pactiv corporation draft permit #0916-aop-r4 afin: 30-00071 · 2019. 12. 30. · draft permit...

RESPONSE TO COMMENTS

Pactiv CorporationDRAFT PERMIT #0916-AOP-R4

AFIN: 30-00071

On October 7, 2009, the Director ofthe Arkansas Department ofEnvironmental Quality gave noticeof a draft permitting decision for the above referenced facility. During the comment period, PactivCorporation submitted comments, data, views or arguments on the draft permitting decision. TheDepartment's response to these issues follows.

Issue 1:

"Pactiv recently did a test ofthe reclaim line and has developed a new styrene emission factor. Thiswill change the styrene limit for the SN-08 from 0.15 lb/hr and 0.66 tpy to 0.43 lb/hr and 1.87 tpy,respectively."

Response 1:

The updated emission rates have been added to the permit as requested by the facility.

Issue 2:

"Page 8, Fluff Silos SN-07, 2nd paragraph - the plant has decided to scrap the "beside the pressgrinder" project. Please remove this complete paragraph."

Response 2:

The process description has been revised to exclude the "beside the press" grinders. Since the"beside the press" grinders were not an actual emission point, no emission changes will result fromthis change.

Issue 3:

"Page 9, 15t Paragraph, 2nd line - this line should read "The degassed resin is then extrudedthrough a die, cut into pellets, and then water cooled to a solid form.""

Response 3:

The permit has been revised as requested by the facility.

Issue 4:

"Page 34, Category A-I - Please add production area heaters (5)"

Response 4:

The production area heaters are "... heating units used for comfort ..." and would be covered underAppendix A, Group B, #2 of Regulation 19. Group B activities are not listed in the permit;therefore, the permit will not be changed but remain as written in the draft.

Issue 5:

"Page 34, Category A-13 - Should be Beringer jet cleaner, not cleaners ... There is only one."

Response 5:


Issue 6:

"Page 34, Category A-13 - Remove the Aerosol can punch and drain. This unit has beenremoved from the facility."

Response 6:


Issue 7:

"Page 34, Category A-13 - Should be Reclaim dryers... There are two of these units at thefacility."

Response 7:

The additional reclaim dryer has been added to the permit as requested by the facility. For claritypurposes, the following description has also been added: "(2 electric powered centrifugaldryers)".

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ADEQARK A N S A SDepartment of Environmental Quality

March 8, 2010

Randy KuykendallPactiv Corporation1105 Industrial LaneMalvern, AR 72104

Dear Mr. Kuykendall:

The enclosed Permit No. 0916-AOP-R4 is issued pursuant to the Arkansas Operating PermitProgram, Regulation # 26.

After considering the facts and requirements of A.c.A. §8-4-101 et seq., and implementingregulations, 1have determined that Permit No. 0916-AOP-R4 for the construction, operation andmaintenance of an air pollution control system for Pactiv Corporation to be issued and effectiveon the date specified in the permit, unless a Commission review has been properly requestedunder Arkansas Department of Pollution Control & Ecology Commission's AdministrativeProcedures, Regulation 8.603, within thirty (30) days after service of this decision.

All persons submitting written comments during the thirty (30) day, and all other persons entitledto do so, may request an adjudicatory hearing and Commission review on whether the decisionof the Director should be reversed or modified. Such a request shall be in the form and mannerrequired by Regulation 8.603, including filing a written Request for Hearing with the APC&ECommission Secretary at 101 E. Capitol Ave., Suite 205, Little Rock, Arkansas 72201. If youhave any questions about filing the request, please call the Commission at 501-682-7890.

Sincerely,

Mike BatesChief, Air Division

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

www.odeq.stote.or.us

ADEQOPERATINGAIR PERMIT

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

Permit No. : 0916-AOP-R4

IS ISSUED TO:

Pactiv Corporation1105 Industrial LaneMalvern, AR 72104Hot Spring CountyAFIN: 30-00071

THIS PERMIT AUTHORIZES THE ABOVE REFERENCED PERMITTEE TO INSTALL,OPERATE, AND MAINTAIN THE EQUIPMENT AND EMISSION UNITS DESCRIBED INTHE PERMIT APPLICATION AND ON THE FOLLOWING PAGES. THIS PERMIT ISVALID BETWEEN:

March 8, 2010 AND March 7, 2015

THE PERMITTEE IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINEDHEREIN.

Signed:

lJ~Mike BatesChief, Air Division

March 8, 2010

Date

Pactiv CorporationPermit #: 0916-AOP-R4AFIN: 30-00071

Table of Contents

SECTION I: FACILITY INFORMATION 4SECTION II: INTRODUCTION 5

Summary of Permit Activity 5Process Description 5Regulations 9Emission Summary 10

SECTION III: PERMIT HISTORy 12SECTION IV: SPECIFIC CONDITIONS 14

SN-01 - Pneumatic Conveying of Pellets to Silos (from railcars) - BaghouseSource Name .. 14SN-02 - Pellet Silos and Pneumatic Conveyer Baghouse 16SN-03 - Pneumatic Conveying of Pellets to Extrusion (from silos) - Baghouse 18SN-04 - Extrusion of Resin Foam 20SN-05 - Roll Storage 21SN-06 - Thennofonning of Resin Foam 22SN-07 - Flake Silos 24SN-08 - Reclaiming of Resin Flakes 26SN-09 - Finished Goods Storage 27

SECTION V: COMPLIANCE PLAN AND SCHEDULE 28SECTION VI: PLANTWIDE CONDITIONS 29

Title VI Provisions 31Permit Shield 32

SECTION VII: INSIGNIFICANT ACTIVITIES 34SECTION VIII: GENERAL PROVISIONS 35

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List of Acronyms and Abbreviations

A.C.A.

AFIN

CFR

CO

HAP

lb/hr

MVAC

No.

NOx

PM

PM IO

SNAP

S02

SSM

Tpy

UTM

VOC

Arkansas Code Annotated

ADEQ Facility Identification Number

Code of Federal Regulations

Carbon Monoxide

Hazardous Air Pollutant

Pound Per Hour

Motor Vehicle Air Conditioner

Number

Nitrogen Oxide

Particulate Matter

Particulate Matter Smaller Than Ten Microns

Significant New Alternatives Program (SNAP)

Sulfur Dioxide

Startup, Shutdown, and Malfunction Plan

Tons Per Year

Universal Transverse Mercator

Volatile Organic Compound

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SECTION I: FACILITY INFORMATION

PERJvlITTEE:

AFIN:

PERMIT NUMBER:

FACILITY ADDRESS:

MAILING ADDRESS:

COUNTY:

CONTACT NAME:

CONTACT POSITION:

Pactiv Corporation

30-00071

0916-AOP-R4

1105 Industrial LaneMalvern, AR 72104

1105 Industrial LaneMalvern, AR 72104

Hot Spring County

Randy Kuykendall

TELEPHONE NUMBER: 501-609-4010

REVIEWING ENGINEER: Melisha Griffin

UTM North South (Y):

UTM East West (X):

Zone 15: 3804231.21 m

Zone 15: 516521.22 m

4


SECTION II: INTRODUCTION

Summary of Permit Activity

The purpose of this modification is to renew the facility's Title V Operating Permit (Permits0916-AOP-R3). The facility is also installing new "beside-the-press grinders" next to each ofthe thermoformers to help improve management of different colors. The additional grinders donot increase the short-term grinding capabilities of the facility as any scrap processed in thebeside-the-press grinders will have been processed in the existing parts grinders. The total shortterm throughput of the beside-the-press grinders is also limited by the capacities of theunderpress grinder blowers, which are not being increased. Therefore, the potential to emit hasnot changed as a result of this addition.

In this renewal, the facility is also updating PM/PMlO and HAP emission rates. The particulatematter emissions were estimated using particular matter emission factors developed by Pactiv;these factors were obtained from source testing on similar processes at other Pactiv facilities.These tests also resulted in the listing of additional HAPs at SN-08 (0.20 tpy of Acetaldehyde,0.01 tpy of Benzene, 0.1 tpy of 1,3-Butadiene, 0.5 tpy of Toluene, and 0.02 tpy of Xylene). TheVOC emissions at SN-08 did not change.

The facility has also discontinued use of powdered talc and the associated mineral oil; the facilitynow uses pelletized talc. Consequently, "Talc Transfer", which referred to powdered talc, and"Flake (fluff) Transfer and Conveyance" have been removed from the Insignificant Activitieslist. Emissions associated with "Flake Transfer (fluff) and Conveyance" have been grouped withemissions from the reclaim extrusion (SN-08).

This facility is not subject to 40 CFR Part 64, Compliance Assurance Monitoring (CAM).Located at the facility are several baghouses and cyclones, two types of equipment normallyconsidered control equipment as defined in 40 CFR 64.1. Pactiv Corporation uses these devicesas an integral part of the pneumatic material handling systems located on site. Guidancedocuments from the EPA direct that if these types of equipment are inherent to the process, thenthey are not defined as control equipment for the purposes of CAM.

Process Description

Pactiv operates an extruded polystyrene foam production facility at 1105 Industrial Lane,Malvern, Hot Spring County, Arkansas 72104. The facility is currently operating 24 hours aday, 365 days a year.

The facility produces a variety of polystyrene foam packaging trays for the food processingindustry. The processes and operations for polystyrene foam manufacturing operations emitprimarily (1) VOCs from the foam blowing agent; (2) small amounts ofPMlO, that are generatedby abrasion of the solid resin pellets against one another or against the walls of the pneumaticconduits, and by processing and conveying ground scrap foam or "fluff'; and (3) Hazardous AirPollutants (HAPs), primarily from degradation of polystyrene during reclaim extrusion. From

5


time to time, physical locations of extrusion and/or thermoforming equipment within the plantmay change as product demand changes.

The processes and operations for polystyrene foam are described below in process sequentialr.rrlpr Thp -t",,..'l'hT r.npr",tp" llnrlpr '" T,tlp \T ()npr",t,no P.,.....,'t lI..T,..., Q 1 h_ A ()P_D "1 nT1,;,,1, 0>"'"''',",0 <>11"'-' .......... _ ..... .&..&..&._ ....._ ................ ,,] "".t"'•.,... _,,-...., ...........'-""_... \.4 ..I. ........ _ Y '-'y_.I."""".I..I..l.6..a. '""".1..1..1..1..1.1. 1,v. ./.1. V~.J. ....'-'.l. --.1.'---", l'Y.I..I..I.'-'.I..1. 6.l.VUPJ U.l.l

sources into nine categories designated by Source Numbers (SN).

Pneumatic Conveying of Virgin Resin Pellets to Pellet Silos (from railcar or truck)(Emission Source SN-Ol)

Virgin resin pellets are delivered to the facility primarily by railcar; however, resin pellets areoccasionally delivered by truck. The pellets are stored in two virgin resin pellet silos. Whendelivered by railcar, the pellets are pneumatically conveyed from the railcars to hoppers at thetop of the silos via two vacuum blowers/air conveyors. There are controls (i.e., cloth filters, etc.)immediately upstream of the vacuum blowers; however, these controls are considered inherent toproper operation of the system, as they are designed to protect the blowers, and therefore are notconsidered emission control equipment. Upon reaching the hoppers, the resin pellets fall bygravity into the silos. Excess air exhausted from this gravity transfer into the silo, which includesa small amount of PM, is exhausted via a vent on each silo, which is equipped with a filter bag toprovide PM emission control.

When delivered by truck, the pellets are pneumatically conveyed from the delivery truck into thesilos via a pressure blower on the truck. Excess conveying air from this transfer into the silos,which includes a small amount of PM, is exhausted via a vent on each silo, which is equippedwith a filter bag to provide PM emission control.

The filter bags are periodically inspected; excess material collected in the filter bags is manuallyremoved as required.

Pneumatic Conveying of Reclaim Resin Pellets to Silos (Emission Source SN-02)

Reclaim resin pellets are pneumatically conveyed from the reclaim extruders to the reclaim resinpellet silos via positive pressure pumps. The reclaim resin pellet silos consist of four insidebins/com bins and 1 outside silo - the outside silo is split into two part (to allow for flexibility inmanaging different color reclaim pellets). Excess conveying air from this transfer into thereclaim silos, which includes a small amount of PM, is exhausted via a vent on each silo, whichis equipped with a filter bag to provide PM emission control. The filter bags are periodicallyinspected; excess material collected in the filter bags is manually removed as required.

6

Pactiv CorporationPermit #: 09l6-AOP-R4AFIN: 30-00071

Pneumatic Conveying of Resin Pellets from Pellet Silos or Gaylords to Extrusion (EmissionSource SN-03)

As resin pellets are needed for extrusion, five air conveyors pneumatically transfer virgin andreclaim resin pellets from the pellet silos to feed hoppers located at the five foam extruders 'viafive vacuum blowers. There are controls (i.e., cloth filters, etc.) immediately upstream of thevacuum blowers; however, these controls are considered inherent to proper operation ofthesystem, as they are designed to protect the blowers, and therefore are not considered emissioncontrol equipment.

Some of the pelletized materials used in extrusion, including colorant and talc, are commonlydelivered via small boxes, commonly referred to as gaylords. Materials are transferred from thegaylords to the extrusion feed hoppers via the same vacuum systems used for transferring theresin pellets.

Foam Extrusion (Emission Source SN-04)

Polystyrene foam is produced by feeding virgin and reclaim resin pellets, color concentrate,nucleating agents and blowing agent to the existing foam extruders (SN-04). The foam extrusionlines are comprised of a two-stage electrically heated screw press extrusion system where theraw materials are heated, melted, and mixed in the primary extruder, and then cooled andstabilized in the secondary extruder. The mixture is extruded in molten form through an annulardie in the form of a thick bubble. The molten mixture is then stretched to a set diameter, drawnover a cooling mandrel, and slit and split into two webs. Each web is fed through an S-wrap andwound onto a roll. Blowing agent and polystyrene usage are recorded for each extrusion line.

Additional ingredients, such as nucleating agents or colorants, can also be added to the rawmaterial mixture, depending upon the desired characteristics (e.g., flexibility, color) of the finalfoam product. The VOC blowing agent is injected under pressure in varying percentages basedon the final product requirements. VOC emissions from the foam extrusion area are vented to theoutside atmosphere.

Roll Storage (Emission Source SN-OS)

When the rolls of foam sheet on the winders reach a set diameter and meet quality specifications,they are transported to the Roll Storage Area (SN-05) to age prior to being moved tothermoforming for processing into the final product. Aging allows the foam structure to cure,thereby resulting in improved thermoforming properties. VOC emissions from the roll storagearea are vented to the outside atmosphere.

Thermoforming (Emission Source SN-06)

Once the polystyrene foam rolls produced in the extrusion process have aged, the rolls meetingspecifications are thermoformed in the ten existing thermoformers (SN-06) (two additionalthermoformers, not yet installed, have also been permitted). The roll is unwound and passed

7


through a heated oven and vacuum formed in a mold where the finished part (e.g., tray) isformed. VOC emissions from the thermoforming process are vented to the outside atmosphere.

Fluff Silos (including grinders and fluff conveyance to silos) (Emission Source SN07)

A portion ofthe foam sheet cannot be used for the finished product. This "engineered scrap",also referred to as webbing or trim, is routed to in-line underpress grinders located at eachthermoformer. The scrap is then mechanically chopped by the grinders into small pieces, called"fluff." The fluff is conveyed pneumatically to the fluff silos, which consist of one bin/com binand four silos. At the fluff silos, the fluff is mechanically separated by the internal conical airfluff separator in each silo. As a result of the grinding and associated destruction of the foamcells, a portion of the VOC blowing agent contained in the foam, as well as PM IO, is liberatedduring the grinding step - the VOC blowing agent and PM IO emissions are exhausted from thevents on each fluff silo.

As previously discussed, the acceptable rollstock produced by the foam extruders is furtherprocessed at the thermoformers. Rollstock that does not meet quality specifications is designatedas scrap and subsequently recycled. In addition, off-spec materials from the extrusion processand thermoformers are also recycled. The scrap rolls are fed to a roll grinder, and the scrapextrusion and thermoformed materials are fed to one of two parts grinders, where the scrap ismechanically chopped into fluff. This fluff is also conveyed pneumatically to the fluff silos.Similar to the engineered scrap, a portion of the VOC blowing agent contained in the foam, aswell as PMIO, is liberated during the grinding step - the VOC blowing agent and PM IO emissionsare exhausted from the vents on each fluff silo.

Reclaim Extrusion of Scrap FoamlFluff (including conveyance of fluff to reclaimextruders) (Emission Source SN-08)

The fluff is conveyed as needed to the reclaim extruders for processing into reclaim resin pelletsfor reuse. The primary reclaim extruder, R3, conveys the fluff from the fluff silos to its feedhopper using an air conveyor/vacuum blower. There are no controls associated with the vacuumblower, but the feed hopper functions as a cyclone - this essentially provides cyclone equivalentcontrol for the fluff transfer. At the other reclaim extruder, R2, the conveying air, which is underpressure, is feed into a cyclone-type feed hopper and then returned to the silos, where is itexhausted through the normal fluff silo vents; this system also provides cyclone equivalentcontrol.

The fluff conveyed to the two existing reclaim extruders is gravity-fed into the reclaim extruders,where the fluff is melted and the blowing agent degassed. The degassed resin is then extrudedthrough a die, cut into pellets, and then water cooled to a solid form. The resulting pellets aretypically conveyed to the reclaim pellet silos for storage until needed in the foam extrusionprocess (see SN-02 description for PM emissions associated with conveyance of reclaim resinpellets to reclaim silos); periodically, the reclaim pellets may be directly fed to the foamextruders. The reclaim extruder vents are exhausted to the outside atmosphere.

8


The degassed blowing agent results in VOC emissions during the reclaim extrusion process.Small amounts of PM are also emitted due to the extrusion temperature. In addition, due to thedegradation of polystyrene, Hazardous Air Pollutants (HAPs) are also emitted.

Finished Goods Storage (Emission Source SN-09)

The finished goods are packaged and moved to the finished goods warehouse for storage beforeshipping. VOC emissions occur due to off-gassing ofthe blowing agent from the finishedproducts. The quantity of VOC blowing agent that escapes from the product varies with thepercent by weight of blowing agent used, the type of product and the length of time the productremains in storage on-site. VOC emissions from finished goods storage are vented to the outsideatmosphere.

Regulations

The following table contains the regulations applicable to this permit.

Regulations

Arkansas Air Pollution Control Code, Regulation 18, effective January 25, 2009

Regulations of the Arkansas Plan of Implementation for Air Pollution Control,Regulation 19, effective July 18, 2009Regulations ofthe Arkansas Operating Air Permit Program, Regulation 26, effectiveJanuary 25, 2009

9


Emission Summary

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

EMISSION SUMMARY

Source Emission Rates

NumberDescription Pollutant

lb/hr tpy

PM 1.7 4

PM lO 1.5 3.7

S02 0 0Total Allowable EmissionsVOC 157.6 624.9

CO 0 0

NOx 0 0

Styrene 0.43 1.87Acetaldehyde

0.05 0.2Benzene

0.01 0.01HAPs

l,3-Butadiene0.01 0.01

Toluene0.01 0.05

Xylene0.01 0.02

Pneumatic Conveying of PelletsPM 0.2 0.1

01 to Silos (from railcar or truck) -PMlO 0.1 0.1

Baghouse

02Pellet Silos and Pneumatic PM 0.1 0.1

Conveyer Baghouse PM lO 0.1 0.1Pneumatic Conveying of Pellets

PM 0.1 0.103 to Extrusion (from silos) -

PM lO 0.1 0.1Baghouse

04 Extrusion of Resin Foam VOC 12.9 56.2

05 Roll Storage VOC 11.6 50.8

06 Thermoforming of Resin Foam VOC 15.5 50.8

PM 0.8 1.607 Flake Silos PM lO 0.8 1.6

VOC 43.7 143.6

10


EMISSION SUMMARY

Source Emission Rates

NumberDescription Pollutant

lb/hr tpy

PM 0.5 2.1PM IO 0.4 1.8VOC 19.6 85.6

Reclaim extrusion of scrap Styrene* 0.43 1.8708 foam/fluff (including conveyance Acetaldehyde* 0.05 0.20

of fluff to reclaim extruders) Benzene* 0.01 0.011,3-Butadiene* 0.01 0.01

Toluene* 0.01 0.05Xylene* 0.01 0.02

09 Finished Goods Storage VOC 54.3 237.9

*HAPs included in the VOC totals. Other HAPs are not mcluded in any other totals unlessspecifically stated.

11


SECTION III: PERMIT HISTORY

On December 7, 1988, the first permit (Permit 916-A) for the facility was obtained by AmocoFoam Products. The addition of an additional silo prompted the permitting action. Thetnr\r1';f1r'at~n.n A-i,.-l ""t t-rl rrncu" Den..........V\"A. .....LJ.""'""... v.J..L U.1U .l.lV\. \..1..1 0 6 ""'1. .1. U.1...-'.

On July 23, 1990, Permit 916-AR-1 was issued to Amoco Foam Products. This modificationallowed the facility to install a new extrusion line. This modification did not trigger PSD.

On April 8, 1992, Permit 916-AR-2 was issued to Amoco Foam Products. This modificationallowed the facility to upgrade its extruders. The upgrades increased throughput at the plant andresulted in an increase in emissions. In addition, emission studies indicated that the existingpermitted emission rates were too low and as a result the emissions were adjusted. Thismodification was less than 250 tons per year by itself and since the facility was not a majorstationary source prior to this modification, PSD did not apply. This permit did establish thefacility as a major stationary source for the purposes ofPSD. It was noted that this facility is notone of the 28 listed source categories and therefore fugitive emissions are not used to determinemajor stationary source status.

On February 17,1995, Permit 916-AR-3 was issued to Amoco Foam Products. Thismodification included an increase in the allowable throughput in some extruder lines, theaddition of a thennofonning machine, and the addition of an air conveyor and silo. Thismodification did not trigger PSD.

Following an evaluation in October 1995 by the Department it was determined that emissionsfrom the thennofonning area, roll storage area and finished goods warehouse area were fugitiveemissions. Fugitive emissions are not included in the total allowable emissions figure whendetermining PSD applicability. Therefore, as a result of this review Amoco was considered aminor stationary source for PSD purposes. However, for the purposes of Title V permittingAmoco was still a major stationary source.

On July 12, 1996, Permit 916-AR-4 was issued to Amoco Foam Products. Permit modificationsincluded the revision and reorganization of Table I - Allowable Emission Rates, the addition ofpreviously unpermitted equipment, the addition of new equipment, and adjustments inproduction capacity of existing equipment.

On May 28,1997, Permit 916-AR-5 was issued to Tenneco Foam Products Company. TennecoFoam Products Company purchased Amoco Foam Products. Permit modifications included anexpansion of the roll storage room, an expansion of the finished goods warehouse, an increase inblowing agent input, and several equipment additions. With this permit, Tenneco wasestablished as a major stationary source for the purposes ofPSD and Title V permitting.

Permit #916-AOP-RO was the first Title V operating permit issued to Tenneco PackagingSpecialty & Consumer Products, Inc. under Regulation #26. No changes were associated withthis permit.

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Permit #916-AOP-RI was issued on April 13,2004. This permitting action is a renewal of theprevious version ofPactiv Corporation's (formerly Tenneco Packaging Specialty & ConsumerProducts) Air permit. Provisions for HAPs were added at the Reclaiming Operations (SN-08)and styrene was added to that source at 0.7 tons per year.

Permit #916-AOP-R2 was issued on October 11,2007. This modification allowed Pactiv tomodify the VOC emission limits throughout the permit to fit the current VOC model used byPactiv to predict emission rates at the facility. This modification allowed a decrease in facilitywide annual permitted emissions of203 tons ofVOC.

Previously, the Department classified Roll Storage (SN-05), Thermoforming (SN-06) andFinished Goods Storage (SN-09) fugitive sources. However, after further review these sourcesare no longer defined as fugitive sources since the emissions of all of these sources occur insidean enclosed building. The facility is classified as a major stationary source for PSD and anyfuture modification which increase emissions above the PSD significance threshold will trigger aPSD review.

Permit #916-AOP-R3 was issued on August 08, 2008. With this minor modification, Pactivrequested permission to install 3 new thermoformers. This modification did not change thepermitted annual throughput limits which were set on a monthly and annual basis by theextrusion area. The facility exhibited that the potential emissions from the additionalthermoformers were less than 18 tons per year of VOc. However, there was no change to thefacility wide annual permitted emissions since emissions were limited by the extrudedthroughput.

13


SECTION IV: SPECIFIC CONDITIONS

SN-01 - Pneumatic Conveying of Pellets to Silos (from railcars) - BaghouseSource Name

The air conveyors (SN-01) pneumatically convey virgin resin pellets received from railcars intovirgin resin pellet silos for storage via vacuum blowers equipped with cloth filters. Virgin resinis also occasionally received by truck. As the resin pellet silos fill, air and a small quantity ofparticulate matter emissions vent through the baghouse filters and are discharged through thevacuum blowers to the outside atmosphere. Materials collected in the filters are manuallyremoved.

Specific Conditions

1. The permittee shall not exceed the emission rates set forth in the following table. Thepermittee shall demonstrate compliance with this condition by compliance withPlantwide Conditions 7 and 10. [Regulation 19, §19.501 et seq., and 40 CFR Part 52,Subpart E]

SN Description Pollutant lb/hr tpy

01Pneumatic Conveying of

PM IO 0.1 0.1Pellets to Silos

2. The permittee shall not exceed the emission rates set forth in the following table. Thepermittee shall demonstrate compliance with this condition by compliance withPlantwide Conditions 7 and 10. [Regulation 18, §18.801, and A.C.A. §8-4-203 asreferenced by A.C.A. §8-4-304 and §8-4-311]



PM 0.2 0.1Pellets to Silos

3. Visible emissions may not exceed the limits specified in the following table of this permitas measured by EPA Reference Method

SN Limit Regulatory Citation

01 5% §18.501

The permittee shall conduct weekly observations of the opacity from source SN-01 andkeep a record of these observations. If the permittee detects visible emissions, thepermittee must immediately take action to identify and correct the cause of the visible

14


emissions. After implementing the corrective action, the permittee must document thatthe source complies with the visible emissions requirements. The permittee shallmaintain records of the cause of any visible emissions and the corrective action taken.The permittee must keep these records onsite and make them available to Department

15


SN-02 - Pellet Silos and Pneumatic Conveyer Baghouse

Source Description

'T~-rl"T;n T"oC'~n ......ol1otC' ~ ...... r1 .,..0"1,,,; ........... .,...a.co; .... ...... cr.1L::JIo+C'O n ....=- n .... _ ....._+l .. ~ ....+1"'\0._ ..... ,1 : __ ..... 11 .......... :1 ......... /01\.T """ 'T"1.-~_,..• ~~ 6.1·1..1 J. "-',,:).1U. 1-'''-'.1.1. .........o U.1JU .1 \.I\.I.1Ul.1.11 .1 \..<.:J.1J.1 l''''''11'''''~'::) a.1"'" \.lUll t,;;lJLl) i:)lVl \;U 111 l-'~llCl i:)11Ui:) \. 01 ~ -V~)_ I1JC::1 c::

are both virgin resin pellet silos and reclaim resin pellet silos. Virgin resin pellets arepneumatically conveyed from railcars to the virgin resin pellet silos.

Reclaim resin pellets are pneumatically conveyed from the reclaim extruders to the reclaim resinpellet silos via positive pressure pumps. The conveying air passes through cloth baghouse filters,which collect the particulate fines, before being discharged with a small quantity of particulatematter emissions to the outside atmosphere from a vent at the top of each silo.

Specific Conditions

4. The permittee shall not exceed the emission rates set forth in the following table. Thepermittee shall demonstrate compliance with this condition by compliance withPlantwide Conditions 7 and 10. [Regulation 19, §19.501 et seq. and 40 CFR Part 52,Subpart E]

SN Description Pollutant lblhr tpy

02Pellet Silos and Pneumatic

PM IO 0.1 0.1Conveyer Baghouse

5. The permittee shall not exceed the emission rates set forth in the following table. Thepermittee shall demonstrate compliance with this condition by compliance withPlantwide Conditions 7 and 10. [Regulation 18, §18.801 and A.C.A. §8-4-203 asreferenced by A.C.A. §8-4-304 and §8-4-311]


02 Pellet Silos and Pneumatic PM 0.1 0.1Conveyer Baghouse

6. Visible emissions may not exceed the limits specified in the following table of this permitas measured by EPA Reference Method 9.


02 5% §18.501

The permittee shall conduct weekly observations of the opacity from sources SN-02 andkeep a record of these observations. If the permittee detects visible emissions, thepermittee must immediately take action to identify and correct the cause of the visible

16


emISSIOns. After implementing the corrective action, the permittee must document thatthe source complies with the visible emissions requirements. The permittee shallmaintain records of the cause of any visible emissions and the corrective action taken.The permittee must keep these records onsite and make them available to Departmentpersonnel upon request

17

Pactiv CorporationPermit #: 0916-AOP-R4AFlN: 30-00071

SN-03 - Pneumatic Conveying of Pellets to Extrusion (from silos) - Baghouse

Source Description

As resin pellets are needed for production air conveyors (Sl'~-03) pneumatically transfer virginand reclaim resin pellets from the pellet silos to the foam extruders via vacuum blowers.Conveying air is routed through cloth baghouse filters before being discharged with a smallamount of particulate matter emissions through the blowers to the outside atmosphere. Materialscollected in the filters are manually removed.

Specific Conditions




PMlO 0.1 0.1Pellets to Extrusion




PM 0.1 0.1Pellets to Extrusion



03 5% §18.501

The permittee shall conduct weekly observations ofthe opacity from source SN-03and keep a record of these observations. If the permittee detects visible emissions, thepermittee must immediately take action to identify and correct the cause of the visibleemissions. After implementing the corrective action, the permittee must document thatthe source complies with the visible emissions requirements. The permittee shallmaintain records of the cause of any visible emissions and the corrective action taken.

18


The permittee must keep these records onsite and make them available to Departmentpersonnel upon request. [§18.1004 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311 ]

19


SN-04 - Extrusion of Resin Foam

Source Description

Pnh,,.yy\t:lo,..- -trVl'YY1l ;co ..........Arln"""orl kU +CIJ:~r1;'f"'\""" ,,; ....n-;....,. n_rl "'C/Ionln;~ ....'"""n~ _ _ ...... 11 ..... .f.~ ........... 1...... _ ........................ ,..._4--_1' ............ V.J..JU.""""'.1. ....VU.1.1.1..1J }'.1.VUU,",VU VJ .1.vvUIJ15 V1.1511.1 UIJU .1,"",,\,.1101111 1""~111 }J~11C;L.~, ,""VJUI \,..Ul1'"'~11LlaLc;,

nucleating agents, and blowing agent to the foam extruders (SN-04). The foam extruder lines arecomprised of a two-stage electrically heated screw press extrusion system where the rawmaterials are heated, melted, and mixed in the primary extruder, and then cooled and stabilizedin the secondary extruder. The mixture is extruded in molten form through a die in the form of athick bubble. The molten mixture is then stretched to a set diameter, drawn over a coolingmandrel, and slit and split into two webs. Each web is fed through an S-wrap and wound onto aroll. Blowing agent and polystyrene usage are recorded for each extrusion line.

Additional ingredients, such as nucleating agents or solids dyes, can also be added to the rawmaterial mixture, depending upon the desired characteristics (e.g., flexibility, color) of the finalfoam product. The VOC blowing agent and other non-VOC blowing agents are injected underpressure in varying percentages based on the final product requirements.

VOC emissions from the foam extrusion area are vented to the outside atmosphere.

Specific Conditions



04 Extrusion of Resin Foam VOC 12.9 56.2

20


SN-05 - Roll Storage

Source Description

When the rolls of foam sheet on the Svwraps reach a set diameter, they arc transported to the RollStorage Area (SN-05) to age prior to being moved to thermoforming for processing into the finalproduct. Aging allows the foam structure to cure, thereby resulting in improved thermoformingproperties.

Specific Conditions



05 Roll Storage VOC 11.6 50.8

21


SN-06 - Thermoforming of Resin Foam

Source Description

specifications are thermoformed in the thermoformers (SN-06). The roll is unwound and passedthrough a heated oven and vacuum formed in a mold where the finished part (e.g., tray) isformed.

Pactiv is permitted to operate 12 thermoformers. The three newest thermoformers (TF-I0, TF11, and TF-12) were approved as a minor modification and as a result require recordkeeping toensure that the emissions from those three thermoformers do not exceed minor modificationthresholds.

Specific Conditions

12. The permittee shall not exceed the emission rates set forth in the following table. Thepermittee shall demonstrate compliance with this condition by compliance with SpecificConditions 13 through 15 and Plantwide Conditions 7 and 10. [Regulation 19, §19.501 etseq. and 40 CFR Part 52, Subpart E]


06Thermoforming of

VOC 15.5 50.8*Resin Foam

*Total emISSIOns from all 12 thermoformers, mcludmg TF-IO, TF-II, and TF-12.

13. The permittee shall not exceed 18 tons ofVOC per rolling 12-month period from TF-I0,TF-11, and TF-12, combined. Compliance with this Specific Condition shall bedemonstrated by compliance with Specific Conditions 14 and 15. [§19.501 and 40 CFRPart 52, Subpart E]

14. The permittee shall record the hours of operation ofTF-10, TF-ll, and TF-12, daily. Thehours of operation of these three thermoformers will be used to calculate the annual VOCemissions to demonstrate compliance with Specific Condition 13. [§19.705, 40 CFR Part52 Subpart E, §18.1004, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

15. The permittee shall maintain records which demonstrate compliance with SpecificCondition 14. These records shall be updated on a monthly basis. These records shall bekept on site, provided to Department personnel upon request, and may be used by theDepartment for enforcement purposes. A twelve month total and each individualmonth's data shall be submitted in accordance with General Provision 7. [§19.705,40CFR Part 52 Subpart E, §18.1004, and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311]

22


16. The facility has until May 26, 2011, to install and operate the thermoformers which wereapproved in Permit# 09l6-AOP-R3. After May 26,2011, if installation and operation ofall the approved new transformers have not begun, the facility must first contact theDepartment for a letter of approval to ensure standards regarding the installation and

Regulation 19, §19.410(B).

23


SN-07 - Flake Silos

Source Description

The underpress grinders cut the salable finished product from the foam sheet leaving a web(trim). The trim scrap portion is then mechanically chopped into small pieces, called "flake" or"fluff." As a result of the destruction of foam cells, a portion of the VOC blowing agentcontained in the foam, as well as particulate matter, is liberated during this grinding process.The VOC blowing agent and particulate matter emissions from the trim presses stay with theflake, which is then conveyed pneumatically to the flake silos.

As discussed, the acceptable rollstock produced by the foam extruders is further processed at thethermoformers. The scrap rollstock, which is comprised of foam rolls that do not meet qualityspecifications, is scrap and must be recycled. In addition, off-spec materials from thethermoformers are also recycled. The scrap rolls are fed to a roll grinder, and the scrapthermoformed materials are fed to parts grinders to be mechanically chopped into small pieces,called "flake" or "fluff." As with the thermoformer underpress grinders, a portion of the VOCblowing agent contained in the foam, as well as particulate matter, is liberated during thisgrinding step. The VOC blowing agent and particulate matter emissions from the grinders staywith the flake, which is then conveyed pneumatically to the flake silos.

Flake from the underpress grinders, parts grinders, and roll grinder is pneumatically conveyed tothe flake silos (SN-07), where the VOC blowing agent and particulate matter generated duringthe grinding operations is separated by the internal cyclones at each silo. The particulate matterthat is separated falls to the bottom of the silos. The blowing agent, which contains a smallamount of particulate matter, is emitted to the outside atmosphere from the flake silo vents. Theflake silos may also be referred to as fluff silos.

The flakes are then conveyed as needed to the reclaim extruders for processing into reclaim resinpellets, with the conveying air being returned and exhausted through the flake silos.

Specific Conditions



PM 10 0.8 1.607 Flake Silos

VOC 43.7 143.6

24




07 Flake Silos PM 0.8 1.6



07 5% §18.50l

The permittee shall conduct weekly observations of the opacity from source SN-07and keep a record of these observations. If the permittee detects visible emissions, thepermittee must immediately take action to identify and correct the cause of the visibleemissions. After implementing the corrective action, the permittee must document thatthe source complies with the visible emissions requirements. The permittee shallmaintain records ofthe cause of any visible emissions and the corrective action taken.The permittee must keep these records onsite and make them available to Departmentpersonnel upon request. [§18.1004 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311]

25


SN-08 - Reclaiming of Resin Flakes

Source Description

The flake is conveyed from the flake silos to the reclaim extruders (SN-08), where the flake ismelted and the blowing agent degassed. The degassed resin is then extruded through a die, watercooled to a solid form, then pelletized. The resulting pellets may be sent either to the reclaimpellets silos for storage until needed in the Foam Extruders, or directly to the Foam Extruders forrecycling. The reclaim extruder vents are exhausted to the atmosphere.

Specific Conditions


SN Description Pollutant Ib/hr tpy

Reclaim extrusion of scrap PM 10 0.4 1.808 foam/fluff (including conveyance of

fluff to reclaim extruders) VOC 19.6 85.6


SN Description Pollutant Ib/hr tpy

PM 0.5 2.1

Styrene 0.43 1.87

Reclaim extrusion of scrapAcetaldehyde 0.05 0.20

08 foam/fluff (including conveyance Benzene 0.01 0.01of fluff to reclaim extruders)

1,3-Butadiene 0.01 0.01

Toluene 0.01 0.05

Xylene 0.01 0.02

26


SN-09 - Finished Goods Storage

Source Description

shipping (SN-09). VOC emissions occur due to off-gassing of the blowing agent from thefinished products.

Specific Conditions



09Finished Goods

VOC 54.3 237.9Storage

27


SECTION V: COMPLIANCE PLAN AND SCHEDULE

Pactiv Corporation will continue to operate in compliance with those identified regulatoryprovisions. The facility will examine and analyze future regulations that may apply anddetermine their applicability with any necessary action taken on a timely basis.

28


SECTION VI: PLANTWIDE CONDITIONS

1. The permittee shall notify the Director in writing within thirty (30) days aftercommencing construction, completing construction, first placing the equipment and/orfacility in operation, and reaching the equipment and/or facility target production rate.[Regulation 19, §19.704, 40 CFR Part 52, Subpart E, and A.C.A §8-4-203 as referencedby AC.A. §8-4-304 and §8-4-311]

2. If the permittee fails to start construction within eighteen months or suspendsconstruction for eighteen months or more, the Director may cancel all or part of thispermit. [Regulation 19, §19.41O(B) and 40 CFR Part 52, Subpart E]

3. The permittee must test any equipment scheduled for testing, unless otherwise stated inthe Specific Conditions of this permit or by any federally regulated requirements, withinthe following time frames: (1) new equipment or newly modified equipment within sixty(60) days of achieving the maximum production rate, but no later than 180 days afterinitial start up of the permitted source or (2) operating equipment according to the timeframes set forth by the Department or within 180 days of permit issuance if no date isspecified. The permittee must notify the Department of the scheduled date of compliancetesting at least fifteen (15) days in advance of such test. The permittee shall submit thecompliance test results to the Department within thirty (30) days after completing thetesting. [Regulation 19, §19.702 and/or Regulation 18 §18.1002 and A.C.A. §8-4-203 asreferenced by AC.A §8-4-304 and §8-4~311]

4. The permittee must provide:

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

[Regulation 19, §19.702 and/or Regulation 18, §18.1002 and AC.A. §8-4-203 asreferenced by A.C.A. §8-4-304 and §8-4-311]

5. The permittee must operate the equipment, control apparatus and emission monitoringequipment within the design limitations. The permittee shall maintain the equipment ingood condition at all times. [Regulation 19, §19.303 and AC.A §8-4-203 as referencedby AC.A §8-4-304 and §8-4-311]

6. This permit subsumes and incorporates all previously issued air permits for this facility.[Regulation 26 and AC.A §8-4-203 as referenced by AC.A §8-4-304 and §8-4-311]

29


7. Throughput of polystyrene in the extrusion area (SN-04) and the reclaim extrusion area(SN-08) shall not exceed the limits set forth in the following table:

Throughput LimitEquipment

pounds per twelve consecutivepounds per month

months

Extrusion Area 4,612,800 54,312,000

Reclaim Extrusion Area 2,604,000 30,660,000

[§19.705, §18.1004, A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, and 40CFR §70.6]

8. The permittee shall maintain records which demonstrate compliance with PlantwideCondition 7. These records shall include the total production for the extrusion area andthe reclaim extrusion area. These records shall be updated on a monthly basis. Theserecords shall be kept on site, provided to Department personnel upon request, and may beused by the Department for enforcement purposes. A twelve month total and eachindividual month's data shall be submitted in accordance with General Provision 7.[§19.705, 40 CFR Part 52 Subpart E, §18.l004, and A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311]

9. The Department shall be notified prior to any changes in the chemical composition of thenon-HAP, VOC blowing agent in the polystyrene foam extrusion process. Any proposedchanges in the chemical composition of the blowing agent must be approved by theDepartment prior to use. [§19.705, A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4311, and 40 CFR §70.6]

10. The permittee shall not use in excess of271,560 pounds ofVOC blowing agent permonth and 3,258,720 pounds ofVOC blowing agent per twelve consecutive months.[§19.705, A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, and 40 CFR §70.6]

11. The permittee shall maintain records which demonstrate compliance with PlantwideCondition 10. These records shall be updated on a monthly basis. These records shall bekept on site, provided to Department personnel upon request, and may be used by theDepartment for enforcement purposes. A twelve month total and each individualmonth's data shall be submitted in accordance with General Provision 7. [§19.705 and40 CFR Part 52 Subpart E]

30


12. The permittee shall only use electric heat in production processes at the facility.[§19.705, §18.1004, A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, and 40CFR §70.6]

Title VI Provisions

13. The permittee must comply with the standards for labeling of products using ozonedepleting substances. [40 CFR Part 82, Subpart E]

a. All containers containing a class I or class II substance stored or transported, allproducts containing a class I substance, and all products directly manufacturedwith a class I substance must bear the required warning statement if it is beingintroduced to interstate commerce pursuant to §82.l 06.

b. The placem ent of the required warning statement must comply with therequirements pursuant to §82.l 08.

c. The form of the label bearing the required warning must comply with therequirements pursuant to §82.1l0.

d. No person rna y modify, remove, or interfere with the required warning statementexcept as described in §82.1l2.

14. The permittee must comply with the standards for recycling and emissions reduction,except as provided for MVACs in Subpart B. [40 CFR Part 82, Subpart F]

a. Persons opening appliances for maintenance, service, repair, or disposal mustcomply with the required practices pursuant to §82.l56.

b. Equipment used during t he maintenance, service, repair, or disposal of appliancesmust comply with the standards for recycling and recovery equipment pursuant to§82.l58.

c. Persons performing maintenance, service repair, or disposal of appliances must becertified by an approved technician certification program pursuant to §82.l6l.

d. Persons disposing of sma 11 appliances, MVACs, and MVAC like appliances mustcomply with record keeping requirements pursuant to §82.l66. ("MVAC likeappliance" as defined at §82.l52)

e. Persons owning commercial or industrial process refrigeration equipment mustcomply with leak repair requirements pursuant to §82.l56.

f. Owners/operators of appliances normally containing 50 or more pounds ofrefrigerant must keep records of refrigerant purchased and added to suchappliances pursuant to §82.l66.

15. If the permittee manufactures, transforms, destroys, imports, or exports a class I or classII substance, the permittee is subject to all requirements as specified in 40 CFR Part 82,Subpart A, Production and Consumption Controls.

16. If the permittee performs a service on motor (fleet) vehicles when this service involvesozone depleting substance refrigerant (or regulated substitute substance) in the motor

31


vehicle air conditioner (MVAC), the permittee is subject to all the applicablerequirements as specified in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle AirConditioners.

assembly of the vehicle has not been completed. The term "MVAC" as used in SubpartB does not include the air tight sealed refrigeration system used as refrigerated cargo, orthe system used on passenger buses using HCFC 22 refrigerant.

17. The permittee can switch from any ozone depleting substance to any alternative listed inthe Significant New Alternatives Program (SNAP) promulgated pursuant to 40 CFR Part82, Subpart G.

Permit Shield

18. Compliance with the conditions of this permit shall be deemed compliance with allapplicable requirements, as of the date of permit issuance, included in and specificallyidentified in the following table of this condition. The permit specifically identifies thefollowing as applicable requirements based upon the information submitted by thepermittee in an application dated January 9, 2009.

Applicable Regulations

Source No. Regulation Description

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

Facility Arkansas Regulation #26 Regulations of the Arkansas Operating PermitProgram

Facility 40 CFR Part 61 Subpart A General Provisions

Facility 40 CFR Part 82 Protection of Stratospheric Ozone

32


The permit specifically identifies the following as inapplicable based upon informationsubmitted by the permittee in an application dated January 9,2009.

Inapplicable Regulations

Description of Regulation Regulatory Affected Source Basis for DeterminationCitation

Standards of Performance for 40 CFR Part 60 Blowing Agent (1) Below the thresholdStorage Vessels for Petroleum Subpart Kb Tank capacity. (2) Not withinLiquids for Which the definition of storageConstruction, Reconstruction, vessel because it is aor Modification Commenced pressurized vesselAfter May 18, 1978, and Prior designed to operate into July 23, 1984. excess of 15 psig.

33


SECTION VII: INSIGNIFICANT ACTIVITIES

The following sources are insignificant activities. Any activity that has a state or federalapplicable requirement shall be considered a significant activity even if this activity meets therritpri::l nf [\')(; 10,d of Regulation ')r:. Ar lict",rl in th", t~hl", 1..",1",,, T~~;~~;+'~~~+~~+;..; ....._....... _-'......._ ......... ,,_oJ_-''''' I '-'..L .&.'-..... __... \...&'-'.1-.1...:.........., '-J.I. .........:H..""" .1..1..1 1..1..1.'--' l.u.UJ.,"-, UVJ.V vv . .l-J.J.~le,lil.l.l\vallL Qvll V lLJ

determinations rely upon the information submitted by the permittee in an application datedJanuary 9, 2009.

Description Category

Finished goods make-up air unit/heaterRollstock make-up air unit/heaterWarehouse heaters/air handlers (3) A-I(fuel burning equipment, each <10 MMBtu/hr and emissions < 10tpy)Storage tanks of 250 gallons or less (maximum 100 vessels,

A-2primarily 55 gallon drums with oil/used oil)Laboratory equipment/vents used exclusively for routine chemicalor physical analysis for quality control or environmental monitoringpurposes including: A-5Blue M ovenQC lab ventWelding and cutting equipment (welding booth, band saws, and

A-7lathes)Containers of 5 gallons or less that do not emit any detectableVOCs or HAPs when closed (maximum 1000 containers, primarily A-8aerosol spray cans)Blowing agent storage (18,000 gallon, pressurized vessel rated at250 psig, designed to operate without emissions)Beringer jet cleanerHot melt adhesiveParts washerSand blasterCooling towers A-13C02 cleanerTalc transferBagging machines with seal barsDrill pressesThermal emboss printersReclaim dryers (2 electric powered centrifugal dryers)Shopvac (back pack style shop vacuum)

34


SECTION VIII: GENERAL PROVISIONS

1. Any terms or conditions included in this permit which specify and reference ArkansasPollution Control & Ecology Commission Regulation 18 or the Arkansas Water and AirPnll11tinn rnntrn! A"t {A r A '\\SLLl_l ()l At COA" 'I ,>CO i-hA ",...lA rv ..;<T;~ ,... .. n~,l m,.. ]..,,..._;h, +~- ..t..;............... _~ .................. ...... _ ............ _ ... .£. .......... \" ..... -.. • .,{ .... ~v I .LV'&' ""'l. ~v'1.J U..:J L.l.l-,"", ~VJ.,"" V.1J.51J.J V..1 aJIU aULl.1VJ.JLY ~Ul l11~

terms or conditions are not required under the Clean Air Act or any of its applicablerequirements, and are not federally enforceable under the Clean Air Act. ArkansasPollution Control & Ecology Commission Regulation 18 was adopted pursuant to theArkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.). Any terms orconditions included in this permit which specify and reference Arkansas PollutionControl & Ecology Commission Regulation 18 or the Arkansas Water and Air PollutionControl Act (A.C.A. §8-4-101 et seq.) as the origin of and authority for the terms orconditions are enforceable under this Arkansas statute. [40 CFR 70.6(b)(2)]

2. This permit shall be valid for a period of five (5) years beginning on the date this permitbecomes effective and ending five (5) years later. [40 CFR 70.6(a)(2) and §26.701(B) ofthe Regulations of the Arkansas Operating Air Permit Program (Regulation 26)]

3. The permittee must submit a complete application for permit renewal at least six (6)months before permit expiration. Permit expiration terminates the permittee's right tooperate unless the permittee submitted a complete renewal application at least six (6)months before permit expiration. If the permittee submits a complete application, theexisting permit will remain in effect until the Department takes final action on therenewal application. The Department will not necessarily notify the permittee when thepermit renewal application is due. [Regulation 26, §26.406]

4. Where an applicable requirement of the Clean Air Act, as amended, 42 U.S.C. 7401, etseq. (Act) is more stringent than an applicable requirement of regulations promulgatedunder Title IV of the Act, the permit incorporates both provisions into the permit, and theDirector or the Administrator can enforce both provisions. [40 CFR 70.6(a)(l)(ii) andRegulation 26, §26.701(A)(2)]

5. The permittee must maintain the following records of monitoring information as requiredby this permit.

a. The date, place as defined in this permit, and time of sampling or measurements;b. The date(s) analyses performed;c. The company or entity performing the analyses;d. The analytical techniques or methods used;e. The results of such analyses; andf. The operating conditions existing at the time of sampling or measurement.

[40 CFR 70.6(a)(3)(ii)(A) and Regulation 26, §26.701(C)(2)]

35


6. The permittee must retain the records of all required monitoring data and supportinformation for at least five (5) years from the date of the monitoring sample,measurement, report, or application. Support information includes all calibration andmaintenance records and all original strip chart recordings for continuous monitoringinstrumentation, and copies of all reports required by this pennit.70.6(a)(3)(ii)(B) and Regulation 26, §26.701(C)(2)(b)]

r A f\ r"'T:'TlL'-tv ~rR

7. The permittee must submit reports of all required monitoring every six (6) months. Ifpermit establishes no other reporting period, the reporting period shall end on the last dayof the anniversary month of the initial Title V permit. The report is due within thirty (30)days of the end of the reporting period. Although the reports are due every six months,each report shall contain a full year of data. The report must clearly identify all instancesof deviations from permit requirements. A responsible official as defined in RegulationNo. 26, §26.2 must certify all required reports. The permittee will send the reports to theaddress below:

Arkansas Department of Environmental QualityAir DivisionATTN: Compliance Inspector Supervisor5301 Northshore DriveNorth Little Rock, AR 72118-5317

[40 C.F.R. 70.6(a)(3)(iii)(A) and Regulation 26, §26.701(C)(3)(a)]

8. The permittee shall report to the Department all deviations from permit requirements,including those attributable to upset conditions as defined in the permit.

a. For all upset conditions (as defined in Regulationl9, § 19.601), the permittee willmake an initial report to the Department by the next business day after thediscovery of the occurrence. The initial report may be made by telephone andshall include:

1. The facility name and location;11. The process unit or emission source deviating from the permit limit;

111. The permit limit, including the identification of pollutants, from whichdeviation occurs;

IV. The date and time the deviation started;v. The duration of the deviation;

VI. The average emissions during the deviation;V11. The probable cause of such deviations;

V111. Any corrective actions or preventive measures taken or being taken toprevent such deviations in the future; and

IX. The name of the person submitting the report.

36


The permittee shall make a full report in writing to the Department within five (5)business days of discovery of the occurrence. The report must include, in addition tothe information required by the initial report, a schedule of actions taken or plannedto eliminate future occurrences and/or to minimize the amount the permit's limitsUTPrp pv('ppr!pr! <:Inr! to rpr!ll('p thp lpnnth of't;.-np thp l;.-n;tC' "'0"0 a...,."aa-la-l T ....o.................... " .. ........... ............~_ '-'""" "' __ ""-__ '- ... .&._ ._...... 0".1..1. V..J.. '-.1..1..1..1"" ".1..1'-' .1.1..1.1..1.1.\.0 VY\,,;.1.\"; "",A""''''''''"'U\'';\..l. ~.1.1"",,

permittee may submit a full report in writing (by facsimile, overnight courier, or othermeans) by the next business day after discovery of the occurrence, and the report willserve as both the initial report and full report.

b. For all deviations, the permittee shall report such events in semi-annual reportingand annual certifications required in this permit. This includes all upsetconditions reported in 8a above. The semi-annual report must include all theinformation as required by the initial and full reports required in 8a.

[Regulation 19, §19.601 and §19.602, Regulation 26, §26.701(C)(3)(b), and 40 CFR70.6(a)(3)(iii)(B)]

9. If any provision of the permit or the application thereof to any person or circumstance isheld invalid, such invalidity will not affect other provisions or applications hereof whichcan be given effect without the invalid provision or application, and to this end,provisions of this Regulation are declared to be separable and severable. [40 CFR70.6(a)(5), Regulation 26, §26.701(E), and A.C.A. §8-4-203 as referenced by A.C.A. §84-304 and §8-4-311]

10. The permittee must comply with all conditions of this Part 70 permit. Any permitnoncompliance with applicable requirements as defined in Regulation 26 constitutes aviolation of the Clean Air Act, as amended, 42 U.S.C. §7401, et seq. and is grounds forenforcement action; for permit termination, revocation and reissuance, for permitmodification; or for denial of a permit renewal application. [40 CFR 70.6(a)(6)(i) andRegulation 26, §26.701(F)(1)]

11. It shall not be a defense for a permittee in an enforcement action that it would have beennecessary to halt or reduce the permitted activity to maintain compliance with theconditions of this permit. [40 CFR 70.6(a)(6)(ii) and Regulation 26, §26.701(F)(2)]

12. The Department may modify, revoke, reopen and reissue the permit or terminate thepermit for cause. The filing of a request by the permittee for a permit modification,revocation and reissuance, termination, or of a notification of planned changes oranticipated noncompliance does not stay any permit condition. [40 CFR 70.6(a)(6)(iii)and Regulation 26, §26.701(F)(3)]

13. This permit does not convey any property rights of any sort, or any exclusive privilege.[40 CFR 70.6(a)(6)(iv) and Regulation 26, §26.701(F)(4)]

37


14. The permittee must furnish to the Director, within the time specified by the Director, anyinformation that the Director may request in writing to determine whether cause exists formodifying, revoking and reissuing, or terminating the permit or to determine compliancewith the permit. Upon request, the permittee must also furnish to the Director copies ofrf"rnrn,;;: rf"ol1irpn hv thp nprrrlit PAr ;ntArrrl<lt;An th", "''''.......;1+'''''' "I.,; ....... " confidentialitv +1.,>.... __ _ -"1.- _- -; - y_ ..L V..L .1..1...&.'-'.1..1..1..1.""''- '-' ".1..1.'-" P"".l.J..I.J.J.l.\.""""" ""J.U.l.1.l.1.:l V.1.l ""'IILIQ.1ILy, LIt\,;.

Department may require the permittee to furnish such records directly to the Directoralong with a claim of confidentiality. [40 CFR 70.6(a)(6)(v) and Regulation 26,§26.701(F)(5)]

15. The permittee must pay all permit fees in accordance with the procedures established inRegulation 9. [40 CFR 70.6(a)(7) and Regulation 26, §26.701(G)]

16. No permit revision shall be required, under any approved economic incentives,marketable permits, emissions trading and other similar programs or processes forchanges provided for elsewhere in this permit. [40 CFR 70.6(a)(8) and Regulation 26,§26.701(H)]

17. If the permit allows different operating scenarios, the permittee shall, contemporaneouslywith making a change from one operating scenario to another, record in a log at thepermitted facility a record ofthe operational scenario. [40 CFR 70.6(a)(9)(i) andRegulation 26, §26.701(I)(1)]

18. The Administrator and citizens may enforce under the Act all terms and conditions in thispermit, including any provisions designed to limit a source's potential to emit, unless theDepartment specifically designates terms and conditions of the permit as being federallyunenforceable under the Act or under any of its applicable requirements. [40 CFR70.6(b) and Regulation 26, §26.702(A) and (B)]

19. Any document (including reports) required by this permit must contain a certification bya responsible official as defined in Regulation 26, §26.2. [40 CFR 70.6(c)(1) andRegulation 26, §26.703(A)]

20. The permittee must allow an authorized representative of the Department, uponpresentation of credentials, to perform the following: [40 CFR 70.6(c)(2) and Regulation26, §26.703(B)]

a. Enter upon the permittee's premises where the permitted source is located oremissions related activity is conducted, or where records must be kept under theconditions of this permit;

b. Have access to and copy, at reasonable times, any records required under theconditions of this permit;

c. Inspect at reasonable times any facilities, equipment (including monitoring and airpollution control equipment), practices, or operations regulated or required underthis permit; and

38


d. As authorized by the Act, sample or monitor at reasonable times substances orparameters for assuring compliance with this permit or applicable requirements.

21. The permittee shall submit a compliance certification with the terms and conditionsC"{"\nt~lnprl in thp T\PrrYllt 1n,...111....1;1'1o pn'YiC'C'lAn limitations CltllinrJn,...r1C1 rv .... "I"1TI"'I. ....1.... ...... P",."+;,.,,coon 'T"t.. ....._'-" ~_ __ y_ ", ""' \.4.\,..1. 0 ",.I..I...I...I.o.,J-.3.1.V.l..1. .1..1..1. J. Ul.l. .I..l~, ,.:n.u.1.luu.lU.::J, VI VVVl.n... Pl«\,.1\..I\.1"".:'). .11\:i

permittee must submit the compliance certification annually within 30 days following thelast day of the anniversary month of the initial Title V permit. The permittee must alsosubmit the compliance certification to the Administrator as well as to the Department.All compliance certifications required by this permit must include the following: [40CFR 70.6(c)(5) and Regulation 26, §26.703(E)(3)]

a. The identification of each term or condition of the permit that is the basis of thecertification;

b. The compliance status;c. Whether compliance was continuous or intermittent;d. The methodes) used for determining the compliance status of the source, currently

and over the reporting period established by the monitoring requirements of thispermit; and

e. Such other facts as the Department may require elsewhere in this permit or by§114(a)(3) and §504(b) of the Act.

22. Nothing in this permit will alter or affect the following: [Regulation 26, §26.704(C)]

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

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

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

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

23. This permit authorizes only those pollutant emitting activities addressed in this permit.[A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

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

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

the current deadline and documents reasons it cannot be met.

39


[Regulation 18, §18.314(A), Regulation 19, §19.416(A), Regulation 26, §26.1013(A),A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, and 40 CFR Part 52,Subpart E]

25. The nermirtee m~v Tenllf>..:t in urritlno !'Inri !'It ]P!'I",t 10 rI",,,,,, ;n ",,.1,,,,n£',,, t"'......nA..n~'- ---' r -'--------'-' ~---,,/ -,-_ 0 -.... '" _ u .. .J v -.~J ~ ..1...1..1. UU ~.1'"''''''' "''''''.1.1.1!-,V.1Ul)

emissions and/or testing that would otherwise exceed an emission rate, throughputrequirement, or other limit in this permit. No such activities are authorized until thepermittee receives written Department approval. Any such emissions shall be included inthe facility's total emissions and reported as such. The Department may grant such arequest, at its discretion under the following conditions:

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

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

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

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

[Regulation 18, §18.314(B), Regulation 19, §19.416(B), Regulation 26, §26.1013(B),A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, and 40 CFR Part 52,Subpart E]

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

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

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

application by the permittee.

[Regulation 18, §18.314(C), Regulation 19, §19.416(C), Regulation 26, §26.1013(C),A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, and 40 CFR Part 52,Subpart E]

40

CERTIFICATE OF SERVICE

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

~)+hPactiv Corporation, 1105 Industrial Lane, Malvern, AR, 72104, on this ;:) day

Pam Owen, AAII, Air Division

pactiv corporation draft permit #0916-aop-r4 afin: 30-00071 · 2019. 12. 30. · draft permit...

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