ADEQ · 02 - wetscrubbers #1 & #2 and SN-03through SN-06 - four naturalgas-fired0.25 MMBtuJhr...

ADEQARK A N S A SDepartment of Environmental Quality

Apri 1 9, 2013

Randy NaylorPlant ManagerTarco, Inc.One Information Way, Suite 225Little Rock, AR 72202

Dear Mr. Naylor:

The enclosed Permit No. 1046-AR-5 is your authority to construct, operate, and maintain theequipment and/or control apparatus as set forth in your application initially received on11/27/2012.

After considering the facts and requirements of A.C.A. §8-4-101 et seq., and implementingregulations, I have determined that Permit No. 1046-AR-5 for the construction, operation andmaintenance of an air pollution control system for Tarco, Inc. to be issued and effective on thedate specified in the permit, unless a Commission review has been properly requested underArkansas Department of Pollution Control & Ecology Commission's Administrative Procedures,Regulation 8, within thirty (30) days after service of this decision.

The applicant or permittee and any other person submitting public comments on the record mayrequest an adjudicatory hearing and Commission review of the final permitting decisions asprovided under Chapter Six of Regulation No.8, Administrative Procedures, Arkansas PollutionControl and Ecology Commission. Such a request shall be in the form and manner required byRegulation 8.603, including filing a written Request for Hearing with the APC&E CommissionSecretary at 101 E. Capitol Ave., Suite 205, Little Rock, Arkansas 72201. If you have anyquestions about filing the request, please call the Commission at 501-682-7890.

Sincerely,

~~~Mike BatesChief, Air Division

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY5301 NORTHSHORE DRIVE / NORTH UTILE ROCK / ARKANSAS 72118-5317 / TELEPHONE 501-682-0744 / FAX 501-682-0880

www.adeq.state.ar.us

ADEQMINOR SOURCE

AIR PERMITPermit No.: 1046-AR-5

IS ISSUED TO:

Tarco, Inc.9515 Hwy 165 South

North Little Rock, AR 72118Pulaski County

AFIN: 60-00853

THIS PERMIT IS THE ABOVE REFERENCED PERMITTEE'S AUTHORITY TOCONSTRUCT, MODIFY, OPERATE, AND/OR MAINTAIN THE EQUIPMENT AND/ORFACILITY IN THE MANNER AS SET FORTH IN THE DEPARTMENT'S MINOR SOURCEAIR PERMIT AND THE APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THEPROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT(ARK. CODE ANN. SEC. 8-4-101 ET SEQ.) AND THE REGULATIONS PROMULGATEDTHEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINEDHEREIN.

Signed:

1-4'UMike BatesChief, Air Division

Apri 1 9, 2013

Date

Tarco, Inc.Permit #: 1046-AR-5AFIN: 60-00853

Table of Contents

Section I: FACILITY INFORMATION 4Section II: INTRODUCTION 5

Summary ofPennit Activity 5Process Description 5Regulations 6Total Allowable Emissions 7

Section III: PERMIT HISTORY 8Section IV: EMISSION UNIT INFORMATION 10

NSPS Subpart UU Conditions 13Continuous Parametric Monitoring Systems 14NESHAP Subpart AAAAAAA Conditions 15NESHAP Subpart CCCCCC Conditions 18

Section V: INSIGNIFICANT ACTIVITIES 20Section VI: GENERAL CONDITIONS 21APPENDIX A 27

40 CFR 60, Subpart UU 27APPENDIX B 29

40 CFR 63, Subpart AAAAAAA 29APPENDIX C 31

40 CFR 63, Subpart CCCCCC 31

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List of Acronyms and Abbreviations

A.c.A.

AFIN

CFR

CO

CPMS

dscf

dscm

GDF

gr

HAP

IPT

kg

lb/hr

Mg

nte

No.

NOx

PM

PMIO

PAR

SIP

SOz

SSMP

tpy

UTM

VOC

Arkansas Code Annotated

ADEQ Facility Identification Number

Code of Federal Regulations

Carbon Monoxide

Continuous Parametric Monitoring Systems

dry standard cubic feet

dry standard cubic meters

Gasoline Dispensing Facility

grams

Hazardous Air Pollutant

Initial Performance Test

kilogram

Pound Per Hour

megagram

not -to-exceed

Number

Nitrogen Oxide

Particulate Matter

Particulate Matter Smaller Than Ten Microns in Diameter

Polycyclic Aromatic Hydrocarbons

State Implementation Plan

Sulfur Dioxide

Site-Specific Monitoring Plan

Tons Per Year

Universal Transverse Mercator

Volatile Organic Compound

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Section I: FACILITY INFORMAnON

PERMITTEE: Tarco, Inc.

AFIN: 60-00853

PERMIT NUMBER: 1046-AR-5

FACILITY ADDRESS: 9515 Hwy 165 SouthNorth Little Rock, AR 72118

MAILING ADDRESS: One Information Way, Suite 225Little Rock, AR 72202

COUNTY: Pulaski County

CONTACT NAME: Randy Naylor

CONTACT POSITION: Plant Manager

TELEPHONE NUMBER: 501-350-8775

REVIEWING ENGINEER: Patty Campbell, PE

UTM North South (Y):

UTM East West (X):

Zone 15: 3843826.36 m

Zone 15: 577091.56 m

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Section II: INTRODUCTION

Summary ofPennit Activity

Tarco, Inc. owns and operates an asphalt saturated roofing paper manufacturing facility locatedat 9515 Highway 165 South, North Little Rock, Pulaski County, Arkansas 72118. Thispermitting action is necessary to allow an increase in the maximum inlet gas temperature to themist eliminator (SN-07) from 120 of to 132.8 of. The requested change in SN-07 operatingtemperature is based on performance testing conducted August 21,2012. There are no changesto permitted emissions.

Process Description

Tarco manufactures asphalt saturated roofing paper on two production lines that are located inthe manufacturing building. Both lines are identical in size, equipment, and operation. Eachproduction line consists of an unwind stand, dry looper, dip tank saturator, cooling section, finishlooper, and winder and cutter.

Dry felt paper is delivered to the plant via truck and stored on-site. Hot asphalt is delivered bytanker truck and pumped into one of four above ground storage tanks (two tanks for eachproduction line). Emissions from the four tanks are routed to the scrubber and then to the fiberbed filter mist eliminator (SN-07) for control of emissions. The asphalt is kept hot by electricalheaters and by a natural gas-fired heaters (SN-03, 04 and 08) located at the storage tanks. Theliquid asphalt circulates in a loop through the saturators and back to the tanks.

Rolls of dry felt are loaded onto the unwind stand and unrolled onto the dry looper. The drylooper consists of a series of rollers, pulled along by a chain, which is used to form loops andmaintain tension on the paper. From the dry looper, the felt enters the saturator. The saturatorconsists of a series of rollers, called gates. The bottom rollers of these gates are submerged inhot asphalt (450°F). The two saturator gates can be raised or lowered to change the level ofsaturation of the asphalt into the felt paper. After the felt paper is saturated, it passes over aseries of three scraper blades, which remove excess asphalt. The second blade can be adjusted inor out to increase or decrease the amount of asphalt removed from the surface of the paper. Thesaturator is totally enclosed and steam vapors from the process are routed to the scrubber/cooler(for cooling) and to the fiber bed filter mist eliminator (SN-07) for control of emissions.

After the saturator, the asphalt saturated felt paper enters the cooling section, also referred to asthe black rack or the striking section, where it is drawn over several rollers and allowed to coolin the ambient air. The cooling section is enclosed (such that 97% of the vapors are captured),and the vapors are routed to the scrubber/cooler and then to the mist eliminator (SN-07) forcontrol.

From the cooling section, the paper rolls onto the finish looper, which is another series of rollersthat forms the paper into hanging loops. The asphalt saturated felt is pulled into the winder,where the rolls are formed and cut. Once the roll is formed it is pushed along a conveyor, where

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it is manually labeled and stacked on to pallets. When a pallet is full, it is automatically bandedand placed in storage prior to shipment. Tarco produces 15-lb and 30-lb felt rolled roofingproducts.

Tarco stores gasoline onsite for company vehicles and equipment in Gasoline Storage Tank (SN09).

Regulations

The following table contains the regulations applicable to this permit,

Regulations

Arkansas Air Pollution Control Code, Regulation 18, effective June 18,2010

Regulations ofthe Arkansas Plan of Implementation for Air Pollution Control,Regulation 19, effective November 18, 2012

40 CFR Part 60, Subpart UU - Standards ofPerformance for Asphalt Processing andAsphalt Roofing Manufacture (Appendix A)

40 CFR Part 63, Subpart AAAAAAA - National Emission Standards for Hazardous AirPollutants for Area Sources: Asphalt Processing and Asphalt Roofing Manufacturing(Appendix B)

40 CFR Part 63, Subpart CCCCCC - National Emission Standards for Hazardous AirPollutants for Source Category: Gasoline Dispensing Facilities (Appendix C) SN-09

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Total Allowable Emissions

The following table is a summary of emissions from the facility. This table, in itself, is not anenforceable condition of the permit.

TOTAL ALLOWABLE EMISSIONS

Emission RatesPollutant

lb/hr tpy

PM 1.5 4.3

PMIO 1.5 4.3

S02 0.3 0.3

VOC 92.5 24.8

CO 6.8 6.2

NOx 0.9 3.0

Benzene 0.16 0.04

Carbonyl Sulfide 0.12 0.39

Formaldehyde 0.13 0.44

Toluene 0.47 0.10

Xylene 0.44 0.10

GHG Status:This facility is classified as a minor source of greenhouse gas emissions because it has thepotential to emit less than 100,000 tpy COzeor less than 100 tpy mass basis combinedgreenhouse gases.

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Section III: PERMIT HISTORY

Initial Permit #1046-A was issued to Tarco, Inc. on June 11, 1990. Tarco, Inc. operated its NorthLittle Rock facility from approximately 1978 through 1990 without an air permit and in violationof40 CFR Part 60, Subpart DU. Tarco is therefore subject to 40 CFR Part 60 Subpart DU forinstalling an affected source without first obtaining an air permit. Sources included: SN-01 &02 - wet scrubbers #1 & #2 and SN-03 through SN-06 - four natural gas-fired 0.25 MMBtuJhrheaters. The total permitted annual emission rate limits associated were: 61.32 tpy PM and 0.52tpyNOx.

Permit #1046-AR-1 was issued to Tarco, Inc. on June 10,2010. This permitting action wasnecessary to: 1.) Update the twenty year old permit to current standards and format; 2.) Install anew Fiber Bed Filter Mist Eliminator to control PM emissions from SN-07; 3.) Designate SN-07as emissions from the two asphalt saturated roofing paper production lines and the four asphaltstorage tanks with the new Mist Eliminator; 4.) Enclose the cooling section of each productionline and route those emissions through the scrubber and to the Mist Eliminator; 5.) Update theapplicable provisions for 40 CFR Part 60, Subpart DU; 6.) Add the applicable provisions for 40CFR Part 63, Subpart AAAAAAA, must be in compliance no later than December 2,2010 anddemonstrate initial compliance within 180 days, no later than May 31, 2011; 7.) Add CPMSconditions for temperature and pressure drop for the Fiber Bed Filter Mist Eliminator SN-07, anew control device; 8.) Conduct SN-07 tests for PM, formaldehyde and carbonyl sulfideemissions not to exceed 0.08, 0.0091, and 0.0081 lb/ton, respectively; 9.) Remove SN-02scrubber #2; 10.) Correct the heat rating and emission calculations for SN-03, 04, 05 and 06; 11.)Add 96,000 tons of finished saturated asphalt roofing paper annual throughput limit; 12.) Add48,000 tons (10,434,780 gallons) of asphalt annual throughput limit to be purchased (SN-07);and 13.) Add the following lAs: 1,000 and 200 gal capacity diesel storage tanks, A-3; 1,000 galcapacity gasoline storage tank, A-13; and oil (asphalt) water separator, A-13. Total permittedannual emission rate limit increases and decreases associated with this modification included:-57.02 tpy PM, 4.3 tpy PM IO, 0.4 tpy S02, 24.0 tpy VOC, 5.9 tpy CO, 1.88 tpy NOx, 0.44 tpyformaldehyde and 0.39 tpy carbonyl sulfide.

Permit #1046-AR-2 was issued to Tarco, Inc. on December 16,2010. This permitting action wasnecessary to: revise the maximum inlet temperature to the mist eliminator (SN-07) to beincreased from 120°F to 150°F. A new Cooler will be installed prior to the mist eliminatorinstead ofmodifying an existing wet scrubber into a "cooling unit". The mist eliminatorinstallation was completed and started-up on October 22,2010. The "target production rate", anotification required in General Provision #3, was achieved on both lines (but notsimultaneously) on October 25,2010. There were no changes in emissions.

Permit #1046-AR-3 was issued to Tarco, Inc. on February 1,2011. This permitting action wasamended to clarify that the phrase "target production rate", a notification requirement in GP #3,undefined by Regulation No. 19, was misinterpreted as "maximum production rate" per 40 CFR60, Subpart DU. The IPT due date specified in SC #12 based on Tarco's achievement date ofthe"target production rate" on each line has been removed. "Target production rate" should not beinterpreted to mean "maximum production rate". There were no changes in emissions.

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Permit #1046-AR-4 was issued to Tarco on February 7,2012. This permitting action wasnecessary to: Remove SN-05 and 06; Install one 4.125 MMBtulhr natural gas-fired heater SN08; Revise SN-03 and 04 description to Line 1 Asphalt Tank Heaters No.1 and 2, respectively;Opacity test for SN-07 was completed; Change temperature parameter for SN-07 to incorporatemanufacturer's performance specifications: inlet gas temperature :::;120°F; and Change 1,000gallon Gasoline Storage Tank from IA to SN-09 and incorporate requirements of 40 CFR 63Subpart CCCCCe. Total permitted annual emission rate limit changes included: -0.1 SOz tpy,0.8 tpy VOC, 0.3 tpy CO, 0.6 tpy NOx, 0.04 tpy Benzene, 0.10 tpy Toluene and 0.10 tpy Xylene.

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Section IV: EMISSION UNIT INFORMATION

Specific Conditions

1. The permittee shall not exceed the emission rates set forth in the following table.[Regulation 19 §19.501 et seq. and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311]

SN Description Pollutant lb/hr tpy

01 Saturator No.1 Scrubber - emissions routed to Mist Eliminator (SN-07)

PM 10 0.1 0.1

Line 1 Asphalt Tank Heater #1S02 0.1 0.1

03 VOC 0.1 0.1(natural gas, 1.25 MMBtu!hr)

CO 0.2 0.6NOx 0.2 0.6

PM 10 0.1 0.1

Line 1 Asphalt Tank Heater #2 S02 0.1 0.104 VOC 0.1 0.1

(natural gas, 1.25 MMBtu!hr)CO 0.2 0.6

NOx 0.2 0.6

Asphalt Saturated Roofing PaperLines #1 and #2 & Four 11,500

PMIO 1.2 3.907

gallon capacity Asphalt StorageVOC 88.7 23.6

Tanks (One Fiber Bed Filter MistCO 6.0 3.5Eliminator and Scrubber @ 98%

efficiency)

PM IO 0.1 0.2

Line 2 Asphalt Tank Heater S02 0.1 0.108 VOC 0.1 0.2(natural gas, 4.125 MMBtu!hr)

CO 0.4 1.5NOx 0.5 1.8

09Gasoline Storage Tank

VOC 3.5 0.8(1,000 gallon capacity)

02,05,06 Removed from service.

2. The permittee shall not exceed the emission rates set forth in the following table.[Regulation 18 §18.801 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

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SN Description Pollutant lb/hr tpy

03Line 1 Asphalt Tank Heater #1

PM 0.1 0.1(natural gas, 1.25 MMBtu/hr)

04Line 1 Asphalt Tank Heater #2

PM 0.1 0.1(natural gas, 1.25 MMBtu/hr)

Asphalt Saturated Roofing PaperLines #1 and #2 and Four

PM 1.2 3.907

11,500 gallon capacity AsphaltFormaldehyde 0.13 0.44Storage Tanks (One Fiber Bed

Filter Mist Eliminator andCarbonyl Sulfide 0.12 0.39

Scrubber @ 98% efficiency)

08Line 2 Asphalt Tank Heater

PM 0.1 0.2(natural gas, 4.125 MMBtulhr)

Gasoline Storage TankBenzene 0.16 0.04

09 Toluene 0.47 0.10(1,000 gallon capacity)

Xylene 0.44 0.10

3. Visible emissions may not exceed the limits specified in the following table of this permitas measured by EPA Reference Method 9 and the procedures in §60.11. Compliancewith this specific condition for SN-03, 04 and 08 shall be demonstrated by compliancewith Specific Condition #6. Visible emissions from SN-07 Saturator Capture Systemmay not exceed 20 percent of any period of consecutive valid observations totaling 60minutes as specified in Specific Condition #13. Visible emissions from SN-07 AsphaltStorage Tanks may not exceed zero (0) percent, except for one consecutive 15-minuteperiod in any 24-hour period when the transfer lines are being blown for clearing. Thecontrol device [Fiber Bed Filter Mist Eliminator] shall not be bypassed during this 15minute period. If, however, the emissions from any asphalt storage tanks are ducted to acontrol device for a saturator, the combined emissions shall meet the emission limitcontained in §60.472(a) during the time the saturator control device is operating. At anyother time the asphalt storage tanks must meet the opacity limit specified below forstorage tanks. [AC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

SN Limit Regulatory Citation

03,04 & 08 5% §18.501 and AC.A (natural gas)

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SN Limit Regulatory Citation

07 (Saturator Capture System) 20% §60.472(a)(2) and (3)

07 (Storage Tanks) 0% §60.472(c)

4. The permittee shall not cause or permit the emission of air contaminants, including odorsor water vapor and including an air contaminant whose emission is not otherwiseprohibited by Regulation #18, if the emission of the air contaminant constitutes airpollution within the meaning of A.C.A. §8-4-303. [Regulation 18 §18.801 andAC.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

5. The permittee shall not conduct operations in such a manner as to unnecessarily cause aircontaminants and other pollutants to become airborne. [Regulation 18 §18.901 andAC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

6. The permittee shall burn only pipeline quality natural gas as fuel at the facility.Combustion emissions from fuel burning process equipment, SN-03, 04 and 08, havebeen calculated at full load for continuous operation and no calculated recordkeeping ofnatural gas usage is required. [Regulation 18 §18.1004, Regulation 19 §19.705 andAC.A §8-4-203 as referenced by §8-4-304 and §8 4-311]

7. The permittee shall not exceed a throughput of96,000 tons of finished saturated asphaltroofing paper (SN-07) at the facility per rolling 12-month period. Tarco produces both15-lb felt and 30-lb felt products. Maximum throughput is based on worst case scenario,which is 30-lb felt product. [Regulation 19 §19.705 and AC.A §8-4-203 as referencedby §8-4-304 and §8-4-311]

8. The permittee shall not purchase more than 48,000 tons (10,434,780 gallons) of asphalt tobe stored in the four tanks (SN-07) at the facility per rolling 12-month period. Asphalt is50% ofthe maximum production. [Regulation 19 §19.705 and AC.A §8-4-203 asreferenced by §8-4-304 and §8-4-311]

9. The permittee shall maintain documentation (e.g., purchase orders or receipts) andmonthly records to demonstrate compliance with Specific Conditions #7 and #8.Material Data Safety Sheets or other equivalent documents shall be maintained on-siteand made available upon request. The permittee shall update these records by thefifteenth day of the month following the month to which the records pertain. The twelvemonth rolling totals and each individual month's data shall be maintained on-site andmade available to Department personnel upon request. [Regulation 19 §19.705 andAC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

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NSPS Subpart UU Conditions

10. The permittee is an asphalt roofing plant and is subject to and must comply with allapplicable provisions of New Source Performance Standards (NSPS), 40 CFR Part 60Subpart UU - Standards ofPerformance for Asphalt Processing and Asphalt RoofingManufacture (Appendix A). [Regulation 19 §19.304 and 40 CFR 60, Subpart UU]

11. The permittee is subject to and must comply with the applicable NSPS Subpart UUemission limitation and standard for SN-07 Saturator, as specified for particulate matter.PM emissions shall not exceed 0.08 lb/ton (0.04 kg/Mg) per saturated felt or smoothsurfaced roll roofing produced. One (1) lb/ton is equivalent to 0.5 kg/Mg. [Regulation18 §18.801, Regulation 19 §19.501, AC.A §8-4-203 as referenced by §8-4-304 and§8-4-311and §60.472(a)(1)(ii)]

12. The permittee shall conduct an initial performance test (IPT) within 60 days afterachieving the maximum production rate at which the affected facility will be operated,but not later than 180 days after initial startup of the fiber bed filter mist eliminator (SN07). SN-07 is subject to testing in accordance with 40 CFR Part 60, Subpart UU todemonstrate compliance with the applicable PM emission standard in Specific Condition#11. [The IPT was performed May 23,2011. The latest performance test was conductedon August 21,2012.] For the saturator (SN-07), the permittee shall conduct performancetests required in §60.8 as follows: [Regulation 18 §18.1002, AC.A §8-4-203 asreferenced by §8-4-304 and §8-4-311 and §60.474(a)(2), (b) and (c)]

a. If the final product is saturated felt or smooth-surfaced roll roofing, the tests shallbe conducted while 6.8-kg (kilogram) (15-lb) felt is being produced;[§60.474(a)(2)]

b. In conducting the performance tests required in §60.8, the permittee shall use asreference methods and procedures the test methods in appendix A of §60.8 orother methods and procedures as specified in 40 CFR §60.474(c)(1) through (3)and (d), except as provided in §60.8(b);

c. The permittee shall determine compliance with the particulate matter standards in§60.472(a)(1)(ii) (Specific Condition #11), as specified in §60.474(c)(1) through(3);

d. The permittee shall maintain continuous temperature and pressure drop totals ofthe mist eliminator during the performance test; and

e. Performance tests may not be conducted during periods of startup, shutdown, ormalfunction, as specified in 40 CFR §60.8(c).

13. The permittee has determined compliance with the opacity standards of the saturator (SN07) in §60.472(a)(3), Specific Condition #3, by using US-EPA reference Method 9 onMay 23,2011 on SN-07. This test successfully documented no visible emissions. Noadditional Method 9 testing is required under this permit unless a new Asphalt SaturatedRoofing Paper line is installed or significant modifications are made to the existingAsphalt Saturated Roofing Paper Lines #1 and #2 & four 11,500 gallon capacity Asphalt

13


Storage Tanks (One Fiber Bed Filter Mist Eliminator) (SN-07), which would alter thepotential emissions. [Regulation 19 §19.503, A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311 and §60.474(d)]

14. The permittee must submit to the Department a copy of the initial and any subsequentperformance tests as specified in Specific Conditions #12 and #13 at the address inGeneral Condition #6, maintain a copy on-site for the life ofthe unit and make availableto Department personnel upon request. [Regulation 19 §19.304 and §19.705]

Continuous Parametric Monitoring Systems

15. The permittee is subject to and must comply with the Continuous Parametric MonitoringSystems (CPMS) Conditions as required by 40 CFR 63, Subpart AAAAAAA (AppendixB). [Regulation 19 §19.703 and A.c.A. §8-4-203 as referenced by §8-4-304 and§8-4-311]

16. The permittee has a control device not mentioned in §60.473(a) or (b) and must provideto the Department information describing the operation of the control device (Fiber BedFilter Mist Eliminator) and the process parameters, which would indicate properoperation and maintenance ofthe device. The permittee must maintain these documentson-site for the life of the control device and make available to Department personnelupon request. [Regulation 19 §19.303 and §60.473(c)]

17. The permittee shall operate the Fiber Bed Filter Mist Eliminator (SN-07) whenever eitherproduction line is operating, including during startup. [Regulation 19 §19.703 andA.c.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

18. The permittee shall maintain CPMS of the Fiber Bed Filter Mist Eliminator (SN-07) forinlet gas temperature and dual pressure drop. The permittee is exempt from quarterlyreports required under §60.7(c). The permittee is required to record and report the inletoperating temperature of the control device during the initial and any subsequentperformance tests and, as required by §60.7(d), maintain a file of the temperature andpressure drop monitoring results for at least five years. The temperature operatingparameter was established during the August 21,2012 performance test. [Regulation 19§19.703, A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311 and Items 2(a) and (b)of Table 4 of Subpart AAAAAAA ofPart 63 - Operating Limits]

SN-07 Parameter Monitored Maximum Operation

Inlet Gas Temperature S 132.8 ofFiber Bed Filter Mist

Eliminator Pressure Drop across 16 inches H2O,

Control Device Main Filter Elements clean and saturated

14


19. The permittee shall install, maintain and operate a continuous temperature gauge andcontinuous pressure device with data loggers or other recording devices to measure,monitor and record temperature and pressures of the mist eliminator. The temperatureand pressure of the control device shall be recorded once every 15 minutes for a period ofconsecutive observations. These values shall be recorded, maintained on-site, and madeavailable to Department personnel upon request. In the event the monitor or associatedequipment malfunctions, the permittee shall follow the SSM Plan developed per SpecificCondition #21. [Regulation 19 §19.703, 40 CFR Part 52 Subpart E and AC.A §8-4-203as referenced by §8-4-304 and §8-4-311]

20. The permittee must retain the records of all required monitoring data and supportinformation for at least five (5) years from the date of the monitoring sample,measurement, report, or application. Support information includes all calibration andmaintenance records and all original strip chart recordings for continuous monitoringinstrumentation, and copies of all reports required by this permit. The permittee mustmaintain these documents on-site and make available to Department personnel uponrequest. [Regulation 19 §19.703, 40 CFR Part 52 Subpart E and AC.A §8-4-203 asreferenced by §8-4-304 and §8-4-311]

NESHAP Subpart AAAAAAA Conditions

21. The permittee is using a control device to comply with the emission limits specified inTables 1 and 2 of Subpart AAAAAAA of Part 63, therefore, the permittee must developand make available for inspection by the Department a Site-Specific Monitoring Plan(SSMP) for each monitoring system that addresses the following and which conforms toall applicable requirements in §63.11563 by December 2, 2010 or by start-up of the misteliminator, whichever is earliest. The mist eliminator installation was completed andstarted-up on October 22,2010. The control device shall be operated in accordance withthe SSMP. [Regulation 18 §18.1003, §63.11563 and AC.A §8-4-203 as referenced by§8-4-304 and §8-4-311]

a. Installation of the CPMS probe or other interface at a measurement locationrelative to each affected process unit such that the measurement is representativeof control of the exhaust emissions (e.g., on or downstream of the last controldevice;

b. Performance and equipment specifications for the probe or interface, the pollutantconcentration or parametric signal analyzer, and the data collection and reductionsystem; and

c. Performance evaluation procedures and acceptance criteria (e.g., calibrations).

22. The permittee is subject to 40 CFR Part 63, Subpart AAAAAAA - National EmissionStandards for Hazardous Air Pollutants (NESHAP) for Area Sources: Asphalt Processingand Asphalt Roofing Manufacturing because it is an existing asphalt roofingmanufacturing operation that is an area source of hazardous air pollutant (HAP)

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emissions, as defined in §63.2. [Regulation 19 §19.304 and 40 CFR §63.11559(a),(b)(2)]

23. The permittee must be in compliance with the applicable provisions in SubpartAAAAAAA ofPart 63 no later than December 2,2010. As specified in §63.11562(g),the permittee must demonstrate initial compliance within 180 calendar days afterDecember 2,2010, effective date May 31,2011. The permittee demonstrated compliancewithin schedule. [Regulation 19 §19.304 and 40 CFR §63.11560(a)]

24. For asphalt roofing manufacturing lines and associated equipment, the permittee mustcomply with the applicable PM or PAH emission limits specified in Table 2 ofNESHAPSubpart AAAAAAA. Tarco will demonstrate compliance with PM standard; therefore,PAH emissions are not required to be estimated. The PM standard applies at all times.The emission limits are as listed in the following table: [§63.11561(b) and (c) and Items2a or 2b of Table 2 ofPart 63, Subpart AAAAAAA-Emission Limits for Asphalt RoofingManufacturing (Coating) Operations]

Table 2 ofPart 63, Subpart AAAAAAA-Emission Limits for Asphalt Roofing Manufacturing (Coating) Operations

2a. Limit PAH emissions to 0.0007Ib/ton of asphaltSaturator-only roofing product manufactured; or

Production Lines(SN-07) 2b. Limit PM emissions to 0.30 lb/ton of asphalt roofing

product manufactured.

25. The permittee owns and operates an asphalt saturated roofing manufacturing facility thatuses a control device to comply with the emission limits in Table 2 of SubpartAAAAAAA of Part 63 (Specific Condition #24). The permittee must:[§63.11562(b)(1)(i-ii) and (b)(3)(i-iii) and Item 2 of Table 4 of Subpart AAAAAAA ofPart 63- Operating Limits]

a. Demonstrate initial compliance by:i. Conducting emission tests using the methods specified in Table 3 of

Subpart AAAAAAA ofPart 63-Test Methods; or11. Using the results of a previously-conducted emission test as specified in

§63.11562(d).b. Establish the value or range of values of the operating parameters specified in

Table 4 of Subpart AAAAAAA ofPart 63 for control devices other than thermaloxidizers: [Tarco does not have a thermal oxidizer. Tarco has a fiber bed filtermist eliminator.]

i. Using the operating parameter data recorded during the complianceemission tests;

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Tarco, Inc.Permit #: 1046-i\R-5AFIN: 60-00853

11. Using the operating parameter data recorded during a previouslyconducted emission test; or

111. Using manufacturer performance specifications.c. If the permittee is using a previously-conducted emission test to demonstrate

compliance with the emission limitations in Subpart AAAAAAA ofPart 63 foran existing source, as specified in §63.11562(b)(I)(ii), the following must be met:

i. The emission test was conducted within the last 5 years;ii. No changes have been made to the process since the time of the emission

test;111. The operating conditions and test methods used for the previous test

conform to the requirements of Subpart AAAAAAA ofPart 63; andIV. The data used to establish the value or range of values of the operating

parameters, as specified in §63.11562(b)(2)(ii), were recorded during theemission test.

d. For existing sources [Tarco is an existing source], the permittee must demonstrateinitial compliance no later than 180 calendar days after December 2,2010,effective date ofMay 31,2011. [Tarco conducted a test on May 23,2011].

e. For emission tests conducted to demonstrate initial compliance with the emissionlimits specified in Tables 1 and 2 of Subpart AAAAAAA of Part 63, the permitteemust follow the requirements specified in §63.11562(i)(I) through (i)(4):

i. The permittee must conduct the tests while manufacturing the product thatgenerates the greatest PAH and PM emissions to the control device inlet,or exiting the process if the permittee is not using a control device tocomply with the emissions limits specified in Tables 1 and 2 of SubpartAAAAAAA ofPart 63.

11. The permittee must conduct a minimum of three (3) separate test runs foreach compliance test, as specified in §63.11562(b)(I)(i), according to therequirements specified in §63.7(e)(3). The sampling time and samplevolume of each test run must be as follows:

(1.) For asphalt coating operations, the sampling time and samplevolume for each test run must be at least 120 minutes and 3.00 drystandard cubic meters (dscm) (106 dscf).

iii. The permittee must use the following equation to demonstrate compliancewith the emission limits specified in Table 2 of Subpart AAAAAAA ofPart 63:

(1.) E = [(C)*(Q)/(P)*(K)]

Where:E = emission rate of particulate matter, kg/Mg (lb/ton)C = concentration of particulate matter, g/dscm (gr/dscf)Q = volumetric flow rate of effluent gas, dscm/hr (dscf/hr)P = the average asphalt roofing production rate or asphalt charging rateover the duration of the test, Mg/hr (ton/hr)K = conversion factor, 1,000 g/kg (7,000 gr/lb)

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26. The permittee must comply with applicable emission limitations and standards used topermit hourly and annual rates for the saturator capture system SN-07, specified forformaldehyde and carbonyl sulfide emissions. The following table summarizes the notto-exceed (nte) formaldehyde (CH20 ) and carbonyl sulfide (COS) emissions limitspermitted for this source and the actual emission results of the IPT. No additionalperformance test, after the initial performance test, is required under this permit unless anew control device is installed or significant modifications are made to the unit whichwould alter the potential emissions. [Regulation 18 §18.1004 and A.c.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311]

Emission Limits

SN Description Pollutant(lb/ton produced)

March 30, 2011SIP - nte

test results

Fiber Bed Filter Formaldehyde 0.0091 0.000407

Mist Eliminator Carbonyl Sulfide 0.0081 0.0040

27. The permittee conducted an initial performance test on March 30, 2011 on the saturatorcapture system (SN-07) for formaldehyde and carbonyl sulfide in accordance withGeneral Condition #7. The formaldehyde and carbonyl sulfide test results were sent tothe Department at the address in General Condition #6. Test results shall be maintainedon-site for the life ofthe unit and made available to Department personnel upon request.[Regulation 18 §18.1004 and A.c.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

NESHAP Subpart CCCCCC Conditions

28. The permittee shall not exceed a throughput of 24,000 gallons of gasoline (SN-09) at thefacility per rolling 12-month period. The permittee shall not exceed a throughput of10,000 gallons of gasoline (SN-09) at the facility per individual month. [Regulation 19§19.705 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

29. The permittee shall maintain documentation (e.g., purchase orders or receipts) andmonthly records which demonstrate compliance with Specific Condition #28. MaterialData Safety Sheets or other equivalent documents shall be maintained on-site and madeavailable upon request. The permittee shall update these records by the fifteenth day ofthe month following the month to which the records pertain. The twelve month rollingtotals and each individual month's data shall be maintained on-site and made available toDepartment personnel upon request. Records shall be kept for a period of five years.[Regulation 19 §19.705 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

30. The permittee is subject to and shall comply with the applicable provisions of40 CFRPart 63, Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutantsfor Gasoline Dispensing Facilities (GDF). Gasoline dispensingfacility (GDF) is defined

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in §63.11132 as any stationary facility which dispenses gasoline into the fuel tank of amotor vehicle, motor vehicle engine, nonroad vehicle, or nonroad engine, including anonroad vehicle or nonroad engine used solely for competition. Tarco, an area source, isa GDF. The affected source includes each gasoline cargo tank during the delivery ofproduct to a GDF and also includes each storage tank. SN-09 is an existing affectedsource to which this subpart applies. Tarco must comply with the standards in 40 CFR63 Subpart CCCCCC no later than January 10, 2011. [Regulation 19 §19.304 and 40CFR 63 Subpart CCCCCC]

31. The permittee must comply with the requirements in §63.11116 because it has a monthlythroughput of less than 10,000 gallons of gasoline. Requirements for facilities withmonthly throughput of less than 10,000 gallons of gasoline are as follows:

a. The permittee must not allow gasoline to be handled in a manner that would resultin vapor releases to the atmosphere for extended periods of time. Measures to betaken include, but are not limited to, the following:

i. Minimize gasoline spills;ii. Clean up spills as expeditiously as practicable;

iii. Cover all open gasoline containers and all gasoline storage tank fill-pipeswith a gasketed seal when not in use; and

IV. Minimize gasoline sent to open waste collection systems that collect andtransport gasoline to reclamation and recycling devices, such as oil/waterseparators.

b. The permittee is not required to submit notifications or reports as specified in§63.11125, §63.11126, or subpart A of Part 63, but you must have recordsavailable within 24 hours of a request by the Department to document yourgasoline throughput.

c. The permittee must comply with the requirements of 40 CFR 63 SubpartCCCCCC by the applicable dates specified in §63.11113.

d. Portable gasoline containers that meet the requirements of 40 CFR Part 59,subpart F, are considered acceptable for compliance with §63.11116(a)(3).

[Regulation 19 §19.304 and §63.11111(b) and §63.11116(a) through (d)]

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Section V: INSIGNIFICANT ACTIVITIES

The Department deems the following types of activities or emissions as insignificant on the basisof size, emission rate, production rate, or activity in accordance with Group A of theInsignificant Activities list found in Regulation 18 and 19 Appendix A. Insignificant activityemission determinations rely upon the information submitted by the permittee in applicationsdated March 19,2010 and September 24,2010.

Description Category

1,000 gallon capacity Diesel Storage Tank A-3

200 gallon capacity Diesel Storage Tank A-3

Oil (asphalt) / Water Separator A-13

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Section VI: GENERAL CONDITIONS

1. Any terms or conditions included in this permit that specify and reference ArkansasPollution Control & Ecology Commission Regulation 18 or the Arkansas Water and AirPollution Control Act (AC.A §8-4-101 et seq.) as the sole origin of and authority for theterms or conditions are not required under the Clean Air Act or any of its applicablerequirements, and are not federally enforceable under the Clean Air Act. ArkansasPollution Control & Ecology Commission Regulation 18 was adopted pursuant to theArkansas Water and Air Pollution Control Act (AC.A §8-4-101 et seq.). Any terms orconditions included in this permit that specify and reference Arkansas Pollution Control& Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution ControlAct (AC.A §8-4-101 et seq.) as the origin of and authority for the terms or conditionsare enforceable under this Arkansas statute.

2. This permit does not relieve the owner or operator of the equipment and/or the facilityfrom compliance with all applicable provisions of the Arkansas Water and Air PollutionControl Act and the regulations promulgated under the Act. [AC.A §8-4-203 asreferenced by §8-4-304 and §8-4-311]

3. The permittee shall notify the Department in writing within thirty (30) days aftercommencement of construction, completion of construction, first operation of equipmentand/or facility, and first attainment of the equipment and/or facility target production rate.[Regulation 19 §19.704 and/or AC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

4. Construction or modification must commence within eighteen (18) months from the dateof permit issuance. [Regulation 19 §19.410(B) and/or Regulation 18 §18.309(B) andAC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

5. The permittee must keep records for five years to enable the Department to determinecompliance with the terms of this permit such as hours of operation, throughput, upsetconditions, and continuous monitoring data. The Department may use the records, at thediscretion ofthe Department, to determine compliance with the conditions of the permit.[Regulation 19 §19.705 and/or Regulation 18 §18.1004 and AC.A §8-4-203 asreferenced by §8-4-304 and §8-4-311]

6. A responsible official must certify any reports required by any condition contained in thispermit and submit any reports to the Department at the address below. [Regulation 19§19.705 and/or Regulation 18 §18.1004 and AC.A. §8-4-203 as referenced by §8-4-304and §8-4-311]

Arkansas Department of Environmental QualityAir DivisionATTN: Compliance Inspector Supervisor

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5301 Northshore DriveNorth Little Rock, AR 72118-5317

7. The permittee shall test any equipment scheduled for testing, unless stated in the SpecificConditions of this permit or by any federally regulated requirements, within the followingtime frames: (1) newly constructed or modified equipment within sixty (60) days ofachieving the maximum production rate, but no later than 180 days after initial start up ofthe permitted source or (2) existing equipment already operating according to the timeframes set forth by the Department. The permittee must notify the Department of thescheduled date of compliance testing at least fifteen (15) business days in advance ofsuch test. The permittee must submit compliance test results to the Department withinthirty (30) calendar days after the completion of testing. [Regulation 19 §19.702 and/orRegulation 18 §18.1002 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

8. The permittee shall provide: [Regulation 19 §19.702 and/or Regulation 18 §18.1002 andAC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

a. Sampling ports adequate for applicable test methods;b. Safe sampling platforms;c. Safe access to sampling platforms; andd. Utilities for sampling and testing equipment

9. The permittee shall operate equipment, control apparatus and emission monitoringequipment within their design limitations. The pennittee shall maintain in goodcondition at all times equipment, control apparatus and emission monitoring equipment.[Regulation 19 §19.303 and/or Regulation 18 §18.1104 and AC.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311]

10. If the permittee exceeds an emission limit established by this permit, the permittee will bedeemed in violation of said permit and will be subject to enforcement action. TheDepartment may forego enforcement action for emissions exceeding any limitsestablished by this permit provided the following requirements are met: [Regulation 19§19.601 and/or Regulation 18 §18.1101 and AC.A. §8-4-203 asreferencedby§8-4-304and §8-4-311]

a. The permittee demonstrates to the satisfaction of the Department that theemissions resulted from an equipment malfunction or upset and are not the resultof negligence or improper maintenance, and the permittee took all reasonablemeasures to immediately minimize or eliminate the excess emissions.

b. The permittee reports the occurrence or upset or breakdown of equipment (bytelephone, facsimile, or overnight delivery) to the Department by the end of thenext business day after the occurrence or the discovery of the occurrence.

c. The permittee must submit to the Department, within five business days after theoccurrence or the discovery of the occurrence, a full, written report of suchoccurrence, including a statement of all known causes and of the scheduling and

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nature of the actions to be taken to minimize or eliminate future occurrences ,including, but not limited to, action to reduce the frequency of occurrence of suchconditions, to minimize the amount by which said limits are exceeded, and toreduce the length of time for which said limits are exceeded. If the information isincluded in the initial report, the information need not be submitted again.

11. The permittee shall allow representatives of the Department upon the presentation ofcredentials: [AC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

a. To enter upon the permittee's premises, or other premises under the control of thepermittee, where an air pollutant source is located or in which any records arerequired to be kept under the terms and conditions of this permit;

b. To have access to and copy any records required to be kept under the terms andconditions of this permit, or the Act;

c. To inspect any monitoring equipment or monitoring method required in thispermit;

d. To sample any emission of pollutants; ande. To perform an operation and maintenance inspection of the permitted source.

12. The Department issued this permit in reliance upon the statements and presentationsmade in the permit application. The Department has no responsibility for the adequacy orproper functioning of the equipment or control apparatus. [AC.A §8-4-203 asreferenced by §8-4-304 and §8-4-311]

13. The Department may revoke or modify this permit when, in the judgment of theDepartment, such revocation or modification is necessary to comply with the applicableprovisions of the Arkansas Water and Air Pollution Control Act and the regulationspromulgated the Arkansas Water and Air Pollution Control Act. [Regulation 19§19.410(A) and/or Regulation 18 §18.309(A) and AC.A §8-4-203 as referenced by §84-304 and §8-4-311]

14. This permit may be transferred. An applicant for a transfer must submit a written requestfor transfer of the permit on a form provided by the Department and submit the disclosurestatement required by Arkansas Code Annotated §8-1-106 at least thirty (30) days inadvance of the proposed transfer date. The permit will be automatically transferred to thenew permittee unless the Department denies the request to transfer within thirty (30) daysof the receipt of the disclosure statement. The Department may deny a transfer on thebasis of the information revealed in the disclosure statement or other investigation or,deliberate falsification or omission of relevant information. [Regulation 19 §19.407(B)and/or Regulation 18 §18.307(B) and AC.A §8-4-203 as referenced by §8-4-304 and §84-311]

15. This permit shall be available for inspection on the premises where the control apparatusis located. [AC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

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16. This pennit authorizes only those pollutant emitting activities addressed herein. [AC.A§8-4-203 as referenced by §8-4-304 and §8-4-311]

17. This permit supersedes and voids all previously issued air permits for this facility.[Regulation 18 and 19 and AC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

18. The pennittee must pay all permit fees in accordance with the procedures established inRegulation No.9. [AC.A §8-1-105(c)]

19. The permittee may request in writing and at least 15 days in advance of the deadline, anextension to any testing, compliance or other dates in this permit, No such extensions areauthorized until the permittee receives written Department approval. The Departmentmay grant such a request, at its discretion in the following circumstances:

a. Such an extension does not violate a federal requirement;b. The permittee demonstrates the need for the extension; andc. The permittee documents that all reasonable measures have been taken to meet

the current deadline and documents reasons it cannot be met.

[Regulation 18 §18.314(A), Regulation 19 §19.416(A), AC.A §8-4-203 as referenced by§8-4-304 and §8-4-311, and 40 CFR Part 52, Subpart E]

20. The permittee may request in writing and at least 30 days in advance, temporaryemissions and/or testing that would otherwise exceed an emission rate, throughputrequirement, or other limit in this permit. No such activities are authorized until thepermittee receives written Department approval. Any such emissions shall be included inthe facilities total emissions and reported as such. The Department may grant such arequest, at its discretion under the following conditions:

a. Such a request does not violate a federal requirement;b. Such a request is temporary in nature;c. Such a request will not result in a condition of air pollution;d. The request contains such information necessary for the Department to evaluate

the request, including but not limited to, quantification of such emissions and thedate/time such emission will occur;

e. Such a request will result in increased emissions less than five tons of anyindividual criteria pollutant, one ton of any single HAP and 2.5 tons of totalHAPs; and

f. The permittee maintains records of the dates and results of such temporaryemissions/testing.

[Regulation 18 §18.314(B), Regulation 19 §19.416(B), AC.A §8-4-203 as referenced by§8-4-304 and §8-4-311, and 40 CFR Part 52, Subpart E]

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21. The permittee may request in writing and at least 30 days in advance, an alternativeto the specified monitoring in this permit. No such alternatives are authorized until thepermittee receives written Department approva1. The Department may grant such arequest, at its discretion under the following conditions:

a. The request does not violate a federal requirement;b. The request provides an equivalent or greater degree of actual monitoring to the

current requirements; andc. Any such request, if approved, is incorporated in the next permit modification

application by the permittee.

[Regulation 18 §18.314(C), Regulation 19 §19.416(C), A.c.A. §8-4-203 as referenced by§8-4-304 and §8-4-311, and 40 CFR Part 52, Subpart E]

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CERTIFICATE OF SERVICE

,2013.

Tarco, Inc., One Information Way, Suite 225, Little Rock, AR, 72202, on this _

day of_----LA-4-pr; L

I, Pam Owen, hereby certify that a copy of this permit has been mailed by first class mail to

q+h

Pam Owen, AAII, Air Division

ADEQ · 02 - wetscrubbers #1 & #2 and SN-03through SN-06 - four naturalgas-fired0.25 MMBtuJhr...

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