response to comments the dow chemical company …

RESPONSE TO COMMENTS

THE DOW CHEMICAL COMPANYPERMIT #0801-AOP-R6

AFIN: 58-00011

On March 20 and March 21, 2009, the Director of the Arkansas Department of EnvironmentalQuality gave notice of a draft permitting decision for the above referenced facility. During thecomment period, written comments on the draft permitting decision were submitted by ECCr, onbehalf of the facility. The Department's response to these issues follows.

Comment #1:Changes to Section I - Facility Information. Please revise the Operating Permit number listed inSection I, Facility Information. The correct number is #0801-AOP-R6. Please change the nameof the facility contact from Jackie Crowe to Jackie Steele.

Response to Comment #1:The above requested change has been made.

Comment #2:We respectfully request that installation of the new vent hood for the DAC III Coating Operation(SN-37) be mentioned in the Summary of Permit Activity provided in Section II, Introduction, ofthe draft permit.

In addition, we also ask that the vent hood be included in the source description for the DAC IIIOperation (page 47).

Response to Comment #2:The above requested change has been made. "equipped with a vent hood" has been added to the5th sentence of the last paragraph on page 8 of this permit. Also, "equipped with a vent hood"has been added to the 4th sentence of the first paragraph on page 47 of this permit.

Comment #3:We request that the facility-wide hourly and annual emission rates for volatile organiccompounds (VOCs) listed in the table be revised so that these values are consistent with othersections of the draft permit and the underlying permit application. The correct emission rates forVOCs are 129.1 pounds per hour (lb/hr) total and 172.2 tons per year (tpy) total.

Response to Comment #3:The above requested change has been made. The pound per hour and ton per year in the draftwere incorrect.

Comment #4:Requested Changes to Specific Conditions for Production Unit #5 Operations (SN-07). SpecificConditions (SCs) #14 and #15 establish the emission limits for the Production Unit #5Operations (SN-07). Compliance is demonstrated by maintaining throughput records for various

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process materials and by calculating the styrene emissions. Conditions #14 and #15 includereferences to old SC #24, which established a facility-wide emission limitation for styrene. Thisprovision has been replaced by Plantwide Condition (PC) #12. We respectfully request that thereferences to SC #24 be deleted. Instead, references to PC #12 should be inserted in theseConditions. For example, SC #14 should read: "Compliance with this condition will bedemonstrated by Specific Conditions #16, #18, #20, #22 and #24 Plantwide Condition #12, andequipment limitations."

SC #15 includes an emission rate summary table for HAPs and acetone. The annual emissionrate for acetone (4.9 tpy) is designated with a double asterisk (**), which means that the acetoneemissions are included in the facility-wide HAP emission limits (9.5 tpy and 23.75 tpy).Acetone is not a HAP. The emissions of this pollutant will not be counted towards the HAPemission "caps." We request that SC #15 be revised accordingly.


Comment #5:During preparation of the draft permit, several of the existing Specific Conditions included in thecurrent air permit were deleted, and several new provisions were added. As a result, thereference numbers for certain Conditions are no longer in sequence. We respectfully request thatthese items be revised for the sake of future reference. A summary of the proposed changes isprovided below:

SourceDescription

Condition Current RevisedNo. No. Reference Reference

SN-09 Casting Resin Storage Tank #2 SC#30 SC#28 SC#26SC#31 SC#28 SC#26

SN-09A Casting Resin Storage ContainersSC#32 SC#28 SC#26SC#33 SC#28 SC#26

SN-IO Methylene Chloride Recovery Still SC#34 SC#37 SC#35SN-13 Anode Bake Oven SC#42 SC#47 SC#45

SN-27 Cathode Oil Coating OperationSC#69 SC#74 SC#72SC#70 SC#74 SC#72

SN-30 Plating Solution Evaporator SC#76 SC#80 SC#78SN-36 DAC V Coating Operation SC#83 SC#87 SC#85

SN-38 Fueling Station SC#88SCs #91 SCs#89and 92 and 90


Comment #6:The source-specific hourly and annual emission rates for hydrochloric acid (HCI) are establishedin several different Specific conditions. Some ofthe reported emission rates are not consistentwith the Emission Rate Summary Table and the underlying permit application. We respectfully

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request that these values be revised for the sake of future reference. A summary of the proposedchanges is provided below:

Source ConditionCurrent HCl Revised HCl

No.Description

No.emission rate emission

(lb/hr) rate (lb/hr)SN-12 Anode Dip Tank SC #41 0.1 0.09SN-20 Membrane Cell Components Dip Tank SC#62 0.1 0.12SN-22 Mix Tank Exhaust SC#64 0.1 0.01

Response to Comment #6:The above requested change has been made. There were no changes to permitted hourly HClemissions for these sources.

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ADEQARK A N S A SDepartment of Environmental Quality

May 22, 2009

Jackie SteeleEH&S TechnicianThe Dow Chemical Company3230 Dow RoadRussellville, AR 72802

Dear Mr. Steele:

The enclosed Permit No. 0801-AOP-R6 is issued pursuant to the Arkansas Operating PermitProgram, Regulation # 26.

After considering the facts and requirements ofA.C.A. §8-4-101 et seq., and implementingregulations, I have determined that Permit No. 0801-AOP-R6 for the construction, operation andmaintenance of an air pollution control system for The Dow Chemical Company to be issued andeffective on the date specified in the permit, unless a Commission review has been properlyrequested under §2.1.14 of Regulation No.8, Arkansas Department ofPollution Control &Ecology Commission's Administrative Procedures, within thirty (30) days after service of thisdecision.

All persons submitting written comments during this thirty (30) day period, and all other personsentitled to do so, may request an adjudicatory hearing and Commission review on whether thedecision of the Director should be reversed or modified. Such a request shall be in the form andmanner required by §2.1.14 of Regulation No.8.

Sincerely,

~.Mike BatesChief, Air Division

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY5301 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS 72118-5317/ TELEPHONE 501-682-0744/ FAX 501-682-0880

www.adeq.state.ar.us

ADEQOPERATINGAIR PERMIT

Pursuant to the Regulations of the Arkansas Operating Air Pennit Program, Regulation #26:

Permit #: 801-AOP-R6

IS ISSUED TO:The Dow Chemical Company

3230 Dow RoadRussellville, AR 72802

Pope CountyAFIN: 58-00011

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:

September 23, 2005 and September 22, 2010

AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN.

Signed:

Mike BatesChief, Air Division

May 22, 2009

Date

The Dow Chemical CompanyPermit #: 801-AOP-R6AFIN: 58-00011

Table of Contents

SECTION I: FACILITY INFORMATION .4

SECTION II: INTRODUCTION 5Summary of Pennit Activity 5Process Description , 5Regulations 9Emission Summary 10

SECTION III: PERMIT HISTORy .14

SECTION IV: SPECIFIC CONDITIONS 16

SECTION V: COMPLIANCE PLAN AND SCHEDULE .49

SECTION VI: PLANTWIDE CONDITIONS .50

SECTION VII: INSIGNIFICANTACTIVITIES 56

SECTION VIII: GENERAL PROVISIONS 57

2


List of Acronyms and Abbreviations

A.C.A.

AFIN

CFR

CO

HAP

lb/hr

MVAC

No.

NOx

PM

PM IO

SNAP

S0 2

Tpy

UTM

VOC

Arkansas Code Annotated

ADEQ Facility Identification Number

Code ofFederal Regulations

Carbon Monoxide

Hazardous Air Pollutant

Pound Per Hour

Motor Vehicle Air Conditioner

Number

Nitrogen Oxide

Particulate Matter

Particulate Matter Smaller Than Ten Microns

Significant New Alternatives Program (SNAP)

Sulfur Dioxide

Tons Per Year

Universal Transverse Mercator

Volatile Organic Compound

3

The Dow Chemical CompanyPennit #: 801-AOP-R6AFIN: 58-00011

SECTION I: FACILITY INFORMATION

PERMITTEE:AFIN:PERMIT NUMBER:

FACILITY ADDRESS:

COUNTY:

CONTACT POSITION:

TELEPHONE NUMBER:

The Dow Chemical Company58-00011801-AOP-R6

3230 Dow RoadRussellville, AR 72802

Pope

Jackie Steele, Environmental, Health &Safety Technician

(479) 968-0832

REVIEWING ENGINEER: Derrick Brown

UTM North-South (X):UTM East-West (Y):

4

Zone 15 3899 kmZone 15 486 km


SECTION II: INTRODUCTION

Summary of Permit Activity

The Dow Chemical Company (Dow) operates an industrial plant located in Russellville,Arkansas. This modification includes an increase in the hourly rate ofmanufacture ofanodeelectrodes for membrane-type chlorine cells. The affected emission sources are SN-12, SN-13,SN-20 through SN-23, and SN-26. HCI emissions have been removed from SN-30 emissioncalculations due to neutralization. Finally, a vent hood for the Dip Coating Process (SN-37) willbe installed. This modification reduces pennitted facility emissions ofVOC and HCI by 7 tonsper year and 8.96 tons per year respectively.

Process Description

Cathode and anode electrodes for chlorine ("chior-alkali") production cells are made andrefurbished at the facility. The polymer concrete components for these units are also fabricatedon-site. Air emissions from this facility are mainly VOCs and PM.

The production activities at the Dow facility include the following: the casting ofpolymerconcrete frames, covers and other parts for chlorine cells; the fabrication ofcathode and anodeelectrodes; the refurbishing ofcertain anode units; multiple electrode coating (i.e., plating)processes; numerous grit blasting and grinding operations; and a variety ofmiscellaneousindustrial activities.

CASTING OF REINFORCED POLYMER CONCRETE COMPONENTS FOR DIAPHRAGMCELLS (PRODUCTION UNIT #5)

Dow makes frames, covers and other components for chlorine production cells ("diaphragm" type units). These reinforced "polymer concrete" parts are made in Production Unit #5.

The raw materials for the batch casting operations include several styrene-based "epoxy vinylester resins," sand, chopped fiberglass, and miscellaneous ingredients. The primary resinmaterials are delivered in bulk by truck. The products are stored in two dedicated storage tanks(SN-D8R and SN-09). A "day tank" (SN-08A) supplies resin to the casting operations. Theresins are also transferred from the bulk tanks into small tote bins. (Resin materials may also bepurchased in tote bins and drums (SN-09A).)

Sand for the casting operations is also received in bulk by truck. It is unloaded into a storage silo(SN-02A). The silo is equipped with a baghouse for the control of dust emissions. Whenneeded, the sand is transferred to a weigh hopper (SN-03A) and then unloaded into a bulk mixer

5


unit. The sand weigh hopper is also equipped with a baghouse.

Chopped fiberglass is received in bulk boxes by truck. The material is transferred into the mixerunit using a vacuum system (SN-15).

The polymer concrete materials are prepared in a large mechanical mixer unit (SN-07). Thematerial is then transferred to the casting area. The bulk mixer is cleaned with methylenechloride after polymer preparation has been completed. Acetone is used to clean the hand toolsused in the casting operations.

The cell frames and covers are cast in large metal molds. Prior to use, each unit is coated with amold release agent (SN-07). Each casting station is equipped with a dedicated vent hood (SN07). No air pollution control equipment is used.

FINISHING OF CAST COMPONENTS FOR DIAPHRAGM CELLS (PRODUCTION UNIT

till

After casting, the polymer concrete components are subjected to various finishing operations.The parts are first transferred to the grit blasting building to remove burrs and rough edges. Thebuilding (SN-06) is equipped with a baghouse for the control of dust emissions. Next, the anodemounting enclosure is laminated with a mixture of resin and fiberglass (SN-07). After thelaminate has cured, an air grinder is used to trim the material (SN-04). The grinder room isequipped with a baghouse. Additional finishing of the cast components is performed at this timeusing mechanical grinders (SN-17). The grinder room is equipped with a baghouse. Completedcell frames are then transferred to Production Units #6 and #7 for assembly or are placed instorage.

REFURBISHING OF DIAPHRAGM ANODE ELECTRODES (PRODUCTION UNIT #6)

Dow refurbishes used anodes ("M-83" diaphragm units) for chlor-alkali cells at the Russellvilleplant. These operations are performed within Production Unit #6.

The M-83 anode assemblies are delivered on trucks, unloaded and then visually inspected forcleanliness. The units are then placed on pallets and sent to an off-site contractor where theanodes are grit blasted to remove the old metal surfacing. Upon return, the anode assembly isrepaired. The anode is then moved to a grit blasting area (SN-14). The blasting room isequipped with filter cartridges for the control of dust emissions. The anode is then transferred toa second grit blasting area (SN-ll) to prepare it for surface coating. The blasting room isequipped with dust filter cartridges.

6


After grit blasting, the anode is subsequently moved to the dip coating area to apply layers ofprecious metals to the electrode unit. A solvent, isopropyl alcohol, is used as the coatingmedium. It is purchased in bulk and stored in a tank (SN-26) prior to use. Anhydrous hydrogenchloride (He1) is used to achieve deposition of the metals onto the electrode surface. The gas ispurchased in cylinders.

The coating solution is prepared in two small open-top mix tanks (SN-22). After mixing, thesolution is transferred to two small coating mix storage tanks (SN-28). Prior to use, the materialis pumped to a small "day tank" (also SN-28) in the coating area. The anode assemblies aresurface coated in a large dip tank (SN-12). The electrode is then transferred to a natural gas-firedoven (SN-13) for curing. The dipping and baking process is repeated until the desired coatingthickness is attained. The anode is subsequently conveyed back to the grit blasting area (SN-14).The backboard is then blasted to prepare it for coating with metal. After blasting, a metal

coating is applied and allowed to cool and harden. The coating booth (SN-16) is equipped with a"hydrostatic precipitator" for the control of metal over-spray. Finally, the repaired anode isplaced within a reinforced polymer concrete frame. The refurbished electrode assembly is thenmoved to storage pending shipment off-site.

MANUFACTURE OF DIAPHRAGM CATHODE ELECTRODES (PRODUCTION UNIT #7)

The cathodes for chlorine production cells ("diaphragm units") are manufactured in ProductionUnit #7. Each unit consists of a "cathode back-screen" and a "cathode pocket assembly." Thetwo components are then assembled to yield the finished cathode.

Cathode Back-Screen Fabrication: The perforated metal sheets and flat steel bars used formaking back-screens are delivered by truck. The sheets are welded, punched and sheared to thecorrect dimensions. Concurrently, the flat steel bars are cut to the desired lengths. Finally, thebars are welded onto the metal sheeting to form a back-screen. Fabrication of the cathode backscreens (no SN) is an insignificant source of air emissions. The manufacturing activities arealmost entirely mechanical in nature.

Cathode Pocket Fabrication: "Pocket metal" sheets, bolts, and bolt-rod assemblies are deliveredby truck. The sheets are loaded onto an automated production line. The metal is then sheared,welded, formed and annealed. The bolts and bolt-rod assembles are subsequently inserted.Fabrication of the cathode pockets (no SN) is an insignificant source of air emissions. Thesemanufacturing activities are almost entirely mechanical in nature.

A hand-held grinder (SN-25) is used to smooth the cathode pockets during the fabricationprocess. The grinding area is equipped with a baghouse for the control of particulate emissions.

7


Assembly ofDiaphragm Cathode Unit: After fabrication, the cathode pocket and back-screenunits are mechanically put together. The cathode assembly operations (no SN) are aninsignificant source of air emissions. Finally, the finished cathode is transferred to an "oilingbooth" (SN-27). A rust preventive is applied using a spray gun. The fInished unit is then storedpending shipment off-site. The oiling booth is equipped with dust fIlters for the control of oilover-spray.

MANUFACTURE OF MEMBRANE CELL ANODES AND CATHODES (PRODUCTIONUNITS #6, #7, #8 AND MEMBRANE CELL UNIT)

Dow makes a second type of chlor-alkali cell ("membrane units") at the Russellville plant. Thisproduct also consists of an anode and cathode. The manufacturing operations are performedwithin Production Units #6, #7, #8 and the Membrane Cell Unit.

Fabrication of Membrane Anodes: The anode electrodes for membrane cells consist primarily ofmetal screens. The mesh material is delivered by truck. The metal screens are first grit blasted toprepare them for surface coating. The blasting room (SN-19) is equipped with a baghouse for thecontrol ofdust emissions.

A dip coating process is then used to apply layers ofprecious metals to the anode lIDits. It isperformed in Production Unit #6. The plating materials are dissolved in a solution of isopropylalcohol and HCI. The coating mixture is prepared in the two mix tanks (SN-22) and then storedin several holding tanks (SN-28). The membrane cell component is surface coated in a large diptank (SN-20). The part is then transferred to an electric "hot box" (also SN-20) for drying. Thecomponent is subsequently conveyed to an electric oven (SN-21) for curing. The dipping andbaking process is repeated until the desired coating thickness is attained. The plated anode isthen routed to the Membrane Cell Unit for final assembly.

Fabrication of Membrane Cathodes: The cathode electrodes for membrane cells consistprimarily of woven wire screens. The metal mesh is delivered by truck. The metal screens arefirst grit blasted to prepare them for surface coating. The blasting room (SN-32) is equipped witha baghouse for the control of dust emissions.

A dip coating process ("DAC III") is then used to apply a layer ofprecious metals to the cathodeunits. It is performed in Production Unit #8. The plating materials are dissolved in an aqueousHCl solution. The coating mixture is prepared in the two mix tanks (SN 22) and then stored inseveral holding tanks (SN-28). The membrane cell cathode is surface coated in a small dip tank(SN-37) equipped with a vent hood. The part is then transferred to an electric "hot box" (alsoSN-37) for drying and then conveyed to an electric oven (SN-21). The cathode is subsequently

8

The Dow Chemical CompanyPermit #: 80l-AOP-R6AFIN: 58-00011

subjected to a second coating operation ("DAC V") to apply another layer of precious metals tothe electrode units. The process is performed in Production Unit #8. The component is coated inseveral small dip tanks (SN 36). The plated cathode is then routed to the Membrane Cell Unitfor final assembly.

Assembly ofMembrane Cell Units: After coating, the cathode and anode units are mechanicallyput together. The finished membrane cell electrode is then stored in the plant warehouse pendingshipment to the customer. The membrane cell assembly operations (no SN) are an insignificantsource of air emissions. These activities are almost entirely mechanical in nature.

MISCELLANEOUS EQUIPMENT AND OPERATIONS

Solvent Recovery Still: Methylene chloride is used to clean the bulk mixer for the polymerconcrete casting operations (Production Unit #5). The spent solvent is collected for recycling. Asmall solvent still (SN-I0) is operated for this purpose. The still is vented directly to theatmosphere. No air pollution control equipment is utilized.

Evaporator for Waste Plating Solutions: The plating solutions from the coating processesbecome spent after repeated use. The wastes are subsequently processed thrOU~1. an electricevaporator unit (SN-30) to recover the plating components and reduce the volume ofwaste. Thespent materials are shipped off-site for further recovery or disposal. The evaporator is notequipped with an air pollution control device.

Fueling Station: Fuel is stored on-site for use in various plant vehicles and equipment. Thefueling station (SN-38) consists of two storage tanks, a 500-gallon gasoline tank and a 900-gallondiesel tank. The vessels are vented directly to the atmosphere.

Regulations

Arkansas Air Pollution Control Code, Regulation 18, effective January 25, 2009

Regulations of the Arkansas Plan of Implementation for Air Pollution Control,Regulation 19, effective January 25, 2009.Regulations of the Arkansas Operating Air Permit Program, Regulation 26, effectiveJanuary 25, 2009

Protection of Stratospheric Ozone, 40 CFR Part 82

The facility is not subject to 40 CFR Part 63 Subpart WWWW, National Emissions Standardsfor Hazardous Air Pollutants: Reinforced Plastic Composites Production because the facility isnot a major source of HAPs.

9

The Dow Chemical CompanyPermit #: 801-AOP-R6AFlN: 58-00011

The following table is a summary ofemissions from the facility. This table, in itself, is not anenforceable condition of the permit.

Emission Summary

EMISSION SUMMARY

Source Description Pollutant Emission Rates CrossNo. Reference

Page

lb/hr tpy

Total Allowable PM 2.7 4.0Emissions PM10 2.6 2.7

S02 0.1 0.1VOC 129.1 172.2CO 0.3 1.0NOx 0.3 1.2

Acetone** 13.0 4.9Ammonia** 3.7 3.6

1, 2-Epoxybutane* 0.06 -(106-88-7)

1,4-Dioxane* 0.28 -(123-91-1)

Hydrochloric Acid** 0.48 -(7647-01-0)

Methylchloroform ** 10.64 -(71-55-6)Methylene 22.45 -

chloride **(75-09-2)Styrene* (l00-42-5) 40.93 -

Single HAP - 9.5Total HAPs - 23.75

01 Upper Sand Silo Permanently Removed from Service.

02A Lower Sand PM 0.4 0.1 16Silo PM10 0.3 0.1

03A Sand Weight PM 0.1 0.1 17Hopper PM10 0.1 0.1

10


EMISSION SUMMARY


Page

lb/hr tpy

04 Grinding PM 0.1 0.3 18Operation #1 PM10 0.1 0.3

05 Dust Collector Permanently Removed from Service.

06 Grit Blasting PM 0.1 0.4 19Operation #1 PM IO 0.1 0.4

07 Production Unit VOC 65.7 16.2 20#5 Operations Acetone** 13.0 4.9

1, 2-Epoxybutane* 0.06 0.011,4-Dioxane* 0.28 0.04

Methyl Chloroform** 10.64 1.33Methylene Chloride** 22.02 9.5

Styrene * 38.70 9.5

08R Casting Resin VOC 1.0 0.1 23Storage Tank #1 Styrene * 1.0 0.05

08A Casting Resin VOC 0.1 0.1 25Day Tank Styrene * 0.03 0.01

09 Casting Resin VOC 1.3 0.1 26Storage Tank #2 Styrene * 1.22 0.03

09A Casting Resin VOC 0.1 0.1 27Container Styrene * 0.02 0.01

10 Methylene Methylene Chloride ** 0.43 0.03 28Chloride

Recovery Still

lOA Methylene Permanently Removed from Service.Chloride

Storage Tank

11 Grit Blasting PM 0.1 0.1 29Operation #2 PM10 0.1 0.1

12 Anode Dip VOC 26.7 150.9++ 30Tank Hydrochloric Acid** 0.09 0.94+++

11


EMISSION SUMMARY


Page

lb/hr tpy

13 Anode Bake PMlO 0.1 0.2 31Oven S02 0.1 0.1

VOC 0.1 0.1CO 0.1 0.3NOx 0.3 1.2

14 Grit Blasting PM 0.5 2.2 32Operation #3 PMlO 0.5 2.2

15 Fiberglass PM 0.7 0.1 33Transfer System PMlO 0.7 0.1

16 Metal Flame PM 0.1 0.3 34Spray Coating PMlO 0.1 0.3

Operation

17 Grinding PM 0.1 0.1 35Operation #2 PMlO 0.1 0.1

18 Dip Tank Deleted sourceDrying Area

Vent


20 and Membrane Cell VOC 4.4 150.9++ 3721 Components Hydrochloric Acid** 0.12 0.94+t+

Dip Tank andElectric Bake

Oven

22 and Mix Tank VOC 3.3 150.9++ 3823 Exhaust Vent Hydrochloric Acid** 0.01 0.94+t+

and Mix RoomExhaust Vent

24 Dust Collector Permanently Removed from Service.

25 Grinding PM 0.1 0.1 39Operation #3 PMlO 0.1 0.1

12


EMISSION SUMMARY


Page

lb/hr tpy

26 Isopropanol VOC 6.3 150.9++ 40Storage Tank

27 Cathode Oil PM 0.1 0.1 41Coating PMlO 0.1 0.1

Operation VOC 11.0 3.3

28 Coating Solvent VOC 2.7 0.1 43and 35 Storage Mix Hydrochloric Acid** 0.06 0.01

Tanks and DayTank

29 Deleted Source

30 Plating Solution VOC 0.5 0.7 44Evaporator Ammonia** 0.5 0,7

31 Trash Permanently Removed from Service.Incinerator


33 Electric Oven Permanently Removed from Service.

34 Paint Booth Permanently Removed from Service.

36 DAC V Coating VOC 0.3 0.3 46Operation Ammonia** 3.2 2.9

37 DAC III Hydrochloric Acid** 0.20 0.18 47Coating

Operation

38 Fueling Station VOC 5.6 0.2 48

* Hazardous Air Pollutants** Air Contaminants such as ammonia, acetone, and certain halogenated solvents are no VOCs.

++ Combined emissions from sources: SN-12, SN-20, SN-21, SN-22, SN-23, and SN-26.

+++ Combined emissions from sources: SN-12, SN-20, SN~21, SN-22, and SN-23.

13


SECTION III: PERMIT HISTORY

Air permit 0801-A was issued to Dow Chemical U.S.A. on 01/07/87 to consolidate various airpermits held by the facility.

Air permit 0801-AR-l was issued on 02/08/89 to remove two degreasing operations and add aprocess for oil coating of finished cathode assemblies.

Air permit 0801-AR-2 was issued on 03/14/90. This permit was to construct a productionfacility to manufacture metal components for membrane cells.

Air permit 0801-AR-3 was issued on 04/01/93. This permit was issued to account for changes inoperating practices that lowered the facility emissions. This permit also included solventemissions from storage tanks not previously permitted.

The permit was reissued as 0801-AR-4 on 04/21/94. This modification allowed for reduction ofthe annual allowable VOC emissions.

Permit 0801-AR-5 was issued on 12/07/94. The permit increased the production rate.

Permit 0801-AR-6 was issued on 04/06/99 and established Dow as a synthetic minor source inregards to Title V Regulations. The facility updated throughput rates and factors to limitemissions to below the Title V thresholds.

Permit 801-AOP-RO was the first operating permit for this facility issued under Regulation #26on 08/04/00. This permit allowed for a facility expansion to allow for greater production. Thisexpansion established Dow as a major stationary source for VOC.

Permit 801-AOP-Rl was a minor modification to the Title V air permit issued on July 9, 2002.This minor modification allowed Dow to replace the existing resin storage tank (SN-09) with anew tank. No increase in permitted emissions resulted from this permit modification.

Permit 801-AOP-R2AA was issued on January 4, 2005. Permit 801-AOP-R2 was issued onFebruary 6, 2004. This minor modification authorized Dow to replace the existing 903 gallonresin day use tank (SN-08A) with a 595 gallon tank, replace the body and hopper of the CopperFlame Spray (SN-16), and remove the methylene storage tank (SN-10A). The annual permittedemission limits for methylene chloride decreased 0.7 tpy and emissions of particulate matterdecreased 0.3 tpy.

14


Permit 801-AOP-R3 was issued on September 23,2005. This Title V renewal included thereplacement of two baghouses (SN-02 and SN-03), the establishment of permit limitations that"cap" the HAP emissions below the HAP major source thresholds, revision ofVOC, PMlPMIO,and HAP emissions based on revised calculations, and removal of two sources, SN-18 and SN24. Permitted emission changes included: decreases ofPM, PM IO, VOC, acetic acid, andammonia by 24.0 tons per year (tpy), 24.3 tpy, 70.3 tpy, 2.5 tpy, and 1.5 tpy respectively, andincreases of acetone by 1.2 tpy.

Permit 801-AOP-R4 was issued on January 2, 2007, This modification included installation of ademister on the suction side ofthe exhaust blower on SN-22, and replacement of existingbaghouse equipment (97% efficiency) on the grinding operation for SN-25 with new baghouseequipment (99% efficiency). There were no changes in permitted emissions.

Permit 801-AOP-R5 was issued January 30, 2008. This modification included the following:1. An increase in the concentration limit for HCI from 0.40 lb/gal to 0.71 lb/gal to provide

greater operational flexibility.2. The hourly emission rates for VOC and HAPs were revised from the anode dip tank (SN

12), membrane cell component dip tank (SN-20), mix tank exhaust vent (SN-22), andcoating solvent mixing storage tanks (SN-28).

3. The casting resin storage tank (SN-08) was replaced with a vertical fixed-roof tank (SN08R).

4. Installation of two new coating solvent mix storage tanks (SN-28).5. Utilization of the baghouse for grinding operation #1 (SN-04) as an alternative control

device for the sand weigh hopper (SN-03A). This contingency will provided greateroperational flexibility and reduced the plant's maintenance workload.

6. Clarification ofthe source description for the grinding operation #1 (SN-04). The VOCand HAP emissions generated with the casting resin mixer (SN-07) can be emitted fromthe nearby baghouse for the grinding area.

7. Remove methanol emissions from SN-27 as the rust preservative no longer containsmethanol.

8. Remove the lower sand silo and sand weigh hopper (SN-02 and SN-03) from the permit.There were no changes in yearly permitted emissions.

15


SECTION IV: SPECIFIC CONDITIONS

SN-02ALower Sand Silo

Source Description

A Torit baghouse, SN-02A is used to capture particulate from silica sand being transferredthrough a system to the production area.

Specific Conditions

1. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 19, §19.501 et seq. effective January 25,2009 and 40 CFR Part 52, SubpartE]

SN

02A

Pollutant

PM10

lb/hr

0.3

tpy

0.1

2. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 18, §18.801 effective January 25,2009, and AC.A. §8-4-203 as referencedby §8-4-304 and §8-4-311]

SN

02A

Pollutant

PM

lb/hr

0.4

tpy

0.1

3. The permittee shall not exceed 5% opacity from SN-02A as measured by EPA ReferenceMethod 9. Compliance with this condition will be demonstrated by Plantwide Condition#7. [Regulation 18, §18.501 and AC.A §8-4-203 as referenced by §8-4-304 and §8-4311]

16

The Dow Chemical CompanyPermit #: 801-AOP-R6APIN: 58-000 II

SN-03ASand Weigh Hopper

Source Description

A Torit baghouse, SN-03A is used to remove particulate from sand prior to its use in the Unit #5(polymer concrete casting) area.

Specific Conditions

4. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 19, §19.501 et seq. and 40 CPR Part 52, Subpart E]

SN

03A

Pollutant

PM IO

lb/hr

0.1

tpy

0.1

5. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 18, §18.801 ofRegulation #18 and A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311]

SN

03A IPollutant

PMIO

lb/hr

0.1

tpy

0.1

6. The permittee shall not exceed 5% opacity from SN-03A as measured by EPA ReferenceMethod 9. Compliance with this condition will be demonstrated by Plantwide Condition#7. [Regulation 18, §18.501 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4311]

7. The permittee shall have the ability to utilize the baghouse for grinding operation # I (SN04) as an alternative control device for the sand weigh hopper (SN-03A). [A.C.A. §8-4203 as referenced by §8-4-304 and §8-4-311]

17


SN-04Grinding Operation #1

Source Description

A Buell Norblo bag dust arrester with a mechanical shaker and electrically controlled air reversalvalve is used to control particulate matter emissions from the Grinding Room adjacent to Unit#5. This control equipment is 99% efficient. SN-04 is also an alternative control device for sandweigh hopper (SN-03A). Also, the emissions generated within the casting resin mixer (part ofSN-07) may be emitted from the nearby baghouse for grinding operation #1. These emissionsare accounted for at the Production Unit #5 operation (SN-07).

Specific Conditions

8. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E]

1L-__P-:-l:-~-~_t_-+--l:-7---t---:-.:---1

9. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 18, §18.801 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 0.1 0.3

10. The permittee shall not exceed 5% opacity from SN-04 as measured by EPA ReferenceMethod 9. Compliance with this condition will be demonstrated by Plantwide Condition#7. [Regulation 18, §18.501 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4311]

18

The Dow Chemical CompanyPennit #: 801-AOP-R6AFfN: 58-00011

SN-06Grit Blasting Operation #1

Source Description

A Torit Jet continuous duty tube house dust collector captures particulate from the gritblasting ofpolymer concrete casting and metal plates. These blasting activities occur in a closed room. Thebaghouse captures dust generated by the grit breaking down during use.

Specific Conditions

II. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 19, §19.50I et seq. and 40 CFR Part 52, Subpart E]

Pollutant lb/hr tpy

PM IO 0.1 0.4


Pollutant lb/hr tpy

PM 0.1 0.4


19


SN-07Production Unit #5 Operations

Source Description

The Unit #5 ventilation system collects and emits styrene emissions from casting Resin use,methyl chloroform emission from the coating of the molds, methylene chloride emissions fromthe cleaning of the mixer in the casting area, acetone emissions from the cleaning ofhand toolsand small parts within the casting area, and naphtha emissions from coating the flat surfaces ofcasting molds.

Specific Conditions

14. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Specific Conditions #16, #18,#20, #22, Plantwide Condition #12, and equipment limitations. [Regulation 19, §19.501et seq. and 40 CFR Part 52, Subpart E]

Pollutant lb/hr tpy

VOC 65.7 16.2

15. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Specific Conditions #16, #18,#20, #22, Plantwide Condition #12 and equipment limitations. [Regulation 18, §18.801and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

Acetone* 13.0 4.9*

1,2-Epoxybutane 0.06 0.01 **

1,4-Dioxane 0.28 0.04**

Methyl 10.64 1.33**Chloroform*

Methylene 22.02 9.5**Chloride*

20

The Dow Chemical CompanyPennit #: 801-AOP-R6APIN: 58-00011

Pollutant lblhr tpy

Styrene 38.70 9.5/23.75*** Nota VQC.** Plantwide Limit of 9.5 tpy of single HAp, 23.75 total. See Plantwide Condition #12.

16. The pennittee shall not use in excess of250 gallons ofChlorothene® SM solvent (whichcontains no more than 1O.64lb/gal methyl chlorofonn, 0.28lb/gall,4-dioxane, or 0.06Ib/gall,2-Epoxybutane in SN-07 during any consecutive twelve-month period.[Regulation 19, §19.501 et seq. of Regulation #19 and 40 CPR Part 52 Subpart E]

17. The pennittee shall maintain records which demonstrate compliance with the throughputand lb/gallimits set in Specific Condition #16. These records may be used by theDepartment for enforcement purposes. A 12-month rolling total and each individualmonth's data shall be updated on a monthly basis, shall be kept on site, and shall beprovided to the Department in accordance with General Condition #7. [Regulation 19,§19.705 of Regulation #19 and 40 CPR Part 52 Subpart E]

18. The pennittee shail not use in excess of2,OOO gallons ofnaphtha in SN-07 during anyconsecutive twelve-month period. [Regulation 19, §19.501 et seq of Regulation #19 and40 CPR Part 52 Subpart E]

19. The pennittee shall maintain records which demonstrate compliance with the throughputlimit set in Specific Condition #18. These records may be used by the Department forenforcement purposes. A 12-month rolling total and each individual month's data shallbe updated on a monthly basis, shall be kept on site, and shall be provided to theDepartment in accordance with General Condition #7. [Regulation 19, §19.705 and 40CPR Part 52 Subpart E]

20. The pennittee shall not use in excess of 1,500 gallons of acetone in SN-07 during anyconsecutive twelve-month period. [Regulation 19, §19.501 et seq. and 40 CPR Part 52Subpart E]

21. The pennittee shall maintain records which demonstrate compliance with the throughputlimit set in Specific Condition #20. These records may be used by the Department forenforcement purposes. A 12-month rolling total and each individual month's data shall beupdated on a monthly basis, shall be kept on site, and shall be provided to the Departmentin accordance with General Condition #7. [Regulation 19, §19.705 and 40 CPR Part 52Subpart E]

21


22. The pennittee shall not use in excess of 1,725 gallons of Cleaning Solvent #1 whichcontains no more than 11.01 lb/gal methylene chloride in SN-07 during any consecutivetwelve-month period. [Regulation 19, §19.501 et seq. of Regulation #19 and 40 CFRPart 52 Subpart E]

23. The pennittee shall maintain records which demonstrate compliance with the throughputand 1b/gallimits set in Specific Condition #22. These records may be used by theDepartment for enforcement purposes. A 12-month rolling total and each individualmonth's data shall be updated on a monthly basis, shall be kept on site, and shall beprovided to the Department in accordance with General Condition #7. [Regulation 19,§19.705 of Regulation #19 and 40 CFR Part 52 Subpart E]

22


SN-08RCasting Resin Storage Tank #1

Source Description

The Resin Storage Tank #IR (V-50l) is a vertical, fixed roof insulated vessel with a totalcapacity of 14,300 gallons.

Specific Conditions

24. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Specific Condition #26 andequipment limitations. [Regulation 19, §19.501 et seq. of Regulation #19 and 40 CFRPart 52, Subpart E]

!__P_:_I~_~_t_-+-__I_:nrr_.o :_~~__--,1

25. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Specific Condition #26 andequipment limitations. [Regulation 18, §18.801 and A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311]

Pollutant lb/hr tpy

Styrene 1.0 0.05**** Plantwlde Lund of 9.5 tpy of smgle HAp, 23.75 total. See Plantwide Condition #12.

26. The permittee shall not have a throughput in excess of 1,472,000 pounds ofcasting resinsnor exceed a Styrene wt.% of50% in SN-08R, SN-08A, SN-09, and SN-09A combinedduring any consecutive twelve-month period. [Regulation 19, §19.501 et seq. and 40CFR Part 52 Subpart E]

23


27. The permittee shall maintain records which demonstrate compliance with the throughputlimit set in Specific Condition #26. These records may be used by the Department forenforcement purposes. A 12-month rolling total and each individual month's data shallbe updated on a monthly basis, shall be kept on site, and shall be provided to theDepartment in accordance with General Condition #7. [Regulation 19, §19.705 and 40CFR Part 52 Subpart E)

24


SN-08ACasting Resin Day Tank

Source Description

The Resin Day Use Tank (V-502R) is a carbon steel vessel installed in 2003. This is a 4-footdiameter by 6.5-foot high, 595-gallon cylindrical atmospheric vessel equipped with Semielliptical heads and angle support legs. It is painted white and is used to mix Derakane*XP71717 Resin. A three inch atmospheric vent pipe exits the top ofthe tank.

Styrene-based resins comprise approximately 20% of the castings in polymer concrete. Theresins, which are delivered to Dow Chemical's Russellville site in 40,000 lb tanker trucks, areunloaded into two storage tanks (SN-08 and SN-09). The material is then pumped from thesestorage tanks to the day use storage tank of tote bins and 55 gallon drums (SN-08A and SN-09A)for use in the Unit #5 (polymer concrete casting) area.

Specific Conditions

28. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Specific Condition #26 andequipment limitations. [Regulation 19, §19.501 et seq. and 40 CPR Part 52, Subpart E]

Pollutant lb/hr tpy

VOC 0.1 0.1


Pollutant lb/hr tpy

Styrene 0.03 0.01 **

** Plantwlde Lnmt of9.5 tpy ofsmgle HAp, 23.75 total. See Plantwide Condition #12.

25


SN-09Casting Resin Storage Tank #2

Source Description

The Casting Resin Storage Tank #2 (V-503) is a 9.5-foot in diameter by 12-foot high fixed roof,insulated vessel. It is painted white and chilled in the summer months to maintain the storagetemperature between 70°F and 80°F. A 3 inch by 2 inch pressure vent pipe exists in the top ofthe tank.

Specific Conditions

30. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Specific Condition #26 andequipment limitations. [Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E]

IF=P=~=1~=~=t==l==1=~~=3==l===:=.~====I1


Pollutant lb/hr tpy

Styrene 1.22 0.03**

** Plantwide Limit of9.5 tpy of single HAp, 23.75 total. See Plantwide Condition #12.

26


SN-09ACasting Resin Storage Containers

Source Description

The Casting Resin tote bins are 3.6 feet wide, 4.1 feet long, and 3.4 feet high. Each has a 350gallon capacity. Resins are also purchased in 55-gallon drums.

Specific Conditions


Pollutant

VOC Ilblhr

0.1 Itpy

0.1


Pollutant lb/hr tpy

Styrene 0.02 0.01 ** .** Plantwide Limit of 9.5 tpy ofsmgle HAp, 23.75 total. See Plantwide Condition #12.

27


SN-IOMethylene Chloride Recovery Still

Source Description

Waste methylene chloride from the Unit #5 bulk mixing area is collected and transferred to arecovery still. The material is distilled to separate solids from the used solvent. The still isvented to the atmosphere. The recycled material is placed in barrels and reused within thefacility.

Specific Conditions


Pollutant lblhr tpy

Methylene 0.43 0.03**Chloride*

*Nota VOC.** Plantwide Limit of 9.5 tpy of single HAP, 23.75 total. See Plantwide Condition #12.

35. The permittee shall not have a still throughput in excess of 19,000 pounds ofMethyleneChloride in SN-lO during any consecutive twelve-month period. [Regulation 18, §18.801and AC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

36. The permittee shall maintain records which demonstrate compliance with the throughputlimit set in Specific Condition #35. These records may be used by the Department forenforcement purposes. A 12-month rolling total and each individual month's data shallbe updated on a monthly basis, shall be kept on site, and shall be provided to theDepartment in accordance with General Condition #7. [Regulation 18, §18.1004 andAC.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

28

The Dow Chemical CompanyPermit #: 801-AOP-R6AFIN: 58-000 II

SN-llGrit Blasting Operation #2

Source Description

A reworked aluminum oxide grit blaster located in the new M-83 Anode Blast Building is usedto remove corrosion and old insulation from used diaphragm anode electrodes. Particulategenerated from these activities are collected by a Torit baghouse.

For health and safety purposes, the blasting debris is assumed to contain asbestos and is managedaccordingly. Grit Blasting Operation # 2 is NOT subject to 40 CFR Part 61 Subpart M. This isbecause the grit blasting operation does not satisfy the regulatory definitions ofmanufacturing,fabricating, demolition, renovation, or spraying activities.

Specific Conditions


Pollutant

PM10

lb/hr

0.1

tpy

0.1

38. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-31I ]

Pollutant

PM

lb/hr

0.1

tpy

0.1

39. The permittee shall not exceed 5% opacity from SN-II as measured by EPA ReferenceMethod 9. Compliance with this condition will be demonstrated by Plantwide Condition#7. [Regulation 18, §18.501 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4311]

29


SN-12Anode Dip Tank

Source Descriptio~

Blasted anodes from the M-83 Anode Blast Building are transferred to Unit #6 where coatingsare applied. The anodes are dipped several times in a tank filled with an isopropyl alcoholsolution containing metal salts and anhydrous hydrochloric acid.

Specific Conditions

40. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Plantwide Condition #9.[Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E]

Pollutant

VOC Ilblhr

26.7 Itpy

150.9**Combined emissions from six sources: SN-12, SN-20, SN-21, SN-22, SN-23, and SN-26.

41. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Plantwide Condition #10.[Regulation 18, §18.801 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

Pollutant Ib/hr tpy

Hydrochloric 0.09 0.94**Acid*

* Nota VOC.** Plantwide Limit of 9.5 tpy of single HAp, 23.75 total. See Plantwide Condition #12.

30

The Dow Chemical CompanyPermit #: 801-AOP-R6AFIN: 58-000 II

SN-13Anode Bake Oven

Source Description

A natural gas fired oven is used for baking anodes and heat treating metal parts. The bakingoven is rated at 2.6 MM Btu/hr. This equipment has been permitted for maximum burnercapacity.

Specific Conditions

42. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Specific Condition #45.[Regulation 19, §I9.501 et seq. and 40 CFR Part 52, Subpart E]

Pollutant lb/hr tpy

PMlO 0.1 0.1

S02 0.1 0.1

VOC 0.1 0.1

CO 0.3 1.0

NOx 0.3 1.2

43. The permittee shall not exceed the emission rates set forth in the following table.[Regulation 18, §I8.801 ofRegulation #18 and A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-31l]

Pollutant

PM

lb/hr

0.1

tpy

0.1

44. The permittee shall not exceed 5% opacity from SN-13 as measured by EPA ReferenceMethod 9. Compliance with this condition will be demonstrated by Specific Condition#48 and equipment limitations. [Regulation 18, §18.50I and A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311]

45. The permittee shall only use pipeline-quality natural gas as fuel in SN-13. [A.C.A. §8-4203 as referenced by §8-4-304 and §8-4-311 and 40 CFR 70.6]

31



Source Description

An aluminum oxide grit blaster is used for blasting metal sheets. Particulate generated fromthese blasting activities is collected by a DCE Vokes baghouse, which is equipped with a 5,100cubic feet per minute fan, Dacron/poly bags, and an air shaker.

Specific Conditions


Pollutant lb/hr tpy

PM10 0.5 2.2


Pollutant

PM

lb/hr

0.5

tpy

2.2

48. The permittee shall not exceed 5% opacity from sources SN-14 as measured by EPAReference Method 9. Compliance with this condition will be demonstrated by PlantwideCondition #7. [Regulation 18, §18.501 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311]

32


SN-15Fiberglass Transfer System

Source Description

A vacuum is used to transfer chopped fiberglass from a bulk container into the Unit #5 polymerconcrete mixer. This system is equipped with a separator cartridge filter rated at 97% particulateremoval efficiency.

Specific Conditions

49. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 19, §19.50l et seq. and 40 CFR Part 52, Subpart E]

Pollutant

PM lO

lb/hr

0.7

tpy

0.1

50. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 18, §18.80l and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

Pollutant

PM

lb/hr

0.7

tpy

0.1


33


SN-16Metal Flame Spray Coating Operation

Source Description

The anode backboard is coated with a thin layer of an electrically-conductive metal through aflame spray process. This coating process, where metal wire is melted and sprayed onto thebackboard, lasts for several hours. Particulate (dust) from the coating activities is captured by aType N Roto-Clone hydrostatic precipitator. This control system cleans the air by combinedaction of centrifugal force and through intermixing of water and dust-laden air.

Specific Conditions


Pollutant lb/hr tpy

PMlO 0.1 0.3

53. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 18, §18.801 and AC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

Pollutant

PM

lb/hr

0.1

tpy

0.3

54. The permittee shall not exceed 5% opacity from SN-16 as measured by EPA ReferenceMethod 9. Compliance with this condition will be demonstrated by Plantwide Condition#7. [Regulation 18, §18.501 and A.C.A §8-4-203 as referenced by §8-4-304 and §8-4311]

34



Source Description

This system is located on the West side of the Unit #5 Building. A vacuum system collectsparticulate from the grinding of frames and covers in the Unit #5 Cell Finishing Area. Thecaptured dust passes through a Hoffman baghouse, which is rated at 97% efficient in capturingparticulate matter.

Specific Conditions


Pollutant

PM IO

lb/hr

0.1

tpy

0.1

56. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 18, §I 8.801 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

Pollutant

PM

lb/hr

0.1

tpy

0.1


35



Source Description

An aluminum oxide grit blaster is used to blast metal screens, which are used in the productionof membrane cells. Particulate is collected by a DCE Vokes baghouse equipped with a 40horsepower fan and air shaker.

Specific Conditions

58. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E)

Pollutant lb/hr tpy

PM10 0.1 0.1

59. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by equipment limitations.[Regulation 18, §18.801 and AC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

Pollutant

PM

lb/hr

0.1

tpy

0.1

60. The permittee shall not exceed 5% opacity from SN-19 as measured by EPA ReferenceMethod 9. Compliance with this condition will be demonstrated by Plantwide Condition#7. [Regulation 18, §18.501 and A.C.A §8-4-203 as referenced by §8-4-304 and §8-4311]

36


SN-20 and SN-21Membrane Cell Component Dip Tank and Electric Oven

Source Description

This dip tank is used to apply solvent alcohol containing metal salts and hydrochloric acid to themembrane cells. Emissions include hanging and drying of the cell components. An electric ovenis used to bake coated membrane cell components. It takes several hours to convert the coatingon each batch from the Membrane Cell Dip Tank to the oxide form. Only one batch will fit intothis oven each baking cycle.

Specific Conditions

61. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Plantwide Condition #9 andequipment limitations. [Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E]

Pollutant Iblhr tpy

VOC 4.4 150.9**Combined emISSIOns from SIX sources: SN-12, SN-20, SN-21, SN-22, SN-23 and SN-26.

62. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Plantwide Condition #10 andequipment limitations. [Regulation 18, §18.801 and A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311]

Pollutant Iblhr tpy


* Nota VOC.** Plantwide Limit of9.5 tpy of single HAp, 23.75 total. See Plantwide Condition #12.

37


SN-22 and SN-23Mix Tank Exhaust and Mix Room Exhaust

Source Description

A mixture of hydrochloric acid and isopropanol is pumped into two mixing vessels in theChemical Mix Room. The mixing vessels are ducted to a blower that removes alcohol fumes.The fumes are generated during the batch mixing of raw materials with inorganic salts to preparecoating mixtures for the Unit #6 process. A demister is installed on the suction side of theexhaust blower to eliminate entrained liquid droplets which form in the vent stream under certainconditions.

A Mix Room exhaust blower is present to protect personnel from over-exposure to hydrocWoricacid and isopropyl alcohol fumes during Unit #6 research testing operations on new coatingformulations. Production type activities are rarely conducted under this exhaust system exceptoccasionally when a need exists to coat a limited number of very small parts which cannot becoated in the large system.

Specific Conditions


Pollutant

VOC Ilblhr

3.3 Itpy

150.9**Combined emissions from six sources: SN-12, SN-20, SN-21, SN-22, SN-23, and SN-26.


Pollutant lblhr tpy


* Nota VOC.** Plantwide Limit of 9.5 tpy of single HAp, 23.75 total. See P1antwide Condition #12.

38



Source Description

Dusts from the grinding activities are captured by a baghouse using Mega-Flo cartridge filters.This dust collector minimizes dust exposure to personnel.

Specific Conditions


Pollutant lblhr tpy

PMIO 0.1 0.1


Pollutant

PM

lblhr

0.1

tpy

0.1

67. The permittee shall not exceed 5% opacity from SN-25 as measured by EPA ReferenceMethod 9. Compliance with this condition will be demonstrated by Plantwide Condition#7. [Regulation 18, §18.501 and A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4311]

39


SN-26Isopropanol Storage Tank

Source Description

The isopropanol storage tank is a 9.0-foot (inside diameter) by 17-foot vertical vessel. Thecarbon steel tank is equipped with a conservation vent (pressure relief and vacuum breakervalve). During unloading activities, the vessel is vented back into the tanker truck.

Specific Conditions


Pollutant lb/hr tpy

VOC 6.3 150.9**Combined emissions from six sources: SN-12, SN-20, SN-21, SN-22, SN-23, and SN-26.

40


SN-27Cathode Oil Coating Operation

Source Description

Finished cathode assemblies are sprayed with a rust preventive in a paint arrester spray booth.Overspray from these activities is trapped by disposable fiberglass batting filters. The spraybooth is 18.25 feet wide, 8.5 feet high and 9.125 feet deep.

Specific Conditions

69. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Specific Condition #72 andequipment limitations. [§19.501 et seq. and 40 CFR Part 52, Subpart E]

Pollutant lb/hr tpy

PM lO 0.1 0.1

VOC 11.0 3.3


Pollutant

PM

lb/hr

0.1

tpy

0.1


72. The permittee shall not use in excess of 1,200 gallons of rust preventive coating whichcontains no more than 5.50 lb/gal VOC in SN-27 during any consecutive twelve-monthperiod. [Regulation 19, §19.501 et seq. and 40 CFR Part 52 Subpart E]

41


73. The pennittee shall maintain records which demonstrate compliance with the throughputand lb/gallimits set in Specific Condition #72. These records may be used by theDepartment for enforcement purposes. A 12-month rolling total and each individualmonth's data shall be updated on a monthly basis, shall be kept on site, and shall beprovided to the Department in accordance with General Condition #7. [Regulation 19,§19.705 and 40 CFR Part 52 Subpart E]

42


SN-28 and SN-35Coating Solvent Mix Storage Tanks and Day Tank

Source Description

A hydrochloric acid and isopropanol mixture will be prepared in vessels which are controlledwith a nitrogen pad. The excess pressure will be vented to the atmosphere once the vessels arefilled with the mixture. There are a mixing tank, a mix storage tank, an emergency dump tank, amembrane day tank, and a membrane storage tank. Each tank is equipped nitrogen blanket andhas its own vent.

The day tank stores the hydrochloric acid, isopropanol, and inorganic salt mixture from the M-83and Membrane Anode Mix Tanks. The tank is nitrogen padded and will vent directly to theatmosphere during filling operations. This tank is filled approximately several times each day.

Specific Conditions


Pollutant lb/hr tpy

VOC 2.7 0.1


Pollutant lb/hr tpy

Hydrochloric 0.06 0.01 **Acid*

*Nota VOC.** Plantwide Limit of9.5 tpy of single HAp, 23.75 total. See Plantwide Condition #12.

43


SN-30Plating Solution Evaporator

Source Description

The plating solutions from the coating processes become spent after repeated use. The wastes aresubsequently processed through an electric evaporator unit (SN-30) to recover the platingcomponents and reduce the volume of waste. The spent materials are shipped off-site for furtherrecovery or disposal. The evaporator is not equipped with an air pollution control device.

Specific Conditions


Pollutant lb/hr tpy

VOC 0.5 0.7


Pollutant

Ammonia*

* Nota VOC.

lb/hr

0.5

tpy

0.7

78. The permittee shall not process in excess of 32,000 gallons of waste plating solution inSN-30 during any consecutive twelve-month period. [Regulation 19, §19.501 et seq. and40 CFR Part 52 Subpart E]

79. The permittee shall maintain records which demonstrate compliance with the throughputlimit set in Specific Condition #78. These records may be used by the Department forenforcement purposes. A 12-month rolling total and each individual month's data shallbe updated on a monthly basis, shall be kept on site, and shall be provided to theDepartment in accordance with General Condition #7. [Regulation 19, §19.705 and 40CFR Part 52 Subpart E]

44

The Dow Chemical CompanyPermit #: 80I-AOP-R6AFIN: 58-00011


Source Description

An aluminum oxide grit blaster is used for blasting iron cell castings as well as collectingfugitive Halar powder dust. Dust emissions are collected by a Zero Manufacturing baghouse. Adifferential pressure gauge is present to assist in monitoring the efficiency of the dust collector.

Specific Conditions


Pollutant

PM10

lb/hr

0.1

tpy

0.1


Pollutant

PM

lb/hr

0.1

tpy

0.1


45


SN-36DAC V Coating Operation

Source Description

The cathode electrode for a membrane cell is subjected to a second coating operation ("DAC V")to apply another layer ofprecious metals to the electrode unit. The process is performed inProduction Unit #8. The component is coated in several small dip tanks (SN-36). The platedcathode is then routed to the Membrane Cell Unit for [mal assembly.

Specific Conditions


Pollutant

VOC

lb/hr

0.3

tpy

0.3 l84. The permittee shall not exceed the emission rates set forth in the following table.

Compliance with this condition will be demonstrated by Specific Condition #85 andequipment limitations. [Regulation 18, §18.801 and A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311]

Pollutant

Ammonia** Nota VOC.

lb/hr

3.2

tpy

2.9

85. The permittee shall not process more than 3,600 units through SN-36 and SN-37combined during any consecutive twelve-month period. [Regulation 18, §18.801 andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

86. The permittee shall maintain records which demonstrate compliance with the throughputlimit set in Specific Condition #85. These records may be used by the Department forenforcement purposes. A 12-month rolling total and each individual month's data shallbe updated on a monthly basis, shall be kept on site, and shall be provided to theDepartment in accordance with General Condition #7. [Regulation 18, §18.1004 andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

46


SN-37DAC III Coating Operation

Source Description

A dip coating process ("DAC III") is used to apply a layer ofprecious metals to the cathodeelectrodes for membrane cells. It is performed in Production Unit #8. The coating mixture isprepared in two mix tanks (SN 22) and then stored in several holding tanks (SN-28). Themembrane cell cathode is surface coated in a small dip tank (SN-37) equipped with a vent hood.The part is then transferred to an electric "hot box" (also SN-37) for drying and then conveyed toan electric oven (SN-21).

Specific Conditions


Pollutant lb/hr tpy


*Nota VOC.** Plantwide Limit of9.5 tpy of single HAp, 23.75 total. See Plantwide Condition #12.

47


SN-38Fueling Station

Source Description

The fueling station consists of two small horizontal storage vessels: a 500-gallon gasoline tankand a 900-gallon diesel fuel tank. The contents of these vessels are used to fuel facilityequipment and vehicles.

Specific Conditions

88. The permittee shall not exceed the emission rates set forth in the following table.Compliance with this condition will be demonstrated by Specific Conditions #89 and#90, and equipment limitations. [Regulation 19, §19.501 et seq. and 40 CFR Part 52,Subpart E]

Pollutant

VOC Ilb/hr

5.6 Itpy

0.2

89. The permittee shall not use in excess of 6,300 gallons of gasoline in SN-38 during anyconsecutive twelve-month period. [Regulation #19, §19.501 et seq. and 40 CFR Part 52Subpart E]

90. The permittee shall not use in excess of 11,000 gallons of diesel fuel in SN-38 during anyconsecutive twelve-month period. [Regulation 19, §19.501 et seq. and 40 CFR Part 52Subpart E]

91. The permittee shall maintain records which demonstrate compliance with the throughputlimits set in Specific Conditions #89 and #90. These records may be used by theDepartment for enforcement purposes. A 12-month rolling total and each individualmonth's data shall be updated on a monthly basis, shall be kept on site, and shall beprovided to the Department in accordance with General Condition #7. [Regulation 19,§19.705 of Regulation #19 and 40 CFR Part 52 Subpart E]

48


SECTION V: COMPLIANCE PLAN AND SCHEDULE

The Dow Chemical Company 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.

49


SECTION VI: PLANTWIDE CONDITIONS

1. The permittee shall notify the Director in writing within thirty (30) days aftercommencing construction, completing construction, first placing the equipment and/orfacility in operation, and reaching the equipment and/or facility target production rate.[Regulation 19, §19.704, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as referencedby A.C.A. §8-4-304 and §8-4-311]

2. Ifthe permittee fails to start construction within eighteen months or suspendsconstruction for eighteen months or more, the Director may cancel all or part of thispermit. [Regulation 19, §19.410(B) and 40 CFR Part 52, Subpart E]

3. The permittee must test any equipment scheduled for testing, unless stated in the SpecificConditions of this permit or by any federally regulated requirements, within the followingtime frames: (1) new equipment or newly modified equipment within sixty (60) days ofachieving the maximum production rate, but no later than 180 days after initial start up ofthe permitted source or (2) operating equipment according to the time frames set forth bythe Department or within 180 days of permit issuance if no date is specified. Thepermittee must notify the Department of the scheduled date of compliance testing at leastfifteen (15) days in advance of such test. The permittee shall submit the compliance testresults to the Department within thirty (30) days after completing the testing. [Regulation19, §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]

4. The permittee must provide: [Regulation 19, §19.702 and/or Regulation 18, §18.1002and 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; andd. Utilities for sampling and testing equipment.

5. The permittee must operate the equipment, control apparatus and emission monitoringequipment within the design limitations. The permittee shall maintain the equipment ingood condition at all times. [Regulation 19, §19.303 and A.C.A. §8-4-203 as referencedby A.C.A. §8-4-304 and §8-4-311]

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

50

The Dow Chemical CompanyPennit #: 80l-AOP-R6AFIN: 58-00011

7. The permittee will conduct weekly observations of the opacity from the followingsources: SN-02A, SN-03A, SN-04, SN-06, SN-ll, SN-14, SN-15, SN-16, SN 17, SN-19,SN-25, SN-27, and SN-32. A record of these observations shall be kept. If the pennitteedetects visible emissions that exceed the limit, then the pennittee must immediately takeaction to identify and correct the cause of the visible emissions. After implementing thecorrective action, the pennittee must document that the source complies with the visibleemissions requirements. The pennittee shall maintain records of the cause of any visibleemission exceedence and the corrective action taken. The pennittee must keep therecords on-site and make the records available to Department personnel upon request.[Regulation No. §18.l004 ofRegulation 18 and A.C.A. §8-4-203 as referenced by §8-4304 and §8-4-311]"

8. The pennittee shall ensure that all calculations perfonned under the requirements of thispennit are of sufficient accuracy to ensure that no applicable regulatory emissionthresholds are exceeded. [Regulation 19, §19.405(B), and A.C.A. §8-4-203 as referencedby §8-4-304 and §8-4-311]

9. The pennittee shall not use in excess of 46,000 gallons of solvent/coating solution whichcontain no more than 7.0 Ib/gal ofVOC at the facility during any consecutive twelvemonth period. [Regulation 18, §18.801 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311]

10. The pennittee shall not use solvent/coating solution which contain no more than 0.71lb/gal ofhydrochloric acid at SN-12, SN-20, SN-21, SN-22 and SN-23 during anyconsecutive twelve-month period. [Regulation 18, §18.801 and A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-3l1]

11. The pennittee shall maintain records which demonstrate compliance with the throughputand lb/gallimit set in Plantwide Conditions #9 and #10. These records may be used bythe Department for enforcement purposes. A 12-month rolling total and each individualmonth's data shall be updated on a monthly basis, shall be kept on site, and shall beprovided to the Department in accordance with General Condition #7. [Regulation 18,§18.1004 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-3l1]

51


12. The permittee shall not exceed the Plantwide HAP emission rates set forth in thefollowing table in a twelve-month rolling period. Compliance with these limitations isassured in accordance with Plantwide Condition #13. [Regulation No. 18 §18.801, andAC.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

Single HAP (tpy) Combined HAPs (tpy)

Facility 9.5 23.75

13. The permittee shall maintain records which can be used to demonstrate compliance withPlantwide Condition #12. These records shall be updated on a monthly basis. Theserecords shall be kept on site, provided to Department personnel upon request and may beused by the Department for enforcement purposes. A 12-month rolling total and eachindividual month's data shall be submitted in accordance with General Provision #7.[Regulation No. 18 §18.801, effective January 25,2009, and AC.A §8-4-203 asreferenced by §8-4-304 and §8-4-311]

14. The permittee shall not exceed a VOC limit of 150.9 tons per year at SN-12, SN-20, SN21, SN-22, SN-23 and SN-26 combined per consecutive twelve month period.[Regulation 19, §19.501 and 40 CFR Part 52, Subpart E]

15. The permittee shall maintain records which demonstrate compliance with SpecificCondition #14. These records may be used by the Department for enforcement purposes.A 12-month rolling total and each individual month's data shall be updated on a monthlybasis, shall be kept on site, and shall be provided to the Department in accordance withGeneral Provision #7. [Regulation 19, §19.705, A.C.A. §8-4-203 as referenced by §8-4304 and §8-4-311]

16. The permittee shall not exceed a HCL limit of 0.94 tons per year at SN-12, SN-20, SN21, SN-22 and SN-23 combined per consecutive twelve month period. [Regulation 18,§18.801 and A.C.A §8-4-203 as referenced by §8-4-304 and §8-4-311]

17. The permittee shall maintain records which demonstrate compliance with SpecificCondition #16. These records may be used by the Department for enforcement purposes.A 12-month rolling total and each individual month's data shall be updated on a monthlybasis, shall be kept on site, and shall be provided to the Department in accordance withGeneral Provision #7. [Regulation 18, §18.1004 and A.C.A §8-4-203 as referenced by§8-4-304 and §8-4-311]

52


Title VI Provisions

18. The permittee must comply with the standards for labeling of products using ozonedepleting substances. [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.

b. The placement of the required warning st atement must comply with therequirements pursuant to §82.1 08.

c. The form of the label bearing the required warning must comply with therequirements pursuant to §82.11 O.

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

19. The permittee must comply with the standards for recycling and emissions reduction,except as provided for MVACs in Subpart B. [40 CFR Part 82, Subpart F]

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.l58.

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.

20. If the permittee manufactures, transforms, destroys, imports, or exports a class lor class IIsubstance, the permittee is subject to all requirements as specified in 40 CFR Part 82,Subpart A, Production and Consumption Controls.

21. Ifthe permittee performs a service on motor (fleet) vehicles when this service involves

53


ozone-depleting substance refrigerant (or regulated substitute substance) in the motorvehicle air conditioner (MVAC), the pennittee is subject to all the applicablerequirements as specified in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle AirConditioners.

The tenn "motor vehicle" as used in Subpart B does not include a vehicle in which finalassembly of the vehicle has not been completed. The tenn "MYAC" as used in Subpart Bdoes not include the air-tight sealed refrigeration system used as refrigerated cargo, or thesystem used on passenger buses using HCFC-22 refrigerant.

22. The pennittee 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.

Permit Shield

23. Compliance with the conditions of this pennit shall be deemed compliance with allapplicable requirements, as of the date of pennit issuance, included in and specificallyidentified in the following table of this condition. The pennit specifically identifies thefollowing as applicable requirements based upon the infonnation submitted by thepermittee in an application dated August 27, 2007.

Source No. Regulation Description

Facility Arkansas Regulation #19 Regulations of the Arkansas Plan ofImplementation for Air Pollution Control

Facility Arkansas Regulation #26 Regulations of the Arkansas Operating AirPermit Program

54


The permit specifically identifies the following as inapplicable based upon information submittedby the permittee in an application dated August 27,2007.

Source No. Regulation Description

SN-26, SN-28 40 CFR 60, Subpart Kb Standards of Performance for Volatileand SN-38 Organic Liquid Storage Vessels (including

Petroleum Liquid Storage Vessels) forWhich Construction, Reconstruction, orModification Commenced After July 23,

1984

SN-ll 40 CFR 61, Subpart M National Emission Standard for Asbestos

SN-07 40 CFR 63, Subpart T National Emission Standard forHalogenated Solvent Cleaning

Facility 40 CFR 63, Subpart T National Emission Standards forHalogenated Solvent Cleaning

Facility 40 CFR 63, Subpart MMMM National Emission Standards forHazardous Air Pollutants for Surface

Coating ofMiscellaneous Metal Parts andProducts

Facility 40 CFR 63, Subpart WWWW National Emission Standards forHazardous Air Pollutants for Reinforced

Plastic Composites Production

SN-13 40 CFR 63, Subpart DDDDD National Emission Standards forHazardous Air Pollutants for Industrial,

Commercial, and Institutional Boilers andProcess Heaters

Facility 40 CFR 52.21 Prevention of Significant Deterioration

Facility 40 CFR64 Compliance Assurance Monitoring

Facility 40 CFR68 Chemical Accident Prevention Provisions

55


SECTION VII: INSIGNIFICANT ACTIVITIES

The following sources are insignificant activities. Any activity that has a state or federalapplicable requirement shall be considered a significant activity even if this activity meets thecriteria of §26.304 of Regulation 26 or listed in the table below. Insignificant activitydeterminations rely upon the information submitted by the permittee in an application datedAugust 27,2007.

Description

None

56

Category


SECTION VIII: GENERAL PROVISIONS

1. Any terms or conditions included in this permit which specify and reference ArkansasPollution Control & Ecology Commission Regulation 18 or the Arkansas Water and AirPollution Control Act (A.C.A. §8-4-101 et seq.) as the sole origin of and authority for theterms or conditions are not required under the Clean Air Act or any of its applicablerequirements, and are not federally enforceable under the Clean Air Act. ArkansasPollution Control & Ecology Commission Regulation 18 was adopted pursuant to theArkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.). Any terms orconditions included in this permit which specify and reference Arkansas PollutionControl & Ecology Commission Regulation 18 or the Arkansas Water and Air PollutionControl Act (A.C.A. §8-4-101 et seq.) as the origin of and authority for the terms orconditions are enforceable under this Arkansas statute. [40 CFR 70.6(b)(2)]

2. This permit shall be valid for a period of five (5) years beginning on the date this permitbecomes effective and ending five (5) years later. [40 CFR 70.6(a)(2) and §26.701(B) ofthe Regulations of the Arkansas Operating Air Permit Program (Regulation 26)]

3. The permittee must submit a complete application for permit renewal at least six (6)months before permit expiration. Permit expiration terminates the permittee's right tooperate unless the permittee submitted a complete renewal application at least six (6)months before permit expiration. If the permittee submits a complete application, theexisting permit will remain in effect until the Department takes final action on therenewal application. The Department will not necessarily notify the permittee when thepermit renewal application is due. [Regulation 26, §26.406]

4. Where an applicable requirement of the Clean Air Act, as amended, 42 U.S.C. 7401, etseq. (Act) is more stringent than an applicable requirement of regulations promulgatedunder Title IV of the Act, the permit incorporates both provisions into the permit, and theDirector or the Administrator can enforce both provisions. [40 CFR 70.6(a)(I)(ii) andRegulation 26, §26.701(A)(2)]

5. The permittee must maintain the following records ofmonitoring information as requiredby this permit.

a. The date, place as defined in this permit, and time of sampling or measurements;b. The date(s) analyses performed;c. The company or entity performing the analyses;d. The analytical techniques or methods used;e. The results of such analyses; and

57


f. The operating conditions existing at the time of sampling or measurement.

[40 CFR 70.6(a)(3)(ii)(A) and Regulation 26, §26.701(C)(2)]

6. The permittee must retain the records of all required monitoring data and supportinformation for at least five (5) years from the date of the monitoring sample,measurement, report, or application. Support information includes all calibration andmaintenance records and all original strip chart recordings for continuous monitoringinstrumentation, and copies of all reports required by this permit. [40 CFR70.6(a)(3)(ii)(B) and Regulation 26, §26.701(C)(2)(b)]

7. The permittee must submit reports of all required monitoring every six (6) months. Ifpermit establishes no other reporting period, the reporting period shall end on the last dayof the anniversary month of the initial Title V permit. The report is due within thirty (30)days of the end of the reporting period. Although the reports are due every six months,each report shall contain a full year of data. The report must clearly identify all instancesof deviations from permit requirements. A responsible official as defined in RegulationNo. 26, §26.2 must certify all required reports. The permittee will send the reports to theaddress below:

Arkansas Department of Environmental QualityAir DivisionATTN: Compliance Inspector Supervisor5301 Northshore DriveNorth Little Rock, AR 72118-5317

[40 C.F.R. 70.6(a)(3)(iii)(A) and Regulation 26, §26.701(C)(3)(a)]

8. The permittee shall report to the Department all deviations from permit requirements,including those attributable to upset conditions as defined in the permit.

a. For all upset conditions (as defined in Regulation19, § 19.601), the permittee willmake an initial report to the Department by the next business day after thediscovery of the occurrence. The initial report may be made by telephone andshall include:

1. The facility name and location;11. The process unit or emission source deviating from the permit limit;

111. The permit limit, including the identification of pollutants, from whichdeviation occurs;

58


IV. The date and time the deviation started;v. The duration of the deviation;

VI. The average emissions during the deviation;Vll. The probable cause of such deviations;

V111. Any corrective actions or preventive measures taken or being taken toprevent such deviations in the future; and

IX. The name of the person submitting the report.

The permittee shall make a full report in writing to the Department within five (5)business days of discovery of the occurrence. The report must include, in addition tothe information required by the initial report, a schedule of actions taken or planned toeliminate future occurrences and/or to minimize the amount the permit's limits wereexceeded and to reduce the length of time the limits were exceeded. The permitteemay submit a full report in writing (by facsimile, overnight courier, or other means)by the next business day after discovery of the occurrence, and the report will serve asboth the initial report and full report.

b. For all deviations, the permittee shall report such events in semi-anl"1ual reportingand annual certifications required in this permit. This includes all upsetconditions reported in 8a above. The semi-annual report must include all theinformation as required by the initial and full reports required in 8a.

[Regulation 19, §19.601 and §19.602, Regulation 26, §26.701(C)(3)(b), and 40 CFR70.6(a)(3)(iii)(B)]

9. If any provision of the permit or the application thereof to any person or circumstance isheld invalid, such invalidity will not affect other provisions or applications hereof whichcan be given effect without the invalid provision or application, and to this end,provisions of this Regulation are declared to be separable and severable. [40 CFR70.6(a)(5), Regulation 26, §26.701(E), and A.C.A. §8-4-203 as referenced by A.C.A. §84-304 and §8-4-311]

10. The permittee must comply with all conditions of this Part 70 permit. Any permitnoncompliance with applicable requirements as defined in Regulation 26 constitutes aviolation of the Clean Air Act, as amended, 42 U.S.C. §7401, et seq. and is grounds forenforcement action; for permit termination, revocation and reissuance, for permitmodification; or for denial of a permit renewal application. [40 CFR 70.6(a)(6)(i) andRegulation 26, §26.701(F)(l)]

59


11. It shall not be a defense for a permittee in an enforcement action that it would have beennecessary to halt or reduce the permitted activity to maintain compliance with theconditions of this permit. [40 CFR 70.6(a)(6)(ii) and Regulation 26, §26.701(F)(2)]

12. The Department may modify, revoke, reopen and reissue the permit or terminate thepermit for cause. The filing of a request by the permittee for a permit modification,revocation and reissuance, termination, or of a notification of planned changes oranticipated noncompliance does not stay any permit condition. [40 CFR 70.6(a)(6)(iii)and Regulation 26, §26.701(F)(3)]

13. This permit does not convey any property rights of any sort, or any exclusive privilege.[40 CFR 70.6(a)(6)(iv) and Regulation 26, §26.701(F)(4)]

14. The permittee must furnish to the Director, within the time specified by the Director, anyinformation that the Director may request in writing to determine whether cause exists formodifying, revoking and reissuing, or terminating the permit or to determine compliancewith the permit. Upon request, the permittee must also furnish to the Director copies ofrecords required by the permit. For information the permittee claims confidentiality, theDepartment may require the permittee to furnish such records directly to the Directoralong with a claim of confidentiality. [40 CFR 70.6(a)(6)(v) and Regulation 26,§26.701(F)(5)]

15. The permittee must pay all permit fees in accordance with the procedures established inRegulation 9. [40 CFR 70.6(a)(7) and Regulation 26, §26.701(G)]

16. No permit revision shall be required, under any approved economic incentives,marketable permits, emissions trading and other similar programs or processes forchanges provided for elsewhere in this permit. [40 CFR 70.6(a)(8) and Regulation 26,§26.701(H)]

17. If the permit allows different operating scenarios, the permittee shall, contemporaneouslywith making a change from one operating scenario to another, record in a log at thepermitted facility a record of the operational scenario. [40 CFR 70.6(a)(9)(i) andRegulation 26, §26.701(I)(1)]

18. The Administrator and citizens may enforce under the Act all terms and conditions in thispermit, including any provisions designed to limit a source's potential to emit, unless theDepartment specifically designates terms and conditions of the permit as being federallyunenforceable under the Act or under any of its applicable requirements. [40 CFR70.6(b) and Regulation 26, §26.702(A) and (B)]

60

The Dow Chemical CompanyPermit #: 801-AOP-R6AFIN: 58-000II

19. Any document (including reports) required by this permit must contain a certification by aresponsible official as defined in Regulation 26, §26.2. [40 CFR 70.6(c)(l) andRegulation 26, §26.703(A)]

20. The permittee must allow an authorized representative of the Department, uponpresentation of credentials, to perform the following: [40 CFR 70.6(c)(2) and Regulation26, §26.703(B)]

a. Enter upon the permittee's premises where the permitted source is located oremissions related activity is conducted, or where records must be kept under theconditions of this permit;

b. Have access to and copy, at reasonable times, any records required under theconditions of this permit;

c. Inspect at reasonable times any facilities, equipment (including monitoring and airpollution control equipment), practices, or operations regulated or required underthis permit; and

d. As authorized by the Act, sample or monitor at reasonable times substances orparameters for assuring compliance with this permit or applicable requirements.

21. The permittee shall submit a compliance certification with the terms and conditionscontained in the permit, including emission limitations, standards, or work practices. Thepermittee must submit the compliance certification annually within 30 days following thelast day of the anniversary month of the initial Title V permit. The permittee must alsosubmit the compliance certification to the Administrator as well as to the Department.All compliance certifications required by this permit must include the following: [40CFR 70.6(c)(5) and Regulation 26, §26.703(E)(3)]

a. The identification of each term or condition of the permit that is the basis of thecertification;

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

and over the reporting period established by the monitoring requirements of thispermit; and

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

61


22. Nothing in this permit will alter or affect the following: [Regulation 26, §26.704(C)]

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

b. The liability of the permittee for any violation of applicable requirements prior toor at the time of permit issuance;

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

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

23. This permit authorizes only those pollutant emitting activities addressed in this permit.[AC.A §8-4-203 as referenced by AC.A §8-4-304 and §8-4-311]

24. The permittee may request in writing and at least 15 days in advance of the deadline, anextension to any testing, compliance or other dates in this permit. No such extensions areauthorized until the permittee receives written Department approval. The Departmentmay 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; andc. 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), Regulation 26, §26.1013(A),AC.A §8-4-203 as referenced by AC.A. §8-4-304 and §8-4-311, and 40 CFR Part 52,Subpart E]

25. The permittee may request in writing and at least 30 days in advance, temporaryemissions and/or testing that would otherwise exceed an emission rate, throughputrequirement, or other limit in this permit. No such activities are authorized until thepermittee receives written Department approval. Any such emissions shall be included inthe facility's total emissions and reported as such. The Department may grant such arequest, 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 of air pollution;

62


d. The request contains such information necessary for the Department to evaluatethe request, including but not limited to, quantification of such emissions and thedate/time such emission will occur;

e. Such a request will result in increased emissions less than five tons of anyindividual criteria pollutant, one ton of any single HAP and 2.5 tons of totalHAPs; and

f. The permittee maintains records of the dates and results of such temporaryemissions/testing.

[Regulation 18, §18.314(B), Regulation 19, §19.416(B), Regulation 26, §26.1013(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]

26. The permittee may request in writing and at least 30 days in advance, an alternativeto the specified monitoring in this permit. No such alternatives are authorized until thepermittee receives written Department approval. The Department may grant such arequest, 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 of actual monitoring to the

current requirements; andc. Any such request, if approved, is incorporated in the next permit modification

application by the permittee.

[Regulation 18, §18.314(C), Regulation 19, §19.416(C), Regulation 26, §26.1013(C),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]

63

j

j

j

j

j

j

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CERTIFICATE OF SERVICE

I, Pam Owen, hereby certify that a copy of this permit has been mailed by first class~6 The

Dow Chemical Company, 3230 Dow Road, Russellville, AR, 72802, on this C18 day

,2009.

Pam Owen, AAII, Air Division

response to comments the dow chemical company …

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