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Tony Grant Plant Manager TGRC the Gates Corporation 1801 North Lincoln Siloam Springs, AR 72761

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Tony Grant Plant Manager TGRC the Gates Corporation 1801 North Lincoln Siloam Springs, AR 72761 ADEQ ARK ANSAS Department of Environmental Quality December 23, 2013 Tony Grant Plant Manager TGRC The Gates Corporation 1801 North Lincoln Siloam Springs, AR 72761 Dear Mr. Grant: The enclosed Permit No. 0378-AR-15 is your authority to construct, operate, and maintain the equipment and/or control apparatus as set forth in your application initially received on 10/1/2013. After considering the facts and requirements ofA.C.A. §8-4-101 et seq., and implementing regulations, I have determined that Permit No. 0378-AR-15 for the construction, operation and maintenance ofan air pollution control system for TGRC The Gates Corporation to be issued and effective on the date specified in the permit, unless a Commission review has been properly requested under Arkansas Department ofPollution 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 public comments on the record may request an adjudicatory hearing and Commission review ofthe final permitting decisions as provided under Chapter Six ofRegulation 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 72201. Ifyou have any questions about filing the request, please call the Commission at 501-682-7890. Sincerely, Mike Bates Chief, Air Division ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY 5301 NORTHSHORE DRIVE / NORTH UTILE ROCK / ARKANSAS 72118-5317 / TELEPHONE 501-682-0744 / FAX 501-682-0880 www.adeq.state.ar.us ADEQ MINOR SOURCE AIR PERMIT Permit No. : 0378-AR-15 IS ISSUED TO: Gates Corporation 1801 North Lincoln Siloam Springs, AR 72761 Benton County AFIN: 04-00111 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. SEC. 8-4-101 ETSEQ.) AND THE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: lA,~ December 23, 2013 Mike Bates Date Chief, Air Division Gates Corporation Permit #: 0378-AR-15 AFIN: 04-00111 Table ofContents Section I: FACILITY INFORMATION 4 Section II: INTRODUCTION 5 Summary ofPermit Activity 5 Process Description 5 Regulations 6 Total Allowable Emissions 7 Section III: PERMIT HISTORY 8 Section IV: EMISSION UNIT INFORMATION 11 NSPS 40 CFR Part 60 Subpart De Conditions 16 NESHAP 40 CFR Part 63 Subpart ZZZZ Conditions 16 Section V: INSIGNIFICANT ACTIVITIES 24 Section VI: GENERAL CONDITIONS 25 Appendix A: NSPS 40 CFR Part 60 Subpart De Appendix B: NESHAP 40 CFR Part 63 Subpart ZZZZ 2 Gates Corporation Permit #: 0378-AR-15 AFIN: 04-00111 List ofAcronyms and Abbreviations A.C.A. Arkansas Code Annotated AFIN ADEQ Facility Identification Number CFR Code ofFederal Regulations CO Carbon Monoxide HAP Hazardous Air Pollutant lb/hr Pound Per Hour No. Number NOx Nitrogen Oxide PM Particulate Matter PMIO Particulate Matter Smaller Than Ten Microns S02 Sulfur Dioxide Tpy Tons Per Year UTM Universal Transverse Mercator VOC Volatile Organic Compound 3 Gates Corporation Permit #: 0378-AR-15 AFIN: 04-00111 Section I: FACILITY INFORMATION PERMITTEE: Gates Corporation AFIN: 04-00111 PERMIT NUMBER: 0378-AR-15 FACILITY ADDRESS: 1801 North Lincoln Siloam Springs, AR 72761 MAILING ADDRESS: 1801 North Lincoln Siloam Springs, AR 72761 COUNTY: Benton County CONTACT NAME: Tony Grant CONTACT POSITION: Plant Manager TELEPHONE NUMBER: 479-524-1211 REVIEWING ENGINEER: Adam McDaniel UTM North South (Y): Zone 15: 4007158.07 m UTM East West (X): Zone 15: 363237.02 m 4 Gates Corporation Permit #: 0378-AR-15 AFIN: 04-00111 Section II: INTRODUCTION Summary ofPermit Activity Gates Corporation of 1801 North Lincoln Street, Siloam Springs, Benton County, Arkansas owns and operates a rubber belt manufacturing facility. The facility submitted a de minimis application to modify their permit to install additional rubber autoclaves (SN-09), additional belt and flat grinders (SN-11), and a 29.2 MMBtu Natural Gas Boiler (SN-15). For SN-09 and SN­ 11, the hourly and annual throughput limits will not be changed and the HAP emissions were updated. Also, the facility submitted a modification application to include the fire pump diesel engine (SN-16) and the emergency generator (SN-17) as permitted sources instead of insignificant activities. Boilers #1 and #2 (SN-01 and SN-02 respectively) had their HAP emissions added to the permit. The total annual permitted emission rate limit changes associated with this modification includes: +1.3 tpy PM/PMIO, +0.3 tpy S02, +1.0 tpy VOC, +11.7 tpy CO, +14.5 tpy NOx, and a small change in most HAPs due to the updated emissions. Process Description Boilers (SN-01 and SN-02) Boilers #1 and #2 are used to provide steam for thermal treatment in the rubber calendaring and belt curing processes. Boiler #1 (SN-01) is a 40.8 MMBtu/hr boiler. It was installed in 1975 and brought on line in 1977. Boiler #2 (SN-02) is a 40.8 MMBtu/hr boiler. It was installed in 1978. They are both fueled by natural gas and fuel oil as a backup. They are not subject to NSPS 40 CFR Part 60 Subpart De because ofthe installation date. SN-01 and SN-02 are not subject to NESHAP 40 CFR Part 63 Subpart JJJJJJ because they meet the definition ofa gas-fired boiler (§63.11195(e)). Belt Builder Area (SN-08) A lathe (builder) is used to build the belts at the facility. Layers ofcalendar stock and treated cord are built-up on the builder to form a belt slab. Tackifiers, consisting of a mixture oftoluene and hexane are applied between the different layers as needed. This source was installed in 1977. Gates uses calendar stock and treated cord to form belt slab. Tackifiers and cement are applied between different layers as needed. Potential emissions are based on the maximum usage ofthe solvent in the tackifiers and cement. The standard tackifier used in this area does not contain HAPs. For certain types ofrubber products, toluene is used as the tackifier. Rubber Autoclave Curing (SN-09) The kettle autoclaves may cure either complete slab stock directly from the builder (Bandless Belts) or the stock may be cut prior to placement on rings and then cured with autoclaves (Banded Belts). In the autoclave process, heat is applied via steam injection under pressure to cure the rubber to the proper consistency. During the curing process, certain volatile components ofthe rubber used to manufacture the belt are driven off. This source was installed in 1977. Rubber Platen Press Curing (SN-10) Some belts at the facility are cured in a step-wise press curing process called Step-Cure (platen press curing). This source was installed in 1977. 5 Gates Corporation Permit #: 0378-AR-15 AFIN: 04-00111 Belt and Flat Grinding (SN-11) Belt profiles are completed through the grinding ofbelts with the grinding wheels on both a horizontal and vertical axis. The specific profile for a given belt depends upon the end use specification for that belt. Approximately 34% ofthe weight ofthe belt is ground off. Emissions from the belt grinders are routed through numerous cyclones numerous cyclones and electrostatic precipitators, which are manifold together and then routed to three stacks vented to the outdoor air. Emissions from the flat grinders are routed through cyclones and fabric filters and then routed either back inside the plant or to stacks vented to the outdoor air. Boilers (SN-15) Boiler #3 is used to provide steam for thermal treatment in the rubber calendaring and belt curing processes. Boiler #3 is a 29.2 MMBTU/hr boiler. It was installed in 2013 and fueled by natural gas only. SN-15 is subject to NSPS 40 CFR Part 60 Subpart De because ofthe installation date, but it is not subject to NESHAP 40 CFR Part 63 Subpart JJJJJJ because it meets the definition of a gas-fired boiler (§63.11195(e)). Fire Pump Diesel Engine (SN-16) SN-16 is a 112 bhp 4S-RB SI Emergency Generator which was ordered and installed in 2002. Emergency Generator (SN-17) SN-17 is a 185 bhp CI Emergency Fire Pump Diesel Engine which was ordered and installed in 1978. Regulations The following table contains the regulations applicable to this permit. Regulations Arkansas Air Pollution Control Code, Regulation 18, effective June 18,2010 Regulations ofthe Arkansas Plan ofImplementation for Air Pollution Control, Regulation 19, effective July 27,2013 NSPS 40 CFR Part 60 Subpart De - Standards ofPerformance for Small Industrial- Commercial-Institutional Steam Generating Units NESHAP 40 CFR Part 63 Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutantsfor Stationary Reciprocating Internal Combustion Engines 6 Gates Corporation Permit #: 0378-AR-15 AFIN: 04-00111 Total Allowable Emissions The following table is a summary ofemissions from the facility. This table, in itself, is not an enforceable condition ofthe permit. TOTAL ALLOWABLE EMISSIONS Emission Rates Pollutant lb/hr tpy PM 5.1 9.3 PMIO 5.1 9.3 S0 2 42.0 31.5 VOC 81.9 41.5 CO 13.6 43.3 NOx 22.3 58.2 Single HAP 28.38 7.205 Total HAP 60.881631 16.548 1,3-Butadiene 0.3586206 0.1183057 Acetophenone 12.301 2.1401 Aniline 0.132 0.031 Benzene 0.3257981 0.062573 Carbon Disulfide 28.38 7.205 Hexane 0.9105 0.7116 Methylene Chloride 0.8380354 0.14970886 Toluene 7.7811993 3.816654 Styrene 0.0289 0.00498 Acrolein 0.07076 0.0120559 Phenol 0.1252 0.02934 Propylene oxide 0.872 0.572 Tetrachloroethylene 1.4587 0.24367 4-methyl-2-Pentanone 1.05 0.18 bis(2-ethylhexyl)phathalate 0.56614 0.10934 Carbonyl Sulfide 3.3229 0.7511 Cumene 0.239 0.0495 Isooctane 0.121 0.0209 2-Chloro-l,3-Butadiene 0.832 0.139 Cadmium Compounds 0.0015495 0.000569 Lead 0.0162 0.0027 m-Xylene + p-Xylene 1.0929 0.1945 Nickel 0.0934281 0.016131 7 Gates Corporation Permit #: 0378-AR-15 AFIN: 04-00111 Section III: PERMIT HISTORY Permit #0378-A was the initial air permit for Gates Rubber Company.
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