STATEMENT OF BASIS
For the issuance of Draft Air Permit # 2156-AOP-RO AFIN: 47-00493
1.
PERMITTING AUTHORITY:
Arkansas Department of Environmental Quality
5301 Northshore Drive
North Little Rock, Arkansas 72118-5317
2.
APPLICANT:
Skyline Steel, LLC
5896 Hwy 18 East
Blytheville, Arkansas 72315
3.
PERMIT WRITER:
Andrea Sandage
4.
PROCESS DESCRIPTION AND NAICS CODE:
NAICS Description: Fabricated Structural Metal Manufacturing
NAICS Code:
332312
5.
SUBMITTALS:
12/18/2009 3/24/2010 5/4/2010 6/15/2010 7/9/2010 7/14/2010
6.
REVIEWER'S NOTES:
Skyline Steel, LLC (Skyline) is located in Blytheville, Mississippi County, Arkansas.
The facility purchases steel piling which is then processed into structural steel
components. Preparation of the structural components may include blasting, welding,
and surface coating operations. This facility is currently permitted under ADEQ Minor
Source Air Permit No. 2156-A. With this application, Skyline requests to increase
permitted surface coating and solvent usage limitations. A designated outdoor painting
area (SN-05) and indoor robotic painting system (SN-06, SN-07, and SN-08) has been
added. This increase resulted in potential emissions from the facility which exceeds the
Title V applicability thresholds. This increase also results in the facility becoming an
effected source under 40 CFR Part 63 Subpart MMMM - National Emission Standards
for Hazardous Air Pollutants: Surface Coating of Miscellaneous Metal Parts and
Products. Permitted emissions changes include the following: decreases of 3.0 tpy PM
and 8.9 tpy PMIO and increases of 194.3 tpy VOC and 94.9 tpy combined HAPs.
Permit #: 2156-AOP-RO
AFIN: 47-00493
Page 2 of5
7.
COMPLIANCE STATUS:
The following summarizes the current compliance of the facility including active/pending
enforcement actions and recent compliance activities and issues. Annual Inspection was
conducted on March 18, 2009 with the following areas of concern. Enforcement is
currently pending. This permit addresses the violations specified in the annual
inspection.
Records indicate that permittee is over usage limits of coasting substances listed in SC-06.
Records indicate that permittee is over VOC limits of cleanup substances listed in SC-07.
Records indicate that permittee is over HAP limits of cleanup substances listed in SC-08.
8.
PSD APPLICABILITY:
a. Did the facility undergo PSD review in this permit (i.e., BACT, Modeling, etc.)?
b. Is the facility categorized as a major source for PSD?
N
N
Single pollutant ~ 100 tpy and on the list 0/28 or single pollutant ~ 250 tpy and not on list?
If yes, explain why this permit modification not PSD?
9. SOURCE AND POLLUTANT SPECIFIC REGULATORY APPLICABILITY:
Source
Pollutant
Facility surface coating
operation(s); as applicable
HAPsNOCs
10.
Regulation
(NSPS, NESHAP or PSD)
40 CFR Part 63, Subpart
MMMM
EMISSION CHANGES AND FEE CALCULATION:
See emission change and fee calculation spreadsheet in Appendix A.
11.
MODELING: 2005 - 2009 MET data - modeled 5 year
Criteria Pollutants - PMIO - Annual 1st high, 24-hr 6th high - SN-05 limited to 8 hrs/day
(8:00-16:00)
Emission NAAQS
Modeled
Averaging
Pollutant
Rate
Standard
Concentration
Time
(~g/m3)
(~g/m3)
(lb/hr)
PMIO
Background
Total Highest
Values
%of
Concentration
NLR2008
NAAQS
(~g/m3)
(ug/m3)
50
Annual
18.67
20
38.67
77.4
150
24-Hour
104.58
37
141.58
94.4
0.87*
* Includes SN-01, 02 @ 0.0167Ib/hr, SN-05 @ 0.8 lb/hr, & SN-06, 07, 08 @ O.Ollllb/hr
Permit #: 2156-AOP-RO
AFIN: 47-00493
Page 3 of5
Non-Criteria Pollutants:
This permit contains a TLV formula for non-criteria pollutants. The equation is
calculated based on the Presumptively Acceptable Emission Rate (PAER) as outlined in
the Non-Criteria Pollutant Control Strategy. The PAER (in lb/hr) for a given HAP
compound is defined as the TLV of that compound, expressed in mg/m3, multiplied by a
factor of 0.11. This, along with the maximum daily coating material usage limitation of
400 gal/day is used to establish the following relationship.
Allowable Content (lb/gal) = (TLV (mg/m3)
* 0.11 * 24 (hr/day))/400 gal/day
Modeling of specific non-criteria pollutants was not performed.
12.
CALCULATIONS:
Emission Factor
Source
(AP-42, testing,
etc.)
SN
01-02
Mass Balance Vendor Air
Quality Data
Sheet
Limited to 400
gal/day total
facility wide
05
06-08
Facility
Wide
13.
Mass Balance
Emission Factor
(lb/ton, lb/hr,
etc.)
Meta-Xylene
0.43 lbs/gal
Ethyl Benzene
0.18 lbs/gal
Para-Xylene
0.19 lbs/gal
Ortho-Xylene
0.13 lbs/gal
Cumene 0.05
lbs/gal
MEKfor
cleaning - 6.72
lb/gal total
VOC
Control
Equipment
Control
Equipment
Efficiency
Particulate
Filter
99%
None
Particulate
Filter
99%
None
-
TESTING REQUIREMENTS:
The permit requires testing of the following sources.
Comments
Indoor Painting
Output - 16.7
gal/hr
Outdoor Painting 4.0 gal/hr
Limited to 8
hrs/day and max
32 gal/day
Indoor Robotic
Painting Output 16.7 gal/hr
Clean-up solvent
and thinner limited
to 100 gal/day
NoHAPs-VOC
only
Permit #: 2156-AOP-RO
AFIN: 47-00493
Page 4 of5
Test
Method
Pollutants
SN
Justification
Test Interval
No test requirements with this permit action.
14.
MONITORING OR CEMS
The permittee must monitor the following parameters with CEMS or other monitoring
equipment (temperature, pressure differential, etc.)
Parameter or Pollutant
Method
Frequency Report (YIN)
to be Monitored
(CEM, Pressure Gauge, etc.)
SN
There are no monitoring or CEM requirements with this permit action.
15.
RECORDKEEPING REQUIREMENTS:
The following are items (such as throughput, fuel usage, VOC content, etc.) that must be
tracked and recorded.
SN
Facility Wide
05
16.
17.
Recorded Item
Permit Limit
Frequency
Report (YIN)
6.0lb/gal
Daily
N
4.0lb/gal
Daily
N
6.72lb/gal
Daily
N
Surface Coatings
60,000 gal/yr
N
Thinners/Solvents
10,000 gal/yr
Monthly - 12month rolling
total
Hours of
Operation
8 hrs per day
8:00 a.m. - 5:00
p.m.
Daily
N
Surface Coating
VOC content
Surface Coating
HAP content
Thinner/cleaners
VOC content
N
OPACITY:
SN
Opacity
05
20%
DELETED CONDITIONS:
Justification for limit
Regulation 19, §19.503
Compliance Mechanism
Weekly Observations
Permit #: 2156-AOP-RO
AFIN: 47-00493
Page 5 of5
Former SC
I
Justification for removal
Initial Permit
18. GROUP A INSIGNIFICANT ACTIVITIES
Emissions (tpy)
Group A
Category
PMlPMlO
Wheelabrator wi
Baghouse
A-13
0.25
Welding
A-7
0.73
A-I
3.26 E-04
2.58 E-05
2.36 E-04
3.61 E-03
A-I
3.26 E-04
2.58 E-05
2.36 E-04
3.61 E-03
Source Name
Heater #1
(0.01 MMBtu/hr)
Heater #2
(0.01 MMBtu/hr)
19.
VOC
S02
CO
NO x
HAPs
Single
Total
0.04
0.071
4.3 E-03
7.7 E-05
8.2 E-05
4.3 E-03
7.7 E-05
8.2 E-05
VOIDED, SUPERSEDED, OR SUBSUMED PERMITS:
List all active permits voided/superseded/subsumed by the issuance of this permit.
Permit #
2156-A
20.
CONCURRENCE BY:
The following supervisor concurs with the permitting decision.
~-----~
.
APPENDIX A - EMISSION CHANGES AND FEE CALCULAnON
Fee Calculation for Major Source
Revised 03-01-10
Facility Name: Skyline Steel, LLC
Permit Number: 2156-AOP-RO
AFIN: 47-00493
$/ton factor
Permit Type
22.07
Initial Permit
Minor Modification Fee $
Minimum Modification Fee $
Renewal with Minor Modification $
Check if Facility Holds an Active Minor Source or Minor
Source General Permit
220.3
4862.021
Annual Chargeable Emissions (tpy)
Permit Fee $
500
1000
500
o
If Hold Active Permit, Amt of Last Annual Air Permit Invoice $
Total Permit Fee Chargeable Emissions (tpy)
Initial Title V Permit Fee Chargeable Emissions (tpy)
191.3
220.3
HAPs not included in VOC or PM:
Chlorine, Hydrazine, HCI, HF, Methyl Chloroform, Methylene Chloride,
Phosphine, Tetrachloroethylene, Titanium Tetrachloride
Air Contaminants:
All air contaminants are chargeable unless they are included in other
totals (e.g., H2S04 in condensible PM, H2S in TRS, etc.)
Pollutant (tpy)
PM
Check if
Chargeable
Emission
p-
Old
Permit
Permit Fee
Annual
Change in Chargeable Chargeable
Emissions Emissions Emissions
New
Permit
-3
6.6
0
0
0
213.7
194.3
194.3
213.7
0
0
0
O
0
0
0
0
3.1
0
-3.1
9.4
0
-9.4
Cumene
0.1
0
-0.1
Toluene
7.7
0
-7.7
4.8
0
-4.8
0
120
120
PM 10
S02
VOC
pp-
CO
NO x
p-
Ethyl Benzene
Xylene
Methyl Isobutyl Ketone
Combined HAPs
r
r
r
9.6
6.6
-3
9.6
0.7
-8.9
O
0
19.4