1427-Aop-R12
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RESPONSE TO COMMENTS PLANTERS COTTON OIL MILL, INC. PERMIT #1427-AOP-RI2 AFIN: 35-00025 On October 19,2013, the Director ofthe Arkansas Department ofEnvironmental Quality gave notice ofa draft permitting decision for the above referenced facility. During the comment period, written comments on the draft permitting decision were submitted by the facility. The Department's response to these issues follows. Note: The following page numbers and condition numbers refer to the draft permit. These references may have changed in the final permit based on changes made during the comment period. Comment #1: Plantwide Condition #10 (and the Statement ofBasis #14): "Please remove the requirements for stack testing in its entirety. This stack test was performed on July 19,2012 and July 20, 2012." Response to Comment #1: Draft Plantwide Condition #10 has been removed from the final permit. The SOB has been updated to reflect the change. Comment #2: Specific Condition #42: "Please change the opacity limit from 5% to 20%. Due to the high particulate emission rate, this source cannot meet the 5% limit." Response to Comment #2: The opacity limit for SN-37, Meal Loading Unit, has been increased to 20% in Specific Condition #42. In addition, the facility will be required to conduct visible emissions readings on a daily basis per Specific Condition #43. Page 1 of 1 ADEQ ARK ANSAS Department of Environmental Quality February 6, 2014 John Jefferson Senior Vice-President Planters Cotton Oil Mill, Inc. 2901 Planters Drive Pine Bluff, AR 71601 Dear Mr. Jefferson: The enclosed Permit No. 1427-AOP-R12 is your authority to construct, operate, and maintain the equipment and/or control apparatus as set forth in your application initially received on 12/16/2011. After considering the facts and requirements ofA.C.A. §8-4-101 et seq., and implementing regulations, I have determined that Permit No. 1427-AOP-R12 for the construction, operation and maintenance ofan air pollution control system for Planters Cotton Oil Mill, Inc. 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.odeq.stote.or.us ADEQ OPERATING AIR PERMIT Pursuant to the Regulations ofthe Arkansas Operating Air Permit Program, Regulation 26: Permit No. : 1427-AOP-R12 IS ISSUED TO: Planters Cotton Oil Mill, Inc. 2901 Planters Drive Pine Bluff, AR 71601 Jefferson County AFIN: 35-00025 THIS PERMIT AUTHORIZES THE ABOVE REFERENCED PERMITTEE TO INSTALL, OPERATE, AND MAINTAIN THE EQUIPMENT AND EMISSION UNITS DESCRIBED IN THE PERMIT APPLICATION AND ON THE FOLLOWING PAGES. THIS PERMIT IS VALID BETWEEN: September 20,2011 AND September 19,2016 THE PERMITTEE IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: February 6, 2014 Mike Bates Date Chief, Air Division Planters Cotton Oil Mill, Inc. Permit #: 1427-AOP-RI2 AFIN: 35-00025 Table ofContents SECTION I: FACILITY INFORMATION 5 SECTION II: INTRODUCTION 6 Summary ofPermit Activity 6 Process Description 6 Regulations 9 Emission Summary 10 SECTION III: PERMIT HISTORy 15 SECTION IV: SPECIFIC CONDITIONS 20 SN-Ol 1st Cut Linter Machines 20 SN-02, 03, & 04 2nd Cut Linter Machines 21 SN-05 & 14 Salvage Reclaim 22 SN-06-l2 and 48-51 Lint Cleaners 23 SN-13 Seed Cleaner 26 SN-15 Recycling System 28 SN-52 Recycling System 29 SN-16 & 17 Bailing Presses 30 SN-18 through 26 and 57 Seed Cleaners 31 SN-27 and 28 Rock Traps #1 and #2 34 SN-29 Stick and Burr Machine 36 SN-30 Motes Beater/Pre-lint Cleaner 38 SN-31 Decorticating/Separating 40 SN-32, 42, 43, 46, and 56 Solvent Extraction Plant 41 SN-34 Dump Enclosure 45 SN-35 Hammennill 46 SN-36 Meal Loading Enclosure 48 SN-37 Meal Loading Unit 49 SN-77 Hull Loading Unit 51 SN-39 and 40 Sacked Hull Houses 52 SN-44 and 45 Boilers #1 and #2 53 SN-47 Bulk House Cooling Fans 55 SN-55 and 61 Trash Beaters #1 and #2 58 SN-58 (RFD-l) & SN-59 (RFD-2) Rotary Drum Filters #1 and #2 59 SN-60 Portable Material Loading Units 61 SN-62 Protein Shakers (Cyclone PS-l) 62 SN-63 Trash Shaker Receiving 63 SN-64 Rotary Drum Filter (RDF-3) 64 SN-65 through SN-71 Hull Shaker Fans, Cascade Fans, and Hull Shaker/Cascade Fans 66 SN-73 Black Cotton Seed Tank 67 SN-74 Baghouse 69 SN-75 Pellet Mill Storage 71 SN-76 Cooling Tower 72 SN-78 Shipping Conveyor 74 SECTION V: COMPLIANCE PLAN AND SCHEDULE 75 SECTION VI: PLANTWIDE CONDITIONS 76 2 Planters Cotton Oil Mill, Inc. Permit #: 1427-AOP-R12 AFlN: 35-00025 Permit Shield 79 Title VI Provisions 81 SECTION VII: INSIGNIFICANT ACTIVITIES 83 SECTION VIII: GENERAL PROVISIONS 84 Appendix A: 40 CFR Part 60 Subpart De Appendix B: 40 CFR Part 63 Subpart GGGG Appendix C: ADEQ Continuous Emission Monitoring Systems Conditions 3 Planters Cotton Oil Mill, Inc. Permit #: 1427-AOP-R12 AFIN: 35-00025 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 MVAC Motor Vehicle Air Conditioner No. Number NO x Nitrogen Oxide PM Particulate Matter PM 10 Particulate Matter Smaller Than Ten Microns SNAP Significant New Alternatives Program (SNAP) S02 Sulfur Dioxide SSM Startup, Shutdown, and Malfunction Plan Tpy Tons Per Year UTM Universal Transverse Mercator VOC Volatile Organic Compound 4 Planters Cotton Oil Mill, Inc. Permit #: 1427-AOP-RI2 AFIN: 35-00025 SECTION I: FACILITY INFORMATION PERMITTEE: Planters Cotton Oil Mill, Inc. AFIN: 35-00025 PERMIT NUMBER: 1427-AOP-RI2 FACILITY ADDRESS: 2901 Planters Drive Pine Bluff, AR 71601 MAILING ADDRESS: 2901 Planters Drive Pine Bluff, AR 71601 COUNTY: Jefferson County CONTACT NAME: John Jefferson CONTACT POSITION: Senior Vice-President TELEPHONE NUMBER: 870-545-3631 REVIEWING ENGINEER: Amanda Leamons UTM North South (Y): Zone 15: 3787578.04 m UTM East West (X): Zone 15: 592931.50m 5 Planters Cotton Oil Mill, Inc. Permit #: 1427-AOP-R12 AFIN: 35-00025 SECTION II: INTRODUCTION Summary ofPermit Activity Planters Cotton Oil Mill (Planters) is located at 2901 Planters Drive in Pine Bluff, Arkansas where it currently produces vegetable oil from cottonseed separation and solvent extraction (NAICS 311223). This permit revision includes a modification to: • Remove the English Boiler (SN-72) from the permit; • Permit a previously installed drag conveyor (SN-78); • Allow the facility the flexibility ofusing the seed houses to also store hulls; • Permit the rerouting ofSN-62 and SN-63 to the existing baghouse, SN-74; • Permit the previously installed Pellet Mill, SN-75; • Permit the previously installed Cooling Tower, SN-76; • Remove the cyclone from SN-38 in order to convert it from a Bulk Hull House to a Bulk Meal House; • Install a new auger type conveyor to direct meal from the Meal Storage Tanks to the Bulk Meal House; • Install a new Hull Loading Unit at Seed House #15; and • Convert the Hull Loading Enclosure (SN-37) to a Meal Loading Unit. The above listed changes at the facility result in overall annual permitted emission limit decreases of9.5 tons PM, 7.3 tons PMIO, 17.6 tons S02, 7 tons VOC, 74.5 tons CO, 26.7 tons NO x and 4.3 tons combined HAP. Process Description Receiving and Storage: The mill receives cottonseed by truck. Each truck is weighed and then sent to one ofthe seed dumps. The cottonseed is dumped from the trucks at a 45 degree angle into receiving pits. There are receiving pits at the Main Facility (also referred to as the Active Mill), the Lower Mill on Michigan Street, and the Old Mill on East s" Avenue across the railroad tracks. Since pneumatic conveying could result in cottonseed damage, mechanical conveying is used to transfer the cottonseed from the receiving pits. A screw conveyor pushes the seed to the vertical elevators which transfer the seed to the elevated system ofbelt conveyors. The belt conveyors carry seed either to one ofthe feed storage houses or directly to the seed cleaning room for processing. Seed stored at the Lower Mill or the Old Mill is conveyed to the Main Facility for processing. 6 Planters Cotton Oil Mill, Inc. Permit #: 1427-AOP-R12 AFIN: 35-00025 Cottonseed Cleaning: Cottonseed is mechanically conveyed to the cleaning area where it is processed through seed cleaning units. These units remove leaves, twigs, pieces ofbolls, sand and other material picked up in the fields or in handling. Lint and trash are collected by cyclones. After cleaning, the seed is conveyed to the lint room. Cottonseed Delinting and Lint Cleaning: In the lint room, the delinting machines cut the short fibers offofthe seeds. The lint is removed by brushes or air and then collected and conveyed to the baling room.