenol 0.03 Xylenes 0.05

Carbonyl Sulfide 0.03 Acrolein 0.03

2-Butanone 0.03 Naphthalene 0.03

Di-n-butyl phthalate 0.03 Chromium 0.03

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

48. Pursuant to §18.501 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, weekly observations of the opacity from this source shall be conducted bypersonnel familiar with the facility’s visible emissions. The facility shall maintainpersonnel trained, but not necessarily certified in EPA Reference Method 9. If visibleemissions which would appear to be in excess of the permitted opacity are detected, thefacility shall immediately take action to identify the cause of the visible emissions,implement corrective action, and document that visible emissions did not appear to be inexcess of the permitted opacity following the corrective action. The facility shallmaintain records which contain the following items in order to demonstrate compliancewith this specific condition. These records shall be updated weekly, kept on site, andmade available to Department personnel upon request.


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

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

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


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SECTION V: COMPLIANCE PLAN AND SCHEDULE

Gates Rubber Company is in compliance with the applicable regulations cited in the permitapplication. Gates Rubber Company will continue to operate in compliance with those identifiedregulatory provisions. The facility will examine and analyze future regulations that may applyand determine their applicability with any necessary action taken on a timely basis.


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SECTION VI: PLANTWIDE CONDITIONS

1. Pursuant to §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 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 §19.410(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 or if the work involved inthe construction or modification is suspended for a total of 18 months or more.

3. Pursuant to §19.702 of Regulation 19 and/or §18.1002 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, any equipment that is to betested, unless stated in the Specific Conditions of this permit or by any federally regulatedrequirements, shall be tested with the following time frames: (1) Equipment to beconstructed or modified shall be tested within sixty (60) days of achieving the maximumproduction rate, but in no event later than 180 days after initial start-up of the permittedsource or (2) equipment already operating shall be tested according to the time frames setforth by the Department or within 180 days of permit issuance if no date is specified. Thepermittee shall notify the Department of the scheduled date of compliance testing at leastfifteen (15) days in advance of such test. Compliance test results shall be submitted tothe Department within thirty (30) days after the completed testing.

4. Pursuant to §19.702 of Regulation 19 and/or §18.1002 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, the permittee shall provide:

a. Sampling ports adequate for applicable test methodsb. Safe sampling platforms c. Safe access to sampling platformsd. Utilities for sampling and testing equipment

5. Pursuant to §19.303 of Regulation 19 and A.C.A. §8-4-203 as referenced by A.C. A.§8-4-304 and §8-4-311, the equipment, control apparatus and emission monitoringequipment shall be operated within their design limitations and maintained in goodcondition at all times.


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6. Pursuant to Regulation 26 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311,this permit subsumes and incorporates all previously issued air permits for this facility.

Acid Rain (Title IV)

7. Pursuant to §26.701 of Regulation #26 and 40 CFR 70.6(a)(4), the permittee is prohibitedfrom causing any emissions which exceed any allowances that the source lawfully holdsunder Title IV of the Act or the regulations promulgated thereunder. No permit revisionis required for increases in emissions that are authorized by allowances acquired pursuantto the acid rain program, provided that such increases do not require a permit revisionunder any other applicable requirement. This permit establishes no limit on the numberof allowances held by the permittee. The source may not, however, use allowances as adefense to noncompliance with any other applicable requirement of this permit or the Act. Any such allowance shall be accounted for according to the procedures established inregulations promulgated under Title IV of the Act.

Title VI Provisions

8. The permittee shall comply with the standards for labeling of products using ozonedepleting substances 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.

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

a. Persons opening appliances for maintenance, service, repair, or disposal 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.


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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.

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.

10. 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.

11. 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.

12. 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.

PERMIT SHIELD

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


40

SN Regulation Description

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

Facility Arkansas Air Regulation 26 Regulations of the Arkansas Operating Air Permit Program

B. The following requirements have been specifically identified as not applicable,based upon information submitted by the permittee in an application datedOctober 8, 1996.

Description of Regulation RegulatoryCitation

AffectedSource

Basis for Determination

Standards of Performance for Small Industrial-Commercial-Institutional Steam GeneratingUnits.

40 CFR 60Subpart Dc

SN-01SN-02

Installed prior to June 9, 1989 and hasnot been reconstructed or modifiedsince that date.

Standards of Performance for Incinerators 40 CFR 60Subpart E

SN-06 Does not burn solid waste.

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

40 CFR 60Subpart K

SN-07 Capacity less than 40,000 gallons andthe source was installed in 1995

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

40 CFR 60Subpart Ka

SN-07 Capacity less than 40,000 gallons andthe source was installed in 1995

Standards of Performance for Storage Vesselsfor Petroleum Liquids for Which Construction,Reconstruction, or Modification CommencedAfter July 23, 1984

40 CFR 60Subpart Kb

SN-07 Capacity less than 40 m3

Standards of Performance for PolymericCoating of Supporting Substrates Facilities

40 CFR 60Subpart VVV

SN-06 Installed prior to April 30, 1987, andhas not been reconstructed ormodified since that date.

National Emission Standards for Hazardous AirPollutants for Industrial Process CoolingTowers

40 CFR 63Subpart Q

--- Cooling tower did not operate withchromium-based chemicals on or afterSeptember 8, 1994

National Emission Standards for Hazardous AirPollutants for Halogenated Solvent Cleaning

40 CFR 63Subpart T

Facility No halogenated solvent cleaningmaterial is used at the facility.


41

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 requirementsprior to or at the time of permit issuance;

The applicable requirements of the acid rain program, consistent with Section408(a) of the Clean Air Act; or

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


42

SECTION VII: INSIGNIFICANT ACTIVITIES

Pursuant to §26.304 of Regulation 26, the following sources are insignificant activities. Anyactivity for which a state or federal applicable requirement applies is not insignificant even if thisactivity meets the criteria of §304 of Regulation 26 or is listed below. Insignificant activitydeterminations rely upon the information submitted by the permittee in an application datedOctober 8, 1996 and supplemental information.

Description Category

All air emissions resulting from the operation of the battery charging stations. B-20

All air emissions resulting from the operation of mills and calendars used for rubber or plasticwithin the facility for which no materials in powder form are added and in which no organicsolvents, dilutants, or thinners are used.

B-69

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

A-13

All emissions from the grinding wheel cleaning process because the facility has demonstrated thatno enforceable permit conditions are necessary to insure compliance with any applicable law orregulation provided that the emissions are less than 5 tpy of any pollutant regulated under thisregulation or less than 1 tpy of a single HAP or the emissions are less than 2.5 tpy of anycombination of HAPs.

A-13

Natural gas space heaters used to provide area heating to the loading dock areas of the facility. B-2

Air conditioning and heating units used for comfort cooling and heating for the facility. B-2

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

B-69

All emissions from the Cooling Tower because the facility has demonstrated that no enforceablepermit conditions are necessary to insure compliance with any applicable law or regulationprovided that the emissions are less than 5 tpy of any pollutant regulated under this regulation orless than 1 tpy of a single HAP or the emissions are less than 2.5 tpy of any combination of HAPs.

A-13

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

A-3

Pursuant to §26.304 of Regulation 26, the emission units, operations, or activities contained inRegulation 19, Appendix A, Group B, have been determined by the Department to beinsignificant activities. Activities included in this list are allowable under this permit and neednot be specifically identified.

SECTION VIII: GENERAL PROVISIONS


43

1. Pursuant to 40 CFR 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 CFR 70.6(a)(2) and §26.701(B) of the Regulations of the ArkansasOperating Air Permit Program (Regulation 26), effective August 10, 2000, this permitshall be valid for a period of five (5) years beginning on the date this permit becomeseffective and ending five (5) years later.

3. Pursuant to §26.406 of Regulation #26, it is the duty of the permittee to submit acomplete application 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 CFR 70.6(a)(1)(ii) and §26.701(A)(2) of Regulation #26, where anapplicable requirement of the Clean Air Act, as amended, 42 U.S.C. 7401, et seq (Act) ismore stringent than an applicable requirement of regulations promulgated under Title IVof the Act, both provisions are incorporated into the permit and shall be enforceable bythe Director or Administrator.

5. Pursuant to 40 CFR 70.6(a)(3)(ii)(A) and §26.701(C)(2) 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;e. The results of such analyses; and f. The operating conditions existing at the time of sampling or measurement.


44

6. Pursuant to 40 CFR 70.6(a)(3)(ii)(B) and §26.701(C)(2)(b) of Regulation #26, records ofall required monitoring data and support information shall be retained for a period of atleast 5 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 CFR 70.6(a)(3)(iii)(A) and §26.701(C)(3)(a) of Regulation #26, thepermittee shall submit reports of all required monitoring every 6 months. If no otherreporting period has been established, the reporting period shall end on the last day of theanniversary month of this permit. The report shall be due within 30 days of the end of thereporting period. Even though the reports are due every six months, each report shallcontain a full year of data. All instances of deviations from permit requirements must beclearly identified in such reports. All required reports must be certified by a responsibleofficial as defined in §26.2 of Regulation #26 and must be sent to the address below.

Arkansas Department of Environmental QualityAir DivisionATTN: Compliance Inspector SupervisorPost Office Box 8913Little Rock, AR 72219

8. Pursuant to 40 CFR 70.6(a)(3)(iii)(B), §26.701(C)(3)(b) of Regulation #26, and §19.601and 19.602 of Regulation #19, all deviations from permit requirements, including thoseattributable to upset conditions as defined in the permit shall be reported to theDepartment. An initial report shall be made to the Department by the next business dayafter 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,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.


45

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) by the nextbusiness day after discovery of the occurrence and such report will serve as both theinitial report and full report.

9. Pursuant to 40 CFR 70.6(a)(5) and §26.701(E) of Regulation #26, and A.C.A.§8-4-203,as referenced by §8-4-304 and §8-4-311, if any provision of the permit or the 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 CFR 70.6(a)(6)(i) and §26.701(F)(1) of Regulation #26, the permitteemust comply 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 CFR 70.6(a)(6)(ii) and §26.701(F)(2) of Regulation #26, it shall not be adefense for a permittee in an enforcement action that it would have been necessary to haltor reduce the permitted activity in order to maintain compliance with the conditions ofthis permit.

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

13. Pursuant to 40 CFR 70.6(a)(6)(iv) and §26.701(F)(4) of Regulation #26, this permit doesnot convey any property rights of any sort, or any exclusive privilege.


46

14. Pursuant to 40 CFR 70.6(a)(6)(v) and §26.701(F)(5) of Regulation #26, the permitteeshall furnish to the Director, within the time specified by the Director, any informationthat the Director may request in writing to determine whether cause exists for modifying,revoking and reissuing, or terminating the permit or to determine compliance with 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 CFR 70.6(a)(7) and §26.701(G) of Regulation #26, the permittee shall payall permit fees in accordance with the procedures established in Regulation #9.

16. Pursuant to 40 CFR 70.6(a)(8) and §26.701(H) of Regulation #26, no permit revisionshall be required, under any approved economic incentives, marketable permits,emissions trading and other similar programs or processes for changes that are providedfor elsewhere in this permit.

17. Pursuant to 40 CFR 70.6(a)(9)(i) and §26.701(I)(1) of Regulation #26, if the permittee 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 CFR 70.6(b) and §26.702(A) and (B) of Regulation #26, all terms andconditions in this permit, including any provisions designed to limit a source's potential toemit, are enforceable by the Administrator and citizens under the Act unless theDepartment has specifically designated as not being federally enforceable under the Actany terms and conditions included in the permit that are not required under the Act orunder any of its applicable requirements.

19. Pursuant to 40 CFR 70.6(c)(1) and §26.703(A) of Regulation #26, any document(including reports) required by this permit shall contain a certification by a responsibleofficial as defined in §26.2 of Regulation #26.

20. Pursuant to 40 CFR 70.6(c)(2) and §26.703(B) of Regulation #26, the permittee shallallow an authorized representative of the Department, upon presentation of credentials, toperform the following:

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;


47

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

c. Inspect at reasonable times any facilities, equipment (including monitoring and airpollution control equipment), practices, or operations regulated or required underthis permit; 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 CFR 70.6(c)(5) and §26.703(E)(3) of Regulation #26, the permittee shallsubmit a compliance certification with terms and conditions contained in the permit,including emission limitations, standards, or work practices. This compliancecertification shall be submitted annually and shall be submitted to the Administrator aswell as to the Department. All compliance certifications required by this permit shallinclude 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 §26.704(C) of Regulation #26, nothing in this permit shall alter or affect thefollowing:

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

b. The liability of the permittee for any violation of applicable requirements prior toor at the time of permit issuance;

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

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

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.


48

49

Route To: FELICIA INMANAdministration

AIR DIVISION

INVOICE REQUEST FORM

(9-96)

Facility Name & Address:Gates Rubber CompanyPO Box 888Siloam Springs, Arkansas 72761

CSN: 04-0111 Permit No: 378-AR-10

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

Initial Fee Calculations:

Title V = 3333(18.08)(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 = $18.08 x (50.6 + 31.1 + 151.5 + 56.4 + 7.43 + 0.04 + 0.03) - $1627 = $5372 - $1627 = $3745

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

F = Not Applicable

Fee Amount: $ 3745

Engineer: Nancy Spencer RogersDate: December 19, 2001

Don’t use this one!!!!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:

Gates Rubber Company of 1801 North Lincoln Street, Siloam Springs, Benton County, Arkansas72761, manufactures rubber belts. Permit #378-AOP-R0 has been issued as the first operatingpermit for this facility as per the requirements of Regulation #26 (Title V) and the Clean Air Act. Under this permit, the facility has increased throughput which has increased production.

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, Information Officer. Citizens desiring technical informationconcerning the application or permit should contact Nancy Spencer Rogers, Engineer. BothRhonda Sharp and Nancy Spencer Rogers can be reached at the Department's central office, 8001National Drive, Little Rock, Arkansas 72209, telephone: (501) 682-0744.

The draft permit and permit application are available for copying at the above address. A copy ofthe draft permit has also been placed at the Ozarks Regional Library Headquarters, 217 EastDickson, Fayetteville, Arkansas 72701. This information may be reviewed during normalbusiness hours. Interested or affected persons may also submit written comments or request a hearing on theproposal, or the proposed modification, to the Department at the above address - Attention:Rhonda Sharp. In order to be considered, the comments must be submitted within thirty (30)days of publication of this notice. Although the Department is not proposing to conduct a publichearing, one will be scheduled if significant comments on the permit provisions are received. If ahearing is scheduled, adequate public notice will be given in the newspaper of largest circulationin the county in which the facility in question is, or will be, located.

The Director shall make a final decision to issue or deny this application or to impose specialconditions in accordance with Section 2.1 of the Arkansas Pollution Control and EcologyCommission’s Administrative Procedures (Regulation #8) and Regulation #26.

Dated this

Randall Mathis Director

Appendix ASample VOC Recordkeeping

SN-06 Cord TreaterSN-08 Belt Builder

Source No Source Description For Month___________________ Year_______ Table A

VOC Emission Rate Calculations*

Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9

Supplier Name Formulation Type MSDS # Density(lb/gallon)

VOC Content(lb/gallon)

Amount Used(gallon/month)

% OverallControl

Efficiency

VOCEmissions (lb/month)

VOC Emission(ton/month)

Total Emissions From Column 9 (tons)

Total Emissions From Previous 11 months (tons)

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

*Emission rates are public information. Only the non-public factors used to determine the emissions can be kept confidential. It may be necessary toprovide both a confidential and a non-confidential version of this to the Department for inspection. In accordance with Department policy, anyinformation requested to be kept confidential must be marked as such in red.

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

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

Appendix BSample HAP Recordkeeping

SN-06 Cord TreaterSN-08 Belt Builder

Source No Source Description For Month___________________ Year_______ Table B

VOC Emission Rate Calculations*

Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9

Supplier Name Formulation Type MSDS # Name ofHAP

HAP Content(lb/gallon)

Amount Used(gallon/month)

% OverallControl

Efficiency

HAPEmissions (lb/month)

HAP Emission(ton/month)

Total Emissions From Column 9 (tons)

Total Emissions From Previous 11 months (tons)

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

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

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

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

INVOICE REQUEST FORMPDS-

Date December 19, 2001

X Air

NPDES

Stormwater

State Permits Branch

Solid Waste

CSN 04-0111

Facility Name Gates Rubber Company

Invoice Mailing Address 1801 North Lincoln, Siloam Springs, Arkansas 72761

Initial

TTTT Modification

Annual

Permit Number 378-AOP-R2 Permit Description Title 5 Permit Fee Code A

Amount Due$ 500.00

Engineer Nancy Spencer Rogers

Paid? GGGGNo GGGGYes Check #

Comments: Air Permit Fee CalculationMinor Mod

Public Notice

Pursuant to the Arkansas Operating Air Permit Program (Regulation #26) Section 602, the Air Division of theArkansas Department of Environmental Quality gives the following notice:

The Gates Rubber Company (CSN: 04-0111) of 1801 North Lincoln Street, Siloam Springs, Benton County,Arkansas manufactures rubber belts. This permit has been modified to add one grinder to SN-13, Bubble BeltGrinders. It is a minor modification to Permit #378-AOP-R1. The total permitted increase in emissions at thisfacility due to the modification is negligible.

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

Citizens wishing to examine the permit application and staff findings and recommendations may do so by contactingSuzanne Carswell, Information Officer. Citizens desiring technical information concerning the application or permitshould contact Nancy Spencer Rogers, Engineer. Both Suzanne Carswell and Nancy Spencer Rogers can be reachedat the Department's central office, 8001 National Drive, Little Rock, Arkansas 72209, telephone: (501) 682-0744.

The draft permit and permit application are available for copying at the above address. A copy of the draft permithas also been placed at the Fayetteville Public Library, 217 East Dickson, Fayetteville, Arkansas 72701. Thisinformation may be reviewed during normal business hours. Interested or affected persons may also submit written comments or request a hearing on the proposal, or theproposed modification, to the Department at the above address - Attention: Suzanne Carswell. In order to beconsidered, the comments must be submitted within thirty (30) days of publication of this notice. Although theDepartment is not proposing to conduct a public hearing, one will be scheduled if significant comments on thepermit provisions are received. If a hearing is scheduled, adequate public notice will be given in the newspaper oflargest circulation in the county in which the facility in question is, or will be, located.

The Director shall make a final decision to issue or deny this application or to impose special conditions inaccordance with Section 2.1 of the Arkansas Pollution Control and Ecology Commission’s AdministrativeProcedures (Regulation #8) and Regulation #26.

Dated this

Richard A. WeissInterim Director

operating air permit - arkansas department of ... · gates rubber company permit #: 378-aop-r2 csn:...

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