ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY

Transcription

1 ADEQ ARK A N S A S Department of Environmental Qualily MAR Benny Bishop, Chief Operating Officer Peco Foods, Inc. P. O. Box 1760 Tuscaloosa, AL Dear Mr. Bishop: The enclosed Permit No A is your authority to construct, operate, and maintain the equipment and/or control apparatus as set forth in your application initially received on 7/28/2016. After considering the facts and requirements of A.C.A et seq. as referenced by , and implementing regulations, I have determined that Permit No A for the construction and operation of equipment at Peco Foods, Inc. shall be issued and effective on the date specified in the permit, unless a Commission review has been properly requested under Arkansas Department of Pollution Control & Ecology Commission's Administrative Procedures, Regulation 8, within thirty (30) days after service ofthis decision. The applicant or permittee and any other person submitting publi c comments on the record may request an adjudicatory hearing and Commission review of the final permitting decisions as provided under Chapter Six of Regulation No.8, Administrative Procedures, Arkansas Pollution Control and Ecology Commission. Such a request shall be in the form and manner required by Regulation 8.603, including filing a written Request for Hearing with the APC&E Commission Secretary at 101 E. Capitol Ave., Suite 205, Little Rock, Arkansas Ifyou have any questions about filing the request, please call the Commission at Stuart Spencer Associate Director, Office of Air Quality Enclosure: Final Permit ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE / NORTH UTILE ROCK / ARKANSAS / TELEPHONE / FAX s

2 ADEQ MINOR SOURCE "AIR PERMIT Permit No.: 2332-A IS ISSUED TO: Peco Foods, Inc Highway 67 South Pocahontas, AR Randolph 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: <it Stuart Spencer Associate Director, Office of Air Quality Date MAR

3 Peco Foods, Inc. Permit #: 2332-A AFIN: Table of Contents Section I: FACILITY INFORMATION... 4 Section II: INTRODUCTION... 5 Summary of Permit Activity... 5 Process Description... 5 Regulations... 8 Total Allowable Emissions... 8 Section III: PERMIT HISTORY Section IV: EMISSION UNIT INFORMATION NSPS Subpart Dc Conditions NSPS Subpart IIII / NESHAP Subpart ZZZZ Conditions NSPS Subpart JJJJ / NESHAP Subpart ZZZZ Conditions NESHAP Subpart JJJJJJ Conditions Section V: INSIGNIFICANT ACTIVITIES Section VI: GENERAL CONDITIONS Appendix A - 40 C.F.R. 60 Subpart Dc Appendix B - 40 C.F.R. 63 Subpart JJJJJJ Appendix C - 40 C.F.R. 60 Subpart IIII Appendix D - 40 C.F.R. 63 Subpart ZZZZ Appendix E - 40 C.F.R. 60 Subpart JJJJ 2

4 Peco Foods, Inc. Permit #: 2332-A AFIN: List of Acronyms and Abbreviations Ark. Code Ann. AFIN C.F.R. CO HAP lb/hr No. NO x 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

5 Peco Foods, Inc. Permit #: 2332-A AFIN: Section I: FACILITY INFORMATION PERMITTEE: Peco Foods, Inc. AFIN: PERMIT NUMBER: 2332-A FACILITY ADDRESS: 4114 Highway 67 South Pocahontas, AR MAILING ADDRESS: P. O. Box 1760 Tuscaloosa, AL COUNTY: CONTACT NAME: CONTACT POSITION: Randolph County Benny Bishop Chief Operating Officer TELEPHONE NUMBER: (205) REVIEWING ENGINEER: Joseph Hurt UTM North South (Y): Zone 15: m UTM East West (X): Zone 15: m 4

6 Peco Foods, Inc. Permit #: 2332-A AFIN: Section II: INTRODUCTION Summary of Permit Activity Peco Foods, Inc. operates a poultry processing plant and hatchery at 4114 Highway 67 South, Pocahontas, Arkansas. The facility requested to: 1. Reduce the facility's permit from Title V to minor source; 2. Install emergency generators (SN-13 through SN-18); 3. Install process water heaters (SN-19 and SN-20); 4. Install a thermal fluid heater (SN-21); 5. Install a set of indirect thermal fat fryers (SN-22); 6. Modify the process description to reflect these changes; 7. Change the permitted fuel types for Protein Plant Boiler #1 (SN-01) and Protein Plant Boiler #2 (SN-02); 8. Remove Specific Condition #6 from the permit, as Protein Plant Boiler #1 (SN-01) and Protein Plant Boiler #2 (SN-02) will not combust No.6 Fuel Oil or "On Spec" Used Oil; 9. Create an emissions bubble for nitrogen oxides (NOx) for several fuel combustion sources; and 10. Remove monthly and 12-month rolling total tracking for sulfur dioxide (SO 2 ), as this will no longer be needed due to the fuel change for the boilers noted above. A minor modification letter was also incorporated with this permitting action. The minor modification allowed the facility to install a natural gas-fired emergency generator (SN-23). All of the above requests have been incorporated with this permitting action. The total annual emissions are being set at 27.9 tpy of PM, 30.8 tpy of PM 10, 58.9 tpy of SO 2, 21.8 tpy of VOC, 57.3 tpy of CO, 99.9 tpy of NO x, tpy of NH 3, 3.00 tpy of H 2 S, 1.61 tpy of Single HAP, and 1.81 tpy of Total HAP. Process Description The permitted site contains several distinct operating plants: Peco Foods, Inc. (Peco) operates the poultry processing plant and hatchery. Darling Ingredients Inc. (Darling) operates a poultry byproducts processing plant. All of these individual plants are included in the permitted site. The emissions sources associated with each plant are discussed below. Peco Hatchery Plant The emissions units at the hatchery plant include three natural gas fueled boilers (SN-06, SN-07, and SN-08). There are also three diesel fueled emergency generators associated with this plant (SN-13, SN-14, and SN-15). 5

7 Peco Foods, Inc. Permit #: 2332-A AFIN: Peco Poultry Processing Plant The emissions units associated with the processing operations include two natural gas fueled water heaters (SN-19 and SN-20) that provide heated water, a natural gas fueled thermal fluid heater (SN-21) that provides heat to the hot oil fryers (SN-22) in which a portion of the produced poultry is cooked. Other emissions units include low sulfur diesel fueled stationary engines: fire pump (SN-11), and emergency generators (SN-16 through SN-18). There are also water storage tanks, cooking oil storage tanks, and used cooking oil tanks (insignificant activities) associated with the processing plant. Darling Protein Plant In partnership with Peco, Darling operates a protein conversion plant on the Peco facility site. The plant processes certain by-products including meat, bone, and offal by-products. Other byproducts (e.g. blood and feathers) are sent off-site to other Darling facilities for processing. The emissions units associated with the protein plant include two boilers (SN-01 and SN-02), which are permitted to combust natural gas, low sulfur diesel fuel, or processed fats. The plant operates two protein conversion processing lines, each consisting of raw material preparation, cooking, and separation equipment. Process heat for the protein plant is provided by SN-01 and SN-02. The poultry by-product raw materials are transferred from the primary Peco-operated processing plant to the Darling-operated plant by tractor-trailer. The materials are offloaded from the trailers into receiving pits located within the plant building confines. The materials are then moved by inclined screw conveyor from the pits to the processing lines. In each process line, the raw materials are first reduced in size by a raw material grinder to a size suitable for processing. The materials are then moved by hydraulic pressure conveyor from the grinder to the cooker (SN-04). The cooker functions to render the raw materials. The rendered materials exiting the cooker pass across a drainer screw to separate the majority of the free fat from the materials. The remaining materials are then moved by covered screw conveyor to presses that remove additional fat. The pressed material exiting the presses (known as crax by nature of its cakelike crunchy matrix) are then moved by covered screw conveyor to a finishing grinder for size reduction to a meal. The ground crax exiting the finishing grinder is then moved by covered screw conveyor to vibrating screens to size the finished protein meal product. Finished meal product that passes through the screens is moved by covered screw conveyor to storage silos. Ground meal that is too large to pass through the screens is diverted back to the inlet of the finishing grinder to be reground and then sent back across the screens again until all meal is reduced to the proper size and sent to storage. Stored finished meal product is moved from the storage silos (insignificant activity) by covered screw conveyor for sale load-out to tractortrailers. 6

8 Peco Foods, Inc. Permit #: 2332-A AFIN: Fat from the drainer screw and the presses is clarified in centrifuges by separating entrained solids from the liquid fat. The solids from the centrifuges are moved by covered screw conveyor back to the processing line, and the clarified fat is pumped to storage tanks (insignificant activity). Stored finished fat is pumped from the tankage for sale load-out to tractor-trailer tankers. Darling utilizes an efficient continuous cooking process; the line equipment is manufactured by specialized rendering equipment suppliers. The continuous cookers are so called because once filled and operating, raw materials are continuously fed into the cooker inlet while rendered materials are continuously removed from the cooker outlet. Steam generated by two boilers (SN-01 and SN-02) is used to indirectly heat and render the raw materials in the cookers. The water evaporated from the raw materials as steam in each cooker is condensed by a dedicated air-cooled condenser for each cooker. These condensers also, by way of condensing the water saturated vapor stream, induce a vapor collapse vacuum that will maintain a slight negative pressure in the cookers. Condenser condensate (known as stick water ), as well as miscellaneous other process waters (raw material trailer drainage, washdown, scrubber blowdown, boiler blowdown, boiler water softener regeneration blowdown, and so on) and captured storm water, is sent by pump and piping from the plant to the primary Peco facility s on-site wastewater treatment system (WWTS) for treatment and subsequent disposition. An induction fan pulls non-condensable high-intensity malodorous tail gas vapors from the cooker condensers through a wet venturi scrubber (one scrubber serves both lines). The venturi scrubber cools and condenses additional water and malodorous vapors; and removes particulate matter (PM) from the vapor stream by providing a restricted area throat section that will take the vapor stream from a laminar flow condition to a turbulent flow condition, and introducing a recirculating water spray into the turbulence. This water spray intermixing with the turbulent vapor flow is very effective in providing quenching and PM removal treatment to condition the vapor stream for the next step of treatment. The vapor stream exiting the venturi scrubber then flows to a regenerative thermal oxidizer (RTO) for high temperature oxidation destruction of all malodorous compounds. The RTO typically operates at a temperature well above the destruction threshold of all malodorous compounds. The treated high temperature stream from the RTO combustion area then flows to the RTO heat recovery area that recovers and stores the heat from the exiting air stream and later transfers the stored heat to the incoming vapor stream. The approximate 250 F exhaust stream is discharged to the atmosphere (SN-04A). This RTO process is highly efficient and effective in malodor destruction. During periods in which the RTO is undergoing maintenance or is otherwise out of service, a high-efficiency, contingency, back-up, stand-by, packed bed scrubber provides chemical oxidation destruction of malodorous compounds (SN-04B). The exhaust stream is vented through the room air scrubber exhaust point. A separate two stage, cross-flow, room air scrubber (insignificant activity) is mounted on the plant roof to capture and treat fugitive low-intensity malodors from within the plant. This scrubber induces a slight negative pressure on the building. Treatment is via conventional wet 7

9 Peco Foods, Inc. Permit #: 2332-A AFIN: scrubbing, with odor control chemistry used in the recirculating water. The chemistry includes ph control and oxidation or sequestration chemistry to thoroughly remove the low-intensity malodors from the air stream. Other emissions units at the protein plant include a diesel-fueled fire pump (SN-12), diesel fuel storage tanks (insignificant activity), water storage tanks (insignificant activity), meal storage bin vents (insignificant activity), fat storage tanks (insignificant activity) and meal loadout (insignificant activity). Regulations The following table contains the regulations applicable to this permit. Regulations Arkansas Air Pollution Control Code, Regulation 18, effective March 14, 2016 Regulations of the Arkansas Plan of Implementation for Air Pollution Control, Regulation 19, effective March 14, C.F.R. Part 60, Subpart Dc - Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units 40 C.F.R. Part 60, Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines 40 C.F.R. 60 Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines 40 C.F.R. Part 63, Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 40 C.F.R. Part 63, Subpart JJJJJJ - National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources 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 PM 2.5 See Note* 8

10 Peco Foods, Inc. Permit #: 2332-A AFIN: TOTAL ALLOWABLE EMISSIONS Pollutant lb/hr Emission Rates tpy SO VOC CO NO x Single HAP Total HAP Ammonia (NH 3 ) Hydrogen Sulfide (H 2 S) *PM 2.5 limits are source specific, if required. Not all sources have PM 2.5 limits. 9

11 Peco Foods, Inc. Permit #: 2332-A AFIN: Section III: PERMIT HISTORY Permit #2332-AOP-R0 was the initial Title V Operating Air Permit for this facility. Permit #2332-AOP-R1 was issued on October 19, This modification revised the plantwide emission tracking for SO 2 by assuming conversion of H 2 S from the Cooker Lines to SO 2 in the Regenerative Thermal Oxidizer (SN-04). This resulted in an increase in SO 2 emission limits at SN-04, which increased the plantwide total emissions to tpy. SN-01 and SN-02 allowable emissions were reduced to accommodate this increase. Hatchery boilers (SN-06, SN-07, SN-08) were moved to the Insignificant Activities List. This modification added a room air scrubber, Meal Storage (SN-09) and Meal Shipping (SN-10) to the Insignificant Activities List. Other typographical corrections were made also. The total permitted emission increases included 0.8 tpy of SO 2 and 0.92 tpy of hexane. The total permitted emission decreases included 24.1 tpy of PM, 19.4 tpy of PM 10, 0.6 tpy of VOC, 3.3 tpy of CO, 20.3 tpy of NO x, 0.01 tpy of formaldehyde, 3.0 tpy of H 2 S and 0.32 tpy of other HAPs. Permit 2332-AOP-R2 was issued on November 8, This permitting action: 1. Updated the process description; 2. Installed two 110 HP diesel-fired emergency fire suppression water pumps (SN-11 and SN-12); 3. Installed a contingency, back-up, stand-by packed bed scrubber for the Cooking Operation (SN-04) to be used when the RTO is down for maintenance, cleaning burnout, or failure; and 4. Removed the 2.5 MMBtu/hr, diesel-fueled emergency generator (SN-05) since it was never installed. The total annual permitted emission rate changes associated with this permitting action included: increases of 0.1 tons per year (tpy) PM, 1.5 tpy PM 10, 13.2 tpy VOC, and 3.0 tpy or less of any non-criteria air pollutant and decreases of 0.7 tpy NO X and tpy or less of any non-criteria air pollutant. 10

12 Peco Foods, Inc. Permit #: 2332-A 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 PM Protein Plant Boiler # 1 ( MMBtu/hr) Protein Plant Boiler # 2 ( MMBtu/hr) Protein Plant Cooking Operations Hatchery Boiler # 1 (3.2 MMBtu/hr) SO VOC CO NO x 10.0 * PM SO VOC CO NO x 10.0 * PM SO VOC CO NO x 0.4 * PM SO VOC CO NO x 0.4 * 11

13 Peco Foods, Inc. Permit #: 2332-A AFIN: SN Description Pollutant lb/hr tpy PM Hatchery Boiler # 2 (3.2 MMBtu/hr) Hatchery Boiler # 3 (3.2 MMBtu/hr) Processing Plant Fire Pump (0.77 MMBtu/hr) SN: PE405L Protein Plant Fire Pump (0.77 MMBtu/hr) SN: PE405L Hatchery Generator # 1 (16.4 MMBtu/hr) SN: SO VOC CO NO x 0.4 * PM SO VOC CO NO x 0.4 * PM SO VOC CO NO x PM SO VOC CO NO x PM SO VOC CO NO x

14 Peco Foods, Inc. Permit #: 2332-A AFIN: SN Description Pollutant lb/hr tpy PM Hatchery Generator # 2 (16.4 MMBtu/hr) SN: Hatchery Live Production Office Generator (1.4 MMBtu/hr) SN: J Processing Plant Generator (2.8 MMBtu/hr) SN: S9P00897 Water Treatment Plant Generator (2.8 MMBtu/hr) SN: S9P01200 Wastewater Treatment Plant Generator (2.1 MMBtu/hr) SN: SO VOC CO NO x PM SO VOC CO NO x PM SO VOC CO NO x PM SO VOC CO NO x PM SO VOC CO NO x

15 Peco Foods, Inc. Permit #: 2332-A AFIN: SN Description Pollutant lb/hr tpy PM * Processing Plant Process Water Heater # 1 (21.0 MMBtu/hr) Processing Plant Process Water Heater # 2 (21.0 MMBtu/hr) Processing Plant Thermal Fluid Heater (12.5 MMBtu/hr) Processing Plant Hot Oil Fryers (2 fryers with 4 stacks) RTO Emergency Generator (Natural Gas-Fired, 51 HP, MMBtu/hr) Annual Bubble for SN-01, SN-02, SN-04, SN-06, SN-07, SN-08, SN-19, SN-20, and SN-21 SO VOC CO NO x 2.1 * PM SO VOC CO NO x 2.1 * PM SO VOC CO NO x 1.5 * PM PM 10 SO 2 VOC CO NO X NO x

16 Peco Foods, Inc. Permit #: 2332-A AFIN: 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 Protein Plant Boiler # 1 ( MMBtu/hr) Protein Plant Boiler # 2 ( MMBtu/hr) Protein Plant Cooking Operations Hatchery Boiler # 1 (3.2 MMBtu/hr) Hatchery Boiler # 2 (3.2 MMBtu/hr) Hatchery Boiler # 3 (3.2 MMBtu/hr) Processing Plant Fire Pump (0.77 MMBtu/hr) SN: PE405L PM Single HAP Total HAP PM Single HAP Total HAP PM Single HAP Total HAP H 2 S NH PM Single HAP Total HAP PM Single HAP Total HAP PM Single HAP Total HAP PM Single HAP Total HAP

17 Peco Foods, Inc. Permit #: 2332-A AFIN: SN Description Pollutant lb/hr tpy Protein Plant Fire Pump (0.77 MMBtu/hr) SN: PE405L Hatchery Generator # 1 (16.4 MMBtu/hr) SN: Hatchery Generator # 2 (16.4 MMBtu/hr) SN: Hatchery Live Production Office Generator (1.4 MMBtu/hr) SN: J Processing Plant Generator (2.8 MMBtu/hr) SN: S9P00897 Water Treatment Plant Generator (2.8 MMBtu/hr) SN: S9P01200 Wastewater Treatment Plant Generator (2.1 MMBtu/hr) SN: Processing Plant Process Water Heater # 1 (21.0 MMBtu/hr) Processing Plant Process Water Heater # 2 (21.0 MMBtu/hr) PM Single HAP Total HAP PM Single HAP Total HAP PM Single HAP Total HAP PM Single HAP Total HAP PM Single HAP Total HAP PM Single HAP Total HAP PM Single HAP Total HAP PM Single HAP Total HAP PM Single HAP Total HAP

18 Peco Foods, Inc. Permit #: 2332-A AFIN: SN Description Pollutant lb/hr tpy Processing Plant Thermal Fluid Heater (12.5 MMBtu/hr) Processing Plant Hot Oil Fryers (2 fryers with 4 stacks) RTO Emergency Generator (Natural Gas-Fired, 51 HP, MMBtu/hr) PM Single HAP Total HAP PM PM Single HAP Total HAP 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 ] 4. 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 ] 5. Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. [Ark. Code Ann as referenced by Ark. Code Ann and ] SN Fuel Type Limit Regulatory Citation Natural Gas 5% Reg & 02 Low Sulfur Diesel 20% Reg Processed Fat 20% Reg , 06, 07, 08, 19, 20, 21, 22, & 23 Natural Gas 5% Reg , 12, 13, 14, 15, 16, 17, & 18 No. 2 Fuel Oil 20% Reg The permittee shall be limited to 82.1 tons of NO x at SN-01, SN-02, SN-04, SN-06, SN- 07, SN-08, SN-19, SN-20, and SN-21 per consecutive 12-month period. The permittee shall calculate and keep records of the monthly NO x emissions from SN-01, SN-02, SN- 04, SN-06, SN-07, SN-08, SN-19, SN-20, and SN-21 based on the fuel usage records and the following emission factors. The rolling 12-month total of NO x emissions shall not exceed the limit set in Specific Condition 1 for SN-01, SN-02, SN-04, SN-06, SN-07, SN-08, SN-19, SN-20, and SN-21. The permittee shall update these records by the last day of the month following the month to which the records pertain. The 12-month rolling totals and each individual month s data shall be maintained on-site, made available to 17

19 Peco Foods, Inc. Permit #: 2332-A AFIN: Department personnel upon request. [Reg et seq., 40 C.F.R. 52 Subpart E, Reg , and Ark. Code Ann as referenced by Ark. Code Ann and ] Source Description NO x Emission Factors SN-01 Protein plant boiler # 1 Natural Gas: 38 lb/mmscf SN-02 Protein plant boiler # 2 Low Sulfur Diesel: 20 lb/mgal Processed fat: 20 lb/mgal SN-04 Protein plant cooking operations (RTO Natural Gas: 100 lb/mmscf burner) SN-06 Hatchery boiler # 1 SN-07 Hatchery boiler # 2 SN-08 Hatchery boiler # 3 SN-19 Processing plant process water heater # 1 SN-20 Processing plant process water heater # 2 SN-21 Processing plant thermal fluid heater 7. The permittee shall test NO x emissions from Boiler 1 and Boiler 2 (SN-01 and SN-02) to demonstrate compliance with the processed fat emission factor of 20 lb NO x /Mgal. The initial test shall take place no later than 180 days after SN-01 and SN-02 begins combusting processed fat, or within 180 days of issuance of Air Permit 2332-A, whichever is later. The test for NO x will take place only in years in which Processed fat is being combusted. Testing shall be conducted while burning Processed fat. Testing shall be performed in accordance with Plantwide Condition 3. The permittee will perform the NO x test using EPA Reference Method 7E. After the initial testing is completed, the permittee shall test one of the two boilers (SN-01 or SN-02) once every 60 months. If the unit is not combusting processed fats on the required date for the performance test, the performance test must be conducted within 30 days of next beginning to combust processed fats. Unless otherwise approved by the Department, 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. Extrapolation shall be the standard linear extrapolation or other method of extrapolation as approved by the Department prior to testing. [Reg and 40 C.F.R. 52 Subpart E] 8. The emissions from SN-04 shall be controlled with the RTO or the packed bed scrubber with room air scrubber any time SN-04 is in operation. [Reg and Ark. Code Ann as referenced by Ark. Code Ann and ] 9. The permittee shall not exceed a throughput of 73,584 tons of finished meal product at SN-04 per rolling 12-month period. [Reg and Ark. Code Ann as referenced by Ark. Code Ann and ] 18

20 Peco Foods, Inc. Permit #: 2332-A AFIN: The permittee shall maintain monthly records to demonstrate compliance with Specific Condition 9. The permittee shall update these records by the last day of the month following the month to which the records pertain. The 12-month rolling 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 ] 11. The permittee shall operate the RTO at a minimum combustion zone temperature of 1,300 F. The permittee shall keep daily records of the regenerative thermal oxidizer combustion zone temperature. A record of each day s temperature shall be recorded in a log book for each day the source is operated. As an alternative, the permittee may operate constant paper graph temperature recorders or other types of digital information gathering/recording systems that would meet the requirements of obtaining a daily check on combustion zone temperature. The past 12 month s data shall be kept. The permittee shall keep the records on-site, and make the records available to Department personnel upon request. [Reg ; Ark. Code Ann as referenced by Ark. Code Ann and ; and 40 C.F.R. 70.6] 12. The permittee shall annually verify the accuracy of the thermocouple used to determine the RTO temperature as required in Specific Condition 11. This annual verification shall use a second, or redundant, thermocouple probe inserted into the incinerator chamber with a hand held meter. The annual verification shall be within +/- 30 F. If the annual verification is outside the acceptable range, then the permittee shall replace the thermocouple required in Specific Condition 11 within in 30 days, and conduct another verification no later than 15 days after the thermocouple is replaced. The permittee will maintain records of all verifications, update the records within 15 days following a verification, keep the records onsite, and make the records available to Department personnel upon request [Reg ; Ark. Code Ann as referenced by Ark. Code Ann and ; and 40 C.F.R. 70.6] 13. The permittee shall operate the Cooking Operations Backup Scrubber when the RTO is not in operation and the cooking operation is operating. The conditions outlined in the following table ensure proper scrubber operation and efficiency. [Reg and A.C.A as referenced by ] SN Description Parameter Units Operation Limits 04 Cooking Operations Scrubber Liquid Flow Rate gal/min 100 (minimum) Backup Scrubber Gas Pressure Drop in. H 2 O 0.2 (minimum) ph The permittee shall maintain daily records of the recirculation rate, ph, and the pressure drop which demonstrates compliance with Specific Condition 13. The permittee shall 19

21 Peco Foods, Inc. Permit #: 2332-A AFIN: maintain the records of the dates and times of operation of the packed bed scrubber. The permittee will update the records by the last day of the month following the month to which the records pertain. The permittee will keep the records onsite, and make the records available to Department personnel upon request. [Reg and A.C.A as referenced by and ] 15. The permittee shall not operate the Processing Plant Fire Pump engine (SN-11) and the Protein Plant Fire Pump engine (SN-12) in excess of 100 total hours, each, (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 ] 16. The permittee shall maintain monthly records to demonstrate compliance with Specific Condition 15. The permittee shall update these records by the last 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 ] 17. The permittee shall not operate the Hatchery Generator # 1 (SN-13), the Hatchery Generator # 2 (SN-14), the Hatchery Live Production Office Generator (SN-15), the Processing Plant Generator (SN-16), the Water Treatment Plant Generator (SN-17), the Wastewater Treatment Plant Generator (SN-18), and the RTO Emergency Generator (SN-23) in excess of 500 total hours, each, (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 ] 18. The permittee shall maintain monthly records to demonstrate compliance with Specific Condition 17. The permittee shall update these records by the last 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 ] 19. The permittee shall use only natural gas to fuel the RTO Emergency Generator (SN-23). [Reg and Ark. Code Ann as referenced by Ark. Code Ann and ] 20

22 Peco Foods, Inc. Permit #: 2332-A AFIN: NSPS Subpart Dc Conditions 20. SN-01, SN-02, SN-19, SN-20, and SN-21 are subject to 40 C.F.R. Part 60, Subpart Dc - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. The requirements of Subpart Dc include, but are not limited to, Specific Conditions 21 through 27. [Reg and 40 C.F.R c] 21. The permittee shall not combust oil that contains greater than 0.5 weight percent sulfur at SN-01, SN-02, SN-19, SN-20, and SN-21. Compliance with the fuel oil sulfur limits may be determined based on a certification from the fuel supplier as described in Specific Condition 22, as applicable. This limit applies at all times, including periods of startup, shutdown, and malfunction. [Reg , 40 C.F.R c(d), 60.42c(h), and 60.44c(h)] 22. Fuel supplier certification shall include the following information: [Reg and 40 C.F.R c(f)] a. For distillate oil: i. The name of the oil supplier; ii. A statement from the oil supplier that the oil complies with the specifications under the definition of distillate oil in 60.41c; and iii. The sulfur content or maximum sulfur content of the oil. 23. The permittee shall submit notification of the date of construction or reconstruction and actual startup, as provided by 40 C.F.R This notification shall include: [Reg and 40 C.F.R c(a)] a. The design heat input capacity of the affected facility and identification of fuels to be combusted in the affected facility. b. If applicable, a copy of any federally enforceable requirement that limits the annual capacity factor for any fuel or mixture of fuels under 60.42c, or 60.43c. c. The annual capacity factor at which the owner or operator anticipates operating the affected facility based on all fuels fired and based on each individual fuel fired. 24. The permittee shall keep the following records and submit reports to the Department as applicable: [Reg and 40 C.F.R c(e)] a. Calendar dates covered in the reporting period. b. Each 30-day average SO 2 emission rate (ng/j or lb/mmbtu), or 30-day average sulfur content (weight percent), calculated during the reporting period, ending with the last 30-day period; reasons for any noncompliance with the emission standards; and a description of corrective actions taken. 21

23 Peco Foods, Inc. Permit #: 2332-A AFIN: c. Each 30-day average percent of potential SO 2 emission rate calculated during the reporting period, ending with the last 30-day period; reasons for any noncompliance with the emission standards; and a description of the corrective actions taken. d. Identification of any steam generating unit operating days for which SO 2 or diluent (O 2 or CO 2 ) data have not been obtained by an approved method for at least 75 percent of the operating hours; justification for not obtaining sufficient data; and a description of corrective actions taken. e. Identification of any times when emissions data have been excluded from the calculation of average emission rates; justification for excluding data; and a description of corrective actions taken if data have been excluded for periods other than those during which coal or oil were not combusted in the steam generating unit. f. Identification of the F factor used in calculations, method of determination, and type of fuel combusted. g. If fuel supplier certification is used to demonstrate compliance, records of fuel supplier certification as described under Specific Condition 22, as applicable. In addition to records of fuel supplier certifications, the report shall include a certified statement signed by the permittee that the records of fuel supplier certifications submitted represent all of the fuel combusted during the reporting period. 25. The permittee shall record the amount of each fuel combusted during each operating day. As an alternative to this requirement, if the permittee combusts only natural gas, wood, fuels using fuel certification in Specific Condition 22 to demonstrate compliance with the SO 2 standard, fuels not subject to an emissions standard (excluding opacity), or a mixture of these fuels, the permittee may elect to record and maintain records of the amount of each fuel combusted during each calendar month. [Reg and 40 C.F.R c(g)] 26. The permittee shall maintain all records required under Subpart Dc for a period of two years following the date of such record. [Reg and 40 C.F.R c(i)] 27. The reporting period for the reports required under this subpart is each six-month period. All reports shall be submitted to the Department and shall be postmarked by the 30 th day following the end of the reporting period. [Reg and 40 C.F.R c(j)] 22

24 Peco Foods, Inc. Permit #: 2332-A AFIN: NSPS Subpart IIII / NESHAP Subpart ZZZZ Conditions 28. The emergency engines (SN-11 and SN-12) are subject to provisions of 40 C.F.R. 63 Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. SN-11 and SN-12 shall meet the requirements of Subpart ZZZZ by complying with the requirements of 40 C.F.R. 60 Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. The requirements of Subpart IIII include, but are not limited to, Specific Conditions 29 through 39. [Reg and 40 C.F.R and (c)(1)] 29. The permittee shall comply with the emission standards in table 4 to 40 C.F.R. 60 Subpart IIII, for all pollutants. [Reg , 40 C.F.R (c), and Table 4 to 40 C.F.R. 60 Subpart IIII] Maximum Engine Power 75 KW<130 (100 HP<175) Model NMHC + NO X CO PM Year(s) g/kw-hr (g/hp-hr) g/kw-hr (g/hp-hr) g/kw-hr (g/hp-hr) (3.0) 5.0 (3.7) 0.30 (0.22) 30. The permittee shall operate and maintain the stationary CI ICE that achieve the emission standards as required in 40 C.F.R over the entire life of the engine. [Reg and 40 C.F.R ] 31. The permittee must use diesel fuel that meets the requirements of 40 C.F.R (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. [Reg and 40 C.F.R (b)] a. A maximum sulfur content of 15 ppm; and b. A minimum cetane index of 40; or c. A maximum aromatic content of 35 volume percent. 32. The permittee must install non-resettable hour meters prior to startup of the engines. [Reg and 40 C.F.R (a)] 33. The permittee shall do all of the following, except as permitted under paragraph (g) of 40 C.F.R : [Reg and 40 C.F.R (a)] a. Operate and maintain the stationary CI internal combustion engines 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 23

25 Peco Foods, Inc. Permit #: 2332-A AFIN: c. Meet the requirements of 40 C.F.R. 89, 94 and/or 1068, as they apply to you. 34. The permittee shall comply by purchasing engines certified to the emission standards in (c), as applicable, for the same model year and maximum (or in the case of fire pumps, NFPA nameplate) engine power. The engines must be installed and configured according to the manufacturer s emission-related specifications, except as permitted in paragraph (g) of 40 C.F.R If the permittee conducts performance tests in-use, the permittee must meet the NTE standards as indicated in 40 C.F.R [Reg and 40 C.F.R (e) and (c)] 35. The permittee shall operate the emergency stationary ICE according to the requirements in paragraphs (f)(1) through (3) of 40 C.F.R In order for the engine to be considered an emergency stationary ICE under 40 C.F.R. 60 Subpart IIII, 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 40 C.F.R , is prohibited. If you do not operate the engine according to the requirements in paragraphs (f)(1) through (3) of 40 C.F.R , the engine will not be considered an emergency engine under 40 C.F.R. 60 Subpart IIII and must meet all requirements for non-emergency engines. [Reg and 40 C.F.R (f)] a. There is no time limit on the use of emergency stationary ICE in emergency situations. [Reg and 40 C.F.R (f)(1)] b. You may operate your emergency stationary ICE for any combination of the purposes specified in paragraphs (f)(2)(i) of 40 C.F.R for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by paragraph (f)(3) of 40 C.F.R counts as part of the 100 hours per calendar year allowed by 40 C.F.R (f)(2). [Reg and 40 C.F.R (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. [Reg and 40 C.F.R (f)(2)(i)] 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 nonemergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in 24

26 Peco Foods, Inc. Permit #: 2332-A AFIN: paragraph (f)(2) of 40 C.F.R Except as provided in paragraph (f)(3)(i) of 40 C.F.R , the 50 hours per calendar year for nonemergency 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. [Reg and 40 C.F.R (f)(3)] 36. If you do not install, configure, operate, and maintain your engines and control device according to the manufacturer s emission-related written instructions, or you change emission-related settings in a way that is not permitted by the manufacturer, you must demonstrate compliance as follows: [Reg and 40 C.F.R (g)] a. The permittee shall 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 you change emission-related settings in a way that is not permitted by the manufacturer. [Reg and 40 C.F.R (g)(2)] 37. If the permittee must conduct performance tests pursuant to 40 C.F.R. 60 Subpart IIII must do so according to paragraphs (a) through (e) of 40 C.F.R [Reg and 40 C.F.R ] 38. If the stationary CI internal combustion engine is an emergency stationary internal combustion engine, the owner or operator is not required to submit an initial notification. Starting with the model years in table 5 to 40 C.F.R. 60 Subpart IIII, if the emergency engine does not meet the standards applicable to non-emergency engines in the applicable model year, the owner or operator must keep records of the operation of the engine in emergency and non-emergency service that are recorded through the non-resettable hour meter. The owner must record the time of operation of the engine and the reason the engine was in operation during that time. [Reg , 40 C.F.R (b), and Table 5 to 40 C.F.R. 60 Subpart IIII] Engine Power Starting Model Year 56 KW<130 (75 HP<175) Table 8 to 40 C.F.R. 60 Subpart IIII shows which parts of the General Provisions in 60.1 through apply to you. [Reg and 40 C.F.R ] 25

27 Peco Foods, Inc. Permit #: 2332-A AFIN: The hatchery generators (SN-13, SN-14, and SN-15), the processing plant generator (SN- 16), the water treatment plant generator (SN-17), and the wastewater treatment plant generator (SN-18) are subject to provisions of 40 C.F.R. 63 Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. SN-13, SN-14, SN-15, SN-16, SN-17, and SN-18 shall meet the requirements of Subpart ZZZZ by complying with the requirements of 40 C.F.R. 60 Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. The requirements of Subpart IIII include, but are not limited to, Specific Conditions 30 through 36, 39, and 41. [Reg and 40 C.F.R and (c)(1)] 41. If the stationary CI internal combustion engine is an emergency stationary internal combustion engine, the owner or operator is not required to submit an initial notification. Starting with the model years in table 5 to 40 C.F.R. 60 Subpart IIII, if the emergency engine does not meet the standards applicable to non-emergency engines in the applicable model year, the owner or operator must keep records of the operation of the engine in emergency and non-emergency service that are recorded through the non-resettable hour meter. The owner must record the time of operation of the engine and the reason the engine was in operation during that time. [Reg , 40 C.F.R (b), and Table 5 to 40 C.F.R. 60 Subpart IIII] Engine Power Starting Model Year KW 130 (HP 175) 2011 NSPS Subpart JJJJ / NESHAP Subpart ZZZZ Conditions 42. The RTO emergency generator (SN-23) is subject to provisions of 40 C.F.R. 63 Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. SN-23 shall meet the requirements of Subpart ZZZZ by complying with the requirements of 40 C.F.R. 60 Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines. The requirements of Subpart JJJJ include, but are not limited to, Specific Conditions 43 through 51. [Reg and 40 C.F.R and (c)(1)] 43. Owners and operators of stationary SI ICE with a maximum engine power greater than 19 KW (25 HP) and less than 75 KW (100 HP) (except gasoline and rich burn engines that use LPG) must comply with the emission standards for field testing in 40 CFR (c) for their non-emergency stationary SI ICE and with the emission standards in Table 1 to 40 C.F.R. Part 60, Subpart JJJJ for their emergency stationary SI ICE. Owners and operators of stationary SI ICE with a maximum engine power greater than 19 KW (25 HP) and less than 75 KW (100 HP) manufactured prior to January 1, 2011, that were certified to the standards in Table 1 to 40 C.F.R. Part 60, Subpart JJJJ applicable to engines with a maximum engine power greater than or equal to 100 HP and less than

28 Peco Foods, Inc. Permit #: 2332-A AFIN: HP, may optionally choose to meet those standards. [Reg and 40 C.F.R (d)] Engine type and fuel Maximum engine power Manufacture date Emergency 25<HP<130 1/1/2009 Emission standards a g/hp-hr ppm vd at 15% O 2 NO X CO VOC c NO X CO VOC c b N/A N/A N/A N/A a Owners and operators of stationary non-certified SI engines may choose to comply with the emission standards in units of either g/hp-hr or ppm vd at 15 percent O 2. b The emission standards applicable to emergency engines between 25 HP and 130 HP are in terms of NO X + HC. c For purposes of 40 C.F.R. Part 60, Subpart JJJJ, when calculating emissions of volatile organic compounds, emissions of formaldehyde should not be included. 44. Owners and operators of stationary SI ICE must operate and maintain stationary SI ICE that achieve the emission standards as required in over the entire life of the engine. [Reg and 40 C.F.R ] 45. If you are an owner or operator of an emergency stationary SI internal combustion engine that is less than 130 HP, was built on or after July 1, 2008, and does not meet the standards applicable to non-emergency engines, you must install a non-resettable hour meter upon startup of your emergency engine. [Reg and 40 C.F.R (c)] 46. If you are an owner or operator of a stationary SI internal combustion engine and must comply with the emission standards specified in (d) or (e), you must demonstrate compliance according to one of the methods specified in paragraphs (b)(1) and (2) of [Reg and 40 C.F.R (b)] a. Purchasing an engine certified according to procedures specified in 40 C.F.R. Part 60, Subpart JJJJ, for the same model year and demonstrating compliance according to one of the methods specified in paragraph (a) of [Reg and 40 C.F.R (b)(1)] 47. If you are an owner or operator of a stationary SI internal combustion engine that is manufactured after July 1, 2008, and must comply with the emission standards specified in (a) through (c), you must comply by purchasing an engine certified to the emission standards in (a) through (c), as applicable, for the same engine class and maximum engine power. In addition, you must meet one of the requirements specified in (a)(1) and (2) of [Reg and 40 C.F.R (a)] a. If you operate and maintain the certified stationary SI internal combustion engine and control device according to the manufacturer's emission-related written instructions, you must keep records of conducted maintenance to demonstrate compliance, but no performance testing is required if you are an owner or operator. You must also meet the requirements as specified in 40 CFR part 1068, subparts A through D, as they apply to you. If you adjust engine settings 27