ADEQ OPERATING AIR PERMITdisulfide unloading and transfer operations. Ammonia is released from the fibrous casing generation process and a small amount of glycerine emissions are released

ADEQ OPERATING AIR

PERMITPursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation #26:

Permit #: 268-AOP-R1Renewal #1

IS ISSUED TO:

Viskase Corporation2221 East Highway 198

Osceola, AR 72370Mississippi County

CSN: 47-0115

THIS PERMIT AUTHORIZES THE ABOVE REFERENCED PERMITTEE TO INSTALL,OPERATE, AND MAINTAIN THE EQUIPMENT AND EMISSION UNITS DESCRIBED INTHE PERMIT APPLICATION AND ON THE FOLLOWING PAGES. THIS PERMIT ISVALID BETWEEN:

and

AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN.

Signed:

Keith A. Michaels Date

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SECTION I: FACILITY INFORMATION

PERMITTEE: Viskase CorporationCSN: 47-0115PERMIT NUMBER: 268-AOP-R1

FACILITY ADDRESS: 2221 East Highway 198Osceola, AR 72370

COUNTY: Mississippi

CONTACT POSITION: Henry Hill, EH&S CoordinatorTELEPHONE NUMBER: (870) 563-3541

REVIEWING ENGINEER: Wesley Crouch

UTM North-South (Y): Zone 16: 3951.4UTM East-West (X): Zone 16: 231.1

Viskase CorporationPermit #: 268-AOP-R1CSN #: 47-0115

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SECTION II: INTRODUCTION

Summary of Permit Activity

This is a renewal of the Title V permit for this facility. Lime usage is being increased and thiswill result in a 0.3 tpy increase of PM10 emissions. Ammonia emissions rates will also increaseby 32.0 tpy to account for fugitive emissions. Lastly, the calculations for natural gas combustionhave been updated to reflect revised emission factors. Emissions increases are due to the use ofupdated factors and corrected calculations. With the exception of the increase in lime usage, noother changes are being made in the operation of the facility.

Process Description

Viskase Corporation operates a cellulose food casing plant located in Osceola, Arkansas. Production of cellulose food casings by the viscose process involves the reaction of a cellulosematerial, either cotton or wood pulp, with an aqueous sodium hydroxide solution. After an agingprocess, the alkali cellulose is reacted with carbon disulfide to form an intermediate compound,cellulose xanthate, which is subsequently dissolved in a dilute caustic solution to form a viscousfluid called “viscose”. After aging and filtering, the viscose is extruded into precision-sizedtubes which are passed through a series of acid baths where the cellulose is regenerated. Theextruded generated cellulose film is then purified, dried, reeled, and finished. Glycerine is addedas a plasticizer and humectant.

Emissions from the viscose process (SN-01) consist primarily of carbon disulfide and hydrogensulfide. These gases occur during xanthation, coagulation, regeneration, and purification stagesof the viscose process. Smaller amounts of carbon disulfide are also emitted during carbondisulfide unloading and transfer operations. Ammonia is released from the fibrous casinggeneration process and a small amount of glycerine emissions are released from dryer vents.

The Osceola facility operates two industrial on-site boilers (SN-02 and SN-03) with a combinedheat input of 142 million BTU/hr. These boilers generate steam for use in multiple productionoperations such as the acid bath evaporator systems, crystallizer, press water wash, glycerinehandling system, deaeration vacuum system, casing process dryers, and space heating. Theboilers are typically fired with natural gas but have the capability to fire No. 2 or No. 6 fuel oil.

A 340 horsepower emergency fire water pump (SN-05) is used in the event of a fire at theOsceola facility. Particulate matter, sulfur dioxide, nitrogen oxides, carbon monoxide,aldehydes, and unspecified volatile organic compounds are emitted during pump operation. Thepump is normally tested one hour a week, 52 weeks a year.


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Viskase also operates an on-site wastewater treatment plant to ensure wastewater is properlytreated prior to discharge to the Mississippi River. Calcium hydroxide is combined with thewater and fed as a lime slurry to neutralize process wastewater. The neutralized wastewater isequalized and clarified before being discharged. The lime is stored in a 150 ton silo equippedwith a baghouse (SN-04) to control particulate emissions.

Carbon disulfide fugitive emissions (SN-06) occur due to unloading operations from tank cars ora portable tank into two submerged storage tanks, transfer of carbon disulfide from storage tanksto weigh scales, and weigh tank operations.

Several fuel oil, gasoline, raw material glycerine, and used oil storage tanks are also present atthe facility. Emissions from these sources are considered insignificant.

Regulations

Viskase is subject to regulation under the Arkansas Air Pollution Control Code (Regulation 18),the Arkansas State Implementation Plan for Air Pollution Control (Regulation 19) and theRegulations of the Arkansas Operating Air Permit (Regulation 26).

The following table is a summary of emissions from the facility. Specific conditions andemissions for each source can be found starting on the page cross referenced in the table. Thistable, in itself, is not an enforceable condition of the permit.

EMISSION SUMMARY

SourceNo.

Description Pollutant Emission Rates CrossReferenc

ePage

lb/hr tpy

Total Allowable Emissions PMPM10SO2

VOCCONOxTRS

13.213.2149.14.014.361.9254.0

40.140.1459.94.742.5185.0954.0


EMISSION SUMMARY

SourceNo.


ePage

lb/hr tpy

5

HAPs* AldehydesCarbon

DisulfideHydrogen

Sulfide

0.2238.856.0

0.4901.6211.0

Air Contaminants ** Ammonia 21.6 63.0

01 Viscose ProcessVent

VOC TRS

Ammonia Carbon

DisulfideHydrogen

Sulfide

2.3254.021.6238.056.0

0.2954.063.0898.0211.0

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02

Industrial Boiler #171 MMBtu/hr(Natural Gas

No. 2 Fuel OilNo. 6 Fuel Oil)

PMPM10SO2

VOCCONOx

6.16.174.20.46.025.7

18.818.8229.11.218.479.3

11

03

Industrial Boiler #271MMBtu/hr(Natural Gas

No. 2 Fuel OilNo. Fuel Oil)

PMPM10SO2

VOCCONOx

6.16.174.20.46.025.7

18.818.8229.11.218.479.3

11

04 Lime Silo (150 tons) PMPM10

0.20.2

0.60.6

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EMISSION SUMMARY

SourceNo.


ePage

lb/hr tpy

6

05 Emergency FireWater Pump

PMPM10SO2

VOCCONOx

Aldehydes

0.80.80.70.92.310.50.2

1.91.91.72.15.726.40.4

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06 Carbon DisulfideFugitive emissions

CarbonDisulfide

0.8 3.6 19

* HAPs included in the VOC totals are indicated by an *. Other HAPs arenot included in any other totals unless specifically stated.

** Air Contaminants such as ammonia, acetone, and certain halogenatedsolvents are not classified as VOC or HAPs.


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SECTION III: PERMIT HISTORY

268-A was the first air permit issued to the facility on October 21, 1974. 268-A permitted theconstruction and operation of the Union Carbide Corporation cellulose food casing facility. Carbon disulfide and hydrogen sulfide emissions were limited to 175 pounds per hour and 26.2pounds per hour, respectively.

On February 25, 1988, air permit 268-AR-1 was issued to Viskase Corporation. This permit wasissued to record the change of ownership from Union Carbide Corporation to ViskaseCorporation. Emission estimates for carbon disulfide, hydrogen sulfide, sulfur dioxide, nitrogenoxides, particulate matter, and other products of combustion were identified in a relatedsummary report relative to permit application.

268-AR-2 was issued to Viskase on October 17, 1996. This permit modification allowed theOsceola facility to operate existing equipment at a capacity that reflected expected marketdemand. The permit additionally supplemented and updated information about existing sourcesat the facility.

268-AOP-R0 is the first operating permit issued to Viskase Corporation under Regulation 26. No physical changes in the method of operation at the facility occurred to prompt this permitissuance. However, Viskase Corporation is including glycerine emissions which have not beenpreviously identified in other air permitting efforts.


SECTION IV: EMISSION UNIT INFORMATION


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SN-01 Viscose Process Vent

Source Description

Carbon disulfide and hydrogen sulfide are emitted during the xanthation, coagulation,regeneration, and purification stages of the viscose process. These gases are then vented to theatmosphere through the viscose process vent (144 foot stack). Ammonia is released from thefibrous casing regeneration process. The emission rates below reflect both process and fugitiveammonia emissions. This source has been in operation at the facility since 1976. There are nocontrol devices associated with this source.

Specific Conditions

1. Pursuant to §19.501 et seq of the Regulation 19 effective February 15, 1999 and 40 CFRPart 52, Subpart E, the permittee shall not exceed the emission rates set forth in thefollowing table. Compliance with this condition will be demonstrated throughcompliance with Specific Condition #4.

Pollutant lb/hr tpy

VOC 2.3 0.2

2. Pursuant to §18.801 of the Arkansas Air Pollution Control Code (Regulation #18)effective February 15, 1999, and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated through compliance withSpecific Condition #3

Pollutant lb/hr tpy

Ammonia 21.6 63.0

CarbonDisulfide

238.0 898.0

HydrogenSulfide

56.0 211.0

TRS* 254.0 954.0* total reduced sulfur


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3. Pursuant to §18.1004 of Regulation 18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not consume more than 2,380,000 pounds of carbondisulfide (CS2 ) per year. The permittee shall monitor and record the monthly amount ofCS2 consumed at the facility, as determined from weigh scales. These records shall bemaintained on a monthly basis and updated monthly. These records shall be maintainedon site and made available to Department personnel upon request. A copy of theserecords shall be submitted in accordance with General Provision #7.

4. Pursuant to §19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, and 40 CFR Part 70.6, the permittee shall not use more than 110 gallons ofsurfactant (Aerosol OT 75%) per consecutive 12 month period. This surfactant shall notexceed 25% VOC content by weight. Compliance shall be demonstrated throughcompliance with Specific Condition #5.

5. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shallmaintain records of the amount of surfactant (Aerosol OT 75%) used and the VOCcontent. These records shall be kept on a monthly basis and updated monthly. Theserecords shall be kept on site and made available to Department personnel upon request. A copy of these records shall be submitted in accordance with General Provision #7.


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SN-02 & 03Industrial Boiler #1 and Industrial Boiler #2

Source Description

The facility utilizes two industrial on-site boilers each with a heat input capacity of 71MMBTU/hr. The boilers generate steam for use in multiple production operations such as theacid bath evaporator systems, crystallizer, process water wash, glycerine handling system,deaeration vacuum system casing process dryers, and space heating. The boilers are currentlypermitted to operate under alternate operating scenarios. Scenario I represents natural gascombustion, Scenario II represents No. 2 Fuel Oil combustion, and Scenario III represents No. 6Fuel Oil combustion. The boilers are typically fired with natural gas. Both boilers have been inoperation at the facility since 1976. No control devices are associated with these sources. Emission limits are worst case based on the type of fuel being fired.

Specific Conditions

6. Pursuant to §19.501 et seq of the Regulation 19 and 40 CFR Part 52, Subpart E, thepermittee shall not exceed the emission rates set forth in the following table. Compliancewith this condition will be demonstrated through compliance with Specific Conditions#9, #11, and #12.

SN-# Pollutant lb/hr ton/yr

02 PM10SO2

VOCCONOx

6.174.20.46.025.7

18.8229.11.218.479.3

03 PM10SO2

VOCCONOx

6.174.20.46.025.7

18.8229.11.218.479.3

7. Pursuant to §18.801 Regulation 18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated through compliance withSpecific Conditions #9, #11, and #12.


12

SN Pollutant lb/hr tpy

02 PM 6.1 18.8

03 PM 6.1 18.8

8. Pursuant to §19.503 of Regulation 19, the permittee shall not exceed 20 percent opacityfrom SN-02 and SN-03. Compliance with the opacity limit when natural gas is beingused as fuel may be demonstrated through evidence that the source is burning onlynatural gas. Compliance with the opacity limit when these sources are combusting fueloil shall be demonstrated through compliance with Plantwide Condition #7.

9. Pursuant to §19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311 and 40 CFR Part 70.6, the permittee shall not exceed 1.0 percent sulfur contentin the No. 2 and No. 6 Fuel Oils used to fire the boilers. The sulfur content of the fuel oilused shall be verified by testing or vendor guarantees. Compliance shall be demonstratedthrough compliance with Specific Condition #10.

10. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shallmaintain records of the sulfur content of the fuel oils used to fire the boilers. Theserecords shall be updated as needed and maintained on site and made available toDepartment personnel upon request. A copy of these records shall be submitted inaccordance with General Provision #7.

11. Pursuant to §19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311 and 40 CFR Part 70.6, when operating under Scenario II, No. 2 fuel oil usageshall be limited on a monthly basis to 548,000 gallons per month and shall not exceed theannual limit of 6,576,000 gallons per any consecutive twelve (12) month period. Compliance shall be demonstrated through compliance with Specific Condition #13.

12. Pursuant to §19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311 and 40 CFR Part 70.6, when operating under Scenario III, No. 6 fuel oil usageshall be limited on a monthly basis to 490,000 gallons per month and shall not exceed theannual limit of 5,800,000 gallons per any consecutive twelve (12) month period. Compliance shall be demonstrated through compliance with Specific Condition #13.

13. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shallmaintain records of the amount of No. 2 and No. 6 fuel oil used. The records shall beupdated on a monthly basis, shall be kept on site, shall be provided to Department


13

personnel upon request, and an annual total and each individual month’s data shall besubmitted in accordance with General Provision #7.

14. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shall

contemporaneously with making a change from one operating scenario to another, recordin a log at the permitted facility a record of the scenario under which the facility orsource is operating. Compliance shall be demonstrated through compliance with GeneralProvision 17.


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SN-04 Lime Silo

Source Description

Viskase operates an on-site wastewater treatment plant to ensure wastewater is properly treatedprior to discharge into the Mississippi River. Calcium hydroxide is combined with water and fedas a lime slurry to neutralize process wastewater. The neutralized wastewater is equalized andclarified before being eventually discharged to the river. The lime is stored in a 150 ton siloequipped with a baghouse (SN-04).

Specific Conditions

15. Pursuant to §19.501 et seq of the Regulation 19 and 40 CFR Part 52, Subpart E, thepermittee shall not exceed the emission rates set forth in the following table. Compliancewith this condition will be demonstrated through compliance with Specific Condition#18.

Pollutant lb/hr tpy

PM10 0.2 0.6

16. Pursuant to §18.801 Regulation 18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated through compliance withSpecific Condition #18.

Pollutant lb/hr tpy

PM 0.2 0.6

17. Pursuant to §19.503 of Regulation 19 and 40 CFR Part 52, Subpart E, visible emissionfrom this source shall not exceed 20 % opacity. Compliance shall be demonstratedthrough compliance with Plantwide Condition #7.

18. Pursuant to §19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311 and 40 CFR Part 70.6, the permittee shall not receive more than 2,000 tons oflime at this source per consecutive twelve month period. Compliance shall bedemonstrated through compliance with Specific Condition #19.


15

19. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shallmaintain records of the amount of lime received at this source. These records shall bemaintained on a monthly basis and updated monthly. The permittee shall maintain arolling twelve month total of the amount of lime received. These records shall bemaintained on site and made available to Department personnel upon request. A copy ofthese records shall be submitted in accordance with General Provision #7

20. Pursuant to 18.1104 of Regulation 18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall operate the control equipment associated with thissource in a manner consistent with good air pollution control practices in order to complywith the applicable emission limits.


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SN-05 Emergency Fire Water Pump

Source Description

A 340 horsepower emergency fire water pump will be used in the event of a fire at the facility. The pump is normally tested one hour a week, fifty-two weeks a year. The pump is additionallyperiodically used as a source of water for other operations and maintenance activities at thefacility.

Specific Conditions

21. Pursuant to §19.501 et seq of the Regulation 19 and 40 CFR Part 52, Subpart E, thepermittee shall not exceed the emission rates set forth in the following table. Compliancewith this condition will be demonstrated through compliance with Specific Condition#25.

Pollutant lb/hr tpy

PM10 0.8 1.9

SO2 0.7 1.7

VOC 0.9 2.1

CO 2.3 5.7

NOX 10.5 26.4

22. Pursuant to §18.801 Regulation 18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated through compliance withSpecific Condition #25.

Pollutant lb/hr tpy

PM 0.8 1.9

Aldehydes 0.2 0.4


17

23. Pursuant to §19.503 of Regulation 19 and 40 CFR Part 52, Subpart E, visibleemissions from this source shall not exceed 20 percent opacity. Compliance shall be demonstrated through compliance with SpecificCondition #24.

24. Pursuant to §18.1004 of Regulation 18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, visible emission observations shall be used as a method of complianceverification for the opacity limits assigned. The observations shall be conducted bypersonnel familiar with the facility’s visible emissions when this source is operating. Ifduring the daily observations, visible emissions are detected which appear to be in excessof the permitted opacity limit, the permittee shall:a. Take immediate action to identify the cause of visible emissions,b. Implement corrective action, andc. If excess visible emissions are still detected, an opacity reading shall be

conducted in accordance with EPA Reference Method 9. The reading shall beconducted by personnel trained and certified in the reference method. If theopacity reading exceeds the permitted limit, further corrective measures shall betaken.

d. If no excessive visible emissions are detected, the incident shall be noted in therecords as described below.

The permittee shall maintain records related to all visible emission observations andMethod 9 readings. The records shall be updated on an as-performed basis. Theserecords shall be kept on site and made available to Department personnel upon request. The records shall contain:

a. The date and time of each observation/reading of any observance of visibleemissions appearing to be above permitted limits or any Method 9 reading whichindicates exceedence,

b. The cause of any observed exceedence of opacity limits, corrective action taken,and results of the reassessment, and

c. The name of the person conducting the observation/reading.

25. Pursuant to §19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311, and 40 CFR Part 70.6, the hours of operationfor SN-05 shall not exceed 5000 hours during any consecutive twelvemonth period. Compliance shall be demonstrated through compliancewith Specific Condition #26.


18

26. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shall maintain records of the hours of operation of SN-05. The records shall be maintained on a monthly basis and updatedmonthly. These records shall be kept on site and made available toDepartment personnel upon request. A copy of these records shall be submittedin accordance with General Provision #7.


19

SN-06 Carbon Disulfide Fugitive Emissions

Source Description

Fugitive emissions occur from the unloading of tank cars to two storage tanks, transfer of carbondisulfide from storage tanks to weigh scales, and weigh tank operations.

Specific Conditions

27. Pursuant to §18.801 Regulation 18 and A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated through compliance withSpecific Conditions #28 and #29.

Pollutant lb/hr tpy

CarbonDisulfide

0.8 3.6

28. Pursuant to §18.1004 of Regulation 18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the unloading of standard tank cars, jumbo tank cars, and intermodalportable tanks shall be limited to 100 hours of operation per year. The permittee shalldemonstrate compliance by maintaining records of the hours that these vessels areunloaded. These records shall be maintained on a weekly basis and updated weekly. These records shall be maintained on site and made available to Department personnelupon request. A copy of these records shall be submitted in accordance with GeneralProvision #7.

29. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52 Subpart E, where no morestringent federal regulation applies, the permittee shall calculate all fugitive emissions foreach process area once every five years. The results of these calculations shall besummarized and included in each Title V renewal application. The fugitive emissionsmay be calculated using usage data (for ancillary chemicals, such as refrigerants and heattransfer fluids), monitoring data with EPA stratified factors, and EPA average SOCMIfactors with component counts. Other methods may also be used if prior approval isreceived from the Department.


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SECTION V: COMPLIANCE PLAN AND SCHEDULE

Viskase Corporation is in compliance with the applicable regulations cited in the permitapplication. Viskase Corporation will continue to operate in compliance with those identifiedregulatory provisions. The facility will examine and analyze future regulations that may applyand determine their applicability with any necessary action taken on a timely basis.


21

SECTION VI: PLANTWIDE CONDITIONS

1. Pursuant to §19.704 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203as referenced by §8-4-304 and §8-4-311, the Director shall be notified in writing withinthirty (30) days after construction has commenced, construction is complete, theequipment and/or facility is first placed in operation, and the equipment and/or facilityfirst reaches the target production rate.

2. Pursuant to §19.410(B) of Regulation 19, 40 CFR Part 52, Subpart E, the Director maycancel all or part of this permit if the construction or modification authorized herein isnot begun within 18 months from the date of the permit issuance or if the work involvedin the construction or modification is suspended for a total of 18 months or more.

3. Pursuant to §19.702 of Regulation 19 and/or §18.1002 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, any equipment that is to betested, unless stated in the Specific Conditions of this permit or by any federallyregulated requirements, shall be tested with the following time frames: (1) Equipment tobe constructed or modified shall be tested within sixty (60) days of achieving themaximum production rate, but in no event later than 180 days after initial start-up of thepermitted source or (2) equipment already operating shall be tested according to the timeframes set forth by the Department or within 180 days of permit issuance if no date isspecified. The permittee shall notify the Department of the scheduled date of compliancetesting at least fifteen (15) days in advance of such test. Compliance test results shall besubmitted to the Department within thirty (30) days after the completed testing.

4. Pursuant to §19.702 of Regulation 19 and/or §18.1002 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, the permittee shall provide:

a. Sampling ports adequate for applicable test methodsb. Safe sampling platforms c. Safe access to sampling platformsd. Utilities for sampling and testing equipment

5. Pursuant to §19.303 of Regulation 19 and A.C.A. §8-4-203 as referenced by A.C. A.§8-4-304 and §8-4-311, the equipment, control apparatus and emission monitoringequipment shall be operated within their design limitations and maintained in goodcondition at all times.


22

6. Pursuant to Regulation 26 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311,this permit subsumes and incorporates all previously issued air permits for this facility.

7. Pursuant to §18.1004 of Regulation 18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, visible emission observations shall be used as a method of complianceverification for the opacity limits assigned. The observations shall be conducted bypersonnel familiar with the facility’s visible emissions. If during the daily observations,visible emissions are detected which appear to be in excess of the permitted opacity limit,the permittee shall:a. Take immediate action to identify the cause of visible emissions,b. Implement corrective action, andc. If excess visible emissions are still detected, an opacity reading shall be

conducted in accordance with EPA Reference Method 9. The reading shall beconducted by personnel trained and certified in the reference method. If theopacity reading exceeds the permitted limit, further corrective measures shall betaken.

d. If no excessive visible emissions are detected, the incident shall be noted in therecords as described below.

The permittee shall maintain records related to all visible emission observations andMethod 9 readings. The records shall be updated on an as-performed basis. Theserecords shall be kept on site and made available to Department personnel upon request. The records shall contain:

a. The date and time of each observation/reading of any observance of visibleemissions appearing to be above permitted limits or any Method 9 reading whichindicates exceedence,

b. The cause of any observed exceedence of opacity limits, corrective action taken,and results of the reassessment, and

c. The name of the person conducting the observation/reading.

Title VI Provisions

8. The permittee shall comply with the standards for labeling of products using ozonedepleting substances pursuant to 40 CFR Part 82, Subpart E:

a. All containers containing a class I or class II substance stored or transported, allproducts containing a class I substance, and all products directly manufacturedwith a class I substance must bear the required warning statement if it is beingintroduced to interstate commerce pursuant to §82.106.


23

b. The placement of the required warning statement must comply with therequirements pursuant to §82.108.

c. The form of the label bearing the required warning must comply with therequirements pursuant to §82.110.

d. No person may modify, remove, or interfere with the required warning statementexcept as described in §82.112.

9. The permittee shall comply with the standards for recycling and emissions reductionpursuant to 40 CFR Part 82, Subpart F, except as provided for MVACs in Subpart B:

a. Persons opening appliances for maintenance, service, repair, or disposal mustcomply with the required practices pursuant to §82.156.

b. Equipment used during the maintenance, service, repair, or disposal of appliancesmust comply with the standards for recycling and recovery equipment pursuant to§82.158.

c. Persons performing maintenance, service repair, or disposal of appliances must becertified by an approved technician certification program pursuant to §82.161.

d. Persons disposing of small appliances, MVACs, and MVAC-like appliances mustcomply with record keeping requirements pursuant to §82.166. (“MVAC-likeappliance” as defined at §82.152.)

e. Persons owning commercial or industrial process refrigeration equipment mustcomply with leak repair requirements pursuant to §82.156.

f. Owners/operators of appliances normally containing 50 or more pounds ofrefrigerant must keep records of refrigerant purchased and added to suchappliances pursuant to §82.166.

10. If the permittee manufactures, transforms, destroys, imports, or exports a class I or classII substance, the permittee is subject to all requirements as specified in 40 CFR part 82,Subpart A, Production and Consumption Controls.

11. If the permittee performs a service on motor (fleet) vehicles when this service involvesozone-depleting substance refrigerant (or regulated substitute substance) in the motorvehicle air conditioner (MVAC), the permittee is subject to all the applicablerequirements as specified in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle AirConditioners.

The term “motor vehicle” as used in Subpart B does not include a vehicle in which finalassembly of the vehicle has not been completed. The term “MVAC” as used in SubpartB does not include the air-tight sealed refrigeration system used as refrigerated cargo, orthe system used on passenger buses using HCFC-22 refrigerant.


24

12. The permittee shall be allowed to switch from any ozone-depleting substance to anyalternative that is listed in the Significant New Alternatives Program (SNAP)promulgated pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives PolicyProgram.


25

SECTION VII: INSIGNIFICANT ACTIVITIES

Pursuant to §26.304 of Regulation 26, the following sources are insignificant activities. Anyactivity for which a state or federal applicable requirement applies is not insignificant even if thisactivity meets the criteria of §304 of Regulation 26 or is listed below. Insignificant activitydeterminations rely upon the information submitted by the permittee in an application datedMarch 4, 2002.

Description Category

Laboratory Vents Group A, #5

Glycerine emissions from dryer stack Group A, #13

Chlorine cylinders Group A, #13

2000 gallon used oil tank, Group A, #13

(2) 14,000 gallon glycerine tanks Group A, #13

(4) fuel oil tanks (1-600 gal., 3-150,000 gal.) Group A, #13

500 gallon gasoline tank Group A, #3

Pursuant to §26.304 of Regulation 26, the emission units, operations, or activities contained inRegulation 19, Appendix A, Group B, have been determined by the Department to beinsignificant activities. Activities included in this list are allowable under this permit and neednot be specifically identified.


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SECTION VIII: GENERAL PROVISIONS

1. Pursuant to 40 CFR 70.6(b)(2), any terms or conditions included in this permit whichspecify and reference Arkansas Pollution Control & Ecology Commission Regulation 18or the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as thesole origin of and authority for the terms or conditions are not required under the CleanAir Act or any of its applicable requirements, and are not federally enforceable under theClean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 18 wasadopted pursuant to the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101et seq.). Any terms or conditions included in this permit which specify and referenceArkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Waterand Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as the origin of and authority forthe terms or conditions are enforceable under this Arkansas statute.

2. Pursuant to 40 CFR 70.6(a)(2) and §26.701(B) of the Regulations of the ArkansasOperating Air Permit Program (Regulation 26), effective August 10, 2000, this permitshall be valid for a period of five (5) years beginning on the date this permit becomeseffective and ending five (5) years later.

3. Pursuant to §26.406 of Regulation #26, it is the duty of the permittee to submit acomplete application for permit renewal at least six (6) months prior to the date of permitexpiration. Permit expiration terminates the permittee's right to operate unless acomplete renewal application was submitted at least six (6) months prior to permitexpiration, in which case the existing permit shall remain in effect until the Departmenttakes final action on the renewal application. The Department will not necessarily notifythe permittee when the permit renewal application is due.

4. Pursuant to 40 CFR 70.6(a)(1)(ii) and §26.701(A)(2) of Regulation #26, where anapplicable requirement of the Clean Air Act, as amended, 42 U.S.C. 7401, et seq (Act) ismore stringent than an applicable requirement of regulations promulgated under Title IVof the Act, both provisions are incorporated into the permit and shall be enforceable bythe Director or Administrator.

5. Pursuant to 40 CFR 70.6(a)(3)(ii)(A) and §26.701(C)(2) of Regulation #26, records ofmonitoring information required by this permit shall include the following:

a. The date, place as defined in this permit, and time of sampling ormeasurements;

b. The date(s) analyses were performed;


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c. The company or entity that performed the analyses;d. The analytical techniques or methods used;e. The results of such analyses; and f. The operating conditions existing at the time of sampling or measurement.

6. Pursuant to 40 CFR 70.6(a)(3)(ii)(B) and §26.701(C)(2)(b) of Regulation #26, records ofall required monitoring data and support information shall be retained for a period of atleast 5 years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all originalstrip-chart recordings for continuous monitoring instrumentation, and copies of allreports required by this permit.

7. Pursuant to 40 CFR 70.6(a)(3)(iii)(A) and §26.701(C)(3)(a) of Regulation #26, thepermittee shall submit reports of all required monitoring every 6 months. If no otherreporting period has been established, the reporting period shall end on the last day of theanniversary month of this permit. The report shall be due within 30 days of the end ofthe reporting period. Even though the reports are due every six months, each report shallcontain a full year of data. All instances of deviations from permit requirements must beclearly identified in such reports. All required reports must be certified by a responsibleofficial as defined in §26.2 of Regulation #26 and must be sent to the address below.

Arkansas Department of Environmental QualityAir DivisionATTN: Compliance Inspector SupervisorPost Office Box 8913Little Rock, AR 72219

8. Pursuant to 40 CFR 70.6(a)(3)(iii)(B), §26.701(C)(3)(b) of Regulation #26, and §19.601and 19.602 of Regulation #19, all deviations from permit requirements, including thoseattributable to upset conditions as defined in the permit shall be reported to theDepartment. An initial report shall be made to the Department by the next business dayafter the discovery of the occurrence. The initial report may be made by telephone andshall include:

a. The facility name and location,b. The process unit or emission source which is deviating from the permit

limit, c. The permit limit, including the identification of pollutants, from which

deviation occurs, d. The date and time the deviation started,


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e. The duration of the deviation, f. The average emissions during the deviation,g. The probable cause of such deviations,h. Any corrective actions or preventive measures taken or being taken to

prevent such deviations in the future, and i. The name of the person submitting the report.

A full report shall be made in writing to the Department within five (5) business days ofdiscovery of the occurrence and shall include in addition to the information required byinitial report a schedule of actions to be taken to eliminate future occurrences and/or tominimize the amount by which the permits limits are exceeded and to reduce the lengthof time for which said limits are exceeded. If the permittee wishes, they may submit afull report in writing (by facsimile, overnight courier, or other means) by the nextbusiness day after discovery of the occurrence and such report will serve as both theinitial report and full report.

9. Pursuant to 40 CFR 70.6(a)(5) and §26.701(E) of Regulation #26, and A.C.A.§8-4-203,as referenced by §8-4-304 and §8-4-311, if any provision of the permit or the applicationthereof to any person or circumstance is held invalid, such invalidity shall not affect otherprovisions or applications hereof which can be given effect without the invalid provisionor application, and to this end, provisions of this Regulation are declared to be separableand severable.

10. Pursuant to 40 CFR 70.6(a)(6)(i) and §26.701(F)(1) of Regulation #26, the permitteemust comply with all conditions of this Part 70 permit. Any permit noncompliance withapplicable requirements as defined in Regulation #26 constitutes a violation of the CleanAir Act, as amended, 42 U.S.C. 7401, et seq. and is grounds for enforcement action; forpermit termination, revocation and reissuance, or modification; or for denial of a permitrenewal application. Any permit noncompliance with a state requirement constitutes aviolation of the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.)and is also grounds for enforcement action; for permit termination, revocation andreissuance, or modification; or for denial of a permit renewal application.

11. Pursuant to 40 CFR 70.6(a)(6)(ii) and §26.701(F)(2) of Regulation #26, it shall not be adefense for a permittee in an enforcement action that it would have been necessary to haltor reduce the permitted activity in order to maintain compliance with the conditions ofthis permit.

12. Pursuant to 40 CFR 70.6(a)(6)(iii) and §26.701(F)(3) of Regulation #26, this permit maybe modified, revoked, reopened, and reissued, or terminated for cause. The filing of arequest by the permittee for a permit modification, revocation and reissuance, or


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termination, or of a notification of planned changes or anticipated noncompliance doesnot stay any permit condition.

13. Pursuant to 40 CFR 70.6(a)(6)(iv) and §26.701(F)(4) of Regulation #26, this permit doesnot convey any property rights of any sort, or any exclusive privilege.

14. Pursuant to 40 CFR 70.6(a)(6)(v) and §26.701(F)(5) of Regulation #26, the permitteeshall furnish to the Director, within the time specified by the Director, any informationthat the Director may request in writing to determine whether cause exists for modifying,revoking and reissuing, or terminating the permit or to determine compliance with thepermit. Upon request, the permittee shall also furnish to the Director copies of recordsrequired to be kept by the permit. For information claimed to be confidential, thepermittee may be required to furnish such records directly to the Administrator alongwith a claim of confidentiality.

15. Pursuant to 40 CFR 70.6(a)(7) and §26.701(G) of Regulation #26, the permittee shall payall permit fees in accordance with the procedures established in Regulation #9.

16. Pursuant to 40 CFR 70.6(a)(8) and §26.701(H) of Regulation #26, no permit revisionshall be required, under any approved economic incentives, marketable permits,emissions trading and other similar programs or processes for changes that are providedfor elsewhere in this permit.

17. Pursuant to 40 CFR 70.6(a)(9)(i) and §26.701(I)(1) of Regulation #26, if the permittee isallowed to operate under different operating scenarios, the permittee shall,contemporaneously with making a change from one operating scenario to another, recordin a log at the permitted facility a record of the scenario under which the facility orsource is operating.

18. Pursuant to 40 CFR 70.6(b) and §26.702(A) and (B) of Regulation #26, all terms andconditions in this permit, including any provisions designed to limit a source's potentialto emit, are enforceable by the Administrator and citizens under the Act unless theDepartment has specifically designated as not being federally enforceable under the Actany terms and conditions included in the permit that are not required under the Act orunder any of its applicable requirements.


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19. Pursuant to 40 CFR 70.6(c)(1) and §26.703(A) of Regulation #26, any document(including reports) required by this permit shall contain a certification by a responsibleofficial as defined in §26.2 of Regulation #26.

20. Pursuant to 40 CFR 70.6(c)(2) and §26.703(B) of Regulation #26, the permittee shallallow an authorized representative of the Department, upon presentation of credentials, toperform the following:

a. Enter upon the permittee's premises where the permitted source is locatedor emissions-related activity is conducted, or where records must be keptunder the conditions of this permit;

b. Have access to and copy, at reasonable times, any records that must bekept under the conditions of this permit;

c. Inspect at reasonable times any facilities, equipment (includingmonitoring and air pollution control equipment), practices, or operationsregulated or required under this permit; and

d. As authorized by the Act, sample or monitor at reasonable timessubstances or parameters for the purpose of assuring compliance with thispermit or applicable requirements.

21. Pursuant to 40 CFR 70.6(c)(5) and §26.703(E)(3) of Regulation #26, the permittee shallsubmit a compliance certification with terms and conditions contained in the permit,including emission limitations, standards, or work practices. This compliancecertification shall be submitted annually and shall be submitted to the Administrator aswell as to the Department. All compliance certifications required by this permit shallinclude the following:

a. The identification of each term or condition of the permit that is the basisof the certification;

b. The compliance status;c. Whether compliance was continuous or intermittent;d. The method(s) used for determining the compliance status of the source,

currently and over the reporting period established by the monitoringrequirements of this permit; and

e. Such other facts as the Department may require elsewhere in this permit orby §114(a)(3) and 504(b) of the Act.

22. Pursuant to §26.704(C) of Regulation #26, nothing in this permit shall alter or affect thefollowing:


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a. The provisions of Section 303 of the Act (emergency orders), includingthe authority of the Administrator under that section;

b. The liability of the permittee for any violation of applicable requirementsprior to or at the time of permit issuance;

c. The applicable requirements of the acid rain program, consistent with§408(a) of the Act; or

d. The ability of EPA to obtain information from a source pursuant to §114of the Act.

23. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, this permitauthorizes only those pollutant emitting activities addressed herein.

Public Notice

Pursuant to the Arkansas Operating Air Permit Program (Regulation #26) Section 602, the AirDivision of the Arkansas Department of Environmental Quality gives the following notice:

Viskase Corporation operates a cellulose food casing plant located at 2221 East State Highway198 in Osceola, Arkansas 72370. This is a renewal of the Title V permit for this facility. Limeusage is being increased and this will result in a 0.3 tpy increase of PM10 emissions. Ammoniaemissions rates will also increase by 32.0 tpy to account for fugitive emissions. Lastly, thecalculations for natural gas combustion have been updated to reflect revised emission factors. Emissions increases are due to the use of updated factors and corrected calculations. With theexception of the increase in lime usage, no other changes are being made in the operation of thefacility.

The application has been reviewed by the staff of the Department and has received theDepartment's tentative approval subject to the terms of this notice.

Citizens wishing to examine the permit application and staff findings and recommendations maydo so by contacting Doug Szenher, Public Affairs Supervisor. Citizens desiring technicalinformation concerning the application or permit should contact Wesley Crouch, Engineer. BothDoug Szenher and Wesley Crouch can be reached at the Department's central office, 8001National Drive, Little Rock, Arkansas 72209, telephone: (501) 682-0744.

The draft permit and permit application are available for copying at the above address. A copyof the draft permit has also been placed at the Blytheville Public Library located at 500 North 5th

in Blytheville, Arkansas 72315. This information may be reviewed during normal businesshours. Interested or affected persons may also submit written comments or request a hearing on theproposal, or the proposed modification, to the Department at the above address - Attention: DougSzenher. In order to be considered, the comments must be submitted within thirty (30) days ofpublication of this notice. Although the Department is not proposing to conduct a publichearing, one will be scheduled if significant comments on the permit provisions are received. Ifa hearing is scheduled, adequate public notice will be given in the newspaper of largestcirculation in the county in which the facility in question is, or will be, located.

The Director shall make a final decision to issue or deny this application or to impose specialconditions in accordance with Section 2.1 of the Arkansas Pollution Control and EcologyCommission’s Administrative Procedures (Regulation #8) and Regulation #26.

Dated this

Marcus C. DevineDirector

Documents

ADEQ OPERATING AIR PERMITdisulfide unloading and transfer operations. Ammonia is released from the fibrous casing generation process and a small amount of glycerine emissions are released