Jerry Mcpherson, Manager of Facilities Hino Motors

ADEQ ARK ANSAS Department of Environmental Quality

Jerry McPherson, Manager ofFacilities Hino Motors Manufacturing 100 Hino Blvd Marion,PJR 72364

Dear Mr. McPherson:

The enclosed Pennit No. 2070-PJR-6 is your authority to construct, operate, and maintain the equipment and/or control apparatus as set forth in your application initially received on 1212112009.

After considering the facts and requirements ofA.c.A. §8-4-101 et seq., and implementing regulations, I have detennined that Pennit No. 2070-PJR-6 for the construction, operation and maintenance ofan air pollution control system for Hino Motors Manufacturing be issued and effective on the date specified in the pennit, unless a Commission review has been properly requested under Arkansas Department ofPollution Control & Ecology Commission's Administrative Procedures, Regulation 8.603, within thirty (30) days after service ofthis decision.

All persons submitting written comments during the thirty (30) day, and all other persons entitled to do so, may request an adjudicatory hearing and Commission review on whether the decision ofthe Director should be reversed or modified. Such a request shall be in the fonn 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

Enclosure

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--S.OilRCE------ AIR PERMIT

Permit No. : 2070-AR-6

IS ISSUED TO:

Hino Motors Manufacturing 100 Hino Blvd Marion, AR 72364 Crittenden County AFIN: 18-00565

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 ET SEQ.) AND THE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN.

Signed:

li~ Mike Bates Date Chief, Air Division Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

Table ofContents

Section I: FACILITY INFORMATION 4 Section II: INTRODUCTION 5 Summary ofPermit Activity 5 Process Description 5 Regulations 8 Total Allowable Emissions 9 Section III: PERMIT HISTORy 10 Section IV: EMISSION UNIT INFORMATION 11 Section V: INSIGNIFICANT ACTIVITIES 17 Section VI: GENERAL CONDITIONS 18

2 Hino Motors Manufacturing Pennit #: 2070-AR-6 AFIN: 18-00565

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 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

Section I: FACILITY INFORMATION

PERMITTEE: Hino Motors Manufacturing

AFIN: 18-00565

PERMIT NUMBER: 2070-AR-6

FACILITY ADDRESS: 100 Hino Blvd Marion, AR 72364

MAILING ADDRESS: 100 Hino Blvd Marion, AR 72364

COUNTY: Crittenden County

CONTACT NAME: Jerry McPherson

CONTACT POSITION: Manager ofFacilities

TELEPHONE NUMBER: 870-702-3037

REVIEWING ENGINEER: Amanda Leamons

UTM North South (Y): Zone 15: 3895975.56 m

UTM East West (X): Zone 15: 749657.00 m

4 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

Section II: INTRODUCTION

Summary ofPermit Activity

Hino Motors Manufacturing U.S.A., Inc (Hino) operates an auto parts production facility located in Marion, Arkansas. With this de minimis modification application, Hino Motors is requesting permission to remove the thermal oxidizer associated with SN-02 and to redesign the dryer section ofSN-02 to reduce the heat rated capacity from 6.0 MMBTUIhr to 3.0 MMBTUIhr. Furthermore, Hino is requesting to transition to a new electrodeposition (ED) coating at SN-01 which is a lower VOC containing coating than previously used. As a result ofthese modifications, the net annual permitted emissions increased 0.8 tons ofmethyl isobutyl ketone and decreased for PMlPMIO, VOC, NOx, and CO.

The predominant emission from the facility is VOC emissions resulting from various coatings applications at 45.3 tpy. Other emissions include particulate (PMIPMIO) emissions from grinding and welding operations, various emissions resulting from natural gas combustion at the coating dryers, and HAP emissions resulting mostly from the coating applications.

Process Description

The scheduled manufacturing operating time and production to meet the annual production goals is two (2) eight-hour (8-hour) shifts, five (5) days per week. Within a shift, the production operating time is 7.75 hours. This design production basis establishes the average hourly production and materials consumption rates for this application.

For periods to catch up on production or to meet client demand shortfalls, it may be necessary to operate three (3) shifts per day and six (6) days per week. The potential 100% capacity operating time is considered to be the equivalent of24 hours per day, 365 days per year or 8,760 hour per year.

There are no limits on annual hours ofoperation.

Truck Parts Electro Deposition Coating Line

Miscellaneous truck axle parts fabricated off-site will be cleaned, surface treated and painted in ·------an-Etecuo Deposition Coating (ED Coating) line (SN-Ot).lne--degreasing and pretreamrent--- operations utilize aqueous dip and rinse tanks with degreasers, surface conditioner, zinc phosphate treatment and inorganic toner solutions. There are no regulated emissions from these process steps. They are listed collectively in the insignificant activities list as Degreasing Operations (See Section V). After degreasing, the parts are ready for coating.

The Electro Deposition Coating (painting) uses a two-component water borne coating of pigments and resin diluted with water in the coating dip tank. There the parts are coated with a

5 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565 low VQC, non-HAP coating. The coated parts then enter a natural gas-fired drying oven (SN-02 A, B, C) to complete the drying process. Upon exiting the oven, finished parts are ready for shipping. The oven has a heat input capacity of3.0 MMBTU/hr.

Machining and Welding Processes

The facility will manufacture front and rear differentials, front and rear axles and suspension parts (upper and lower, front and rear knuckle arms). The factory floor will have multiple lines and stations for machining, welding, treating, cleaning and assembly ofthe parts. Only the Welding Activities (SN-04) have any quantifiable emissions.

Machining offront and rear knuckle parts is carried out in enclosed grinding machines using water with soluble cutting/polishing oil and additives. Manufacture ofa knuckle can involve machining, preparation, welding and assembly ofabout fifteen (15) different parts that go into a knuckle assembly. All welding stations are closed or hooded and connected to the welding exhaust system.

The rear axle shaft process involves machining and heat treating. Enclosed machining prevents cutting solution mist that might be generated in the machine from being released into the work room. The heat treating operation is electric high frequency treating and quench with no emission release.

The differential case lines involve enclosed machining. One line includes electric heat treating. The differential case and parts come together at the differential assembly line.

Parts washed in the several aqueous washing machines are air dried after the hot water wash.

There are two (2) rear axle housing lines involving machining and arc welding activities. The axle fabrication involves welding together the cast upper steel upper and lower halves ofthe housing and the attached parts and performing necessary machining ofsurfaces. The rear axle housing, shaft and differential come together in the rear axle assembly station. The axle painting activity is in this area.

The welding activities carried out on the rear axle housing and the upper and lower, front and rear suspension arms are the only source of quantifiable emissions from these truck parts fabrication areas. All welding stations are in exhausted cabinets or utilize hoods connected to the plant welding exhaust system. This exhaust system will use two (2) fans located outside the southwest comer ofthe building to exhaust all ofthe welding stations in the plant. Welding uses gas metal arc welding wire with carbon dioxide and argon shielding gases.

Rear Axle Paint Line

After assembly ofthe rear axle housing, shafts, differential and other components, the assembled rear axle is prepared for painting on a conveyerized Axle Coating Line, and painted in two booths (SN-05a & SN-05b). For painting, the axles are hung on an overhead conveyor line to

6 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

pass through the spray coating booths and the gas fired curing oven. All axles are painted using only one (l) black, waterborne coating.

Paint application will be performed in two (2) cross-flow booths in series, where opposite sides ofthe axle will be sprayed with electrostatic air assisted spray guns. The booths will be custom built with replaceable outlet air filters to control overspray particulate emissions. A waterborne, low-VOC and low-HAP is used. This is a mixture ofwater dispersion epoxy resin, pigments, additives and solvents. Total solvent content is typically less than 10% by weight basis.

From the paint booths, the axles pass into one ofthe gas fired Axle Coating Curing Ovens (SN 06, SN-09). SN-06 uses a 10w-NOx natural gas burner with a nominal heat input capacity of2.0 MMBtu/hr, while SN-09 uses a natural gas burner with a nominalheat input capacity of2.45 MMBtu/hr. To adequately cure the high boiling temperature solvents used in contemporary low solvent coatings, the oven operates at a relatively high temperature with an outlet exhaust temperature in the 250 to 300 degrees F range. The paint line and curing oven will be custom built for the Hino axle plant. Additional exhaust may include a flash zone between the spray booths and oven and an oven conveyor exit exhaust hood to remove heat. Addition ofthese features will have no impact on emissions.

Utilities

The axle plant will use natural gas for comfort heating in make-up air units, gas fired unit heaters at doors and other locations around the inside periphery ofthe building and in some ofthe rooftop air conditioning units. These are Group B insignificant activities.

Press Plant

The Press Plant produces suspension parts for pickup trucks and SUVs assembled elsewhere by others. The facility will receive coiled steel sheet and perform pressing to produce customer truck parts.

The material (coiled steel sheet) used for the press is carried into the factory by tractor trailer and placed on a set area by overhead crane or forklift. The coiled material is next set in the blanking line by the overhead traveling crane and cut into sizes for the parts. The cut parts are piled on a special pallet stored in set place by the forklift. The parts for pressing are set at the head ofthe feeder ofthe pressing line by the forklift or the hoist crane and pressed automatically. Pressed parts are taken out one by one with the feed controlling device (transfer device), set in the ------fottowing-rTIetatmuhr,--anu--pre-sse-cr-agaiII.

The completed parts are put on the conveyer with the transfer device after taking out ofthe final metal mold, transported outside the line, and dropped into a special box (pallet). The completed parts in the box are carried to the set area by the forklift. After that, the completed parts are picked up by the worker in the following process with the forklift ifnecessary for shipping.

7 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

Shot Blasting

The truck frame parts coating is where the parts roll formed and laser holed. Parts are then transferred through shot blasting followed by chemical pretreatment processes. A dust collector (SN-I0) with 98% efficiency will be used to control the PM emissions from the shot blasting operations.

Powder Coating

The parts are powder coated (SN-ll), and then baked in a 1.3 MMBtu/hr oven (SN-12). The particulate matter emissions from the powder coating operation will be controlled by a fabric filter with a control efficiency of98%. Any overspray is exhausted through filters before venting to the atmosphere. A gauge measures the pressure drop across the filters. The parts then go through touch-up, inspection, and finally go out to be shipped.

Regulations

The following table contains the regulations applicable to this permit.

Regulations

Arkansas Air Pollution Control Code, Regulation 18, effective January 25, 2009 Regulations ofthe Arkansas Plan ofImplementation for Air Pollution Control, Regulation 19, effective July 18, 2009

8 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

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 5.5 14.1

PM 10 5.5 14.1 S02 0.4 0.4 VOC 12.0 45.3 CO 1.0 3.5

NOx 1.0 4.0 Manganese Compounds 0.12 0.6 Methyl isobutyl ketone 0.2 0.8 Individual Coating HAP - 9.5 Total Coating HAPs 10.3 13.8 Total HAPs - 15.2

-_. --_.~~~~.....~~---~-_.~- -~~-

9 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

Section III: PERMIT HISTORY

Permit #2070-A, issued on November 22, 2004, is the initial permit for the facility.

Permit #2070-AR-l, issued on August 2,2005, included changes allowed by a de minimis approval dated April 1, 2005. The facility was permitted to construct and operate the necessary equipment for operation of a Press Plant (SN-07).

Permit #2070-AR-2, issued on January 23, 2006, allowed increased emission limits at the Axle Coating Operations (SN-05) to allow for additional coating flexibility. VOC emissions were increased by 19.2 tons per year and PM/PM10 was increased by 3.3 tons per year.

Permit #2070-AR-3 was issued on October 17,2007. With the modification, Hino installed an additional 2.0 MMBtulhr axle coating drying oven at SN-08 and increased axle production at SN-05. The modification resulted in annual emission increases of 1.7 tons ofPM/PMIO, 7.1 tons ofVOC, 0.1 tons of S02, 0.9 tons ofNOx, and 0.8 tons ofCO.

Permit #2070-AR-4 was issued on September 29,2008. With modification, Hino installed a new paint line. The installation ofthe new paint line required the demolition ofan existing drying oven (SN-08), the installation of a new drying oven (SN-09), and the installation ofa new paint booth (SN-05b). The total permitted emission increases included 0.2 tpy ofCO and 0.2 tpy of NOx.

Permit #2070-AR-5 was issued on July 23, 2009. With this de minimis modification, Hino Motors installed a new powder coating line for truck frame parts. The new line included shot blasting operations (SN-10), powder coating operations (SN-l1), and a new baking oven (SN 12). The total permitted emission increases include 0.5 tpy ofPM/PM10, 0.1 tpy ofS02, 0.1 tpy ofVOC, 0.5 tpy ofCO, and 0.6 tpy ofNOx.

10 Hino Motors Manufacturing Pennit #: 2070-AR-6 AFIN: 18-00565

Section IV: EMISSION UNIT INFORMAnON

Specific Conditions

1. The pennittee shall not exceed the emission rates set forth in the following table. [Regulation 19, §19.501 et seq., and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

SN Description Pollutant lb/hr tpy Electro Deposition (ED) 01 VOC 0.8 3.6 Coating

PM10 0.1 0.1 S02 0.1 0.1 ED Drying Oven· 02a, b, & c VOC 0.6 2.0 (3.0 MMBtu/hr) CO 0.3 1.2

NOx 0.3 1.4 04 Welding Operations PMIO 1.0 4.4

Axle Coating PMIO 2.4 8.9 05a & 05b (2 Booths) VOC 10.3 39.4

PM10 0.1 0.1 S02 0.1 0.1 Axle Coating Drying 06 Oven VOC 0.1 0.1 (2.0 MMBtu/hr) CO 0.2 0.8

NOx 0.2 0.9 07 Press Plant No Emissions Axle Coating Drying 08 Oven # 2 Removed from service in 2008 (2.0 MMBtu/hr) I- PM10 0.1 0.1

S0 2 0.1 0.1 Axle Coating Drying 09 Oven # 2 VOC 0.1 0.1 (2.45 MMBtu/hr) CO 0.3 1.0

NOx 0.3 1.1

11 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

SN Description Pollutant lb/hr tpy

10 Shot Blasting PMIO 0.1 0.1

11 Powder Spray Coating PMIO 1.6 0.3

PMIO 0.1 0.1 S02 0.1 0.1 Powder Spray Coating 12 Drying Oven VOC 0.1 0.1 (1.3 MMBtu/hr) CO 0.2 0.5

NOx 0.2 0.6

2. The permittee shall not exceed the emission rates set forth in the following table. [Regulation 18, §18.801 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8 4-311]

SN Description Pollutant lb/hr tpy Electro Deposition 01 Methyl isobutyl ketone 0.1 0.5 (ED) Coating ED Drying Oven PM 0.1 0.1 02a, b, & c (3.0 MMBtu/hr) Methyl isobutyl ketone 0.1 0.3 Welding PM 1.0 4.4 04 Operations Manganese 0.12 0.60 PM 2.4 8.9 Axle Coating 05a & 05b Individual HAP* - 9.5 (2 Booths) Total Coating HAPs 10.3* 13.8 Axle Coating 06 Drying Oven PM 0.1 0.1 (2.0 MMBtu/hr) 07 Press Plant No Emissions Axle Coating 08 Drying Oven # 2 Removed from service in 2008 (2.0 MMBtulhr) Axle Coating 09 Drying Oven # 2 PM 0.1 0.1 (2.45 MMBtu/hr) 10 Shot blasting PM 0.1 0.1

12 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

SN Description Pollutant lb/hr tpy Powder Spray 11 PM 1.6 0.3 Coating Powder Spray Coating Drying 12 PM 0.1 0.1 Oven (1.3 MMBtu/hr) * HAP emissions are limited by TLV and wt %, the maximum allowable HAP emissions might be less depending on the TLV ofthe HAP. HAP emissions ofmethyl isobutyl ketone and manganese are not included or permitted at SN-05.

3. Visible emissions may not exceed the limits specified in the following table ofthis permit as measured by EPA Reference Method 9. [A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

SN Limit Regulatory Citation

10 & 11 5% §19.503 02 - 06, 09, & 12 20% §19.503

4. The permittee shall not cause or permit the emission of air contaminants, including odors or water vapor and including an air contaminant whose emission is not otherwise prohibited by Regulation #18, ifthe emission ofthe air contaminant constitutes air pollution within the meaning ofA.C.A. §8-4-303. [Regulation 18, §18.801 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

5. The permittee shall not conduct operations in such a manner as to unnecessarily cause air contaminants and other pollutants to become airborne. [Regulation 18, §18.901 and A.C.A. §8-4-203 as referenced by AC.A. §8-4-304 and §8-4-311]

6. The permittee shall operate all control equipment associated with this facility in a manner consistent with good air pollution control practices in order to comply with the applicable emission limits. [Regulation 19, §19.303 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4 304 and §8-4-311]

7. The permittee shall not consume more than 925,275 pounds ofED coating (pigment + resin) at SN-Ol per consecutive 12-month period. [RegulatIOn 19, §19.705 and A.C.A §8-4-203 as referenced by AC.A. §8-4-304 and §8-4-311]

13 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00S65

8. The permittee will maintain monthly records which demonstrate compliance with Specific Condition # 7. The permittee shall update the records by the fifteenth day ofthe month following the month to which the records pertain. A rolling total ofthe past twelve month's data shall be kept. The permittee shall keep the records on-site, and make the records available to Department personnel upon request. [Regulation 19, §19.705 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

9. The permittee shall not exceed a maximum weight percent VOC content of 1.2% and a maximum weight percent HAP content of0.14% in the ED coating resin and pigment used at SN-01 and SN-02. Compliance shall be demonstrated by Specific Condition #17. [Regulation 18, §18.1 004 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 ]

10. The permittee shall only consume pipeline quality natural gas at SN-02a, SN-02b, SN 02c, SN-06, and SN-12. [Regulation 19, §19.705 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

11. The permittee shall not consume more than 1,023,562 pounds (464,280 kg) ofwelding wire at SN-04 per consecutive 12-month period. [Regulation 19, §19.70S and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

12. The permittee shall maintain monthly records which demonstrate compliance with Specific Condition #11. The permittee shall update the records by the fifteenth day ofthe month following the month to which the records pertain. A rolling total ofthe past twelve month's data shall be kept. The permittee shall keep the records on-site, and make the records available to Department personnel upon request. [Regulation 19, §19.705 and A.C.A. §8-4-203 as referenced by A.c.A. §8-4-304 and §8-4-311]

13. The permittee shall perform monthly VOC emission rate calculations based on actual material usage at SN-Ol, SN-02, SN-OSa, and SN-05b. These calculations shall be kept with a 12 month rolling total for demonstration ofcompliance with the SN-01, SN-02, SN-05a, and SN-05b ton per year VOC limits ofSpecific Condition #1. Calculations and supporting information shall be kept on-site and made available to Department personnel upon request. Calculations shall be updated by the lSth day ofthe month following the month to which they pertain. [Regulation 19, §19.70S and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

14. The permittee shall perform monthly HAP emission rate calculations based on actual material usage at SN-Ol, SN-02, SN-OSa, and SN-05b. These calculations shall be kept with a 12 month rolling total for demonstration ofcompliance with SN-01, SN-02, SN OSa, and SN-OSb total and individual ton per year HAP limits ofSpecific Condition #2. Calculations and supporting information shall be kept on-site and made available to Department personnel upon request. Calculations shall be updated by the lSth day ofthe month following the month to which they pertain. [Regulation 19, §19.705 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

14 Hino Motors Manufacturing Pennit #: 2070-AR-6 AFlN: 18-00565

15. The pennittee shall not exceed the maximmn weight percent content of 12% for any VOC containing material at SN-05a & SN-05b. [Regulation 19, §19.705 and A.C.A. §8 4-203 as referenced by §8-4-304 and §8-4-311]

16. The pennitteeshall not use coatings at SN-05 containing methyl isobutyl ketone or manganese. The pennittee shall not exceed the maximum weight percent content for any individual HAP containing material at SN-05a & SN-05b as detennined using the TLV for that HAP in the following table:

3 Maximmn Content Minimum TLV (mg/m ) HAP%* (wt%) 3.43 12% 100% 1.71 6.0% 50% 0.86 3.0% 25% 0.34 1.5% 10% 0.17 0.6% 5.0% 0.03 0.12% 1.0% 3 Fonnula: Maximum Content (wt %) = TLV (mg/m ) x 3.49 * HAP% is the % ofmaximum allowable VOC content that is HAP. **Table based on maximum density of 10.l81b/gal.

At any time ofinspection, the pennittee shall demonstrate compliance with this table by presenting MSDS sheets or equivalent for any coating used at SN-05a & SN-05b.

TLVs used must be published by the American Conference ofGovernmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLV) values as listed on current MSDS fonns, or in the ACGIH handbook ofThreshold Limit Values (TLVs) and Biological Exposure Indices (BEls). TLVs not published by this reference must receive written approval by the Department. Glycol ethers shall be considered as an aggregate total and 3 the group has an ADEQ approved TLV of 100 mg/m . Ethylene glycol isopropyl ether __m_e~_ts the d~jinition of"glycol ethers" as gescribed by the Clean Air Act Section 112(]:)}. _

[Regulation 18, §18.1 004 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

15 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

17. The permittee shall maintain MSDS sheets, product labels, or other similar product specification sheets to verify contents used for calculations required by Specific Conditions #13 and #14 and to verify Specific Conditions #9, #15, and #16 requirements. The permittee shall update the records by the 15th day ofthe month following the month to which the records pertain. The permittee shall keep the records on-site and make the records available to Department personnel upon request. [Regulation 19, §19.705, §18.1004, and A.CA. §8-4-304 and §8-4-311]

18. At the Press Plant (SN-07), the permittee shall not use any oils, cleaners, or other products which would contribute to VOC emissions. Also, the permittee shall not saw materials or otherwise operate in a manner to cause discharge ofparticulate emissions into the air. Compliance shall be demonstrated during routine inspection. [Regulation 19, §19.705 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

19. The permittee shall not use more than 138,700 pounds ofShot Blast at SN-I0 per consecutive 12-month period. [Regulation 19, §19.705 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

20. The permittee shall not consume more than 138,700 pounds ofPowder Coating at SN-ll per consecutive 12-month period. [Regulation 19, §19.705 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

21. The permittee will maintain monthly records which demonstrate compliance with Specific Conditions # 19 and # 20. The permittee shall update the records by the fifteenth day ofthe month following the month to which the records pertain. A rolling total ofthe past twelve month's data shall be kept. The permittee shall keep the records on-site, and make the records available to Department personnel upon request. [Regulation 19, §19.705 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

16 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

Section V: INSIGNIFICANT ACTIVITIES

The Department deems the following types ofactivities or emissions as insignificant on the basis ofsize, emission rate, production rate, or activity in accordance with Group A ofthe Insignificant Activities list found in Regulation 18 and 19 Appendix A. Insignificant activity emission determinations rely upon the information submitted by the permittee in an application dated June 16,2004.

Description Category

Degreasing Operations A-13

----~~--

17 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

Section VI: GENERAL CONDITIONS

1. Any terms or conditions included in this permit that specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as the sole origin ofand authority for the terms or conditions are not required under the Clean Air Act or any ofits applicable requirements, and are not federally enforceable under the Clean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 18 was adopted pursuant to the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.). Any terms or conditions included in this permit that specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as the origin ofand authority for the terms or conditions are enforceable under this Arkansas statute.

2. This permit does not relieve the owner or operator ofthe equipment and/or the facility from compliance with all applicable provisions ofthe Arkansas Water and Air Pollution Control Act and the regulations promulgated under the Act. [A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

3. The permittee shall notify the Department in writing within thirty (30) days after commencement ofconstruction, completion ofconstruction, first operation of equipment and/or facility, and first attainment ofthe equipment and/or facility target production rate. [Regulation 19, §19.704 and/or A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

4. Construction or modification must commence within eighteen (18) months from the date ofpermit issuance. [Regulation 19, §19.410(B) and/or Regulation 18, §18.309(B) and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-31I ]

5. The permittee must keep records for five years to enable the Department to determine compliance with the terms ofthis permit such as hours ofoperation, throughput, upset conditions, and continuous monitoring data. The Department may use the records, at the discretion ofthe Department, to determine compliance with the conditions ofthe permit. [Regulation 19, §19.705 and/or Regulation 18, §18.1004 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

6. A responsible official must certify any reports required by any condition contained in this permit and submit any reports to the Department at the address below. [Regulation 19, §19.705 and/or Regulation 18, §18.1004 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

Arkansas Department of Environmental Quality Air Division ATTN: Compliance Inspector Supervisor

18 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

5301 Northshore Drive North Little Rock, AR 72118-5317

7. The permittee shall test any equipment scheduled for testing, unless stated in the Specific Conditions ofthis permit or by any federally regulated requirements, within the following time frames: (1) newly constructed or modified equipment within sixty (60) days of achieving the maximum production rate, but no later than 180 days after initial start up of the permitted source or (2) existing equipment already operating according to the time frames set forth by the Department. The permittee must notify the Department ofthe scheduled date ofcompliance testing at least fifteen (15) days in advance ofsuch test. The permittee must submit compliance test results to the Department within thirty (30) days after the completion oftesting. [Regulation 19, §19.702 and/or Regulation 18, §18.1 002 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

8. The permittee shall provide: [Regulation 19, §19.702 and/or Regulation 18, §18.1002 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

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

9. The permittee shall operate equipment, control apparatus and emission monitoring equipment within their design limitations. The permittee shall maintain in good condition at all times equipment, control apparatus and emission monitoring equipment. [Regulation 19, §19.303 and/or Regulation 18, §18.1l04andA.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

10. Ifthe permittee exceeds an emission limit established by this permit, the permittee will be deemed in violation ofsaid permit and will be subject to enforcement action. The Department may forego enforcement action for emissions exceeding any limits established by this permit provided the following requirements are met: [Regulation 19, §19.601 and/or Regulation 18, §18.11 01 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

a. The permittee demonstrates to the satisfaction ofthe Department that the emissions resulted from an equipment malfunction or upset and are not the result ------nofllegligerrce-orimpropermaintenance, and the-permittee-tookaH--reasonable-----~-- measures to immediately minimize or eliminate the excess emissions. b. The permittee reports the occurrence or upset or breakdown ofequipment (by telephone, facsimile, orovemight delivery) to the Department by the end ofthe next business day after the occurrence or the discovery ofthe occurrence. c. The permittee must submit to the Department, within five business days after the occurrence or the discovery ofthe occurrence, a full, written report ofsuch occurrence, including a statement ofall known causes and ofthe scheduling and

19 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

nature ofthe actions to be taken to minimize or eliminate future occurrences, including, but not limited to, action to reduce the frequency ofoccurrence ofsuch conditions, to minimize the amount by which said limits are exceeded, and to reduce the length oftime for which said limits are exceeded. Ifthe information is included in the initial report, the information need not be submitted again.

11. The permittee shall allow representatives ofthe Department upon the presentation of credentials: [A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

a. To enter upon the permittee's premises, or other premises under the control ofthe permittee, where an air pollutant source is located or in which any records are required to be kept under the terms and conditions ofthis permit; b. To have access to and copy any records required to be kept under the terms and conditions ofthis permit, or the Act; c. To inspect any monitoring equipment or monitoring method required in this permit; d. To sample any emission ofpollutants; and e. To perform an operation and maintenance inspection ofthe permitted source.

12. The Department issued this permit in reliance upon the statements and presentations made in the permit application. The Department has no responsibility for the adequacy or proper functioning ofthe equipment or control apparatus. [A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

13. The Department may revoke or modify this permit when, in the judgment ofthe Department, such revocation or modification is necessary to comply with the applicable provisions ofthe Arkansas Water and Air Pollution Control Act and the regulations promulgated the Arkansas Water and Air Pollution Control Act. [Regulation 19, §19.41O(A) and/or Regulation 18, §18.309(A) and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

14. This permit may be transferred. An applicant for a transfer must submit a written request for transfer ofthe permit on a form provided by the Department and submit the disclosure statement required by Arkansas Code Annotated §8-1-106 at least thirty (30) days in advance ofthe proposed transfer date. The permit will be automatically transferred to the new permittee unless the Department denies the request to transfer within thirty (30) days ofthe receipt ofthe disclosure statement. The Department may deny a transfer on the basis ofthe information revealed in the disclosure statement or other investigation or, deliberate falsification or omission ofrelevant information. [Regulation 19, §19.407(B) and/or Regulation 18, §18.307(B) and A.C.A. §8-4-203 as referenced by A.C.A. §8-4 304 and §8-4-311]

15. This permit shall be available for inspection on the premises where the control apparatus is located. [A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

20 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

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

17. This permit supersedes and voids all previously issued air permits for this facility. [Regulation 18 and 19 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4 311]

18. The permittee must pay all permit fees in accordance with the procedures established in Regulation No.9. [A.C.A §8-1-105(c)]

19. The permittee may request in writing and at least 15 days in advance ofthe deadline, an extension to any testing, compliance or other dates in this permit. No such extensions are authorized until the permittee receives written Department approval. The Department may 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; and c. The permittee documents that all reasonable measures have been taken to meet the current deadline and documents reasons it cannot be met.

[Regulation 18, §18.314(A), Regulation 19, §19.416(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]

20. The permittee may request in writing and at least 30 days in advance, temporary emissions and/or testing that would otherwise exceed an emission rate, throughput requirement, or other limit in this permit. No such activities are authorized until the permittee receives written Department approval. Any such emissions shall be included in the facilities total emissions and reported as such. The Department may grant such a request, 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 ofair pollution; d. The request contains such information necessary for the Department to evaluate the request, including but not limited to, quantification ofsuch emissions and the date/time such emission will occur; e. Such a request will result in increased emissions less than five tons ofany - . ~---~ --~~------indtvidual-criteria-poHutant;-one ·ton-of··any-single-H-kP-and--2-:-5-tons--of-total---- HAPs; and f. The permittee maintains records ofthe dates and results ofsuch temporary emissions/testing.

[Regulation 18, §18.314(B), Regulation 19, §19.416(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]

21 Hino Motors Manufacturing Permit #: 2070-AR-6 AFIN: 18-00565

21. The permittee may request in writing and at least 30 days in advance, an alternative to the specified monitoring in this permit. No such alternatives are authorized until the permittee receives written Department approval. The Department may grant such a request, 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 ofactual monitoring to the current requirements; and c. Any such request, ifapproved, is incorporated in the next permit modification application by the permittee.

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

22 CERTIFICATE OF SERVICE

I, Cynthia Hook, hereby certify that a copy ofthis permit has been mailed by first class mail to /)-I/~ Hino Motors Manufacturing, 100 .Hino B.lvd, M~,...rion, AR, 72364, on this "> Ulday ofApril, 2010.

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