STATEMENT OF BASIS. For the issuance of Draft Air Permit # 2065-A AFIN: PERMITTING AUTHORITY:

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1 STATEMET OF BASIS For the issuance of Draft Air Permit # 2065-A AFI: PERMITTIG AUTHORITY: Arkansas Department of Environmental Quality 8001 ational Drive Little Rock, Arkansas APPLICAT: HilBilt Manufacturing Company, Inc Interstate 30 Benton, Arkansas PERMIT WRITER: Ann Sudmeyer 4. PROCESS DESCRIPTIO AD AICS CODE: AICS Description: Dump Body and Trailer Manufacturing AICS Code: SUBMITTALS: April 30, REVIEWER S OTES: HilBilt Manufacturing Company, Inc. located at Interstate 30, Benton, Arkansas is a manufacturer of dump bodies and trailers. This permitting action is necessary to formally permit operations at the facility. The total permitted emission rates at this facility include: 4.0 tons per year (tpy) PM/PM 10, 12.0 tpy VOC, 3.6 ty O X, 0.6 tpy 2- butoxyethylacetate, 0.7 tpy ethylbenzene, 0.01 tpy lead chromate, 0.26 tpy manganese, 0.01 tpy styrene, 0.98 tpy tetrachloroethylene, 2.3 tpy toluene, 3.5 tpy xylene, and 1.9 tpy acetone. The body filler lb/hr emission rate limit is based on the annual emissions being emitted in one 8-hour day.

2 AFI: Page 2 of COMPLIACE STATUS: The following summarizes the current compliance of the facility including active/pending enforcement actions and recent compliance activities and issues. HilBilt is currently operating under Consent Administrative Order LIS This CAO was issued for operating without a permit. 8. APPLICABLE REGULATIOS: PSD Applicability Did the facility undergo PSD review in this permit (i.e., BACT, Modeling, etc.)? Has the facility undergone PSD review in the past? Is the facility categorized as a major source for PSD? 100 tpy and on the list of 28? 250 tpy all other? PSD etting Was netting performed to avoid PSD review in this permit? Source and Specific Regulatory Applicability Source /A Regulation (SPS, ESHAP or PSD) 9. EMISSIO CHAGES: The following table summarizes plantwide emission changes associated with this permitting action. Plantwide Permitted Emissions (tpy) Permit # /A Permit #2065-A Change PM PM SO VOC CO O x

3 AFI: Page 3 of 10 Plantwide Permitted Emissions (tpy) Permit # /A Permit #2065-A Change 2-butoxyethylacetate Ethyl benzene Lead Chromate Manganese Styrene Tetrachloroethylene Toluene Xylene Acetone MODELIG: Criteria s Examination of the source type, location, plot plan, land use, emission parameters, and other available information indicate that modeling is not warranted at this time. All criteria pollutants are less than 100 tpy. on-criteria s: 1 st Tier Screening (PAER) Estimated hourly emissions from the following sources were compared to the Presumptively Acceptable Emission Rate (PAER) for each compound. The Department has deemed the PAER to be the product, in lb/hr, of 0.11 and the Threshold Limit Value (mg/m 3 ), as listed by the American Conference of Governmental Industrial Hygienists (ACGIH). TLV (mg/m 3 ) PAER (lb/hr) = 0.11 TLV Proposed lb/hr 2-butoxyethylacetate Y Ethyl benzene Y Lead Chromate 0.05* Manganese Pass?

4 AFI: Page 4 of 10 TLV (mg/m 3 ) PAER (lb/hr) = 0.11 TLV Proposed lb/hr Styrene Y Tetrachloroethylene Y Toluene Y Xylene Y Acetone Y *TLV for water-soluble Cr VI compounds. 2 nd Tier Screening (PAIL) Pass? ISCST3 air dispersion modeling was performed on the estimated hourly emissions from the following sources, in order to predict ambient concentrations beyond the property boundary. The Presumptively Acceptable Impact Level (PAIL) for each compound has been deemed by the Department to be one one-hundredth of the Threshold Limit Value as listed by the ACGIH. PAIL (g/m 3 ) = 1/100 of Threshold Limit Value Modeled Concentration (g/m 3 ) Pass? Manganese Y Lead Chromate Y Other Modeling: Odor: Odor modeling for sources emitting styrene. H 2 S Modeling: /A Threshold value 1-hour average Modeled Concentration (g/m 3 ) Pass? Styrene 1361 µg/m Y A.C.A requires hydrogen sulfide emissions to meet specific ambient standards. Many sources are exempt from this regulation, refer to the Arkansas Code for details. Is the facility exempt from the H 2 S Standards If exempt, explain: Y/

5 AFI: Page 5 of 10 H 2 S Threshold value 20 parts per billion (5-minute average*) 80 parts per billion (8-hour average) residential area 100 parts per billion (8-hour average) nonresidential area Modeled Concentration (ppb) Pass? *To determine the 5-minute average use the following equation Cp = Cm (t m /t p ) 0.2 where Cp = 5-minute average concentration Cm = 1-hour average concentration t m = 60 minutes t p = 5 minutes 11. CALCULATIOS: S Source (AP-42, testing, etc.) AP and Emission of Fume, itrogen Oxides and oise in Plasma Cutting of Stainless and Mild Steel South Coast Air Quality Management District Permit Processing Handbook, Section 2, Unconfined Abrasive Blasting, (lb/ton, lb/hr, etc.) Welding: 5.2 lb PM 10 /1000 lb lb Cr/1000 lb lb Co/1000 lb lb Mn/1000 lb lb i/1000 lb Plasma Cutting: 3.1 L Ox/min 4.0 g fume/min 10% of fume is Mn /A Efficiency /A 20 lb PM 10 /ton abrasive Booth 90% Comments Hourly welding emission rates based on annual emission rate emitted in one month. Annual emission rate based on 50,000 lb weld wire/yr. Hourly based on 812 lb grit/hr. Annual based on 1,300 tons grit/yr. Emission factor

6 AFI: Page 6 of 10 S 03 Source (AP-42, testing, etc.) (lb/ton, lb/hr, etc.) Efficiency Comments 8/89 accepted since AP- 42 gives 27 lb PM/1,000 lb and states that total PM from grit blasting is 24% of total PM from sand blasting. Material Balance, MSDS 5.41 lb VOC/gal 2.31 lb tetrachloroethylene/gal Primer/Sealer: 2.97 lb VOC/gal lb cobalt/gal 0.43 lb acetone/gal /A /A Hourly based on 2.0 gal/hr. Annual based on 840 gal/yr. Material Balance, MSDS Reducer for Primer/Sealer: 6.59 lb acetone/gal Paint: 5.7 lb VOC/gal 0.48 lb 2-butoxyethyl acetate/gal 0.67 lb ethyl benzene/gal 1.43 lb lead chromate/gal 0.95 lb nickel antimony titanate/gal 1.24 lb toluene/gal 3.80 lb xylene/gal Reducer for Paint: 5.71 lb VOC/gal 0.21 lb 2-butoxyethyl acetate/gal 0.07 lb ethyl benzene/gal 2.78 lb toluene/gal 0.41 lb xylene/gal 1.02 lb acetone/gal Fiberglass filters 99.3% Hourly emissions based on 5.2 gal/hr application rate and mixing rates. Hourly body filler emissions based on annual emitted in one 8-hour day. Annual based on 1,272 gal primersealer/yr; 318 gal primer-sealer reducer/yr; 1,740 gal paint/yr; 871 gal paint reducer/yr; 218 gal hardener/yr; and 6 gal/yr. Hardener: 1.39 lb VOC/gal Body Filler: 9.6 lb VOC/gal

7 AFI: Page 7 of 10 S Source (AP-42, testing, etc.) (lb/ton, lb/hr, etc.) 1.92 lb styrene/gal Efficiency Comments 12. TESTIG REQUIREMETS: The permit requires testing of the following sources. S s Test Method Test Interval Justification 13. MOITORIG OR CEMS /A The permittee must monitor the following parameters with CEMS or other monitoring equipment (temperature, pressure differential, etc.) S Parameter or to be Monitored Method (CEM, Pressure Gauge, etc.) Frequency Report (Y/) /A 14. RECORD KEEPIG REQUIREMETS: The following are items (such as throughput, fuel usage, VOC content, etc.) that must be tracked and recorded. S Recorded Item Permit Limit Frequency Report (Y/) 01 Welding Wire Usage 50,000 lb/yr Monthly 02 Grit Usage 1,300 tons/yr Monthly MSDS for VOC Content MSDS for tetrachloroethylene Content 5.41 lb/gal As eeded 2.31 lb/gal As eeded 03 Degreaser Usage 840 gal/yr Monthly MSDS for VOC Content Primer/Sealer: 2.97 lb/gal Paint: As eeded

8 AFI: Page 8 of 10 S Recorded Item Permit Limit Frequency Report (Y/) 5.7 lb/gal Reducer for Paint: 5.71 lb/gal Hardener: 1.39 lb/gal Body Filler: 9.6 lb VOC/gal Primer/Sealer: lb cobalt/gal 0.43 lb acetone/gal Reducer for Primer/Sealer: 6.59 lb acetone/gal MSDS for Content Paint: 0.48 lb 2-butoxyethyl acetate/gal 0.67 lb ethyl benzene/gal 1.43 lb lead chromate/gal 0.95 lb nickel antimony titanate/gal 1.24 lb toluene/gal 3.80 lb xylene/gal As eeded Reducer for Paint: 0.21 lb 2-butoxyethyl acetate/gal 0.07 lb ethyl benzene/gal 2.78 lb toluene/gal 0.41 lb xylene/gal 1.02 lb acetone/gal Primer/Sealer Body Filler: 1.92 lb styrene/gal 1,272 gal/yr Monthly

9 AFI: Page 9 of 10 S Recorded Item Permit Limit Frequency Report (Y/) 15. OPACITY: Reducer for Primer/Sealer Paint Reducer for Paint Hardener for Paint Body Filler 318 gal/yr 1,740 gal/yr 871 gal/yr 218 gal/yr 6 gal/yr Monthly Monthly Monthly Monthly Monthly S Opacity Justification for limit Compliance Mechanism 01 5% Dept. Guidance % Dept. Guidance --- 5% Dept. Guidance DELETED CODITIOS: Former SC Justification for removal /A 17. VOIDED, SUPERCEDED, OR SUBSUMED PERMITS: List all active permits voided/superceded/subsumed by the issuance of this permit. Permit # /A

10 AFI: Page 10 of COCURRECE BY: The following supervisor concurs with the permitting decision. Phillip Murphy, P.E.

STATEMENT OF BASIS. for the issuance of Draft Air Permit # 617-AOP-R2

STATEMENT OF BASIS. for the issuance of Draft Air Permit # 617-AOP-R2 1. PERMITTING AUTHORITY: STATEMENT OF BASIS for the issuance of Draft Air Permit # 617-AOP-R2 Arkansas Department of Environmental Quality 8001 National Drive Post Office Box 8913 Little Rock, Arkansas