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ADEQOPERATINGAIR PERMIT

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

Permit #: 906-AOP-R1

IS ISSUED TO:

Columbian Chemicals Company713 Industrial Park Road

El Dorado, AR 71730-6623Union CountyCSN: 70-0014

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:

February 18, 1998 and February 17, 2003

AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN.

Signed:

Keith A. Michaels Date Modified

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SECTION I: FACILITY INFORMATION

PERMITTEE: Columbian Chemicals CompanyCSN: 70-0014PERMIT NUMBER: 906-AOP-R1

FACILITY ADDRESS: 713 Industrial Park RoadEl Dorado, AR 71730-6623

COUNTY: Union

CONTACT POSITION: Jim McGuffin / Robert VigilTELEPHONE NUMBER: (870) 862-4205

REVIEWING ENGINEER: Michael H. Watt

UTM North-South (Y): Zone 15 3673.8 kmUTM East-West (X): Zone 15 536.5 km

Columbian Chemicals CompanyPermit #: 906-AOP-R1CSN #: 70-0014

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SECTION II: INTRODUCTION

Summary of Permit Activity

Columbian Chemicals Company owns and operates a carbon black manufacturing facility locatedat 713 Industrial Road, El Dorado, Arkansas. This facility manufactures carbon black using theoil furnace process. Columbian Chemicals is proposing to install a new unit (Unit D whichinvolves SN-08, SN-31, SN-48, SN-49, SN-60, SN-61, and SN-63) in order to increaseproduction of carcass carbon black and also install a new dryer stack for emissions from Unit Band Unit D (SN-24). (Note: Columbian Chemicals Company was allowed to install a separatedryer stack for Unit B under Permit #906-AOP-R0. However, the facility never installed thestack.)

Process Description

The oil furnace process is the dominant process used today in the manufacturing of carbon black. The feedstock consists primarily of an aromatic liquid hydrocarbon. The most common sourceof this feedstock is Gulf Coast oil refineries. Refinery cracking unit bottoms contain thecondensed-ring hydrocarbons necessary for the carbon black process and can be obtained at anacceptable cost.

The first step in the production process is a cracking or pyrolysis step. The hydrocarbonfeedstock is heated and injected continuously into a reactor vessel. The reactor is a speciallydesigned furnace with injection ports located strategically around the combustion zone. The heatnecessary to initiate the carbon black process in the combustion zone is provided by either thehydrocarbon feed stock or natural gas. In the reaction zone, the hydrocarbon decomposes (i.e.,cracks) to form carbon black. Careful control of the process (or combustion) air is required toinsure that complete combustion does not occur. The particles of carbon black generated in thereactor are carried downstream with the process gas, which is commonly referred to as “tail gas.” This tail gas typically consists of approximately 10 to 17 percent carbon monoxide with smallerconcentrations of other compounds, such as hydrogen sulfide, carbonyl sulfide, carbon disulfide,acetylene, particulate matter, sulfur dioxide, and oxides of nitrogen. The majority of the gasconsists of nitrogen and contains about 40% water vapor. A portion of the tail gas is used as fuelfor the dryers and boilers located at this facility. The remainder of the tail gas is currently ventedto the atmosphere. Under this permit, the tail gas will be combusted in a thermal oxidizersystem. In the event of routine maintenance or equipment malfunction, as provided for morespecifically later in this permit, the facility will be permitted to vent a limited amount of tail gasto the atmosphere.


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To stop the cracking process, water is used to cool the tail gases from the reactor toapproximately 1,200 to 1,500EF (650 to 800EC). The carbon black laden tail gas is furthercooled to about 450EF (230EC) by heat exchange, followed by additional injection of water.

The carbon black is separated from the tail gas by high efficiency fabric filters. Each of the fourunits at this facility is equipped with its own collection system.

After the separation of the tail gas and the carbon black, the carbon black is further processed tomeet customer requirements. The two reactors located at Unit A produce general tread carbonblack, the reactors located at Units B and D produce carcass carbon black, and the reactor locatedat Unit C produces specialty carbon black. A special beading process is part of the Unit A, UnitB, and Unit D reactor processes. Carbon black is mixed with water containing the beadingbinding agent and is dried in one of the unit dryers. The Unit C carbon black is beaded with a“bead oil” to form the specialty product. Consequently, there is not a dryer associated with UnitC.

This facility also includes mechanical and air conveying systems that transfer the materials fromthe reactor/dryer system to the product storage area. The product is stored in bulk storagecontainers and may be shipped to the customer using one of three methods: bulk shipment in railcars and hopper trucks, supersacks or tote bins, and smaller bags (typically 50-lb).

Prevention of Significant Deterioration

With the installation of the new equipment, SO2 emissions will increase 9,121 tons per year,NOX emissions will increase 863 tons per year, and PM10 emissions will increase 13 tons peryear. All other pollutants’ proposed emissions are lower than the past actual emissions becauseof the addition of new control equipment and changes in emission factors. The emissionincreases of SO2 and NOX will exceed the PSD Significant Increase Levels, while PM10emissions are below the PSD threshold.


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BACT ANALYSIS

For a PSD permit, the applicant must perform a BACT analysis for each new unit. The applicantmust also perform a BACT analysis for each affected unit that is undergoing a physical change ora change in the method of operation. The BACT evaluation must address each pollutant subjectto PSD review emitted by the unit. BACT is determined on a case-by-case basis for each sourcetaking into account technical feasibility, energy and environmental impacts, and cost in a top-down approach. That is, after discarding the technically infeasible options, the applicant mustconsider the remaining technologies in order of control efficiency and document any findingswhich result in not using the most effective control technology.

BACT analyses were conducted for the SO2 and the NOX emissions from the new natural gasfired units (SN-31, SN-48, and SN-49), SN-23, SN-24, and SN-37.

BACT Analyses for SO2 & NOX from natural gas fired sources (SN-31, SN-48, and SN-49)

The natural gas fired burners are specifically designed for the carbon black process and will notoperate in excess of 500 hours in any consecutive twelve month period. Due to the low level ofemissions from these burners (less than 0.01 tpy of SO2 and 1.0 tpy of NOX per source), anycontrols would be economically infeasible.

Therefore, BACT for sources SN-31, SN-48, and SN-49 is considered to be proper design andcombustion practices.

BACT Analysis for SO2 from SN-23, SN-24, and SN-37

Under Permit #906-AOP-R0, use of a feedstock oil with a sulfur content of 3.0% by weight wasdetermined to be BACT for this facility.

Several methods of lowering the sulfur dioxide emissions from these sources were examined inthe permit application. The pre-combustion control methods included lowering the sulfurcontent of the feedstock oil by either treating the feedstock or using a low sulfur contentfeedstock, and treating pre-oxidation and pre-dryer/tail gas boiler gases for hydrogen sulfide orother sulfur compounds. The post-combustion control methods examined in the permitapplication included treating the oxidized tail gas through flue gas desulfurization (FGD)processes and treating existing dryer and/or tail gas boiler streams individually, in addition totreating the oxidizer exhaust using flue-gas desulfurization processes.


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Removal of sulfur from the feedstock oil was rejected because the theoretical methods for thesulfur removal would saturate the condensed ring hydrocarbons which are the basis of the carbonblack process, and there are no other known methods to remove the sulfur from the oil which arecommercially available and economic.

The only technically feasible post combustion control technique was Non-Regenerative, WetFGD with lime. The annual cost of this system was over $11,000,000. This option would alsorequire an additional boiler or quench system and would generate approximately 84,000 tons ofsolid waste per year. No other carbon black plant has been required to install a FGD device. Post combustion control techniques were rejected due to economic unreasonableness, otherenvironmental impacts, and lack of practical use of the equipment for that purpose.

The maximum sulfur content of the feedstock oil currently in use at this facility is less than thelimits for other facilities found in the RBLC database. Therefore, it has been determined thatcontinuing to allow the facility to use feedstock oil with a maximum sulfur content of 3% byweight is the most technically and economically feasible method of controlling sulfur emissionsat this facility. The facility may blend higher sulfur feedstocks with lower sulfur feedstocks toensure that the sulfur content of the feed to the reactors is less then or equal to 3% by weight.

BACT Analysis for NOx from SN-23, SN-24, and SN-37

Specific information could not be obtained on NOx control measures beyond proper combustioncontrol or low NOx burners. Due to the peculiar characteristics of carbon black tail gas,conventional low NOx burners are not applicable for use in combusting tail gas. However, avariation has been developed such that the combustor proposed for this facility’s new boilers anddryers will achieve 300 ppm by volume or less.


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BACT Summary

Emission Unit Pollutant BACT Determination

SN-23 SO2 Maximum 3% sulfur by weightin blended feedstock oil

SN-23 NOX Good combustion practiceEmissions of # 300 ppm by vol.

on a wet basis


SN-24 NOx Good combustion practiceEmissions of # 300 ppm by vol.

on a wet basis

SN-31 SO2 Proper design & goodcombustion practice

SN-31 NOx Proper design & goodcombustion practice


SN-37 NOx Good combustion practiceEmissions of # 300 ppm by vol.

on a wet basis

SN-48 & SN-49 SO2 Proper design & goodcombustion practice

SN-48 & SN-49 NOx Proper design & goodcombustion practice


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AMBIENT AIR IMPACT ANALYSIS

An air dispersion modeling analysis is a required part of a PSD permit application. The airdispersion modeling analysis is used to demonstrate that the emissions resulting from a proposedmodification will not cause or contribute to a violation of any applicable National Ambient AirQuality Standard (NAAQS) or surpass a PSD increment. The USEPA requires that PSDmodeling be performed in two stages: the significance analysis and the full impact analysis. Thefull impact analysis is further divided into the NAAQS and PSD Increment Analyses.

SIGNIFICANCE ANALYSIS

The significance analysis considers the emission increases associated with the proposedmodifications at Columbian Chemicals Company in order to determine whether or not themodifications will have a significant impact upon the area surrounding the facility. If the resultsof the significance analysis are above the Modeling Significance Levels (MSLs), the full impactanalysis will be required for that pollutant. In addition, if the results of the significance analysisare above the Monitoring De Minimis Concentrations, PSD ambient monitoring requirementsmust also be addressed for that pollutant.

The PSD ambient monitoring is used to establish background air quality concentrations in thevicinity of the proposed sources. The Monitoring De Minimis Concentrations establish levels atwhich a facility would need to conduct pre-construction ambient air quality monitoring.

The results of the significance analysis are contained in the following table.

Maximum Predicted Concentration in Comparison withModeling Significance Levels and Monitoring De Minimis Concentrations

Pollutant AveragingPeriod

ModeledConcentration

(µg/m3)

PSD ModelingSignificance

Level (µg/m3)

PSD Monitoring DeMinimis

Concentrations (µg/m3)

SO2 3-hour >140 25 --

24-hour >45 5 13

Annual >4.5 1 --

NOX Annual 0.49 1 14


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AMBIENT MONITORING

Columbian Chemicals was not required to address ambient monitoring for NOX due to the lowconcentration predicted in the significance analysis. However, the permittee was required toaddress ambient monitoring requirements for SO2 because the 24-hour concentration predicted inthe significance analysis exceeded the monitoring de minimis level. In lieu of conducting theirown ambient monitoring, Columbian Chemicals requested, and the Department approved, the useof existing monitoring data from the Department’s SO2 monitor located in El Dorado.

FULL IMPACT ANALYSIS

Because the emission increases of sulfur dioxide associated with the proposed modifications areshown to have a potentially significant impact (i.e., ambient concentrations exceed MSLs), a fullimpact was conducted. The full impact analysis consists of a NAAQS and PSD Incrementcompliance demonstration.

NAAQS ANALYSIS

The NAAQS are maximum concentration ceilings measured in terms of the total concentration ofa pollutant in the atmosphere. In the NAAQS analysis, Columbian Chemicals Company’semissions were combined with those from other nearby sources that have the potential tocontribute significantly to receptors within the Radius of Impact (ROI) of Columbian Chemicals.

The table below contains the results of the NAAQS analysis for sulfur dioxide.

Modeled Concentration with Backgroundin Comparison with the NAAQS

Pollutant Averaging Period ModeledConcentration

(µg/m3)

ModeledConcentration with

Background (µg/m3)

NAAQS(µg/m3)

SO2 3-hour1 823.0 989.0 1,300

24-hour1 293.0 361.0 365

Annual2 26.5 39.8 801. Highest, 2nd Highest Concentration2. Highest


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PSD INCREMENT ANALYSIS

PSD Increment is the maximum allowable increase in concentration that is allowed to occurabove a set baseline concentration for a specific pollutant. The baseline concentration is definedfor each pollutant and averaging time. It is the ambient concentration existing at the time that thefirst complete PSD permit application is submitted for a distinct area. PSD minor source triggerdate for SO2 has been established for Union county as August 8, 1999.

Increment consuming sources were obtained using the same methodology for the NAAQSAnalysis. Permitted dates of sources were evaluated to determine if the source was increment-consuming or in the baseline.

Emissions increases and decreases for all increment-affected sources located within the baselinearea are modeled along with the emissions from Columbian Chemicals.

The facility constructed an overall increment model. In this model, all increment consumingsources within the ROI were modeled. This was then compared to the total increment available. The highest results of the Increment Analysis for SO2 is contained in the following table.

Total Available Increment Analysis Results for SO2

AveragingPeriod

Maximum ModeledIncrement Consumption

(µg/m3)

Total Increment(µg/m3)

Percent ofIncrementConsumed

3-hour 288.0 512.0 56.3%

24-hour 89.2 91.0 98.0%

Annual 13.9 20.0 69.5%

According to §19.9.4(c)(4) of Regulation #19, if issuance of a permit would result in theconsumption of more than 80% of the short-term increment or 50% of the available increment,the permittee shall submit an assessment of (a) the effects that the consumption would have uponthe industrial and economic development within the area, and (b) alternatives to the consumptionincluding alternative siting of the source or portions. The results of this analysis are includedbelow.


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a. Columbian Chemicals also performed increment consumption modeling usingdata from the facility only. This was done to show how the emissions changes atColumbian Chemicals alone would effect the available increment. The results ofthis modeling show that the impacts from Columbian Chemical alone are belowthe thresholds specified in Regulation 19.904. The data are also representative ofthe increment consumption that is occurring around the plant itself, and thereforewould not restrict development in the site vicinity.

b. In the modeling that included all increment consuming sources, the results showthat the maximum consumption is occurring near other facilities that are locatedaway from the Columbian plant. It would not be feasible to consider analternative site to this facility, as the increment consumption would beapproximately the same wherever it is located. The proposed location is in anarea that will have a limited impact on growth.

Class I Area Impact Analysis

The PSD Regulations require that written notification be provided to the Federal Land Managerin the event that a major source or modification is located within 100 kilometers of a Class IArea. Columbian Chemicals Company is located approximately 177 kilometers from the nearestClass I Area. Therefore, neither notification to the Federal Land Manager nor a Class I AreaImpact Analysis is required.

Additional Impacts Review

Three areas constitute the Additional Impacts Review: a growth analysis, a soils and vegetationanalysis, and a visibility analysis.

The growth analysis includes a projection of the associated industrial, commercial, andresidential growth that will occur in the area as a result of the source. The potential impact onthe ambient air due to the growth is also a part of the analysis. Columbian Chemicals does notexpect an increase in industrial, commercial, or residential growth as a result of the proposedmodification.

If all ambient concentrations are below the secondary NAAQS then soils and vegetation shouldnot suffer any harmful effects as a result of the proposed modification. The modeling resultswere all below the secondary NAAQS levels.

Through modeling, it has been shown that the proposed emission rates will not have a significantimpact at any off property locations. Thus, the proposed modification will not cause any


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visibility impairment.

Regulations

Permit #906-AOP-R1 is the second operating permit issued to Columbian Chemicals Companyunder Regulation 26. Columbian Chemicals is also subject to 40 CFR Part 60, Subpart Kb NewSource Performance Standards for Volatile Organic Storage Vessels, Regulations of theArkansas Operating Air Permit Program (Title V, Regulation #26), Regulations of the ArkansasPlan of Implementation for Air Pollution Control (SIP, Regulation #19), and Arkansas AirPollution Control Code (Code, Regulation #18).

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

EMISSION SUMMARY

SourceNo.

Description Pollutant Emission Rates CrossReference

Pagelb/hr tpy

Total Allowable Emissions PMPM10SO2

VOCCONOx

40.140.1

2,590.8659.8

13,591.7305.3

78.078.0

10,085.1278.0

5,723.91,090.1

HAPs* Carbon -Disulfide*Carbonyl -Sulfide*

208.39

31.99

87.75

13.46

Air Contaminants ** Hydrogen -Sulfide**

TRS**

279.63

520.11

117.76

219.04

08 Feedstock Oil Tank VOC 0.1 0.1 24

12 Vapor Bag CollectorUnit B

PMPM10

1.11.1

4.54.5

25


EMISSION SUMMARY

SourceNo.


Pagelb/hr tpy

13

13 Vapor Bag CollectorUnit A

PMPM10

1.01.0

4.24.2

25

14 Reject PulsaireCollector Unit B

PMPM10

0.10.1

0.30.3

27

15 Pulsaire Collector UnitA

PMPM10

2.02.0

8.48.4

27

20 Air Conveying PulsaireUnit C

PMPM10

0.50.5

2.02.0

27

21 Twilight TankBaghouse

(Unit A & B Start-ups)

PMPM10

0.10.1

0.30.3

30

23 Boilers, Unit A DryersCombined Stack

PMPM10SO2

VOCCONOX

Carbon - Disulfide

Carbonyl -Sulfide

Hydrogen -Sulfide

TRS

1.41.4

419.05.8

119.041.01.82

0.28

2.45

4.60

5.35.3

1,672.023.0

475.0178.07.28

1.12

9.77

18.20

31


EMISSION SUMMARY

SourceNo.


Pagelb/hr tpy

14

24 Units B & D DryersStack

PMPM10SO2

VOCCONOX

Carbon - Disulfide

Carbonyl -Sulfide

Hydrogen -Sulfide

TRS

2.22.2

681.09.4

193.066.02.97

0.46

3.98

7.41

8.68.6

2,709.037.0

770.0289.011.80

1.81

15.84

29.45

34

27 Tail Gas Bypass Stack PMPM10SO2

VOCCONOX

Carbon - Disulfide

Carbonyl -Sulfide

Hydrogen -Sulfide

TRS

12.812.860.0

623.012,868.0

28.8197.37

30.29

264.84

492.50

2.92.9

13.3139.0

2,861.06.4

43.88

6.73

58.88

109.49

37

28 Natural Gas CoastStack Unit A

PMPM10SO2

VOCCONOx

0.30.30.10.20.53.0

0.20.20.10.10.31.5

39


EMISSION SUMMARY

SourceNo.


Pagelb/hr tpy

15

29 Natural Gas CoastStack Unit B

PMPM10SO2

VOCCONOx

0.30.30.10.20.42.4

0.20.20.10.10.21.2

39

30 Natural Gas CoastStack Unit C

PMPM10SO2

VOCCONOx

0.20.20.10.10.31.5

0.20.20.10.10.31.5

39

31 Natural Gas CoastStack Unit D

PMPM10SO2

VOCCONOx

0.30.30.10.10.83.0

0.10.10.10.10.20.8

39

32 Unit B Warehouse PMPM10

0.50.5

0.50.5

27

33 Hopper Car UnloadingVent

PMPM10

6.96.9

7.27.2

42

34 Unit A Warehouse PMPM10

0.40.4

0.50.5

27

36 Feedstock Oil Tank #7 VOC 0.1 0.1 24


EMISSION SUMMARY

SourceNo.


Pagelb/hr tpy

16

37 Thermal OxidizerStack

PMPM10SO2

VOCCONOX

Carbon -Disulfide

Carbonyl -Sulfide

Hydrogen -Sulfide

TRS

4.64.6

1,430.019.7

406.0139.06.23

0.96

8.36

15.60

17.917.9

5,690.078.0

1,616.0608.024.79

3.80

33.27

61.90

44

39, 40,and 41

Unit B Reactor Vents PMPM10SO2

VOCCONOx

0.70.70.10.41.17.0

0.10.10.10.10.20.9

47

42 and43

Unit C Reactor Vents PMPM10SO2

VOCCONOx

0.30.30.10.20.53.0

0.10.10.10.10.20.8

47

44, 45,46,

and 47

Unit A Reactor Vents PMPM10SO2

VOCCONOx

0.60.60.10.40.95.9

0.10.10.10.10.20.8

47


EMISSION SUMMARY

SourceNo.


Pagelb/hr tpy

17

48 and49

Unit D Reactor Vents PMPM10SO2

VOCCONOx

0.50.50.10.11.24.7

0.20.20.10.10.31.2

47

61 Unit D Vapor BagCollector

PMPM10

1.11.1

4.64.6

25

62 Air Conveying PulsaireUnit D

PMPM10

2.12.1

9.19.1

27

63 Warehouse PMPM10

0.10.1

0.50.5

27

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

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


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SECTION III: PERMIT HISTORY

Cities Service Company owned and operated a carbon black manufacturing facility in El Doradowhich began operation in the early 1950s. This facility was registered with the Department priorto July 30, 1969. In 1980, Cities Service Company formed Columbian Chemicals Company as afree-standing company. With the exception of replacing outdated or uneconomical equipment,the plant operations changed little until 1989.

Permit #906-A was issued to Columbian Chemicals Company on January 18, 1989. This permitallowed the facility to make numerous modifications over a three year period. Thesemodifications included replacing reactors on two units with newer state-of-the-art Columbianpatented designs, replacing the bag filters and wet scrubbers on all units with newer technologybag filters, installing a new stack, and converting an existing natural gas fired boiler to use planttail gas as its primary fuel.

Permit #906-A expired on December 31, 1992. An extension on this permit was granted by theDirector of the Department on December 14, 1992. This extension allowed the facility tocontinue operation under Permit #906-A through December 31, 1993.

On November 1, 1994, this facility began operating under Consent Administrative Order (CAO)LIS-94-133.

Permit #906-AOP-R0 was issued to Columbian Chemicals Company on February 18, 1998. Columbian Chemicals proposed to install a thermal oxidizer to oxidize the unused tail gas whichwas previously vented to the atmosphere. Following the installation and startup of the thermaloxidizer, restrictions were placed on the use of the tail gas bypass stack, SN-27. ColumbianChemicals submitted a PSD permit application for these proposed modifications addressingemissions from all modified and affected units.

The following are the proposed emission changes that were included in Columbian Chemicals’PSD permit application and/or required by the Department.

1. A thermal oxidizer (SN-37) will be installed to oxidize the uncombusted tail gas. Thisgas was previously routed through the tail gas bypass stack (SN-27). As a result of theinstallation of the thermal oxidizer, there will be significant increases of sulfur dioxideand oxides of nitrogen emissions. However, permitted emissions of carbon monoxidewill be greatly reduced. Construction of the thermal oxidizer will begin within 18 monthsof the issuance of this permit. Operation of this source will begin within 33 months fromthe date of issuance of this permit.


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2. Columbian Chemicals will have the option to increase production with this permit. If thefacility chooses to increase production, a new stack, SN-24, will be installed. This newstack will vent emissions from the Unit B dryers. The increase in production, as stated inseveral specific conditions and Plantwide Condition #11 and #12, may not take placeuntil sources SN-24 and SN-37 have been installed and are operating.

3. Continuous operation of source SN-27 will cease upon the installation of source SN-37. The permittee will be allowed to use the bypass stack under the following two conditions:

a. Emergency release of tail gases as allowed under §26.7(f) of Regulation 26, for whichnotification must be submitted under General Provision #8 of this permit, and

b. During periods of planned maintenance which must coincide with the shutdown ofeither Unit A or Unit B. The permittee will be required to maintain documentationdemonstrating that one of the two required units was shutdown and that the hours ofoperation for this source were not exceeded.

The net emission increase will exceed the PSD significant emission rates for oxides of nitrogen(NOx) and sulfur dioxide (SO2). A summary of the net emission increases that are above the PSDsignificant emission rates is contained in the following table.

Pollutant Net Emission Increase(tpy)

PSD Significant EmissionRate (tpy)

SO2 5277.0 40.0

NOx 768.0 40.0

The increased emissions from the thermal oxidizer will not affect any source besides SN-27which will be taken out of service within 60 days of the installation of source SN-37 except asherein provided. All annual emissions at source SN-27 are decreasing as a result of theinstallation of the thermal oxidizer. The installation of the Unit B dryer stack will cause a changein the method of operation at SN-23.

Three pollutants have significant increases at sources SN-24 and SN-37. However, theseincreases were not subject to PSD review due to reduction of these pollutants at other sources atthe facility. The installation and operation of the thermal oxidizer is responsible for most of thecreditable decreases in emissions. Based upon information submitted by the permittee, it isexpected that sources SN-24, if the facility chooses to increase production, and SN-37 will be inoperation within 33 months of permit issuance. Conditions have been placed in this permit


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requiring that the decreases occur at the same time that the increased emissions occur.

A summary of the net emission decreases is contained in the table below.

Pollutant Net Emission Decrease(tpy)

Actual Emissions(tpy)

Permitted Emissions(tpy)

CO 26,660.0 32,194 5534

TRS 913.0 1106.0 193.0

H2S 552.0 663.0 111.0

VOC 735.0 914.0 179.0

BACT Analysis for SO2 from SN-23, SN-24, and SN-37

Currently, the permittee is allowed to use feedstock oil with a sulfur content of 2.9% by weight.

Several methods of lowering the sulfur dioxide emissions from these sources were examined inthe permit application. The pre-combustion control methods include lowering the sulfur contentof the feedstock oil either by treating the feedstock or by using a low sulfur content feedstock,and treating pre-oxidation and pre-dryer/tail gas boiler gases for H2S and/or other sulfurcompounds. The post-combustion control methods examined in the permit application includetreating the oxidized tail gas through flue-gas desulfurization processes and treating existingdryer and/or tail gas boiler streams individually, in addition to treating the oxidizer exhaust usingflue-gas desulfurization processes.

Removal of sulfur from the feedstock oil was rejected because the theoretical methods for thesulfur removal would saturate the condensed ring hydrocarbons which are the basis of the carbonblack process and there are no known methods which are commercially available and economicto remove the sulfur from the oil. The post combustion control techniques were also rejected dueto cost and/or unavailability.

The maximum sulfur content of the feedstock oil currently in use at this facility is less than thelimits for other facilities found in the RBLC database. Therefore, it has been determined thatcontinuing to allow the facility to use feedstock oil with a maximum sulfur content of 3% byweight is the most technically and economically feasible method of controlling sulfur emissionsat this facility. The facility may blend higher sulfur feedstocks with lower sulfur feedstocks toensure that the sulfur content of the feed to the reactors is less then or equal to 3% by weight.


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22

BACT Analysis for NOx from SN-24 and SN-37

Specific information could not be obtained on NOx control measures beyond proper combustioncontrol or low NOx burners. Due to the peculiar characteristics of carbon black tail gas,conventional low NOx burners are not applicable to the thermal oxidizer design. However, avariation has been developed such that the combustor proposed for this facility’s thermaloxidizer will achieve 300 ppm by volume or less.

BACT Summary

Emission Unit Pollutant BACT Determination



SN-24 NOx Good combustion practice


SN-37 NOx

Good combustion practice

Ambient Air Impact Analysis

The results of the significance analysis for NOx from Columbian Chemicals were below thecorresponding Modeling Significance Level. Therefore, the full impact analysis of NOx was notrequired. In addition, the modeling results were below the corresponding Monitoring DeMinimis Concentration thus no ambient monitoring is required.

The results of the significance analysis for SO2 from Columbian Chemicals were above thecorresponding Modeling Significance levels. Therefore, the full impact analysis was required forSO2. The results of the full impact analysis were below the corresponding NAAQS levels. Thesignificance analysis for SO2 also showed that the Monitoring De Minimis Concentration wasexceeded on a 24 hour average. In lieu of pre-construction monitoring, the Department hasaccepted the use of existing data from an SO2 monitor located in El Dorado. The PSD IncrementAnalysis showed that no PSD increments would be completely consumed or exceeded.


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Results of Significance Analysis

Pollutant AveragingPeriod

Concentration,(µg/m3)

ModelingSignificance Level,

(µg/m3)

Monitoring DeMinimis

Concentration, (µg/m3)

SO2 3 hour24 hourAnnual

122.433.34.1

2551

--13--

NOx Annual 0.2 1 14

Results of Full Impact Analysis

Pollutant Averaging Period Concentration,(µg/m3)

NAAQS,(µg/m3)


780.3342.160.9

13001

36580

1. There is no primary NAAQS standard for SO2 on a 3-hour average. Therefore, the secondary NAAQS standard hasbeen used.

Results of PSD Increment Analysis

Pollutant Averaging Period Concentration,(µg/m3)

PSD Increment, (µg/m3)


123.034.34.58

5129120

Class I Area Impact Analysis

The PSD Regulations require that written notification be provided to the Federal Land Managerin the event that a major source or modification is located within 100 kilometers of a Class IArea. Columbian Chemicals Company is located approximately 177 kilometers from the nearestClass I Area. Therefore, neither notification to the Federal Land Manager nor a Class I AreaImpact Analysis is required.


SECTION IV: EMISSION UNIT INFORMATION


25

SN-08 and SN-36 Feedstock Oil Tanks

Source Description

The feedstock oil tanks store the raw materials which are used at this facility. The carbon blackfeedstock is similar to residual #6 fuel oil. The material stored in these tanks has a vaporpressure less than 0.5 psia. Source SN-36 has a volume of 2384.8 m3 (630, 000 gallons). SourceSN-08 has a volume of 757.1 m3 (200,000 gallons). Therefore, under 40 CFR §60.110b(c), thesesources are exempt from most of the requirements of 40 CFR Part 60, Subpart A, and 40 CFRPart 60, Subpart Kb. The only requirements are the notification and record keepingrequirements.

Specific Conditions

1. Pursuant to §19.501 et seq of the Regulations of the Arkansas Plan of Implementation for Air Pollution Control (Regulation #19) effective February 15, 1999 and 40 CFR Part52, Subpart E, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated by equipment limitations.

SN Pollutant lb/hr tpy

08 VOC 0.1 0.1

36 VOC 0.1 0.1

2. Pursuant to §19.705 of Regulation 19, A.C.A. §8-4-203 as referenced by §8-4-304 and§8-4-311, and 40 CFR §70.6, the permittee shall not store any materials at sources SN-08and SN-36 which have a true vapor pressure in excess of 0.5 psia.

3. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shallmaintain records of the dimensions of sources SN-08 and SN-36 on site. These recordsshall be made available to Department personnel upon request.


26

SN-12, SN-13, and SN-61 Vapor Bag Collectors

Source Description

These baghouses control the particulate emissions from the dryers located at Units A, B, and D. (Unit C does not have a dryer.) SN-12 is located at Unit B while SN-13 is located at Unit A andSN-61 is located at Unit D. Sources SN-12 and SN-13 were both installed or last modified in1988. Source SN-61 is being installed under this permit. These sources are permitted to run atcapacity for 8,760 hours per year. Therefore, no throughput records are required to be kept forthese sources.

Specific Conditions

4. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, thepermittee shall not exceed the emission rates set forth in the following table. Compliancewith this condition will be demonstrated by Specific Condition #6, Plantwide Condition#13, and equipment limitations.


12 PM10 1.1 4.5

13 PM10 1.0 4.2

61 PM10 1.1 4.6

5. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated by Specific Condition #6,Plantwide Condition #13, and equipment limitations.


12 PM 1.1 4.5

13 PM 1.0 4.2

61 PM 1.1 4.6


27

6. Pursuant to §18.501 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not cause to be discharged to the atmosphere gaseswhich exhibit an opacity greater than 5%. The opacity shall be measured in accordancewith EPA Reference Method 9 as found in 40 CFR Part 60 Appendix A. Compliancewith this condition will be demonstrated by Plantwide Condition #15.


28

SN-14, SN-15, SN-20, SN-32, SN-34, SN-62, and SN-63 Conveying, Reject, Equipment Vent, and Warehouse Bag Collectors

Source Description

At Unit A, carbon black is pneumatically conveyed from the main unit bag collector to theconveying pulseaire bag collector (SN-15) above the dense tank. The conveying pulseaire bagcollector also receives carbon black rejected from the product screens, discharge from thewarehouse bag collector, and venting from the dense tank and downstream mechanical conveyingequipment. The Unit A warehouse bag collector (SN-34) vents some mechanical conveyingequipment, the unit’s bag packaging system, and the venting during the loading of hopper carsand trucks. Carbon black discharged from the collector is returned to the conveying pulseairebag collector.

At Unit B, powder carbon black is mechanically conveyed by a series of screw conveyors and abucket elevator from the main unit bag collector to the dense tank and does not require aconveying pulseaire bag collector. Also at Unit B, a reject pulseaire bag collector (SN-14) islocated above the dense tank to receive carbon black rejected from the product screens, dischargefrom the warehouse bag collector, venting from the dense tank, and downstream mechanicalconveying equipment. The Unit B warehouse bag collector (SN-32) vents some mechanicalconveying equipment, the unit’s bag packaging system, and the venting during the loading ofhopper cars and trucks. Carbon black discharged from the collector is returned to the rejectpulseaire collector.

At Unit C, powder carbon black is pneumatically conveyed from the main unit bag collector tothe conveying pulseaire bag collector (SN-20) above the dense tank. Alternatively, carbon blackfrom Unit C may be directed to Unit A, combining with the Unit A production for beading anddrying. The conveying pulseaire bag collector also receives carbon black rejected from theproduct screens and venting from the dense tank, downstream mechanical conveying equipment,and loading railroad hopper cars and trucks.

At Unit D, powder carbon black will be pneumatically conveyed from the main unit bag collectorto the conveying pulseaire bag collector (SN-62) above the dense tank. The conveying pulseairebag collector will also receive carbon black re-run from the start-up tank and venting from thedense tank. Unit D will have an equipment vent collector (SN-63) located above the start-uptank to handle venting of downstream mechanical conveying equipment (from dryer to storagetank) and venting from loading railroad hopper cars and trucks. Collected carbon black will bedischarged into the Unit D start-up tank.


29

Specific Conditions

7. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, thepermittee shall not exceed the emission rates set forth in the following table. Compliancewith this condition will be demonstrated by Specific Conditions #9, #10, and #12,Plantwide Condition #13, and equipment limitations.


14 PM10 0.1 0.3

15 PM10 2.0 8.4

20 PM10 0.5 2.0

32 PM10 0.5 0.5

34 PM10 0.4 0.5

62 PM10 2.1 9.1

63 PM10 0.1 0.5

8. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated by Specific Conditions #9,#10, and #12, Plantwide Condition #13, and equipment limitations.


14 PM 0.1 0.3

15 PM 2.0 8.4

20 PM 0.5 2.0

32 PM 0.5 0.5

34 PM 0.4 0.5

62 PM 2.1 9.1

63 PM 0.1 0.5


30


10. Pursuant to §19.705 of Regulation 19, 40 CFR 70.6, A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311 and §18.1004 of Regulation 18, the permittee shall not exceed thelimits set forth in the following table at the designated sources in any consecutive twelvemonth period.

SN Process Rate Units (PRUs)

32 100,604

34 138,518

11. Pursuant to §19.705 of Regulation #19 and 40 CFR Part 52, Subpart E, the permitteeshall maintain records which demonstrate compliance with Specific Condition #10. Therecords shall be updated on a monthly basis. These records shall be kept on site,provided to Department personnel upon request, and may be used by the Department forenforcement purposes. An annual total and each month’s individual data shall besubmitted to the Department in accordance with General Provision #7.

12. Pursuant to §19.702 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shalltest source SN-62 for PM10 using EPA Reference Method 201A within 60 days ofachieving maximum production but no later than 180 days after initial start-up. This testis being required because the net emissions increase of PM10 is close to the PSDSignificant Increase Level. This test is not required of all new sources which will bepermitted to emit PM10 due to their low level of emissions.


31

SN-21 Twilight Tank Bag Collector

Source Description

Units A and B share a twilight tank (start-up tank) which is divided into two compartments. Onoccasion, carbon black being reprocessed would be dense phase conveyed to the twilight tank,venting the air through the twilight tank bag collector (SN-21). Normally, the bag collectorfunctions as a vent for the tank.

Specific Conditions

13. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, thepermittee shall not exceed the emission rates set forth in the following table. Compliancewith this condition will be demonstrated by Specific Condition #15, Plantwide Condition#13, and equipment limitations.

Pollutant lb/hr tpy

PM10 0.1 0.3

14. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated by Specific Condition #15,Plantwide Condition #13, and equipment limitations.

Pollutant lb/hr tpy

PM 0.1 0.3



32

SN-23 Unit A Dryers and Boilers

Source Description

No physical modification is occurring at this source with the issuance of this permit. However,some of the permitted emission rates are changing due to the use of new emission factors. Currently, this source vents emissions from the boilers and Unit A and B dryers. After theinstallation of source SN-24, the emissions from the Unit B dryers and boilers will be routedthrough the new stack. Emissions from this source are the result of the combustion of tail gas. The dryers and boilers are permitted to operate at capacity for 8,760 hours per year.

Specific Conditions

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

Pollutant lb/hr tpy

PM10VOCCO

1.45.8

119.0

5.323.0

475.0

17. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated by Specific Conditions #19,#21, and equipment limitations.

Pollutant lb/hr tpy

PMCarbon DisulfideCarbonyl SulfideHydrogen Sulfide

TRS

1.41.820.282.454.60

5.37.281.129.7718.2


33

18. Pursuant to §19.501 et seq and §19.901 et seq of Regulation 19 and 40 CFR Part 52,Subpart E, the permittee shall not exceed the emission rates set forth in the followingtable at source SN-23. The emission rates are based upon the capacity of the equipment. Compliance with this condition will be demonstrated by Specific Conditions #20 and#21, Plantwide Condition #11, and equipment limitations.

Pollutant lb/hr tpy

SO2NOX

419.041.0

1,672.0178.0


20. Pursuant to §19.501 et seq and §19.901 et seq of Regulation 19 and 40 CFR Part 52,Subpart E, the permittee shall not emit NOX in concentrations exceeding 300 ppm byvolume. Compliance with this condition will be demonstrated by Specific Condition #21and equipment limitations.

21. Pursuant to §19.702 and §19.901 et seq of Regulation 19 and 40 CFR Part 52, Subpart E,the permittee shall annually conduct the following tests using the indicated test methodunless another method is approved by the Department at least 15 days prior to the testtaking place.

Pollutant EPA Reference Method

SO2 6C

NOX 7E

TRS 15


34

22. Pursuant to §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part 52, Subpart E, andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the Department reserves theright to require CEMS for sulfur dioxide and total reduced sulfur at source SN-23 if thecompliance tests show that the mass balance method of calculating the amount of sulfurbeing emitted is inaccurate. The Department will provide the permittee the CEMSstandards in the future if necessary. Inaccurate is defined, for the purposes of this specificcondition, as a deviation of more than 5% from the tested emission rate.

23. Pursuant to §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part 52, Subpart E, andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permittee may propose analternate method of demonstrating continual compliance for sulfur dioxide, oxides ofnitrogen, and total reduced sulfur emissions to include monitoring flue gas temperature,oxygen content (in accordance with 40 CFR Part 60, Appendix B, PerformanceSpecification 3), and the sulfur mass balance method. This method must demonstrateacceptability through the concurrent measurements during the first two compliance testsof this source. The first compliance test was performed prior to the issuance of thispermit.


35

SN-24Unit B and Unit D Dryer Stack

Source Description

Source SN-24 will vent the emissions from the Unit B and Unit D dryers. Emissions from thissource will be the result of the combustion of tail gas.

Specific Conditions


Pollutant lb/hr tpy

PM10VOCCO

2.29.4

193.0

8.637.0

770.0


Pollutant lb/hr tpy


TRS

2.22.970.463.987.41

8.611.801.81

15.8429.45


36

26. Pursuant to §19.501 et seq and §19.901 et seq of Regulation 19 and 40 CFR Part 52,Subpart E, the permittee shall not exceed the emission rates set forth in the followingtable at source SN-24. The emission rates are based upon the capacity of the equipment. Compliance with this condition will be demonstrated by Specific Conditions #28 and#29, Plantwide Condition #11, and equipment limitations.

Pollutant lb/hr tpy

SO2NOX

681.066.0

2,709.0289.0



29. Pursuant to §19.702 and §19.901 et seq of Regulation 19 and 40 CFR Part 52, Subpart E,the permittee shall conduct the following tests using the indicated test method unlessanother method is approved by the Department at least 15 days prior to the test takingplace. The tests must be completed within 60 days of achieving maximum production butno later than 180 days after the initial start-up. Annual testing shall be performed forSO2, NOX, and TRS.


SO2 6C

CO 10

NOX 7E

TRS 15

Opacity 9


37


31. Pursuant to §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part 52, Subpart E, andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permittee may propose analternate method of demonstrating continual compliance for sulfur dioxide, oxides ofnitrogen, and total reduced sulfur emissions to include monitoring flue gas temperature,oxygen content (in accordance with 40 CFR Part 60, Appendix B, PerformanceSpecification 3), and the sulfur mass balance method. This method must demonstrateacceptability through the concurrent measurements during the first two compliance testsof this source.


38

SN-27 Tail Gas Bypass

Source Description

Uncombusted tail gas is vented through this source. Due to the installation of the thermaloxidizer (SN-37), this source is not permitted to operate continuously.

Specific Conditions


Pollutant lb/hr tpy

PM10SO2

VOCCO

NOX

12.860.0

623.012,868.0

28.8

2.913.3

139.02,861.0

6.4


Pollutant lb/hr tpy


TRS

12.8197.3730.29

264.84492.50

2.943.886.73

58.88109.49


39


35. Pursuant to §19.705 and §19.901et seq of Regulation 19, 40 CFR Part 52, Subpart E, 40CFR §70.6, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permitteeshall not operate source SN-27 in excess of 438 hours in any consecutive twelve monthperiod.

36. Pursuant to §19.705 and §19.901 et seq of Regulation 19 and 40 CFR Part 52, Subpart E,the permittee shall maintain records of the hours of operation of source SN-27 in order todemonstrate compliance with Specific Condition #35 and which may be used by theDepartment for enforcement purposes. These records shall be updated no later than thetenth day of the month following the month which the records represent, shall be kept onsite, and shall be made available to Department personnel upon request. An annual totaland each month’s individual data shall be submitted to the Department in accordancewith General Provision 7.


40

SN-28 Through SN-31 Natural Gas Coast Stacks

Source Description

The natural gas coast stacks for Units A, B, and C were installed in the late 1980's and early1990's. The natural gas coast stack for Unit D will be installed along with Unit D. These stacksexhaust the reactors when natural gas is being fired to keep the units heated. There is no carbonblack production during these periods.

Specific Conditions

37. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, thepermittee shall not exceed the emission rates set forth in the following table. Compliancewith this condition will be demonstrated by Specific Conditions #40, #41, #42, andequipment limitations.


28 PM10SO2

VOCCO

NOX

0.30.10.20.53.0

0.20.10.10.31.5

29 PM10SO2

VOCCO

NOX

0.30.10.20.40.4

0.20.10.10.21.2

30 PM10SO2

VOCCO

NOX

0.20.10.10.31.5

0.20.10.10.31.5

31 PM10VOCCO

0.30.10.8

0.10.10.2


41

38. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated by Specific Conditions #40,#41, #42, and equipment limitations.


28 PM 0.3 0.2

29 PM 0.3 0.2

30 PM 0.2 0.2

31 PM 0.3 0.1

39. Pursuant to §19.501 et seq and §19.901 et seq of Regulation 19 and 40 CFR Part 52,Subpart E, the permittee shall not exceed the emission rates set forth in the followingtable. The hourly emissions are based upon the capacity of the equipment. Compliancewith this condition will be demonstrated by Specific Conditions #44, #45, and equipmentlimitations.


31 SO2NOX

0.13.0

0.10.8

40. Pursuant to §18.501 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not cause to be discharged to the atmosphere gaseswhich exhibit an opacity greater than 5%. The opacity shall be measured in accordancewith EPA Reference Method 9 as found in 40 CFR Part 60 Appendix A. Compliancewith this condition will be demonstrated by burning only natural gas.

41. Pursuant to §19.705 of Regulation 19, 40 CFR 70.6, A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311, and §18.1004 of Regulation 18, only emissions which are theresult of the combustion of natural gas shall be vented at sources SN-28, SN-29, andSN-30.

42. Pursuant to §19.705 of Regulation 19, 40 CFR 70.6, A.C.A. §8-4-203 as referenced by§8-4-304 and §8-4-311, and §18.1004 of Regulation 18, the permittee shall only operate


42

sources SN-28, SN-29, and SN-30 during periods of non-production.

43. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shallmaintain records of the hours of operation of sources SN-28, SN-29, and SN-30 and thehours of nonproduction at those sources in order to demonstrate compliance with SpecificCondition #42 which may be used by the Department for enforcement purposes. Theserecords shall be updated monthly, kept on site, and shall be made available to Departmentpersonnel upon request.

44. Pursuant to §19.705 and §19.901 et seq. of Regulation 19, 40 CFR 70.6, A.C.A. §8-4-203as referenced by §8-4-304 and §8-4-311, and §18.1004 of Regulation 18, only emissionswhich are the result of the combustion of natural gas shall be vented at source SN-31.

45. Pursuant to §19.705 and §19.901 et seq. of Regulation 19, 40 CFR 70.6, A.C.A. §8-4-203as referenced by §8-4-304 and §8-4-311, and §18.1004 of Regulation 18, the permitteeshall only operate source SN-31 during periods of non-production.

46. Pursuant to §19.705 and §19.901 et seq. of Regulation 19 and 40 CFR Part 52, Subpart E,the permittee shall maintain records of the hours of operation of source SN-31 and thehours of nonproduction at this source in order to demonstrate compliance with SpecificCondition #45 which may be used by the Department for enforcement purposes. Theserecords shall be updated monthly, kept on site, and shall be made available to Departmentpersonnel upon request.


43

SN-33 Hopper Car Unloading Vent

Source Description

A hopper car unloading collector (SN-33) is occasionally used during the emptying of returnedrailroad hopper cars or hopper trucks.

Specific Conditions


Pollutant lb/hr tpy

PM10 6.9 7.2


Pollutant lb/hr tpy

PM 6.9 7.2


50. Pursuant to §19.705 of Regulation 19, 40 CFR 70.6, and/or A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311 and §18.1004 of Regulation 18, the permittee shallnot process in excess of 284,700 Process Rate Units in any consecutive twelve monthperiod.


44

51. Pursuant to §19.705 of Regulation #19, 40 CFR Part 52, Subpart E and §18.1004 ofRegulation 18, the permittee shall maintain records which demonstrate compliance withSpecific Condition #50. The records shall be updated on a monthly basis. These recordsshall be kept on site, provided to Department personnel upon request, and may be used bythe Department for enforcement purposes. An annual total and each month’s individualdata shall be submitted to the Department in accordance with General Provision #7.


45

SN-37 Thermal Oxidizer

Source Description

The thermal oxidizer will be used to oxidize the tail gas which is not used as fuel for the productdryers and the tail gas boilers. This source is capable of oxidizing 2.58 MMSCF/hr of tail gas. The oxidizer will operate at approximately 1900EF, have a residence time of 0.4 seconds, and adestruction and removal efficiency of 98% for VOCs and CO.

Specific Conditions


Pollutant lb/hr tpy

PM10VOCCO

4.619.7

406.0

17.978.0

1,616.0


Pollutant lb/hr tpy

PM 4.6 17.9

Carbon Disulfide 6.23 24.79

Carbonyl Sulfide 0.96 3.80

Hydrogen Sulfide 8.36 33.27

TRS 15.60 61.90


46

54. Pursuant to §19.501 et seq and §19.901 et seq of Regulation 19 and 40 CFR Part 52,Subpart E, the permittee shall not exceed the emission rates set forth in the followingtable. The emission rates are based upon the capacity of the equipment. Compliancewith this condition will be demonstrated by Specific Condition #56 and #57, PlantwideCondition #11, and equipment limitations.

Pollutant lb/hr tpy

SO2NOX

1,430.0139.0

5,690.0608.0



57. Pursuant to §19.702 and §19.901 et seq of Regulation 19 and 40 CFR Part 52, Subpart E,the permittee shall annually conduct the following tests using the indicated test methodunless another method is approved by the Department at least 15 days prior to the testtaking place.


SO2 6C

NOX 7E

TRS 15


47


59. Pursuant to §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part 52, Subpart E, andA.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permittee may propose analternate method of demonstrating continual compliance for sulfur dioxide, oxides ofnitrogen, and total reduced sulfur emissions to include monitoring flue gas temperature,oxygen content (in accordance with 40 CFR Part 60, Appendix B, PerformanceSpecification 3), and the sulfur mass balance method. This method must demonstrateacceptability through the concurrent measurements during the first two compliance testsof this source. The first compliance test was performed prior to the issuance of thispermit.


48

SN-39 Through SN-49 Reactor Vents

Source Description

All of the reactor vents emit pollutants caused by the combustion of natural gas. The emissionsare vented through the stacks only during times of non-production. During times of production,the combustion products are sent through a heat exchanger. Hourly emissions have beencalculated based upon the maximum amount that could be emitted through during an hour ofnon-production. Annual emissions have been based upon the number of non-production hourswhich this facility expects to have in any consecutive twelve month period.

Two reactors are located at Unit A. There is one reactor vent before and one reactor vent aftereach of the heat exchangers (SN-44 through SN-47) at Unit A. Each of the natural gascombustion sources which vent through SN-44 through SN-47 has a rated capacity of 10.5MMBTU/hr and was installed or last modified in 1966.

One reactor is located at Unit B. At Unit B, there are two reactor vents before and one reactorvent after the heat exchanger (SN-39 through SN-41). Each of the natural gas combustionsources which vent through SN-39 through SN-41 has a rated capacity of 16.5 MMBTU/hr andwas installed or last modified in 1979.

One reactor is located at Unit C. Unit C has one reactor vent before and one reactor vent afterthe heat exchanger (SN-42 and SN-43). Each of the natural gas combustion sources which ventthrough SN-42 and SN-43 has a rated capacity of 10.5 MMBTU/hr and was installed or lastmodified in 1977.

One reactor will be located at Unit D. Unit D will have one reactor vent before and one reactorvent after the heat exchanger (SN-48 and SN-49). Each of the natural gas combustion sourceswhich vent through SN-48 and SN-49 will have a rated capacity of 16.5 MMBTU/hr and will beinstalled along with the installation of Unit D.


49

Specific Conditions

60. Pursuant to §19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, thepermittee shall not exceed the emission rates set forth in the following table. Compliancewith this condition will be demonstrated by Specific Conditions #63, #64, #65, andequipment limitations.


39, 40, and41

PM10SO2

VOCCO

NOX

0.70.10.41.17.0

0.10.10.10.20.9

42 and 43 PM10SO2

VOCCO

NOX

0.30.10.20.53.0

0.10.10.10.20.8

44, 45, 46,and 47

PM10SO2

VOCCO

NOX

0.60.10.40.95.9

0.10.10.10.20.8

48 and 49 PM10VOCCO

0.50.11.2

0.20.10.3


50

61. Pursuant to §18.801 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated by Specific Conditions #63,#64, #65, and equipment limitations.


39, 40, and41

PM 0.7 0.1

42 and 43 PM 0.3 0.1

44, 45, 46,and 47

PM 0.6 0.1

48 and 49 PM 0.5 0.2

62. Pursuant to §19.501 et seq and §19.901 et seq of Regulation 19 and 40 CFR Part 52,Subpart E, the permittee shall not exceed the emission rates set forth in the followingtable at sources SN-48 and SN-49. The hourly emissions are based upon the capacity ofthe equipment. Compliance with this condition will be demonstrated by SpecificConditions #67, #68, and equipment limitations.


48 and 49 SO2NOX

0.14.7

0.11.2

63. Pursuant to §18.501 of Regulation #18 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not cause to be discharged to the atmosphere gaseswhich exhibit an opacity greater than 5%. The opacity shall be measured in accordancewith EPA Reference Method 9 as found in 40 CFR Part 60 Appendix A. Compliancewith this condition will be demonstrated by burning only natural gas.

64. Pursuant to §19.705 of Regulation 19, 40 CFR 70.6, and/or A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311 and §18.1004 of Regulation 18, only emissionswhich are the result of the combustion of natural gas shall be vented at sources SN-39,SN-40, SN-41, SN-42, SN-43, SN-44, SN-45, SN-46, and SN-47.


51

65. Pursuant to §19.705 of Regulation 19, 40 CFR 70.6, and/or A.C.A. §8-4-203 asreferenced by §8-4-304 and §8-4-311 and §18.1004 of Regulation 18, the permittee shallonly operate sources SN-39, SN-40, SN-41, SN-42, SN-43, SN-44, SN-45, SN-46, andSN-47 during periods of non-production.

66. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shallmaintain records of the hours of operation of sources SN-39, SN-40, SN-41, SN-42, SN-43, SN-44, SN-45, SN-46, and SN-47 and the hours of nonproduction in order todemonstrate compliance with Specific Condition #65 and which may be used by theDepartment for enforcement purposes. These records shall be updated monthly, kept onsite, and shall be made available to Department personnel upon request.

67. Pursuant to §19.705 and §19.901 et seq of Regulation 19, 40 CFR 70.6, and/or A.C.A.§8-4-203 as referenced by §8-4-304 and §8-4-311 and §18.1004 of Regulation 18, onlyemissions which are the result of the combustion of natural gas shall be vented at sourcesSN-48 and SN-49.

68. Pursuant to §19.705 and §19.901 et seq of Regulation 19, 40 CFR 70.6, and/or A.C.A.§8-4-203 as referenced by §8-4-304 and §8-4-311 and §18.1004 of Regulation 18, thepermittee shall only operate sources SN-48 and SN-49 during periods of non-production.

69. Pursuant to §19.705 and §19.901 et seq of Regulation 19 and 40 CFR Part 52, Subpart E,the permittee shall maintain records of the hours of operation of sources SN-48 and SN-49 and the hours of nonproduction in order to demonstrate compliance with SpecificCondition #68 and which may be used by the Department for enforcement purposes. These records shall be updated monthly, kept on site, and shall be made available toDepartment personnel upon request.


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SECTION V: COMPLIANCE PLAN AND SCHEDULE

Columbian Chemicals Company is in compliance with the applicable regulations cited in thepermit application. Columbian Chemicals Company will continue to operate in compliance withthose identified regulatory provisions. The facility will examine and analyze future regulationsthat may apply and determine their applicability with any necessary action taken on a timelybasis.


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SECTION VI: PLANTWIDE CONDITIONS

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

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

3. Pursuant to §19.702 of Regulation 19 and/or §18.1002 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, any equipment that is to betested, unless stated in the Specific Conditions of this permit or by any federally regulatedrequirements, shall be tested with the following time frames: (1) Equipment to beconstructed or modified shall be tested within sixty (60) days of achieving the maximumproduction rate, but in no event later than 180 days after initial start-up of the permittedsource or (2) equipment already operating shall be tested according to the time frames setforth by the Department or within 180 days of permit issuance if no date is specified. Thepermittee shall notify the Department of the scheduled date of compliance testing at leastfifteen (15) days in advance of such test. Compliance test results shall be submitted tothe Department within thirty (30) days after the completed testing.

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

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

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


54

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

7. Pursuant to §18.801of Regulation 18, the permittee shall not cause or permit the emissionof air contaminants, including odors or water vapor and including an air contaminantwhose emission is not otherwise prohibited by Regulation #18, if the emission of the aircontaminant constitute air pollution within the meaning of A.C.A. §8-4-303.

8. Pursuant to §18.901 of Regulation 18, the permittee shall not conduct operations in sucha manner as to unnecessarily cause air contaminants and other pollutants from becomingairborne.

9. Pursuant to §19.705 and §19.901 et seq of Regulation 19, 40 CFR Part 52, Subpart E, 40CFR 70.6, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the sulfurcontent of the feedstock oil may not exceed 3.0% by weight. If feedstock oil with a sulfurcontent greater than 3.0% by weight is received, the permittee may blend if withfeedstock oil that has a lower sulfur content in order to meet the 3.0% limit.

10. Pursuant to §19.705 and §19.901 et seq of Regulation 19 and 40 CFR Part 52, Subpart E,the permittee shall maintain records of any feedstock blending which takes place. Thedaily testing of the sulfur content of the feedstock oil required for the sulfur mass balancemay be used to satisfy this requirement.

11. Pursuant to §19.7 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shalluse a mass balance to calculate the combined sulfur emissions from SN-23, SN-24, andSN-37. The following variables shall be recorded weekly or as noted below:

a. The sulfur content of the feedstock oil once per day at the header valve as the oilenters each unit,

b. The sulfur content of each type of carbon black produced at each of the four units,c. The amount of feedstock oil processed in each of the three units,d. The amount of each type of carbon black produced in each unit,e. The amount of sulfur entering the units (This will be calculated by multiplying the

sulfur content of the feedstock oil by the amount of oil processed),f. The amount of sulfur contained in the carbon black products (This will be calculated

by multiplying the sulfur contents of each type of carbon black by the amount thatwas produced), and

g. The combined amount of SO2 emitted from sources SN-23, SN-24, and SN-37 (Thiswill be calculated by multiplying 0.98 times twice the difference between the amountof sulfur entering the units and the amount of sulfur contained in the carbon black


55

products from the three units).

12. Pursuant to §19.705 and §19.901 et seq of Regulation 19 and 40 CFR Part 52, Subpart E,the permittee shall maintain records of the sulfur mass balance calculations in order todemonstrate compliance with the emission rates for sources SN-23, SN-24, and SN-37and which may be used by the Department for the enforcement purposes. The permitteeshall update the sulfur mass balance records at least once per week and make theserecords available to Department personnel upon request. These records shall besubmitted to the Department in accordance with General Provision.

13. Pursuant to §19.705 and §19.901 et seq of Regulation 19, 40 CFR Part 52, Subpart E, 40CFR 70.6, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permitteeshall not produce in excess of 368,241 Process Rate Units of carbon black at this facilityin any consecutive twelve month period.

14. Pursuant to §19.705 and §19.901 et seq of Regulation 19, and 40 CFR Part 52, Subpart E,the permittee shall maintain records of the number of Process Rate Units of carbon blackproduced in order to demonstrate compliance with Plantwide Condition #13 and whichmay be used by the Department for enforcement purposes. These records shall beupdated weekly, kept on site, and shall be made available to Department personnel uponrequest. These records shall be submitted to the Department in accordance with GeneralProvision 7.

15. Pursuant to §19.7 of the Regulation #19 and 40 CFR Part 52, Subpart E, weeklyobservations of the opacity of SN-12 through SN-15, SN-20, SN-21, SN-23, SN-24,SN-27 through SN-34, SN-37, SN-39 through SN-49, SN-61, SN-62, and SN-63 shall beconducted by personnel familiar with the permittee’s visible emissions. The permitteeshall maintain personnel trained in EPA Reference Method 9. If, at any time, visibleemissions which appear to be in excess of the permitted opacity are detected, thepermittee shall immediately take action to identify the cause of the visible emissions,implement corrective action, and document that visible emissions did not appear to be inexcess of the permitted opacity following the corrective action. If opacity is still greaterthan permit limits, a full Method 9 reading is required. The permittee shall maintainrecords which contain the following items in order to demonstrate compliance with thisspecific condition. These records shall be updated weekly, kept on site, and madeavailable to Department personnel upon request.

a. The date and time of the observationb. If visible emissions which appeared to be above the permitted limit were

detected


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c. If visible emissions which appeared to be above the permitted limit weredetected, the cause of the exceedance of the opacity limit, the correctiveaction taken, and if the visible emissions appeared to be below thepermitted limit after the corrective action was taken.

d. The name of the person conducting the opacity observations.

Permit Shield

16. Compliance with the conditions of this permit shall be deemed compliance with allapplicable requirements, as of the date of permit issuance, included in and specificallyidentified in item A of this condition:

A. The following have been specifically identified as applicable requirements based uponinformation submitted by the permittee in an application dated October 10, 1996.

Source No. Regulation Description

Facility 19 SIP

Facility 26 Operating Permit Program Regulations

B. The following requirements have been specifically identified as not applicable, basedupon information submitted by the permittee in an application dated October 10,1996.

Description of Regulation RegulatoryCitation

AffectedSource

Basis for Determination

NSPS for VOL Storage Vessels 40 CFR Part60, Subpart Kb

SN-36 andSN-08

The vapor pressure of the tanks are lowenough so that they are not subject to any

of the requirements of this subpart.

C. Nothing shall alter or affect the following:

Provisions of Section 303 of the Clean Air Act;

The liability of an owner or operator for any violation of applicable requirements


57

prior to or at the time of permit issuance;

The applicable requirements of the acid rain program, consistent with Section 408(a)of the Clean Air Act; or

The ability of the EPA to obtain information under Section 114 of the Clean Air Act.

Title VI Provisions

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

a. All containers containing a class I or class II substance stored or transported, allproducts containing a class I substance, and all products directly manufactured with aclass I substance must bear the required warning statement if it is being introduced tointerstate commerce pursuant to §82.106.

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

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

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

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

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

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

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

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

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

f. Owners/operators of appliances normally containing 50 or more pounds of refrigerant


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must keep records of refrigerant purchased and added to such appliances pursuant to§82.166.

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

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

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

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


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SECTION VII: INSIGNIFICANT ACTIVITIES

Pursuant to §26.304 of Regulation 26, the following sources are insignificant activities. Anyactivity for which a state or federal applicable requirement applies is not insignificant even if thisactivity meets the criteria of §304 of Regulation 26 or is listed below. Insignificant activitydeterminations rely upon the information submitted by the permittee in an application datedJanuary 2000.

Description Category

Feedstock Oil Tanks(SN-01 through SN-06)

A-13

Bead Oil Sludge Tank(SN-35)

A-3

Bead Oil Tanks (SN-51 through SN-53)

A-3

Potassium Carbonate Solution Tank(SN-38)

A-3

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


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SECTION VIII: GENERAL PROVISIONS

1. Pursuant to 40 CFR 70.6(b)(2), any terms or conditions included in this permit whichspecify and reference Arkansas Pollution Control & Ecology Commission Regulation 18or the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as the soleorigin of and authority for the terms or conditions are not required under the Clean Air Actor any of its applicable requirements, and are not federally enforceable under the Clean AirAct. Arkansas Pollution Control & Ecology Commission Regulation 18 was adoptedpursuant to the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.). 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 origin of and authority for the termsor conditions are enforceable under this Arkansas statute.

2. Pursuant to 40 CFR 70.6(a)(2) and §26.7 of the Regulations of the Arkansas Operating AirPermit Program (Regulation 26), this permit shall be valid for a period of five (5) yearsbeginning on the date this permit becomes effective and ending five (5) years later.

3. Pursuant to §26.4 of Regulation #26, it is the duty of the permittee to submit a completeapplication for permit renewal at least six (6) months prior to the date of permit expiration. Permit expiration terminates the permittee's right to operate unless a complete renewalapplication was submitted at least six (6) months prior to permit expiration, in which casethe existing permit shall 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.

4. Pursuant to 40 CFR 70.6(a)(1)(ii) and §26.7 of Regulation #26, where an applicablerequirement of the Clean Air Act, as amended, 42 U.S.C. 7401, et seq (Act) is morestringent than an applicable requirement of regulations promulgated under Title IV of theAct, both provisions are incorporated into the permit and shall be enforceable by theDirector or Administrator.

5. Pursuant to 40 CFR 70.6(a)(3)(ii)(A) and §26.7 of Regulation #26, records of monitoringinformation required by this permit shall include the following:

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

b. The date(s) analyses were performed;c. The company or entity that performed the analyses;d. The analytical techniques or methods used;


61

e. The results of such analyses; and f. The operating conditions existing at the time of sampling or measurement.

6. Pursuant to 40 CFR 70.6(a)(3)(ii)(B) and §26.7 of Regulation #26, records of all requiredmonitoring data and support information shall be retained for a period of at least 5 yearsfrom the date of the monitoring sample, measurement, report, or application. Supportinformation includes all calibration and maintenance records and all original strip-chartrecordings for continuous monitoring instrumentation, and copies of all reports required bythis permit.

7. Pursuant to 40 CFR 70.6(a)(3)(iii)(A) and §26.7 of Regulation #26, the permittee shallsubmit reports of all required monitoring every 6 months. If no other reporting period hasbeen established, the reporting period shall end on the last day of the anniversary month ofthis permit. The report shall be due within 30 days of the end of the reporting period.Even though the reports are due every six months, each report shall contain a full year ofdata. All instances of deviations from permit requirements must be clearly identified insuch reports. All required reports must be certified by a responsible official as defined in§26.2 of Regulation #26 and must be sent to the address below.

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

8. Pursuant to 40 CFR 70.6(a)(3)(iii)(B), §26.7 of Regulation #26, and §19.601 and 19.602of Regulation #19, all deviations from permit requirements, including those attributable toupset conditions as defined in the permit shall be reported to the Department. An initialreport shall be made to the Department by the next business day after the occurrence. Theinitial report may be made by telephone and shall include:

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

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

deviation occurs, d. The date and time the deviation started, e. The duration of the deviation, f. The average emissions during the deviation,g. The probable cause of such deviations,


62

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

i. The name of the person submitting the report.

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

9. Pursuant to 40 CFR 70.6(a)(5) and §26.7 of Regulation #26, and A.C.A.§8-4-203, asreferenced by §8-4-304 and §8-4-311, if any provision of the permit or the applicationthereof to any person or circumstance is held invalid, such invalidity shall not affect otherprovisions or applications hereof which can be given effect without the invalid provisionor application, and to this end, provisions of this Regulation are declared to be separableand severable.

10. Pursuant to 40 CFR 70.6(a)(6)(i) and §26.7 of Regulation #26, the permittee must complywith all conditions of this Part 70 permit. Any permit noncompliance with applicablerequirements as defined in Regulation #26 constitutes a violation of the Clean Air Act, asamended, 42 U.S.C. 7401, et seq. and is grounds for enforcement action; for permittermination, revocation and reissuance, or modification; or for denial of a permit renewalapplication. Any permit noncompliance with a state requirement constitutes a violation ofthe Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) and is alsogrounds for enforcement action; for permit termination, revocation and reissuance, ormodification; or for denial of a permit renewal application.

11. Pursuant to 40 CFR 70.6(a)(6)(ii) and §26.7 of Regulation #26, it shall not be a defense fora permittee in an enforcement action that it would have been necessary to halt or reducethe permitted activity in order to maintain compliance with the conditions of this permit.


63

12. Pursuant to 40 CFR 70.6(a)(6)(iii) and §26.7 of Regulation #26, this permit may bemodified, revoked, reopened, and reissued, or terminated for cause. The filing of a requestby the permittee for a permit modification, revocation and reissuance, or termination, or ofa notification of planned changes or anticipated noncompliance does not stay any permitcondition.

13. Pursuant to 40 CFR 70.6(a)(6)(iv) and §26.7 of Regulation #26, this permit does notconvey any property rights of any sort, or any exclusive privilege.

14. Pursuant to 40 CFR 70.6(a)(6)(v) and §26.7 of Regulation #26, the permittee shall furnishto the Director, within the time specified by the Director, any information that the Directormay request in writing to determine whether cause exists for modifying, revoking andreissuing, or terminating the permit or to determine compliance with the permit. Uponrequest, the permittee shall also furnish to the Director copies of records required to bekept by the permit. For information claimed to be confidential, the permittee may berequired to furnish such records directly to the Administrator along with a claim ofconfidentiality.

15. Pursuant to 40 CFR 70.6(a)(7) and §26.7 of Regulation #26, the permittee shall pay allpermit fees in accordance with the procedures established in Regulation #9.

16. Pursuant to 40 CFR 70.6(a)(8) and §26.7 of Regulation #26, no permit revision shall berequired, under any approved economic incentives, marketable permits, emissions tradingand other similar programs or processes for changes that are provided for elsewhere in thispermit.

17. Pursuant to 40 CFR 70.6(a)(9)(i) and §26.7 of Regulation #26, if the permittee is allowedto operate under different operating scenarios, the permittee shall, contemporaneously withmaking a change from one operating scenario to another, record in a log at the permittedfacility a record of the scenario under which the facility or source is operating.

18. Pursuant to 40 CFR 70.6(b) and §26.7 of Regulation #26, all terms and conditions in thispermit, including any provisions designed to limit a source's potential to emit, areenforceable by the Administrator and citizens under the Act unless the Department hasspecifically designated as not being federally enforceable under the Act any terms andconditions included in the permit that are not required under the Act or under any of itsapplicable requirements.


64

19. Pursuant to 40 CFR 70.6(c)(1) and §26.7 of Regulation #26, any document (includingreports) required by this permit shall contain a certification by a responsible official asdefined in §26.2 of Regulation #26.

20. Pursuant to 40 CFR 70.6(c)(2) and §26.7 of Regulation #26, the permittee shall allow anauthorized representative of the Department, upon presentation of credentials, to performthe following:

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

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

c. Inspect at reasonable times any facilities, equipment (including monitoringand air pollution control equipment), practices, or operations regulated orrequired under this permit; and

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

21. Pursuant to 40 CFR 70.6(c)(5) and §26.7 of Regulation #26, the permittee shall submit acompliance certification with terms and conditions contained in the permit, includingemission limitations, standards, or work practices. This compliance certification shall besubmitted annually and shall be submitted to the Administrator as well as to theDepartment. All compliance certifications required by this permit shall include thefollowing:

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

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

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

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

22. Pursuant to §26.7 of Regulation #26, nothing in this permit shall alter or affect thefollowing:


65

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

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

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

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

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

APPENDIX A

APPENDIX B

APPENDIX C

APPENDIX D

INVOICE REQUEST FORMPDS-

Date October 11, 2001

X Air

NPDES

Stormwater

State Permits Branch

Solid Waste

CSN 70-0014

Facility Name Columbian Chemicals Company

Invoice Mailing Address 1800 West Oak Commons Court

Marietta, GA 30062-2253

Initial

X Modification

Annual

Permit Number 906-AOP-R1 Permit Description Title 5 Permit Fee Code A

Amount Due $ 1,000

Engineer Michael H. Watt

Paid? GGGGNo GGGGYes Check #

Comments: Air Permit Fee Calculation$19.12 * (-54.5-54.5+4000-1184.9+832.7-1463.27-2084.09) = -8.56 so minimum $1,000

Public Notice

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

Columbian Chemicals Company owns and operates a carbon black manufacturing facility locatedat 713 Industrial Road, El Dorado, Arkansas. This facility manufactures carbon black using the oilfurnace process. Columbian Chemicals is proposing to install a new unit (Unit D which involvesSN-08, SN-31, SN-48, SN-49, SN-60, SN-61, and SN-63) in order to increase production of carcasscarbon black, install a boiler to support Unit D (SN-31), and install a new dryer stack for emissionsfrom Unit B and Unit D (SN-24). Permit #906-AOP-R1 is the second operating permit issued toColumbian Chemicals Company under Regulation 26. Columbian Chemicals is also subject toRegulations of the Arkansas Operating Air Permit Program (Title V, Regulation #26), Regulationsof the Arkansas Plan of Implementation for Air Pollution Control (SIP, Regulation #19), andArkansas Air Pollution Control Code (Code, Regulation #18).

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

Citizens wishing to examine the permit application and staff findings and recommendations may doso by contacting Suzanne Carswell, Information Officer. Citizens desiring technical informationconcerning the application or permit should contact Michael H. Watt, Engineer. Both SuzanneCarswell and Michael H. Watt can be reached at the Department's central office, 8001 NationalDrive, Little Rock, Arkansas 72209, telephone: (501) 682-0744.

The draft permit and permit application are available for copying at the above address. A copy ofthe draft permit has also been placed at the Barton Library, East Fifth and N. Jefferson, El Dorado,Arkansas 71730 . This information may be reviewed during normal business hours. Interested or affected persons may also submit written comments or request a hearing on theproposal, or the proposed modification, to the Department at the above address - Attention: SuzanneCarswell. In order to be considered, the comments must be submitted within thirty (30) days ofpublication of this notice. Although the Department is not proposing to conduct a public hearing,one will be scheduled if significant comments on the permit provisions are received. If a hearing isscheduled, adequate public notice will be given in the newspaper of largest circulation in the countyin which the facility in question is, or will be, located.

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

Dated this

Richard A. Weiss

Interim Director

adeq operating air permit€¦ · adeq operating air permit ... the oil furnace process is the...

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