ADEQ DRAFT MINOR SOURCE AIR PERMIT

Transcription

1 ADEQ DRAFT MINOR SOURCE AIR PERMIT Permit No. : 2318-AR-1 IS ISSUED TO: BlueOak Arkansas, LLC 1024 Olhendorf Road Osceola, AR Mississippi County AFIN: THIS PERMIT IS THE ABOVE REFERENCED PERMITTEE S AUTHORITY TO CONSTRUCT, MODIFY, OPERATE, AND/OR MAINTAIN THE EQUIPMENT AND/OR FACILITY IN THE MANNER AS SET FORTH IN THE DEPARTMENT S MINOR SOURCE AIR PERMIT AND THE APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THE PROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT (ARK. CODE ANN ET SEQ.) AND THE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Stuart Spencer Chief, Air Division Date

2 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: Table of Contents Section I: FACILITY INFORMATION... 4 Section II: INTRODUCTION... 5 Summary of Permit Activity... 5 Process Description... 5 Regulations... 7 Total Allowable Emissions... 7 Section III: PERMIT HISTORY... 9 Section IV: EMISSION UNIT INFORMATION SN-01 Conditions- WEEE Receiving SN-02/03 Conditions WEEE Handling & Shredding SN-11 Conditions Plasma Furnace with Afterburner and Lime Injection SN-13 Conditions Tapping & Casting SN-14 Conditions Emergency Generator SN-15 Conditions Plasmarok Handling Section V: INSIGNIFICANT ACTIVITIES Section VI: GENERAL CONDITIONS Appendix A: 40 CFR 60, Subpart IIII Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Appendix B: 40 CFR 63, Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 2

3 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: List of Acronyms and Abbreviations Ark. Code Ann. AFIN C.F.R. CO HAP lb/hr No. NOx PM PM 10 SO 2 Tpy UTM VOC Arkansas Code Annotated ADEQ Facility Identification Number Code of Federal Regulations Carbon Monoxide Hazardous Air Pollutant Pound Per Hour Number Nitrogen Oxide Particulate Matter Particulate Matter Smaller Than Ten Microns Sulfur Dioxide Tons Per Year Universal Transverse Mercator Volatile Organic Compound 3

4 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: Section I: FACILITY INFORMATION PERMITTEE: BlueOak Arkansas, LLC AFIN: PERMIT NUMBER: 2318-AR-1 FACILITY ADDRESS: MAILING ADDRESS: 1024 Olhendorf Road Osceola, AR Olhendork Road Osceola, AR COUNTY: CONTACT NAME: CONTACT POSITION: Mississippi County Mark Wester CAO & Manager TELEPHONE NUMBER: (706) REVIEWING ENGINEER: Kailin Schwan UTM North South (Y): Zone 16: m UTM East West (X): Zone 16: m 4

5 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: Section II: INTRODUCTION Summary of Permit Activity BlueOak Arkansas, LLC is located at 1024 Olhendorf Road, Osceola Arkansas. BlueOak Arkansas is an electronic circuit board recycling facility. The facility submitted a De Minimis modification to install an indoor ash storage silo (SN-18a); an indoor ash hopper (SN-18b); an indoor silica sand & main tap slag storage silo (SN-19a); an indoor silica sand & main tap slag storage hopper (SN-19b); a thermal reduction unit (SN-20); a ball mill (SN-21); an induction furnace (SN-22); a Tundish preheater/ granulator (SN-23); a slag overflow preheater (SN-24); and two crucible re-melt furnaces (SN-25 & SN-26). This modification also addresses the installation and operation of up to four (4) 2,000 cubic feet per minute Torit dust collectors inside the main production building replacing the initially permitted control device (SN-02/03). Additionally, the facility has requested the replacement of fabric filter baghouse (SN-11) with high temperature ceramic filter. Additional changes to SN-11include the addition of a cyclone after the afterburner, redesign of internal natural gas burners that will result in a change in emissions, and an addition of a urea injection system to assist in the reduction of NO x emissions from the plasma furnace. Lastly, the facility has requested the replacement of a 250kW emergency engine with a 750 kw diesel-fired emergency engine (SN-14), replacement of a 1.0 MMBTU/hr ladle pre-heater with a 0.7MMBTU/hr natural gas fired ladle pre-heater (SN-12), and a larger baghouse (SN-13) to collect and recover fugitive dust from equipment to be installed to support the laboratory testing, as well as operations associated with the primary process line. Total allowable emission changes are tpy PM, tpy PM 10, +0.7 tpy SO 2, tpy CO, +5.4 tpy NO x, tpy Lead, +1.0 tpy Hydrochloric Acid, tpy Hydrogen Cyanide, and tpy Formaldehyde. Process Description The electronic circuit board recycling facility, BlueOak Arkansas, LLC, is capable of recovering precious metals. The facility will use a Plasma Metal Recovery System (PMRS), to recover Precious Metals (PM) including gold (Au), silver (Ag) and Platinum Group Metals (PGM) from Waste Electrical and Electronic Equipment (WEEE). The WEEE material will be melted by a plasma furnace using a water-cooled cathodic plasma torch. The melted material will consist of an upper molten Plasmarok layer containing the oxides and a lower molten copper based metallic layer containing the vast majority of the precious metal material. Fluxing agents will be added as appropriate to ensure that the Plasmarok is molten at suitable furnace operating temperatures, typically 1300 C to 1600 C, and has a low viscosity for optimum mixing of the reactants in the Plasmarok and partitioning of the precious metal. The balance of the ingredients react to form droplets of iron or copper and bubbles of gaseous by-products; the copper percolates through the Plasmarok and gathers the precious metal into the collector metal layer, which accumulates at the base of the furnace, while the bubbles encourage localized mixing of reactants within the bath. The blend of raw materials is chosen to ensure sufficient iron or copper is present to give the required precious metal content in the collector metal. Technical precious metal recovery rates of > 98% precious metal are possible using this process. 5

6 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: The metal and Plasmarok tapped from the furnace at the lower tap hole are poured into a preheated ladle and then transferred onto a casting table as soon as possible after tapping. This ensures the Plasmarok and metal spread out into a thin sheet so that it can be broken up easily and segregated for further processing. The Plasmarok that exits the furnace with the collector metal, i.e. main tap Plasmarok, may be subjected to further crushing (and magnetic separation if using iron as the collector) to recover the entrapped pieces of collector metal for recycling to the plasma furnace. The cast and solidified collector are typically crushed, using the same product dressing equipment, to a powder prior to valuation and final refining. The following emission sources have been identified as being associated with the proposed precious metal recovery plant: SN-01 WEEE Receiving & Storage System SN-02 WEEE Handling System (Raw Material Hopper with Conveyor) controlled by CD-01 Material Handling Dust Collection System (Fabric Filter Baghouse) SN-03 WEEE Shredding System controlled by CD-01 Material Handling Dust Collection System (Fabric Filter Baghouse) SN-04 Shredded WEEE Storage SN-05 Shredded WEEE Transportation SN-06 - E-waste storage silo / storage container with top loading and bottom discharge into loss in weight feeder hopper via sealing SN-07 - E-waste storage hopper with top loading and bottom discharge incorporating weigh platform for loss in weight discharge onto feed SN-08 - Flux (CaO) storage silo with top loading and bottom discharge into loss in weight feeder hopper via sealing valve SN-09 - Flux (CaO) storage hopper with top loading and bottom discharge incorporating weigh platform for loss in weight discharge onto feed conveyor SN-10 Furnace Feed Station - Delivers feedstock from feed station into the plasma furnace SN-11 Plasma Furnace controlled by CD-02 - Plasma Furnace Dust Collection System (Ceramic Filter Baghouse), CD-04 - Plasma Furnace Off-Gas Abatement System (Off-Gas Afterburner/Hydrated Urea Injection System) and Hydrated Lime Injection System. SN-11A Natural gas fired burner (CD-04 Afterburner) SN MMBtu/hr natural gas fired ladle pre-heater SN-13 - Tapping & Casting Operations controlled by CD-03 - Product Handling Dust Collection System (Fabric Filter Baghouse) SN-14 One (1) Emergency Generator 750 HP (5.25 MMBtu/hr) SN-15 - Plasmarok Handling and Conveying SN-16 - In-Plant Paved Roads - Material Transport SN-17 Hydrated Lime Silo SN-18a Indoor Ash Storage Silo SN-18b Indoor Ash Hopper SN-19a Indoor Silica Sand & Main Tap Slag Storage Silo SN-19b Indoor Silica Sand & Main Tap Slag Storage Hopper SN-20 Thermal Reduction Unit 6

7 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: SN-21 Ball Mill SN-22 Induction Furnace SN-23 Tundish Preheater/ Granulator SN-24 Slag Overflow Preheater SN-25 Crucible Remelt Furnace #1 SN-26 Crucible Remelt Furnace #2 Regulations The following table contains the regulations applicable to this permit. Regulations Arkansas Air Pollution Control Code, Regulation 18, effective June 18, 2010 Regulations of the Arkansas Plan of Implementation for Air Pollution Control, Regulation 19, effective September 13, CFR Part 60, Subpart IIII- Standards of Performance for Stationary Compression Ignition Internal Combustion Engines 40 CFR Part 63, Subpart ZZZZ National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Total Allowable Emissions The following table is a summary of emissions from the facility. This table, in itself, is not an enforceable condition of the permit. TOTAL ALLOWABLE EMISSIONS Pollutant lb/hr Emission Rates tpy PM PM SO VOC CO NO x Lead (Pb)

8 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: TOTAL ALLOWABLE EMISSIONS Pollutant lb/hr Emission Rates tpy Total HAPs Dioxin/Furans 5.69E E-7 Hydrochloric Acid Hydrogen Sulfide Hydrogen Cyanide ,3-Butadiene Acrolein Formaldehyde POM H 2 SO

9 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: Section III: PERMIT HISTORY 2318-A This permit was the initial permit for the facility. Total allowable emissions were 14.7 tons per year (tpy) PM/PM 10, 1.7 tpy SO 2, 1.2 tpy VOC, 99.8 tpy CO, 18.4 tpy NO x, tpy Lead, and 5.6 tpy HAPs. 9

10 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: Section IV: EMISSION UNIT INFORMATION Specific Conditions 1. The permittee shall not exceed the emission rates set forth in the following table. [Reg et seq. and Ark. Code Ann as referenced by Ark. Code Ann and ] SN Description Pollutant lb/hr tpy 01 WEEE Receiving & PM Storage Pb WEEE Handling Baghouse CD-01 PM WEEE Shredding Pb Baghouse CD Shredded WEEE PM Storage Pb Shredded WEEE PM Transportation Pb WEEE Storage Silo PM Pb WEEE Storage PM Hopper Pb Flux Storage Silo PM Pb Flux Storage Hopper PM Pb Furnace Feed Station PM Pb Plasma Furnace with PM 10 SO afterburner, urea VOC injection, and ceramic CO filter CD-02 NO X Pb Ladle Preheater 13 Tapping & Casting Baghouse CD-03 PM 10 SO 2 VOC CO NO X Pb PM10 Pb

11 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: SN Description Pollutant lb/hr tpy Emergency Generator 750 HP (5.25 MMBtu/hr) Plamarok Handling & Conveying PM 10 SO 2 VOC CO NO X PM Lime Silo PM a Indoor Ash Storage Silo PM b Indoor Ash Hopper PM a Indoor Silica Sand & Main Tap Slag PM Storage Silo 19b Indoor Silica Sand & Main Tap Slag Storage Hopper PM Thermal Reduction Unit PM10 SO 2 VOC CO NO X Pb Ball Mill PM Induction Furnace PM Tundish Preheater/ Granulator Slag Overflow Preheater Crucible Remelt Furnace #1 PM10 SO 2 VOC CO NO X Pb PM10 SO 2 VOC CO NO X Pb PM10 SO 2 VOC CO

12 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: SN Description Pollutant lb/hr tpy 26 Crucible Remelt Furnace #2 NO X Pb PM10 SO 2 VOC CO NO X Pb The permittee shall not exceed the emission rates set forth in the following table. [Reg and Ark. Code Ann as referenced by Ark. Code Ann and ] SN Description Pollutant lb/hr tpy 01 WEEE Receiving & Storage PM WEEE Handling Baghouse CD WEEE Shredding Baghouse CD-01 PM Shredded WEEE Storage PM Shredded WEEE Transportation PM WEEE Storage Silo PM WEEE Storage Hopper PM Flux Storage Silo PM Flux Storage Hopper PM Furnace Feed Station PM Plasma Furnace with afterburner, urea injection, and ceramic filter CD Ladle Preheater PM Dioxin/Furans Hydrochloric Acid Hydrogen Sulfide Hydrogen Cyanide Formaldehyde POM Total HAPs PM Formaldehyde POM E E

13 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: SN Description Pollutant lb/hr tpy Tapping & Casting Baghouse CD-03 Emergency Generator 750 HP (5.25 MMBtu/hr) Plamarok Handling & Conveying Total HAPs PM PM 1,3-Butadiene Acrolein Formaldehyde POM H 2 SO 4 Total HAPs PM Lime Silo PM a Indoor Ash Storage Silo PM b Indoor Ash Hopper PM a Indoor Silica Sand & Main Tap Slag PM Storage Silo 19b Indoor Silica Sand & Main Tap Slag Storage Hopper PM Thermal Reduction Unit PM Formaldehyde Total HAPs Ball Mill PM Induction Furnace PM Tundish Preheater/ Granulator Slag Overflow Preheater Crucible Remelt Furnace #1 Crucible Remelt Furnace #2 PM Formaldehyde Total HAPs PM Formaldehyde Total HAPs PM Formaldehyde Total HAPs PM Formaldehyde Total HAPs

14 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. Compliance with this condition shall be demonstrated by natural gas only. [Ark. Code Ann as referenced by Ark. Code Ann and ] SN Limit Regulatory Citation 02& a/b 19a/b % Regulation The permittee shall not cause or permit the emission of air contaminants, including odors or water vapor and including an air contaminant whose emission is not otherwise prohibited by Regulation 18, if the emission of the air contaminant constitutes air pollution within the meaning of Ark. Code Ann [Reg and Ark. Code Ann as referenced by Ark. Code Ann and ] 5. The permittee shall not conduct operations in such a manner as to unnecessarily cause air contaminants and other pollutants to become airborne. [Reg and Ark. Code Ann as referenced by Ark. Code Ann and ] 6. The permittee shall demonstrate that the degree of accuracy of the calculations used to determine emissions is sufficient to prove that the major source thresholds have not been exceeded if the actual emissions are calculated at or above 95% of the major source thresholds (i.e. 95 tpy criteria pollutants, 9.5/23.75 tpy of individual/combined HAPs). [Reg and Ark. Code Ann as referenced by Ark. Code Ann and ] 7. The permittee shall only process Waste Electrical and Electronic Equipment (WEEE) (shredded circuit boards) as defined by Regulation 23, Section 261 (Hazardous Waste Management). Recycled shredded circuit boards are not defined as solid waste provided they are stored in containers sufficient to prevent a release to the environment prior to recovery and free of mercury switches, mercury relays and nickel-cadmium batteries and lithium batteries. The facility shall be engaged solely in the storage, processing, and resale or reuse of recovered materials and the owner or operator must be able to demonstrate that substantially all of the incoming material at the facility are sold, used, or reused within one year. [A.C.A as referenced by and ] 14

15 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: The permittee shall inspect and verify each shipment that any waste material to be processed qualifies as WEEE as per the above definition. [Regulation 19, and A.C.A as referenced by and ] 9. All material handling operations may only be accomplished by drop operation. No pneumatic conveying allowed. [Regulation and A.C.A as referenced by and ] SN-01 Conditions- WEEE Receiving 10. The permittee shall not exceed a throughput of 11,388 tons of WEEE Material at SN-01 per rolling 12 month period. [Regulation 19, and A.C.A as referenced by and ] 11. The permittee shall maintain monthly records to demonstrate compliance with Specific Condition #10. The permittee shall update these records by the fifteenth day of the month following the month to which the records pertain. The twelve month rolling totals and each individual month s data shall be maintained on-site and made available to Department personnel upon request. [Regulation 19, and A.C.A as referenced by and ] SN-02/03 Conditions WEEE Handling & Shredding 12. The permittee, as per manufacturer s performance warranty, shall keep the CD-01 baghouse for SN-02 & SN-03 in good working condition at all times and shall meet the conditions shown in the following table. The pressure drop across the filters shall be measured daily. The results shall be kept on site and be available to Department personnel upon request. [Regulation 19, and A.C.A as referenced by and ] SN Control Equipment Parameter Units Minimum Operating Limits Maximum Operating Limits 02/03 baghouse Pressure drop In. H 2 O The permittee shall perform an initial test of CD-01 for PM using Method 5. This test shall take place at least 30 days after startup and no more than 90 days after startup and in accordance with General Condition #7. Testing shall be conducted with SN-02 and SN- 03 operating each at least at 90% of its permitted capacity. Emission testing results shall be extrapolated to correlate with 100% of the permitted capacity to demonstrate compliance. Failure to test within this range shall limit the permittee to operating within 10% above the tested rate. The permittee shall measure the operation rate during the test and if testing is conducted below 90% of the permitted capacity, records shall be maintained at all times to demonstrate that the source does not exceed operation at 10% 15

16 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: above the tested rate. [Regulation and/or Regulation and A.C.A as referenced by and ] SN-11 Conditions Plasma Furnace with Afterburner and Lime Injection 14. The permittee shall not exceed a throughput of 10,249 tons of WEEE Material at SN-11 per rolling 12 month period. [Regulation 19, and A.C.A as referenced by and ] 15. The permittee shall maintain monthly records to demonstrate compliance with Specific Condition #14. The permittee shall update these records by the fifteenth day of the month following the month to which the records pertain. The twelve month rolling totals and each individual month s data shall be maintained on-site and made available to Department personnel upon request. [Regulation 19, and A.C.A as referenced by and ] 15. The permittee shall perform initial and every 5 years stack testing of SN-11 at the CD-02 ceramic filter for lead (Pb) emissions. The permittee shall measure lead emissions in accordance with General Provision #7 and EPA Reference Method 12 or other alternate method, provided the Department approves the alternate method prior to use. Testing shall be conducted with SN-11 operating at least at 90% of its permitted capacity and throughput of WEEE. Emission testing results shall be extrapolated to correlate with 100% of the permitted capacity to demonstrate compliance. Failure to test within this range shall limit the permittee to operating within 10% above the tested rate. The permittee shall measure the operation rate during the test and if testing is conducted below 90% of the permitted capacity, records shall be maintained at all times to demonstrate that the source does not exceed operation at 10% above the tested rate. [Regulation and A.C.A as referenced by and ] 16. The permittee shall install and maintain Continuous Emission Monitoring Systems (CEMS) to demonstrate compliance with the hourly and annual CO emission limits in Specific Condition #01. The CEM shall be installed at the outlet of CD-02. This CEM shall comply with the Air Division s Continuous Emission Monitoring Systems Conditions. Attached in Appendix C. This CEMS shall be installed and operating within 180 days of issuance of Permit #2318-A. [Regulation and A.C.A as referenced by and ] 17. The permittee shall perform initial and every 5 years stack testing of SN-11 for NOx emissions at the CD-02 ceramic filter. This test shall be conducted in accordance with General Condition 7 and EPA Method 7E for NOx. The permittee shall perform this test simultaneously with a test for CO, using Method 10, or in lieu of testing, a CEM for CO. Testing shall be conducted with SN-11 operating at least at 90% of its permitted capacity and throughput of WEEE. Emission testing results shall be extrapolated to correlate with 100% of the permitted capacity to demonstrate compliance. Failure to test within this range shall limit the permittee to operating within 10% above the tested rate. The 16

17 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: permittee shall measure the operation rate during the test and if testing is conducted below 90% of the permitted capacity, records shall be maintained at all times to demonstrate that the source does not exceed operation at 10% above the tested rate. [Regulation and A.C.A as referenced by and ] 18. The CD-02 ceramic filter for SN-11 shall be kept in good working condition at all times and shall meet the conditions shown in the following table. The pressure drop across the filters shall be measured daily. The results shall be kept on site and be available to Department personnel upon request. [Regulation 19, and A.C.A as referenced by and ] SN Control Equipment 11 Ceramic Filter Parameter Units Minimum Operating Limits Maximum Operating Limits Pressure drop In. H 2 O The permittee shall perform an initial test of CD-02 for PM using Method 5. This test shall take place at least 30 days after startup and no more than 90 days after startup and in accordance with General Condition #7. Testing shall be conducted with SN-11 operating at least at 90% of its permitted capacity and throughput of WEEE. Emission testing results shall be extrapolated to correlate with 100% of the permitted capacity to demonstrate compliance. Failure to test within this range shall limit the permittee to operating within 10% above the tested rate. The permittee shall measure the operation rate during the test and if testing is conducted below 90% of the permitted capacity, records shall be maintained at all times to demonstrate that the source does not exceed operation at 10% above the tested rate. [Regulation and/or Regulation and A.C.A as referenced by and ] 20. The permittee shall test for hazardous air pollutants, both those currently permitted and those that may be present using Method 320 exhausted from CD-02 during normal operation of SN-11. The facility is only permitted for the HAPs and NO x listed in Specific Condition #02. Testing shall be conducted with SN-11 and its associated control equipment operating at least at 90% of its permitted capacity and throughput of WEEE. Emission testing results shall be extrapolated to correlate with 100% of the permitted capacity to demonstrate compliance. Failure to test within this range shall limit the permittee to operating within 10% above the tested rate. The permittee shall measure the operation rate during the test and if testing is conducted below 90% of the permitted capacity, records shall be maintained at all times to demonstrate that the source does not exceed operation at 10% above the tested rate. [Regulation and A.C.A as referenced by and ] 21. The permittee must establish the minimum and maximum temperature profiles of the Plasma Furnace and Afterburner (SN-11) during CO testing or CEMS operation and Method 320 testing. The permittee must establish the hourly rolling average limit as the 17

18 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: average of the test run averages. [Regulation and A.C.A as referenced by and ] 22. The permittee shall continuously monitor, record, and maintain records of the temperature profiles that were established in Specific Condition #21 once the limits are established. The permittee shall update these records by the fifteenth day of the month following the month to which the records pertain. Each individual month s data shall be maintained on-site and made available to Department personnel upon request. [Regulation and A.C.A as referenced by and ] 23. The permittee shall continuously monitor the lime and urea injection rate during HAP and NO x testing as required by Specific Condition #20. The feed rate shall be monitored continuously. The permittee must establish limits for the lime and urea injection rate based on an hourly rolling average calculated as the average of the test run averages. [Regulation and A.C.A as referenced by and ] 24. The permittee shall monitor, record, and maintain records of the lime and urea injection rate that was established in Specific Condition #23 once the limits are established. The permittee shall update these records by the fifteenth day of the month following the month to which the records pertain. Each individual month s data shall be maintained on-site and made available to Department personnel upon request. [Regulation and A.C.A as referenced by and ] SN-13 Conditions Tapping & Casting 25. The permittee shall not exceed a throughput of 2,365 tons of molten metal alloy at SN-13 Tapping & Casting per rolling 12 month period. [Regulation 19, and A.C.A as referenced by and ] 26. The permittee shall maintain monthly records to demonstrate compliance with Specific Condition #25. The permittee shall update these records by the fifteenth day of the month following the month to which the records pertain. The twelve month rolling totals and each individual month s data shall be maintained on-site and made available to Department personnel upon request. [Regulation 19, and A.C.A as referenced by and ] 27. The permittee, as per manufacturer s performance warranty, shall keep the CD-03 baghouse for SN-13 in good working condition at all times and shall meet the conditions shown in the following table. The pressure drop across the filters shall be measured daily. The results shall be kept on site and be available to Department personnel upon request. [Regulation 19, and A.C.A as referenced by and ] SN Control Equipment Parameter Units Minimum Operating Limits Maximum Operating Limits 18

19 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: SN Control Equipment Parameter Units Minimum Operating Limits Maximum Operating Limits 13 baghouse Pressure drop In. H 2 O The permittee shall test SN-13 (CD-03) for PM using Method 5. This test shall take place at least 30 days after startup and no more than 90 days after startup and in accordance with General Condition #7. Testing shall be conducted with the source operating at least at 90% of its permitted capacity. Emission testing results shall be extrapolated to correlate with 100% of the permitted capacity to demonstrate compliance. Failure to test within this range shall limit the permittee to operating within 10% above the tested rate. The permittee shall measure the operation rate during the test and if testing is conducted below 90% of the permitted capacity, records shall be maintained at all times to demonstrate that the source does not exceed operation at 10% above the tested rate. [Regulation and/or Regulation and A.C.A as referenced by and ] SN-14 Conditions Emergency Generator 29. The permittee shall not operate the emergency generator SN-14 in excess of 100 total hours (emergency and non-emergency) per calendar year in order to demonstrate compliance with the annual emission rate limits. Emergency operation in excess of these hours may be allowable but shall be reported and will be evaluated in accordance with Reg and other applicable regulations. [Reg and Ark. Code Ann as referenced by Ark. Code Ann and ] 30. The permittee shall maintain monthly records to demonstrate compliance with Specific Condition #29. The permittee shall update these records by the fifteenth day of the month following the month to which the records pertain. The calendar year totals and each individual month s data shall be maintained on-site and made available to Department personnel upon request. [Reg and Ark. Code Ann as referenced by Ark. Code Ann and ] NESHAP Subpart ZZZZ & IIII Requirements SN Source SN-14 is subject to the provisions of 40 CFR Part 63, Subpart ZZZZ National Emissions Standards for Stationary Reciprocating Internal Combustion Engines. Compliance with Subpart ZZZZ shall be demonstrated through compliance with requirements of 40 CFR Part 60 Subpart IIII. [40 CFR , (a) and A.C.A as referenced by and ] 32. Source SN-14 is subject to the provisions of 40 CFR Part 60, Subpart IIII Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. The applicable provisions of this subpart include, but are not limited to, the items found in 19

20 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: Specific Conditions #33 through #65.[40 CFR , (c) (a) and A.C.A as referenced by and ] 33. Owners and operators of 2007 model year and later emergency stationary CI ICE with a displacement of less than 30 liters per cylinder that are not fire pump engines must comply with the emission standards for new nonroad CI engines in , for all pollutants, for the same model year and maximum engine power for their 2007 model year and later emergency stationary CI ICE. [Regulation and 40 CFR Part 60, Subpart IIII (b)] 34. Owners and operators of emergency stationary CI engines with a displacement of greater than or equal to 30 liters per cylinder must meet the requirements in this section. a. For engines installed on or after January 1, 2012, limit the emissions of NO X in the stationary CI internal combustion engine exhaust to the following: i g/kw-hr (10.7 g/hp-hr) when maximum engine speed is less than 130 rpm; ii. 44 n 0.23 g/kw-hr (33 n 0.23 g/hp-hr) when maximum engine speed is greater than or equal to 130 but less than 2,000 rpm and where n is maximum engine speed; and iii. 7.7 g/kw-hr (5.7 g/hp-hr) when maximum engine speed is greater than or equal to 2,000 rpm. b. Limit the emissions of PM in the stationary CI internal combustion engine exhaust to 0.40 g/kw-hr (0.30 g/hp-hr). [Regulation and 40 CFR Part 60, Subpart IIII (d)(2-3)] 35. Owners and operators of emergency stationary CI ICE with a displacement of less than 30 liters per cylinder who conduct performance tests in-use must meet the NTE standards as indicated in [Regulation and 40 CFR Part 60, Subpart IIII (e)] 36. Owners and operators of any modified or reconstructed emergency stationary CI ICE subject to this subpart must meet the emission standards applicable to the model year, maximum engine power, and displacement of the modified or reconstructed CI ICE that are specified in paragraphs (a) through (e) of [Regulation and 40 CFR Part 60, Subpart IIII (f)] 37. Owners and operators of stationary CI ICE must operate and maintain stationary CI ICE that achieve the emission standards as required in and over the entire life of the engine. [Regulation and 40 CFR Part 60, Subpart IIII ] 38. Beginning October 1, 2007, owners and operators of stationary CI ICE subject to this subpart that use diesel fuel must use diesel fuel that meets the requirements of 40 CFR (a). [Regulation and 40 CFR Part 60, Subpart IIII (a)] 20

21 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: Beginning October 1, 2010, owners and operators of stationary CI ICE subject to this subpart with a displacement of less than 30 liters per cylinder that use diesel fuel must use diesel fuel that meets the requirements of 40 CFR (b) for nonroad diesel fuel, except that any existing diesel fuel purchased (or otherwise obtained) prior to October 1, 2010, may be used until depleted. [Regulation and 40 CFR Part 60, Subpart IIII (b)] 40. Beginning June 1, 2012, owners and operators of stationary CI ICE subject to this subpart with a displacement of greater than or equal to 30 liters per cylinder are no longer subject to the requirements of paragraph (a) of this section, and must use fuel that meets a maximum per-gallon sulfur content of 1,000 parts per million (ppm). [Regulation and 40 CFR Part 60, Subpart IIII (d)] 41. After December 31, 2008, owners and operators may not install stationary CI ICE (excluding fire pump engines) that do not meet the applicable requirements for 2007 model year engines. [Regulation and 40 CFR Part 60, Subpart IIII (a)] 42. In addition to the requirements specified in , , , and , it is prohibited to import stationary CI ICE with a displacement of less than 30 liters per cylinder that do not meet the applicable requirements specified in paragraphs (a) through (g) of after the dates specified in paragraphs (a) through (g) of [Regulation and 40 CFR Part 60, Subpart IIII (h)] 43. The requirements of this section do not apply to owners or operators of stationary CI ICE that have been modified, reconstructed, and do not apply to engines that were removed from one existing location and reinstalled at a new location. [Regulation and 40 CFR Part 60, Subpart IIII (i)] 44. If the permittee is an owner or operator, the permittee must meet the monitoring requirements of In addition, the permittee must also meet the monitoring requirements specified in a. If the permittee is an owner or operator of an emergency stationary CI internal combustion engine that does not meet the standards applicable to non-emergency engines, the permittee must install a non-resettable hour meter prior to startup of the engine. b. If the permittee is an owner or operator of a stationary CI internal combustion engine equipped with a diesel particulate filter to comply with the emission standards in , the diesel particulate filter must be installed with a backpressure monitor that notifies the owner or operator when the high backpressure limit of the engine is approached. [Regulation and 40 CFR Part 60, Subpart IIII (a-b)] 21

22 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: If the permittee is an owner or operator and must comply with the emission standards specified in this subpart, the permittee must do all of the following, except as permitted under paragraph (g) of : a. Operate and maintain the stationary CI internal combustion engine and control device according to the manufacturer's emission-related written instructions; b. Change only those emission-related settings that are permitted by the manufacturer; and c. Meet the requirements of 40 CFR parts 89, 94 and/or 1068, as they apply to the permittee. [Regulation and 40 CFR Part 60, Subpart IIII (a)(1-3)] 46. If the permittee is an owner or operator of a 2007 model year and later stationary CI internal combustion engine and must comply with the emission standards specified in (b) or (b), the permittee must comply by purchasing an engine certified to the emission standards in (b), or (b) or (c), as applicable, for the same model year and maximum engine power. The engine must be installed and configured according to the manufacturer's emission-related specifications, except as permitted in paragraph (g) of [Regulation and 40 CFR Part 60, Subpart IIII (c)] 47. If the permittee is an owner or operator and must comply with the emission standards specified in (c) or (d), the permittee must demonstrate compliance according to the requirements specified in paragraphs (d)(1) through (3) of a. Conducting an initial performance test to demonstrate initial compliance with the emission standards as specified in b. Establishing operating parameters to be monitored continuously to ensure the stationary internal combustion engine continues to meet the emission standards. The owner or operator must petition the Administrator for approval of operating parameters to be monitored continuously. The petition must include the information described in paragraphs (d)(2)(i) through (v) of this section. i. Identification of the specific parameters the permittee proposes to monitor continuously; ii. A discussion of the relationship between these parameters and NOX and PM emissions, identifying how the emissions of these pollutants change with changes in these parameters, and how limitations on these parameters will serve to limit NOX and PM emissions; iii. A discussion of how the permittee will establish the upper and/or lower values for these parameters which will establish the limits on these parameters in the operating limitations; iv. A discussion identifying the methods and the instruments the permittee will use to monitor these parameters, as well as the relative accuracy and precision of these methods and instruments; and 22

23 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: v. A discussion identifying the frequency and methods for recalibrating the instruments the permittee will use for monitoring these parameters. [Regulation and 40 CFR Part 60, Subpart IIII (d)(1-2)] 48. If the permittee is an owner or operator of a modified or reconstructed stationary CI internal combustion engine and must comply with the emission standards specified in (e) or (f), the permittee must demonstrate compliance according to one of the methods specified in paragraphs (e)(1) or (2) of a. Purchasing, or otherwise owning or operating, an engine certified to the emission standards in (e) or (f), as applicable. b. Conducting a performance test to demonstrate initial compliance with the emission standards according to the requirements specified in or , as appropriate. The test must be conducted within 60 days after the engine commences operation after the modification or reconstruction. [Regulation and 40 CFR Part 60, Subpart IIII (e)(1-2)] 49. If the permittee owns or operates an emergency stationary ICE, the permittee must operate the emergency stationary ICE according to the requirements in paragraphs (f)(1) through (3) of In order for the engine to be considered an emergency stationary ICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in paragraphs (f)(1) through (3) of , is prohibited. If the permittee does not operate the engine according to the requirements in paragraphs (f)(1) through (3) of , the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines. a. There is no time limit on the use of emergency stationary ICE in emergency situations. b. The permittee may operate the permittee s emergency stationary ICE for any combination of the purposes specified in paragraphs (f)(2)(i) through (iii) of for a maximum of 100 hours per calendar year. Any operation for nonemergency situations as allowed by paragraph (f)(3) of counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2). i. Emergency stationary ICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar year. 23

24 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: ii. Emergency stationary ICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see 60.17), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP iii. Emergency stationary ICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. c. Emergency stationary ICE may be operated for up to 50 hours per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in paragraph (f)(2) of Except as provided in paragraph (f)(3)(i) of , the 50 hours per calendar year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. i. The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: A. The engine is dispatched by the local balancing authority or local transmission and distribution system operator; B. The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region. C. The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines. D. The power is provided only to the facility itself or to support the local transmission and distribution system. E. The owner or operator identifies and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator. [Regulation and 40 CFR Part 60, Subpart IIII (f)(1-3)] 50. If the permittee does not install, configure, operate, and maintain the permittee s engine and control device according to the manufacturer's emission-related written instructions, 24

25 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: or the permittee changes emission-related settings in a way that is not permitted by the manufacturer, the permittee must demonstrate compliance as follows: a. If the permittee is an owner or operator of a stationary CI internal combustion engine greater than 500 HP, the permittee must keep a maintenance plan and records of conducted maintenance and must, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, the permittee must conduct an initial performance test to demonstrate compliance with the applicable emission standards within 1 year of startup, or within 1 year after an engine and control device is no longer installed, configured, operated, and maintained in accordance with the manufacturer's emission-related written instructions, or within 1 year after the permittee changes emission-related settings in a way that is not permitted by the manufacturer. The permittee must conduct subsequent performance testing every 8,760 hours of engine operation or 3 years, whichever comes first, thereafter to demonstrate compliance with the applicable emission standards. [Regulation and 40 CFR Part 60, Subpart IIII (g)(3)] 51. Owners and operators of stationary CI ICE with a displacement of less than 30 liters per cylinder who conduct performance tests pursuant to this subpart must do so according to paragraphs (a) through (e) of [Regulation and 40 CFR Part 60, Subpart IIII ] 52. The performance test must be conducted according to the in-use testing procedures in 40 CFR part 1039, subpart F, for stationary CI ICE with a displacement of less than 10 liters per cylinder, and according to 40 CFR part 1042, subpart F, for stationary CI ICE with a displacement of greater than or equal to 10 liters per cylinder and less than 30 liters per cylinder. [Regulation and 40 CFR Part 60, Subpart IIII (a)] 53. Exhaust emissions from stationary CI ICE that are complying with the emission standards for new CI engines in 40 CFR part 1039 must not exceed the not-to-exceed (NTE) standards for the same model year and maximum engine power as required in 40 CFR (e) and 40 CFR (g)(1), except as specified in 40 CFR (d). This requirement starts when NTE requirements take effect for nonroad diesel engines under 40 CFR part [Regulation and 40 CFR Part 60, Subpart IIII (b)] 54. Exhaust emissions from stationary CI ICE that are complying with the emission standards for new CI engines in 40 CFR or 40 CFR 94.8, as applicable, must not exceed the NTE numerical requirements, rounded to the same number of decimal places as the applicable standard in 40 CFR or 40 CFR 94.8, as applicable, determined from the following equation: Where: STD = The standard specified for that pollutant in 40 CFR or 40 CFR 94.8, as applicable. 25

26 BlueOak Arkansas, LLC Permit #: 2318-AR-1 AFIN: Alternatively, stationary CI ICE that are complying with the emission standards for new CI engines in 40 CFR or 40 CFR 94.8 may follow the testing procedures specified in of this subpart, as appropriate. [Regulation and 40 CFR Part 60, Subpart IIII (c)] 55. Exhaust emissions from stationary CI ICE that are complying with the emission standards for new CI engines in 40 CFR part 1042 must not exceed the NTE standards for the same model year and maximum engine power as required in 40 CFR (c). [Regulation and 40 CFR Part 60, Subpart IIII (e)] 56. Owners and operators of stationary CI ICE with a displacement of greater than or equal to 30 liters per cylinder must conduct performance tests according to paragraphs (a) through (f) of [Regulation and 40 CFR Part 60, Subpart IIII ] 57. Each performance test must be conducted according to the requirements in 60.8 and under the specific conditions that Subpart IIII specifies in table 7. The test must be conducted within 10 percent of 100 percent peak (or the highest achievable) load. [Regulation and 40 CFR Part 60, Subpart IIII (a)] Table 7 to Subpart IIII of Part 60 Requirements for Performance Tests for Stationary CI ICE With a Displacement of 30 Liters per Cylinder As stated in , the permittee must comply with the following requirements for performance tests for stationary CI ICE with a displacement of 30 liters per cylinder: Each 1. Stationary CI internal combustion engine with a displacement of 30 liters per cylinder Complying with the requirement to The permittee must a. Reduce i. Select the sampling NO X emissions by port location and 90 percent or more; number/location of traverse points at the inlet and outlet of the control device; Using According to the following requirements (a) For NO X, O 2, and moisture measurement, ducts 6 inches in diameter may be sampled at a single point located at the duct centroid and ducts >6 and 12 inches in diameter may be sampled at 3 traverse points located at 16.7, 50.0, and 83.3% of the measurement line ('3-point long line'). If the duct is >12 inches in diameter and the sampling port location meets the two and halfdiameter criterion of Section of Method 1 of 40 CFR part 60, appendix A-1, the duct may be sampled at '3- point long line'; otherwise, conduct the stratification testing and select sampling points according to Section 26