INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
April 19, 2012

FOR:
Eka Chemicals Inc
4374 Nashville Ferry Road East
Columbus, MS 39702    

FACILITY DESCRIPTION
Eka Chemicals manufactures sodium chlorate and hydrogen peroxide.  The facility’s operations are defined by Standard Industrial Classification (SIC) Codes 2819 and 2879.  This permit action is for renewal of the existing Title V permit.  The following changes have been made:  (1) Emission Points AE-001 and AH-001 have been removed. (2)  Emission Point AD-004 has been removed from service.  (3)  Emission Points AB-011 and AB-012 are subject to the Major Source Boiler MACT.    

TITLE V PROGRAM APPLICABILITY BASIS
The facility’s potential-to-emit exceeds 100 tons per year (TPY) for each of the following criteria pollutants: Particulate Matter, Particulate Matter less than 10 microns , and Particulate Matter less than 2.5 microns (PM/PM10/PM2.5), Nitrogen Oxides (NOx), Carbon Monoxide (CO) and Volatile Organic Compounds (VOC).  The facility has the potential-to-emit more than 10 TPY of the following hazardous air pollutants (HAP): HCl, and Chlorine.

Summary of Potential Emissions:
Pollutant	lb/hr	tpy	
PM	373.9	1351.8	
PM10	373.9	1351.8	
PM2.5	373.9	1351.8	
SO2	18.9	28.0	
NOx	102.8	315.6	
CO	34.2	119.1	
VOC	26.7	103.7	
Naphthalene	1.8	7.7	
HCl	313.8	1375	
Chlorine	685.2	3001.2	
CO2		24862	
CH4		0.47	
N2O		0.047	
GHG Mass Total		24863	
CO2(e)		24887	

LEGAL AND FACTUAL BASIS FOR DRAFT PERMIT CONDITIONS

The State and Federally-enforceable conditions of Title V Operating Permits are based upon the requirements of the State of Mississippi Air Emissions Operating Permit Regulations for the Purposes of Title V of the Federal Clean Air Act (APC-S-6), and applicable requirements effective upon the date of permit issuance.  Applicable requirement means all of the following as they apply to emissions units in a Title V source:

1.	any standard or other requirement set forth in the State Implementation Plan (SIP) approved or promulgated by EPA through rulemaking under Title I of the Federal Clean Air Act (Federal Act) including the following:

a.	most of the State of Mississippi Air Emission Regulations for the Prevention, Abatement, and Control of Air Contaminants (APC-S-1) 
b.	the State of Mississippi Regulations for the Prevention of Air Pollution Emergency Episodes (APC-S-3),
c.	the State of Mississippi Regulations for the Prevention of Significant Deterioration of Air Quality (APC-S-5), and 40 CFR Part 52.21 by reference, and
d.	the provisions of the State of Mississippi Permit Regulations for the Construction and/or Operation of Air Emissions Equipment (APC-S-2), relating to construction permits and synthetic minor operating permits;

2.	any term or condition of any construction permits issued pursuant to Mississippi regulations approved or promulgated through rulemaking under Title I;

3.	any standard or other requirement under Section 111 of the Federal Act, including Section 111(d) which includes Title 40, Part 60 of the Code of Federal Regulations (40 CFR Part 60) and relevant sections of APC-S-1;

4.	any standard or other requirement under Section 112 of the Federal Act, including relevant sections of APC-S-1 and 40 CFR Parts 61, 63, and 68;

5.	any standard or other requirement of the acid rain program under Title IV of the Federal Act or the regulations promulgated thereunder, including the State of Mississippi Acid Rain Program Permit Regulations for Purposes of Title IV of the Federal Clean Air Act (APC-S-7)  adopted November 17, 1994, and 40 CFR Parts 72, 73, 75, 77, and 78;

6.	any requirements established pursuant to Section 504(b) or Section 114(a)(3) of the Federal Act;

7.	any standard or other requirement governing solid waste incineration under Section 129 of the Federal Act;

8.	any standard or other requirement for consumer and commercial products under Section 183(e) of the Federal Act;

9.	any standard or other requirement for tank vessels under Section 183(f) of the Federal Act;

10.	any standard or other requirement of the program to control air pollution from outer continental shelf sources under Section 328 of the Federal Act;

11.	any standard or other requirement of the regulations promulgated to protect stratospheric ozone under Title VI of the Federal Act;

12.	any national ambient air quality standard or increment or visibility requirement under part C of Title I of the Federal Act.

Each State and Federally-enforceable condition of the draft Title V Operating Permit references the specific relevant requirements of APC-S-6 or the applicable requirement upon which it is based. Any condition of the draft Title V permit that is enforceable by the State but is not Federally-enforceable is identified in the draft Title V permit as such.

CAM APPLICABILITY
Emission Points AH-002, AI-001, AI-003, AI-006, AI-007, AJ-001, AJ-002, AJ-003, AJ-004, AJ-009, AJ-010, AJ-011, and AJ-012 are subject to CAM.  CAM plans were submitted and approved during the previous Title V renewal and are attached in Appendix B.

MACT and NSPS APPLICABILITY
•	Standards of Performance for Industrial-Commercial-Institutional Steam Generating Unit – 40 CFR 60, Subpart Db
Emission Point AB-011 is subject to this NSPS.

•	Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Unit – 40 CFR 60, Subpart Dc
Emission Point AB-012 is subject to this NSPS.  

•	National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines – 40 CFR 63, Subpart ZZZZ
Emission Point AB-010 is an existing compression ignition emergency fire pump with a rating of less than 500 hp.  
Emission Points AE-005, AI-011, and AI-012 are existing compression ignition emergency generators with a rating of more than 500 hp.  These emission points only have to comply with 40 CFR 63.6640(f)(2).

•	National Emission Standards for Hazardous Air Pollutants for Industrial-Commercial-Institutional Boilers and Process Heaters – 40 CFR 63, Subpart DDDDD
Emission Points AB-011 and AB-013 are subject to this MACT.  These units burn natural gas or hydrogen gas produced onsite only.  These units are existing sources and have no emission limits, only work practice standards.  The hydrogen meets the definition of “other gas 1 fuel”.

Note that AB-011 was recently rebuilt due to an explosion.  However, the cost of the rebuild was less than 50% of the cost of a new boiler, and is, therefore, not considered “reconstruction”.

SPECIFIC APPLICABLE REQUIREMENTS

EMISSION LIMITS	
Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AB-010  AE-005  AI-011   AI-012  	PM (filterable only)	0.6 lbs/MMBTU	Monitor and maintain monthly records on the type, quantity, and sulfur content of all fuels combusted.

Because only diesel/No. 2 Fuel Oil is allowed, the PTE of these sources is well below state standards. 	
AB-011   AB-012		E = 0.8808*I-0.1667		
AB-010  AB-011  AB-012	SO2	4.8 lbs/MMBTU		
Sodium Chlorate Process	PM (filterable only)	E = 4.1(p)0.67	Testing not required because of large margin of compliance.  Process weight equation allows for 112.46 lb/hr and PTE of the process is 6.23 lb/hr.  This process is also subject to CAM.	
AB-011*	NOx	0.07 lbs/MMBTU, not to exceed 8.93 lbs/hr and 39.1 tpy	Install, calibrate, maintain, and operate CEMS for measure nitrogen oxides emission discharged to the atmosphere	
	Fuel Restriction	Natural gas and/or hydrogen only	Record and maintain records of the amount of fuel combusted during each month.	
AB-012	NOx	14.53 lbs/hr and 31.38 tpy	Record and maintain records of the maximum hourly nitrogen oxides emission rate and the consecutive 12-month nitrogen oxide emission rate in tons per year.  	
	Fuel Restriction	Natural gas only	Monitor and maintain monthly records on the type, quantity, and sulfur content of all fuels combusted.	
AE-005	Fuel Restriction	No. 2 Fuel Oil or Diesel with sulfur content ≤ 0.4% only	Monitor and maintain monthly records on the type, quantity, and sulfur content of all fuels combusted.	
AI-011   AI-012	Fuel Restriction	No. 2 Fuel Oil or Diesel with sulfur content ≤ 0.4% only	Monitor and maintain monthly records on the type, quantity, and sulfur content of all fuels combusted.	
AH-002	PM/PM10 (filterable only)	2.63 lb/hr and 11.5 tpy	Stack testing once per permit term to demonstrate compliance with the permitted emission limitations for particulate matter. Testing is reduced to once per permit term because a significant margin of compliance has been demonstrated; the limits are low, and the sources are also subject to CAM..  

Source also measure sodium chlorate concentration in the scrubbing liquid daily per the CAM plan.  

Conduct an opacity evaluation to demonstrate compliance with the state opacity limit of 40%.	
AJ-008	Hours of Operation	< 750 hours per year	Monitor the hours of operation on a 12-month rolling basis.	
AJ-001	VOC	2.42 lb/hr and 10.6 tpy	Stack testing once per permit term to demonstrate compliance with the permitted emission limitations for volatile organic compounds.

Testing is reduced to once per permit term because a significant margin of compliance has been demonstrated; the limits are low, and the sources are also subject to CAM.  	
AJ-011  AJ-012		1.3 lb/hr and 4.0 tpy		
AJ-002   AJ-003   AJ-004		1.3 lb/hr and 5.5 tpy		
AJ-009		0.525 lb/hr and 2.3 tpy		
AJ-010		0.525 lb/hr and 2.3 tpy		
AB-010	HAP	MACT Subpart ZZZZ	Change oil and filter every 500 hours of operation or annually; inspect air cleaner every 1000 hours of operation or annually; and inspection all hoses and belts every 500 hours of operation or annually.

Install a non-resettable hour meter if one is not already installed.

Minimize the engine’s time spent at idle during startup and minimize the engine’s startup time to a period need for appropriate and safe loading of the engine, not to exceed 30 minutes.

Any operation other than emergency operation, maintenance and testing, and operation in non-emergency situations for 50 hours per year is prohibited.  

AB-011	HAP	MACT Subpart DDDDD	Conduct an annual tune-up of the boiler or process heater and an energy assessment performed by a qualified energy assessor.	
AB-013			Conduct a biennial tune-up of the boiler or process heater and an energy assessment performed by a qualified energy assessor.	
*AB-011 – NSPS limit of 0.20 lb/MMBTU (30-day rolling average) superseded by PTC limit of 0.07 lb/MMBTU (3-hour rolling average) which is more stringent.  NSPS monitoring requirements will be used to demonstrate compliance with permit limits.

PM/PM10 Limits:
The PM and PM10 limits established in applicable standards and permits issued prior to January 1, 2011, were reevaluated to determine if they were based upon the filterable portion only or both the filterable and condensable portion. The limits were determined to be based on the filterable portion of the PM because the monitoring previously established did not require a demonstration of compliance using both a filterable and a condensable test method. As allowed under 40 CFR 52.21(b)(50)(vi), limits established prior to January 1, 2011, need not include condensable PM.  All PM/PM10 limits in the permit now indicate the portion of PM to which the limit applies.

Mississippi’s state standards for PM found in APC-S-1 were developed based upon filterable PM to ensure ambient air quality met the Total Suspended Particulate (TSP) NAAQS and were also established prior to the regulation of condensable PM.  Therefore, they are considered “filterable only” PM standards and are indicated as such in the permit.

MODIFICATIONS:
•	Fuel burning PM limits, SO2 limits, restrictions on hours of operation, NOx, CO, and VOC limits have been removed from Emission Points AE-005, AI-011, and AI-012.  These are emergency use only RICE engines; therefore, the RICE MACT restricts non-emergency use.  Previous permit limits were not established to avoid PSD since these have always been permitted as emergency use only engines. Also, these engines are only allowed to combust No. 2 fuel oil/diesel.  Therefore, through renewal of the Title V, the Construction Permit issued April 12, 1995, is being modified to remove specific limits, since these limits are unnecessary for avoiding PSD.  
•	For Emission Points AI-001, AI-003, AI-006, and AI-007, the process weight equation was used incorrectly to derive PM limits.  Process weight equation has been correctly applied to the sodium chlorate process, as a whole.  The PTE for this process is 6.23 lb/hr compared to the process weight equation, which allows 112.46 lb/hr.  The existing CAM requirements for these sources ensure compliance with the process weight equation.  Also, previous stack testing results for these sources have shown a significant margin of compliance with the process weight equation.
•	For Emission Point AJ-001, AJ-002, AJ-003, AJ-004, AJ-011 and AJ-012, the monitoring required by construction permits were removed because CAM is required; thus, these requirements are redundant.  
•	AJ-008 – In previous Title V permits, there have been PM limits on this emission point which were established in a Construction Permit issued February 22, 1994.  The limits were not established in a PSD permit and were not necessary to avoid PSD.  This emission point is only used 2 to 3 hours every 10 days when regeneration material is changed.  Back calculating from the existing permit limits, the hours of operation used as a basis for the Construction Permit limits are calculated to be 784.  We have limited the hours of operation to 750 to be consistent with the basis of the previous permitted limits.  Given its limited use and the inability to perform a complete stack test, the PM limits have been removed.  Instead a more practical approach of limiting the hours of operation and requiring use and maintenance of the baghouse is now required.