Permit #: 1427-AOP-R6 AFIN: 35-00025 Page 1 of 12 ...€¦ · The Protein Shakers remove excess hulls and large fiber from the meat and are mixed back into the finished hull product

Permit #: 1427-AOP-R6 AFIN: 35-00025 Page 1 of 12 STATEMENT OF BASIS

for the issuance of Draft Air Permit # 1427-AOP-R6 1. PERMITTING AUTHORITY:

Arkansas Department of Environmental Quality 8001 National Drive Post Office Box 8913 Little Rock, Arkansas 72219-8913

2. APPLICANT:

Planters Cotton Oil Mill, Inc. 2901 Planters Drive Pine Bluff, Arkansas 71601

3. PERMIT WRITER:

James G, Siganos, P.E. 4. PROCESS DESCRIPTION AND SIC CODE:

NAICS Description: Other Oil Seed Processing - Cottonseed Oil Mill NAICS Code: 311223

5. SUBMITTALS: May 28, 2003 6. REVIEWER=S NOTES:

Planters Cotton Oil Mill is proposing to install two (2) Protein Shakers with one (1) 54” cyclone, in the separation Department, to be designated as SN-62. This minor modification will remove larger fiber particles and any remaining hulls from the meat stream, and will help maintain a high protein content, and will improve the quality of the finished meal product. The Protein Shakers remove excess hulls and large fiber from the meat and are mixed back into the finished hull product. The addition of two (2) Protein Shakers will help maintain a higher protein content and will improve the equality of the finished meal product. The exhaust from each Protein Shaker will be routed through a new 54” cyclone The flow rate through the new cyclone will be 8,000 cfm and will handle both shakers. The excess hulls and larger fibers removed from the meat will be mixed back into the finished hull product. In addition during the modification period Planters Cotton Oil Mill will replace existing boiler

Permit #: 1427-AOP-R6 AFIN: 35-00025 Page 2 of 12 SN-44, which blew up in October 2002, and plans to overhaul existing boiler SN-45. A temporary boiler will be taken out of service and removed from the site. Boiler #1 (SN-44) was installed in 2003. Boiler #2 was installed in 1993 and overhauled in 2003. 7. COMPLIANCE STATUS:

The following summarizes the current compliance status of the facility including active/pending enforcement actions and recent compliance activities and issues: The facility violated their monthly hexane usage limit for several months during 2002 and January 2003. In addition the facility was also found to be in violation for record keeping. A CAO has been issued to address these violations.

8. APPLICABLE REGULATIONS:

A. Applicability Did the facility undergo PSD review in this permit (i.e., BACT, Modeling, et cetera) (Y/N) N Has this facility underwent PSD review in the past (Y/N) ___N___ Permit # ______________ Is this facility categorized as a major source for PSD? (Y/N) N

$ 100 tpy and on the list of 28 (100 tpy)? (Y/N) ___N __ $ 250 tpy all other (Y/N) ___N*__

Other applicable regulations *VOC emissions are greater than 250 tpy . Consideration of fugitive emissions (32.4 lb/hr) results in applicable rate below 250 tpy

B. PSD Netting Was netting performed to avoid PSD review in this permit? (Y/N) N

If so, indicate increases and decreases used in netting for PSD purposes only.

Permit #: 1427-AOP-R6 AFIN: 35-00025 Page 3 of 12

C. Source and Pollutant Specific Regulatory Applicability

Source

Pollutant

Regulation

[NSPS, NESHAP (Part 61 & Part 63), or PSD only]

SN-44

ALL

NSPS Subpart Dc

SN-45

ALL

NSPS Subpart Dc

9. EMISSION CHANGES:

The following table summarizes plantwide emission changes associated with this permitting action.

Plantwide Permitted Emissions (ton/yr)

Pollutant

Air Permit

1427-AOP-R5

Air Permit

1427-AOP-R6

Change

PM

228.1 235.7

+7.6 PM10 227.4 237.6 +10.2

SO2

0.2 0.2

0

VOC

252.7 255.1

+2.40

CO

6.6 27.6

21.0

NOx

25.8 21.6

-4.20

Hexane

252.1 252.1

0

Permit #: 1427-AOP-R6 AFIN: 35-00025 Page 4 of 12 10. MODELING ( performed for previous permit R4):

A. Criteria Pollutants

Pollutant

Emission

Rate (lb/hr)

NAAQS

Standard (µg/m3)

Averaging

Time

Highest

Concentration (µg/m3)

% of

NAAQS

50

Annual

N/A

0%

PM10

64.5

150

24-hour

N/A

0%

80

Annual

N/A

0%

1,300

3-hour

N/A

0%

SO2

0.2

365

24-hour

N/A

0%

NOX 5.0

100

Annual

N/A

0%

VOC

64.1

0.12

1-hour (ppm)

N/A

0%

10,000

8-hour

N/A

0%

CO

6.4

40,000

1-hour

N/A

0% B. Non-Criteria Pollutants

1st Tier Screening (PAER)

Estimated hourly emissions from the following sources were compared to the Presumptively Acceptable Emission Rate (PAER) for each compound. The PAER was deemed by the Department to be the product, in lb/hr, of 0.11 and the Threshold Limit Value (mg/m3), as listed by the American Conference of Governmental Industrial Hygienists (ACGIH).

Pollutant

TLV

(mg/m3)

PAER (lb/hr) = 0.11*TLV

Proposed lb/hr

Pass?

n-hexane

176

19.36

40.32

NO


2nd Tier Screening (PAIL)

SCREEN3 air dispersion modeling was performed on the estimated hourly emissions from the following sources, in order to predict ambient concentrations beyond the property boundary. The Presumptively Acceptable Impact Level (PAIL) for each compound was deemed by the Department to be one one-hundredth of the Threshold Limit Value, as listed by the ACGIH.

Pollutant

(PAIL, µg/m3) = 1/100 of Threshold Limit Value

Modeled

Concentration (µg/m3)

Pass?

n-hexane

1760

1464

YES 11. CALCULATIONS:

Note: The data shown below was taken from the previous permit, #1427-AOP-R5, except for the new Protein Shakers (SN-62). Also SN-44 and SN-45 can be considered as replacements.

SN

Emission

Factor Source (AP-42,

Testing, etc)

Emission Factor

and units (lbs/ton, lbs/hr,

etc)

Control

Equipment Type

( if any)

Control

Equipment Efficiency

Comments

(Emission factor controlled/ uncontrolled, etc)

01

testing

0.0528 gr/dscf

cyclone

---

Had a safety factor of 50%

02

testing

0.0230 gr/dscf

cyclone

---

Factor modified due to addition of another yclone c

03

testing

0.0230 gr/dscf

cyclone

---

Factor modified due to addition of another cyclone

04

testing

0.0191 gr/dscf

cyclone

---


05

testing

0.0154 gr/dscf

cyclone

---

AP-42, woodworking yclone c

14

testing

0.0154 gr/dscf

cyclone

---


06

AP-42, mass balance

0.0168 gr/dscf

cyclone

---

emissions reapportioned for SN-06 through 12 due to addition of 4 new cyclones(SN-48-51)


07 AP-42, mass balance

0.0168 gr/dscf

cyclone

---

emissions reapportioned for SN-06 through 12 due to addition of 4 new yclones(SN-48-51) c

08

AP-42, mass balance

0.0168 gr/dscf

cyclone

---


09

AP-42, mass balance

0.0168 gr/dscf

cyclone

---


10

AP-42, mass balance

0.0168 gr/dscf

cyclone

---


11

AP-42, mass balance

0.0168 gr/dscf

cyclone

---


12

AP-42, mass balance

0.0168 gr/dscf

cyclone

---


48

AP-42, mass balance

0.0168 gr/dscf

cyclone

---


49

AP-42, mass balance

0.0168 gr/dscf

cyclone

---


50

AP-42, mass balance

0.0168 gr/dscf

cyclone

---

emissions reapportioned for SN-06 through 12 due to addition of 4 new cyclones(SN-48-51)


51 AP-42, mass balance

0.0168 gr/dscf

cyclone

---


13

testing

0.03 gr/dscf

cyclone

---


15

testing, mass balance

0.0256

cyclone

---


52

testing, mass

alance b

0.0256

cyclone


16

testing

0.0181

cyclone

---


17

testing

0.0181

cyclone

---


18

testing

0.01gr/dscf

cyclone

---

Similar source

19

testing

0.01gr/dscf

cyclone

---

Similar source

20

testing

0.01gr/dscf

cyclone

---

Similar source

21

testing

0.01gr/dscf

cyclone

---

Similar source

22

testing

0.01gr/dscf

cyclone

---

Similar source

23

testing

0.01gr/dscf

cyclone

---

Similar source

24

testing

0.01gr/dscf

cyclone

---

Similar source

25

testing

0.01gr/dscf

cyclone

---

Similar source

26

testing

0.01gr/dscf

cyclone

---

Similar source

57

testing

0.01gr/dscf

cyclone

---

Similar source

27

testing

0.03 gr/dscf

cyclone

---

AP-42, woodworking cyclone

28

testing

0.03 gr/dscf

cyclone

---


29

Moved to SN-02

30

AP-42

0.03 gr/dscf

cyclone

---


31

testing

0.0263

cyclone

---

Tested at less than 90% capacity


32 solvent not recovered

0.3 gal/ton

---

---

Based on 31.5% assignment. Assumes 100% lost at facility.

33

Source Emissions Deleted

34

testing

0.03 gr/dscf

cyclone

---


35

Emissions routed to drum filter (SN-58)

36


37

testing

0.03 gr/dscf

cyclone

---


38

testing

0.03 gr/dscf

cyclone

---


39


40


41

Source Removed from Service

42

testing solvent lost

PM, 0.02 gr/dscf VOC, 0.3 gal/ton

cyclone

---

AP-42, woodworking cyclone Based on 8.6% assignment. Assumes 100% lost at facility. Emissions reapportioned

ue to addition of SN-56. d

43 testing solvent lost


cyclone

---

AP-42, woodworking cyclone Based on 8.6% assignment. Assumes 100% lost at facility. Emissions reapportioned

ue to addition of SN-56. d

56 testing solvent lost


cyclone

---

AP-42, woodworking cyclone Based on 8.6% assignment. Assumes 100% lost at facility. Emissions reapportioned due to addition of SN-56.


44 AP-42, natural gas

PM10, 13.7 lb/mmscf

SO2, 0.6 lb/mmscfVOC, 2.784

lb/mmscf CO, 35 lb/mmscf

NOX, 140 lb/mmscf

---

---

45

AP-42, natural gas

PM10, 13.7 lb/mmscf

SO2, 0.6 lb/mmscfVOC, 2.784

lb/mmscf CO, 35 lb/mmscf

NOX, 140 lb/mmscf

---

---

46

solvent lost

VOC, 0.3 gal/ton

---

---

Assumes remaining olvent lost at the facility. s

47

unsubstantiated

4.23 lb/hr

---

---

Requiring them to test the ource. s

55

AP-42

0.03 gr/dscf

cyclone

---


58

manufacturer=s specs

0.004 gr/dscf

C

C

Used 33% factor of safety in emission factor, factor was supplied by

anufacturer of filter m

61 AP-42

0.03 gr/dscf

cyclone

---


62

AP-42

0.03 gr/dscf

cyclone

---


Permit #: 1427-AOP-R6 AFIN: 35-00025 Page 10 of 12 12. TESTING REQUIREMENTS: Note: The data shown below was taken from the previous permit, #1427-AOP-R5.

This permit requires stack testing of the following sources.

SN(s)

Pollutant

Test

Method

Test

Interval Justification For Test Requirement

01-04, 14,15,

27,28, 31 PM/PM10

5

1 time every 5 years

Testing was performed when facility was brand new. A portion of the previous testing was not performed at 90% of capacity.

47

PM/PM10

5

1 time

Consultant could not justify the numbers they submitted. They submitted numbers that were not public information, no longer had access to, and could not provide the reviewer with a copy.

13. MONITORING OR CEMS

Not Applicable 14. RECORD KEEPING REQUIREMENTS

Permit #: 1427-AOP-R6 AFIN: 35-00025 Page 11 of 12 Note: The data shown below was taken from the previous permit, #1427-AOP-R5 except for the new and overhauled boilers (SN-44 and SN-45).

The following are items (such as throughput, fuel usage, VOC content of coating, etc) that must be tracked and recorded, frequency of recording and whether records are needed to be included in any annual, semiannual or other reports.

SN

Recorded Item

Limit (as established in

permit)

Frequency*

Report (Y/N)*

Facility

Cottonseed Throughput

300,000 tpy

monthly

no

32,42,43,46

& 56

hexane

270 gallon per day

90,000 gallon per year

daily

monthly

no no

44 & 45 Natural gas usage Operating boilers at maximum capacity monthly no

* Indicate frequency of recording required for the item (Continuously, hourly, daily, etc.) ** Indicates whether the item needs to be included in reports 15. OPACITY Note: The data shown below was taken from the previous permit, #1427-AOP-R5, except for the new Protein Shakers (SN-62). Also SN-44 and SN-45 can be considered as replacements.

SN

Opacity

%

Justification

(NSPS limit, Dept. Guidance, etc)

Compliance Mechanism

(daily observation, weekly, control

equipment operation, etc)

18-28, 35-37, 44, 45, 47

5%

Previous Permit

Weekly Observation

01-15, 31, 38, 48-52, 55, 58, 59

10%

Previous Permit

Daily Observation

62 10% Dept Guidance Weekly Observation

Permit #: 1427-AOP-R6 AFIN: 35-00025 Page 12 of 12 16. DELETED CONDITIONS: Note: The data shown below was taken from the previous permit, #1427-AOP-R5.

The following Specific Conditions were included in the previous permit, but deleted for the current permitting action. The numbering sequence did not change.

Former

SC

Justification for removal 9, 10, 11

& 12

These Specific Conditions were applicable to the 3rd cut linter machines which were converted to 2nd cut linter machines.

17. VOIDED, SUPERSEDED OR SUBSUMED PERMITS

List all active permits for this facility which are voided/superseded/subsumed by issuance of this permit.

Permit #

1427-AOP-R5 18. CONCURRENCE BY:

The following supervisor concurs with the permitting decision:

_______________________ Thomas Rheaume, P.E.

Documents

Permit #: 1427-AOP-R6 AFIN: 35-00025 Page 1 of 12 ...€¦ · The Protein Shakers remove excess hulls and large fiber from the meat and are mixed back into the finished hull product