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RESPONSE TO COMMENTSFISHING HOLDINGS, LLC (WOOD MANUFACTURING COMPANY, INC.)PERMIT #0979-AOP-R8AFIN: 45-00008On September 8,2013, the Director of the Arkansas Department of Environmental Quality gave. notice of a draft permitting decision for the above referenced facility. During the commentperiod, written comments on the draft permitting decision were submitted by Akemi Bauer ofECCI, on behalf of the facility. The Department's response to these issues follows.Note: The following page numbers and condition numbers refer to the draft permit. Thesereferences may have changed in the final permit based on changes made during the commentperiodComment #1: Section II: Emission Summary, Page 15"Acetone emissions from SN-42 should be 0.21 lb/hr. In addition, Acetone emissions from SN43 should be 15.56 lb/hr. The total hourly Acetone emissions should be 252.9 lb/hr. (Seecalculation section of the application)"Response to Comment #1: The hourly acetone emissions in the summary table for SN-42 andSN-43 have been changed to the requested amounts as listed above and on the revised emissionrate tables for those sources, submitted on October 9,2013.Comment #2: Section IV: Specific Condition #1, Pages 27 and 28:"The source description for SN-26a should be Wall VentlFiberglassing Dust. The sourcedescription for SN-59b should be Old Boat Repair Building."Response to Comment #2: The source descriptions for SN-26a and SN-59b have been changedto the requested descriptions as listed above and on the revised emission rate tables for thosesources, submitted on October 9,2013.Comment #3: Section IV: Specific Condition #2, Pages 31 through 35:"The source description for SN-16b and SN-16c should be Roof Vent for Gel Coat Work-upBooth. SN-26a should be Wall Vent/Fiberglassing Dust. The source description for SN-59bshould be Old Boat Repair Building."Response to Comment #3: The source descriptions for SN-16b, SN-26a, and SN-59b have beenchanged to the requested descriptions as listed above. The source description for SN-16c, nowreads, "Roof vent for Gel Coat Touch-up Booth" as listed on emission rate table submitted withthe original application.Comment #4: Section IV: Specific Condition #11, Page 41:"VQC emissions from SN-21 and SN-22 should be 64.4lb/hr. (See calculation section of theapplication)"Page I of2

Response to Comment #4: The typographical error listed above has been corrected in the finalpermit.Comment #5: Section IV: Specific Condition #12, Page 42:"Acetone emissions from SN-42 should be 0.21 lb/hr. In addition, Acetone emissions from SN43 should be 15.56Ib/hr. (See calculation section of the application)"Response to Comment #5: The hourly acetone emissions in Specific Condition #12 for SN-42and SN-43 have been changed to the requested amounts as listed above and on the revisedemission rate tables for those sources, submitted on October 9,2013.Page 2 of2

ADEQARK A N S A SDepartment of Environmental QualityNovember 26, 2013Kenneth HowardEnvironmental Health and Safety ManagerFishing Holdings, LLC (Wood Manufacturing Company, Inc.)P.O. Box 179Flippin, AR 72634-0179Dear Mr. Howard:The enclosed Permit No. 0979-AOP-R8 is your authority to construct, operate, and maintain theequipment and/or control apparatus as set forth in your application initially received on10/5/2009.After considering the facts and requirements of A.C.A. §8-4-101 et seq., and implementingregulations, I have determined that Permit No. 0979-AOP-R8 for the construction, operation andmaintenance of an air pollution control system for Fishing Holdings, LLC (WoodManufacturing Company, Inc.) to be issued and effective on the date specified in the permit,unless a Commission review has been properly requested under Arkansas Department ofPollution Control & Ecology Commission's Administrative Procedures, Regulation 8, withinthirty (30) days after service of this decision.The applicant or permittee and any other person submitting public comments on the record mayrequest an adjudicatory hearing and Commission review of the final permitting decisions asprovided under Chapter Six of Regulation No.8, Administrative Procedures, Arkansas PollutionControl and Ecology Commission. Such a request shall be in the form and manner required byRegulation 8.603, including filing a written Request for Hearing with the APC&E CommissionSecretary at 101 E. Capitol Ave., Suite 205, Little Rock, Arkansas 72201. If you have anyquestions about filing the request, please call the Commission at 501-682-7890.Sincerely,Mike BatesChief, Air DivisionenclosureARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY5301 NORTHSHORE DRIVE / NORTH UTILE ROCK / ARKANSAS 72118-5317 / TELEPHONE 501-682-0744 / FAX 501-682-0880www.adeq.state.ar.us

ADEQOPERATINGAIR PERMITPursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation 26:Permit No. : 0979-AOP-R8IS ISSUED TO:Fishing Holdings, LLC (Wood Manufacturing Company, Inc.)Highway 178 NorthFlippin, AR 72634Marion CountyAFIN: 45-00008THIS 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:November 26, 2013ANDNovember 15, 2018THE PERMITTEE IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINEDHEREIN.Signed: Mike BatesChief, Air DivisionNovember 26, 2013Date

Fishing Holdings, LLC (Wood Manufacturing Company, Inc.)Permit #: 0979-AOP-R8AFIN: 45-00008Table of ContentsSECTION I: FACILITY INFORMATIONSECTION II: INTRODUCTIONSummary of Permit ActivityProcess Description'"RegulationsEmission SummarySECTION III: PERMIT HISTORYSECTION IV: SPECIFIC CONDITIONSStyrene Emission Sources Laminating, Repair and Gel Coat Work-up BoothsPaint Prep, Painting, Waxing, Cleaning, and Gluing Emission SourcesGrinding and Sanding Dust Collector Emission SourcesSECTION V: COMPLIANCE PLAN AND SCHEDULESECTION VI: PLANTWIDE CONDITIONSNESHAP, Subpart VVVV:SECTION VII: INSIGNIFICANT ACTIVITIESSECTION VIII: GENERAL PROVISIONSAppendix A: 40 CFR Part 63, Subpart VVVVAppendix B: 40 CFR Part 63, Subpart MMMM245556723252540445051547071

Fishing Holdings, LLC (Wood Manufacturing Company, Inc.)Permit #: 0979-AOP-R8AFIN: 45-00008List of Acronyms and AbbreviationsA.C.A.Arkansas Code AnnotatedAFINADEQ Facility Identification NumberCFRCode of Federal RegulationsCOCarbon MonoxideHAPHazardous Air Pollutantlb/hrPound Per HourMVACMotor Vehicle Air ConditionerNo.NumberNO xNitrogen OxidePMParticulate MatterPM 10Particulate Matter Smaller Than Ten MicronsSNAPSignificant New Alternatives Program (SNAP)S0 2Sulfur DioxideSSMStartup, Shutdown, and Malfunction PlanTpyTons Per YearUTMUniversal Transverse MercatorVOCVolatile Organic Compound3

Fishing Holdings, LLC (Wood Manufacturing Company, Inc.)Permit #: 0979-AOP-R8AFIN: 45-00008SECTION I: FACILITY INFORMATIONPERMITTEE:Fishing Holdings, LLC (Wood Manufacturing Company,AFIN:45-00008PERMIT NUMBER:0979-AOP-R8FACILITY ADDRESS:Highway 178 NorthFlippin, AR 72634MAILING ADDRESS:P.O. Box 179Flippin, AR 72634-0179Inc.). COUNTY:Marion CountyCONTACT NAME:Kenneth HowardCONTACT POSITION:Environmental Health and Safety ManagerTELEPHONE NUMBER:870-453-2222REVIEWING ENGINEER: Amanda LeamonsUTM North South (Y):Zone 15: 4016034.59 mUTM East West (X):Zone 15: 535756.43 m4

Fishing Holdings, LLC (Wood Manufacturing Company, Inc.)Permit #: 0979-AOP-R8AFIN: 45-00008SECTION II: INTRODUCTIONSummary of Permit ActivityFishing Holdings, LLC (Fishing Holdings, AFIN: 45-00008) located on Highway 178 North inFlippin, Arkansas, manufactures fiberglass boats, boat trailers, and a small line of fiberglassproducts for the boat industry. The boat and fiberglass product manufacturing process utilizes alaminating technique involving various coatings. The major components of the laminations arestyrene based resins and gel coat. This is the second Title V Renewal for the facility. This renewalincludes a minor modification to the permit, approved on July 2, 2013. The minor modificationallows the Saw Dust Collector/Pultrusion Baghouse (SN-40) to be emitted to the atmosphere.With this permit renewal the TLV table was modified based on updated modeling; hourly emissionrates were revised for several particulate and VOC sources based on current emission factor data;and particulate emissions from SN-40 were added to the permit. The annual permitted emissionsincreased 0.9 tons of PM and PMIO, while all other permitted emissions remained at the samelevels as permitted previously.Process DescriptionThe boat manufacturing process begins with the preparation of a mold. Molds are manufactured inthe Tooling Building. Sawdust collected from the manufacture and repair of molds is exhaustedthrough dust collectors (SN-40) to the atmosphere. The completed molds are then lined with athick gel coat material (SN-46 and SN-47).The boat units consist of the hull and the deck (the rail). When the two pieces are assembled, acavity remains between them which is filled with foam for flotation. The first step inmanufacturing these two pieces is to apply a styrene based gel coat to the inside of the mold. Thisoccurs at the New Plant Building (SN-OI through SN-04 and SN-13 through SN-16a, b, and c, 76,77, 78, and 79). These pieces are then built up by laminating layers of fiberglass and resins (SN05 through SN-12). When hardened, the boat is pulled out of the mold.Other laminating operations include the manufacture of boat trailer fenders at the Fenders andCCBM Building (SN-26 through 31); and small parts at the CCBM Building (SN-32 through 39),the Tooling Building (SN-46 and SN-47), and the Small Parts Building (SN-49 through SN-52).Boat repair operations, including laminating activities, occur at the New Boat Repair Building(SN-63 through SN-70), the Old Boat Repair Building (SN-59), and at the building referred to asClaudie's Repair (SN-59b). None-point sources have been eliminated from this application, andemissions have been accounted for under their respective point source numbers.Dust from sanding of the boat components is collected and exhausted through dust collectorsthroughout the plant (SN-17, 23, 24, 48a, and 70a). Boat seats and interior components aremanufactured at the facility. These operations include adhesive applications (SN-53, 54, and 61)and wood shop (SN-41).5

Fishing Holdings, LLC (Wood Manufacturing Company, Inc.)Permit #: 0979-AOP-R8AFIN: 45-00008Boat trailer manufacturing is also performed on-site. Dust from the sandblasting operations iscollected in two baghouses (SN-25 and SN-62). The fabricated trailers are painted in two paintbooths in the Trailer Shop (SN-21 and SN-22) or in the Truck Shop (SN-73 and SN-74). Paintingalso takes place in the Trailer Repair Department (SN-71 and SN-72).Six acetone storage tanks are maintained on site. These include three 450 gallon waste acetonetanks (SN-19, SN-20, and SN-45), one 450 gallon recovered acetone tank (SN-44), one 10,000gallon virgin acetone tank (SN-18), and one 3,500 gallon virgin acetone tank (SN-43). Toincorporate waste minimization into Ranger's waste management program, a still has been placedinto the operation for the recovery of waste acetone for reuse. The still is totally enclosed and isequipped with a condenser vent (SN-42).Foaming operations create no air emissions except for fugitives from equipment cleaning (SN-55).RegulationsThe following table contains the regulations applicable to this permit.RegulationsArkansas Air Pollution Control Code, Regulation 18, effective June 18,2010Regulations ofthe Arkansas Plan ofImplementation for Air Pollution Control,Regulation 19, effective July 27,2013Regulations of the Arkansas Operating Air Permit Program, Regulation 26, effectiveNovember 18,201240 CFR Part 63, Subpart VVVV (Appendix A)40 CFR Part 63, Subpart MMMM (Appendix B)6