ADEQ MINOR SOURCE AIR PERMIT MINOR SOURCE AIR PERMIT Permit #: ... are located on the shell side....

ADEQMINOR SOURCE

AIR PERMITPermit #: 1590-AR-3

IS ISSUED TO:

Borden Chemical, Inc.185 North Industrial Drive

Hope, AR 71801Hempstead County

CSN: 29-0125

THIS PERMIT IS YOUR AUTHORITY TO CONSTRUCT, MODIFY, OPERATE, AND/ORMAINTAIN THE EQUIPMENT AND/OR FACILITY IN THE MANNER AS SET FORTH INTHE DEPARTMENT’S MINOR SOURCE AIR PERMIT AND YOUR APPLICATION. THISPERMIT IS ISSUED PURSUANT TO THE PROVISIONS OF THE ARKANSAS WATERAND AIR POLLUTION CONTROL ACT (ARK. CODE ANN. SEC. 8-4-101 ET SEQ.) ANDTHE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALLLIMITS AND CONDITIONS CONTAINED HEREIN.

Signed:

Keith A. Michaels Date

11

SECTION I: FACILITY INFORMATION

PERMITTEE: Borden Chemical, Inc.CSN: 29-0125PERMIT NUMBER: 1590-AR-3

FACILITY ADDRESS: 185 North Industrial DriveHope, AR 71801

COUNTY: Hempstead

CONTACT POSITION: Plant ManagerTELEPHONE NUMBER: (870) 722-5100

REVIEWING ENGINEER: Derrick Brown

UTM North-South (X): 3720000

UTM East-West (Y): 440000

Borden Chemical, Inc.Permit #: 1590-AR-3CSN: 29-0125

2

SECTION II: INTRODUCTION

Summary

Borden Chemical, Inc. owns and operates a resin and formaldehyde production facility located at185 North Industrial Drive, Hope, Hempstead County, Arkansas. Permit #1590-AR-3 is beingissued to the facility to incorporate an increase in production, emission rates based on testing, andthe removal of a spray dry resin plant.

Process Description

Raw Material Receiving and StorageUpon arrival at the facility via tank truck, a solution of 50% sodium hydroxide and a solution of50% potassium hydroxide are transferred into individual storage tanks (a list of tanks is given inTable I on page 17) to be stored until needed for processing.

Rail hopper cars are used to haul urea granules to the facility. The granules are unloaded fromthe cars and sent to a silo (SN-04) via a below-grade hopper, inclined screw conveyor, and abucket elevator. A Goretex or equivalent sock is used to control emissions from the silo.

Phenol is transported to the facility via railcar and stored in individual storage tanks. The fumecollection header and fume scrubber system (SN-01) is used to vent the emissions from therailcar and the storage tanks.

The tanks, both formaldehyde and phenol storage, are designed to operate in a pressure range ofatmospheric to slight vacuum pressure (less 2 inches of water). The tanks are also insulated. Asteam coil maintains the tank temperature at approximately 131EF.

As an alternative to having formaldehyde shipped to the facility, formaldehyde is now manufactured on site. Formaldehyde storage tank emissions are directed to the inlet of theformaldehyde process. Loading emissions are controlled by either vapor balance or the fumescrubber (SN-01).

Formaldehyde Manufacture:Upon arrival at the facility, methanol is received in rail tank cars and stored in a tank.

A 50% by weight aqueous formaldehyde solution is manufactured through the air oxidation ofmethanol on a molybdenum-iron oxide fixed bed catalyst inside a vertical shell and tube heatexchanger. The catalyst rings are loaded in the tube side of this reactor and a eutectic mixture ofdiphenyl and diphenyl oxide (DDO) are located on the shell side.


3

The heat from this reaction is removed through vaporization of the DDO. The vaporized DDO iscondensed in a kettle reboiler producing steam. The DDO vaporization and condensation cycleis a closed loop system.

The hot reaction gas is cooled as it exits the vertical exchanger by passing through the tube sideof a different shell and tube heat exchanger for cooling. From there, the reaction gas enters theabsorber column where a scrubbing liquid consisting of formaldehyde water solution absorbs theformaldehyde from the gas phase and condenses the water formed in the reaction.

The oxygen source for the reaction is ambient air. Non-reacting materials of nitrogen, argon,water vapor, and carbon dioxide are introduced to the process with the air flow. Followingreaction, the oxygen depleted air stream, methyl dimethyl ether (DME), and carbon monoxide arevented from the system to the catalytic oxidizer (SN-03). Product storage tank vents are directedto the inlet of the formaldehyde process.

Resin Manufacture

UF Resin Manufacturing:Formaldehyde from the storage tanks is pumped to the top of a reactor and combined with ureagranules conveyed from the silo in order to produce a resin. An acid catalyst is added to thismixture in order to speed up the reaction. Steam inside the internal coils is used to heat the resinfrom 40EF (Fahrenheit) to 100EC. The reactor is maintained at a constant temperature of 100EFuntil the resin reaches its desired viscosity.

Depending upon the particular formulation being made, the steam generated while the resin isboiling is condensed in the overhead condenser and returned to the reactor, or drawn off to astorage tank. A condenser located in the top of the reactor is used to cool air displaced by theformaldehyde to below 40EC (Celsius). This cooled air, along with the air displaced by the ureagranules and the air displaced during the chemical reaction of the urea and formaldehyde isvented through the fume scrubber (SN-01).

After the desired viscosity has been reached, a small amount of base is added to neutralize thereaction. At this point, the steam is turned off, the vacuum pump is turned on, and the pressurein the reactor is reduced. As a result of the change pressure, the resin begins to boil. The steamis condensed in the overhead condenser. The small amount of non-condensible gases flowthrough the vacuum pump and then to the fume scrubber (SN-01). The condensate from thecondenser is either returned to the reactor or drawn off as distillate.


4

The resin temperature is decreased after the heat is removed and the pressure is decreased. Whenthe temperature has reached 50EC, the vacuum pump is turned off, the cooling water to theinternal coils is turned on, and the vent valve is opened on the reactor, thus allowing air into thereactor again. Once the reactor has reached atmospheric pressure, additional urea is added to theresin. The addition of urea, along with the cooling effect of the cooling oils, causes the resintemperature to decrease to -30EC.

The cooled resin is pumped to a storage tank where it is further cooled by water chilled internalcoils to 25EC. The storage tank is vented directly to the atmosphere.

PF Resin Manufacturing:Water, washwater, and sodium hydroxide are pumped into the top of a reactor. The water isused to dilute the phenol which is then partially reacted with the sodium hydroxide to form sodium phenate. A vacuum pump is then used to lower the pressure in the reactor to 5 psia. Themixture temperature is -60EC. At this temperature and pressure, the mixture is near its boilingpoint.

The air removed by the vacuum pump is sent to the fume scrubber (SN-01). The air displaced bythe phenol is cooled by the overhead condenser to below 40EC and then routed to the fumescrubber.

Formaldehyde is reacted with the phenol mixture as it is added into the reactor. The steamgenerated by this reaction is condensed in the overhead condenser and returned to the reactor. The pressure in the reactor is slowly increased to atmospheric pressure as the formaldehyde isadded. The resultant temperature is -96EC. During this period, the air in the reactor is displacedby resin; therefore, the air flow to the scrubber is negligible.

Once the desired viscosity has been reached, the temperature of the batch is decreased byincreasing the vacuum. Additional sodium or potassium hydroxide is added, and the resin isfurther cooled.

The vacuum is used to lower the resin temperature to -40EC. Once the temperature has beenreached, the vacuum pump is turned off and cooling water is circulated through the internal coils. The vent valve is opened on the reactor, thereby, allowing air to enter. When the reactor hasreached atmospheric pressure, urea is conveyed to the top of the reactor from the overhead silo.(Depending upon the formulation of the product, urea may not need to be added.) The airdisplaced by the urea is vented to the fume scrubber (SN-01) through the overhead condenser.


5

From the reactor, the resin is pumped to a storage tank where water chilled internal coils are usedto cool the resin product to -25EC. An automated pumping system is used to load the tanktrucks in order to ship the finished resin to customers.

Wax Emulsion ManufactureRaw materials of slack wax, stearic acid, and triethanolamine are received in their molten formsfrom tank trucks and are combined with recycled washwater and/or fresh water in the closedsystem homogenizer. The emulsion is then cooled in a water heat exchanger.

Vapor Recovery SystemsThe facility employs two vapor recovery systems. The first system vents formaldehyde tanks andformaldehyde loading to formaldehyde production. The second vents resin reactors, phenol tanksand phenol loading to the fume scrubber (SN-01). Formaldehyde tanks and formaldehydeloading are vented to the fume scrubber when the formaldehyde production operation is not inoperation.

Regulations

This facility is subject to regulations under the Arkansas Air Pollution Control Code (Air code),the Arkansas Plan of Implementation for Air Pollution Control (SIP), and the New SourcePerformance Standards (NSPS).

The boiler is subject to New Source Performance Standards (NSPS) regulations under Title 40 ofthe Code of Federal Regulations Part 60, Subpart Dc-Standards of Performance for SmallIndustrial-Commercial-Institutional Steam Generating Units (Appendix A).

The formaldehyde, methanol, and phenol storage tanks are subject to NSPS regulations under40 CFR Part 60, Subpart Kb-Standards of Performance for Volatile Organic Liquid StorageVessels (Appendix B). The other tanks on site are not subject to NSPS regulations. A summaryof tanks located at the facility is contained in Table II.

The air oxidation reactor and recovery system is regulated under 40 CFR Part 60, Subpart III-Standards of Performance for Volatile Organic Compound (VOC) Emissions From the SyntheticOrganic Chemical Manufacturing Industry (SOCMI) Air Oxidation Process (Appendix C).

The pumps, pressure relief devices, sampling connection systems, open-ended valves and lines,valves, flanges, and other connectors in VOC service at this facility are regulated under 40 CFRPart 60, Subpart VV-Standards of Performance for equipment Leaks of VOC in the SyntheticOrganic Chemicals Manufacturing Industry (Appendix D).


6

The following table is a summary of the facility’s total emissions.

TOTAL ALLOWABLE EMISSIONS

Pollutant Emission Rates

lb/hr tpy

PMPM10SO2

VOCCONOx

Formaldehyde*Phenol*

Methanol*Triethylamine*

0.40.40.1

11.37.92.70.60.42.01.0

1.31.30.5

32.634.511.81.81.28.34.4

*Included in VOCs.


7

SECTION III: PERMIT HISTORY

Permit #1590-A, the initial air permit for this facility, was issued on January 17, 1995. Thepurpose of this permit was to construct a urea-formaldehyde (UF) and phenol-formaldehyde (PF)resin plant. Emission limits were permitted at 1.3 tpy PM/PM10, 0.4 tpy SO2, 0.4 tpy VOC, 3.1tpy CO, 11.8 tpy NOX, 5.7 tpy formaldehyde, 0.4 tpy phenol, and 3.5 tpy methanol.

Permit #1590-AR-1 was issued to the facility on February 21, 1996. This permit was issued todocument the addition of the formaldehyde and wax emulsion manufacturing facilities and toallow an increase in the production of UF and PF resins. Under this permit, emission limits werepermitted at 1.3 tpy of PM/PM10, 0.5 tpy of SO2, 0.4 tpy of VOC, 31.8 tpy of CO, 11.8 tpy ofNOX, 5.9 tpy of formaldehyde, 1.5 tpy of phenol, 4.1 tpy of methanol, and 10.0 tpy of dimethylether.

Permit #1590-AR-2 was issued to the facility on July 25, 1997. This permitting action includedthe addition of a spray dried phenolic resin plant. Permitted emissions under this action were33.5 tpy of PM/PM10, 1.0 tpy of SO2, 93.2 tpy of VOC, 38.2 tpy of CO, 26.6 tpy of NOX, 10.0 tpyof dimethyl ether, and 0.1 tpy of Dowtherm.


8

SECTION IV: EMISSION UNIT INFORMATION

Specific Conditions

1. Pursuant to §19.501 et seq of the Regulations of the Arkansas Plan of Implementation forAir Pollution Control, effective February 15, 1999 (Regulation 19) and A.C.A. §8-4-203as referenced by §8-4-304 and §8-4-311, the permittee shall not exceed the emission ratesset forth in the following table.

SN Description Pollutant lb/hr tpy

01 Fume Scrubber VOC 4.6 19.6

02 Steam Boiler(Natural Gas)

PM10SO2

VOCCONOX

0.30.10.10.72.7

1.20.50.33.0

11.8

03 Catalytic Oxidizer VOCCO

2.97.2

12.231.5

04 Urea WeighHopper, H1

PM10 0.1 0.1

05 FormaldehydePlant (Fugitive

Emissions)

VOC 0.4 0.5


9

2. Pursuant to §18.801 of the Arkansas Air Pollution Control Code, effective February 15,1999 (Regulation 18) and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, thepermittee shall not exceed the emission rates set forth in the following table.

SN Description Pollutant lb/hr tpy

01 Fume Scrubber FormaldehydePhenol

MethanolTriethylamine

0.30.31.51.0

1.01.16.64.4

02 Steam Boiler(Natural Gas)

PM 0.3 1.2

03 Catalytic Oxidizer FormaldehydeMethanol

0.20.4

0.61.6

04 Urea WeighHopper, H1

PM 0.1 0.1

05 FormaldehydePlant (Fugitive

Emissions)

MethanolFormaldehyde

Phenol

0.10.10.1

0.10.20.1


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3. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, visible emissionsshall not exceed the limits specified in the following table of this permit as measured byEPA Reference Method 9.

SN Limit RegulatoryCitation

01 10 §18.501 of Regulation 18





4. 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 cause or permit the emission of air contaminants,including odors or water vapor and including an air contaminant whose emission is nototherwise prohibited by Regulation #18, if the emission of the air contaminant constitutesair pollution within the meaning of A.C.A. §8-4-303.

5. Pursuant to §18.901 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not conduct operations in such a manner as tounnecessarily cause air contaminants and other pollutants to become airborne.


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SN-01 Conditions

6. Pursuant to §19.705 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, urea-formaldehyde resin production shall not exceed 250,000,000 poundsper consecutive twelve month period.

7. Pursuant to §19.705 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall maintain monthly records which demonstratecompliance with Specific Condition 6. Records shall be updated by the fifteenth day ofthe month following the month to which the records pertain. These records shall be kepton site, and shall be made available to Department personnel upon request. A twelvemonth rolling average and each individual month’s data shall be submitted in accordancewith General Condition 6.

8. Pursuant to §19.705 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, urea-phenol resin production shall not exceed 225,000,000 pounds perconsecutive twelve month period.

9. Pursuant to §19.705 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall maintain monthly records which demonstratecompliance with Specific Condition 8. Records shall be updated by the fifteenth day ofthe month following the month to which the records pertain. These records shall be kepton site, and shall be made available to Department personnel upon request. A twelvemonth rolling average and each individual month’s data shall be submitted in accordancewith General Condition 6.

10. Pursuant to §19.303 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall maintain and operate each vapor recovery system inserviceable condition as prescribed by the manufacturer. The vapor recovery system forformaldehyde tanks and formaldehyde loading shall be vented to formaldehydeproduction. The vapor recovery system for the resin reactor, phenol tanks and phenolloading shall be vented to the fume scrubber (SN-01). When formaldehyde production isnot in operation the formaldehyde tanks and formaldehyde loading shall be vented to thescrubber also. Failure to control vapor emissions by both systems or wet scrubbingsingularly when formaldehyde production is not in operation shall be a violation of thispermit.


12

11. Pursuant to §19.303 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall maintain the catalytic oxidizer (SN-03) in goodoperating condition and operate the catalytic oxidizer according to manufacturer’sspecifications. It shall be used whenever the formaldehyde process is operating. Formaldehyde shall not be manufactured during any period of equipment failure ormaintenance shut-down on the catalytic oxidizer.

12. Pursuant to §19.303 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall maintain the catalyst in good operating condition. Thecatalyst shall be tested once every year and replaced when necessary.

SN-03 NSPS Requirements

13. Pursuant to 40 CFR Part §60.610 the facility is subject to applicable provisions of 40CFR Part 60, Subpart III. These provisions are outlined in Specific Conditions 14through 19.

14. Pursuant to 40 CFR Part 60.612(a) the permittee shall reduce emissions of TOC (minusmethane and ethane) by 98 weight-percent, or to a TOC (minus methane and ethane)concentration of 20 ppmv on a dry basis corrected to 3 percent oxygen, whichever is lessstringent.

15. Pursuant to 40 CFR Part §60.613(a)(1) the permittee shall install, calibrate, maintain, andoperate according to manufacturer’s specifications the following equipment:

(a) A temperature monitoring device equipped with a continuous recorder and havingan accuracy of ±1 percent of the temperature being monitored expressed indegrees Celsius or ±0.5 degrees Celsius, whichever is greater. Temperaturemonitoring devices shall be installed in the gas stream immediately before andafter the catalyst bed.

16. Pursuant to 40 CFR Part §60.615(b)(1)(i) the permittee shall keep up-to-date, readily


13

accessible records of the following data measured during the performance testing requiredin §60.614:

(a) The average temperature upstream and downstream of the catalyst bed for acatalytic incinerator, measured at least every 15 minutes and averaged over thesame time period of the performance testing, and

(b) The percent reduction of TOC determined in §60.614(b) achieved by theincinerator, or the concentration of TOC (ppmv, by compound) determined asspecified in §60.614(b) at the outlet of the control device on a dry basis correctedto 3 percent oxygen.

17. Pursuant to 40 CFR Part §60.615(c) the permittee shall keep up-to-date, readilyaccessible continuous records of the equipment operating parameters specified to bemonitored under §60.613(a) as well as up-to-date, readily accessible records of periods ofoperation during which the parameter boundaries established during the most recentperformance test are exceeded. Periods of operation during which the parameterboundaries established during the most recent performance tests are exceeded are, forcatalytic incinerators, all 3-hour periods of operation during which the averagetemperature of the vent stream immediately before the catalyst bed is more than28degrees Celsius (50 degrees Fahrenheit) below the average temperature of the ventstream during the most recent performance test at which compliance with §60.612(a) wasdetermined. The owner or operator also shall record all 3-hour periods of operationduring which the average temperature difference of the device during the most recentperformance test at which compliance with §60.612(a) was determined.

18. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, the permittee shallmaintain a record of test results from the testing requirements of §60.614 to showcompliance with specific condition 14. These records shall be maintained on site andshall be made available to Department personnel upon request.

19. Pursuant to 40 CFR Part §60.615(j) the permittee shall submit to the Departmentsemiannual reports of exceedances of monitored parameters recorded under §60.615(c).

Equipment Leaks - All Sources


14

20. Pursuant to 40 CFR Part §60.480 the facility is subject to applicable provisions of 40CFR Part 60, Subpart VV. These provisions are outlined in Specific Conditions 21through 23.

21. Pursuant to 40 CFR Part §60.482-1(a) the permittee shall demonstrate compliance withthe requirements of §60.482-1 through §60.482-10 for any equipment defined as anaffected facility. The permittee shall maintain a list of all affected facilities (i.e., pumps,compressors, valves, etc.) for sources subject to the provisions of §60.482-1 through§60.482-10.

22. Pursuant to 40 CFR Part §60.482-1(b) the permittee shall demonstrate compliance with§60.482-1 through §60.482-10 by review of records and reports, review of performancetest results, and inspection using the methods and procedures specified in §60.485. Thepermittee shall maintain records demonstrating compliance with applicable standards,monitoring requirements, test methods and procedures, and record keeping requirementsfor sources subject to Subpart VV. The records specified in this condition and in Specific Condition 23 shall be maintained on site and made available to Departmentpersonnel upon request.

23. Pursuant to 40 CFR Part §60.487(c) the permittee shall submit semi annual reports to theDepartment containing the following:

(a) Process unit identification.

(b) For each month during the semiannual period:

(1) Number of valves subject to the requirements of §60.482-7.(2) Number of valves for which leaks were detected.(3) Number of valves for which leaks were not repaired.(4) Number of pumps subject to the requirements of §60.482-2.(5) Number of pumps for which leaks were detected.(6) Number of pumps for which leaks were not repaired.(7) The facts that explain each delay of repair and, where appropriate, why a

process unit shutdown was technically infeasible.

(c) Dates of process unit shutdowns which occurred during the semiannual reportingperiod.

(d) Revisions of items reported in the semiannual report if changes have occurred


15

since the initial report or subsequent revisions to the initial report.

Storage Tanks

24. Pursuant to 40 CFR §60.110b the facility is subject to applicable provisions of 40 CFRPart 60, Subpart Kb. These provisions are outlined in Specific Conditions 25 through 30.

25. Pursuant to 40 CFR Part §60.110(a) & (b) formaldehyde tanks T-73, T-74, T-75, T-76, T-77, T-83, and T-84 and phenol tanks T-71 and T-72 are subject to applicable provisionsof 40 CFR Part 60, Subpart Kb. In accordance with the Monitoring of Operationrequirements of §60.116b (a) & (b), readily accessible records showing the dimension ofthe storage vessel and an analysis showing the capacity of the storage vessel shall bemaintained onsite and kept for the life of the source, period of storage, and maximum truevapor pressure of the true vapor pressure shall be maintained. Records to proveexemption shall be maintained on-site and made available to Department personnel uponrequest. (The tanks are exempt from the other provisions due to the capacity of the tanksand a true vapor pressure of less than 3.5 kPa.)

26. Pursuant to 40 CFR Part §60.6110b(a) methanol tank T-101 is subject to applicableprovisions of 40 CFR Part 60, Subpart Kb.

27. Pursuant to 40 CFR Part §60.112b methanol tank T-101 is equipped with an internalfloating roof with a double seal.

28. Pursuant to 40 CFR Part §60.113b the permittee shall perform all testing and proceduresrequired for facilities with storage tanks equipped with an internal floating roof asrequired by 40 CFR §60.113b (a).

29. Pursuant to 40 CFR Part §60.115b the permittee shall maintain records and furnishreports for facilities with storage tanks equipped with an internal floating roof as requiredby paragraph (a) of 40 CFR Part §60.116b. The facility shall keep copies of all reportsand records required by this section for at least 2 years.

30. Pursuant to 40 CFR Part §60.116b, the permittee shall keep copies of the followingrecords:

(a) All records required by §60.116b shall be kept for two years.

(b) Readily accessible records shall be kept showing the dimension of the storage


16

vessel and an analysis of the capacity.

(c) The facility shall maintain a record of the VOL stored, the period of storage, andthe maximum true vapor pressure of the VOL during the respective storageperiod.

(d) The Department shall be notified within 30 days if the maximum true vaporpressure of the liquid exceeds the maximum true vapor pressure value of thevolume range.

A copy of the records shall be maintained on-site and made available to the Departmentupon request.

Oxidizer Operation

31. Pursuant to §19.705 of Regulation 19 and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not exceed 80 pounds per hour of additional methanolto the inlet of the incinerator as supplemental fuel to ensure proper operation.


17

Table IList of Tanks

TankID

Description Volume TVP YearInstalled

Regulation Vent Termination

gallons psia

DT-1 Dowtherm A 8,000 <0.001 1996 Insignificant Atmosphere

T-10 Storage 1,000 <0.001 1996 Insignificant Atmosphere

T-11 PF Washwater Storage 28,000 <0.1 1996 Insignificant Atmosphere

T-12 PF Washwater Storage 28,000 <0.1 1996 Insignificant Atmosphere

T-13 UF Washwater Storage 28,000 <0.1 1996 Insignificant Atmosphere

T-14 PF Resin 28,000 <0.1 1996 Insignificant Atmosphere







T-25 PF Resin Storage 28,000 <0.1 1996 Insignificant Atmosphere


T-31 UF Resin Storage 28,000 <0.1 1996 Insignificant Atmosphere




T-35 Resin Storage, UF 28,000 <0.1 1996 Insignificant Atmosphere

T-36 Resin Storage, UF 28,000 <0.1 1996 Insignificant Atmosphere

T-41 Chilled Water 28,000 0.00 1996 Insignificant Atmosphere

T-42 UF Resin 28,000 <0.1 1996 Insignificant Atmosphere



TankID



gallons psia

18


T-44 UF-MDF Resin Storage 28,000 <0.1 1996 Insignificant Atmosphere

T-45 UF-MDF Resin Storage 28,000 <0.1 1996 Insignificant Atmosphere

T-46 UF SCAV Resin Storage 28,000 <0.1 1996 Insignificant Atmosphere

T-61 Wax Washwater 12,000 0.00 1996 Insignificant Atmosphere

T-62 TEA Storage 12,000 0.00 1996 Insignificant Atmosphere

T-63 Stearic Acid Storage 12,000 0.00 1996 Insignificant Atmosphere

T-64 Wax Emulsion Storage 20,000 0.00 1996 Insignificant Atmosphere

T-65 Wax Emulsion Storage 20,000 0.00 1996 Insignificant Atmosphere

T-66 Slack Wax Storage 20,000 0.00 1996 Insignificant Atmosphere

T-67 Slack Wax Storage 20,000 0.00 1996 Insignificant Atmosphere

T-68 Aqueous Ammonia Tank 9,400 15.0 1996 Insignificant Vapor Balance

T-71 Phenol Tank 28,000 0.1 1996 NSPSSubpart Kb

Scrubber

T-72 Phenol Tank 27,532 0.1 1996 NSPSSubpart Kb

Scrubber

T-73 Formaldehyde Tank 28,000 0.44 1996 NSPSSubpart Kb Inlet to

FormaldehydeProcess


FormaldehydeProcess


FormaldehydeProcess



TankID



gallons psia

19


FormaldehydeProcess

T-77 Formaldehyde Tank 80,000 0.44 1997 NSPSSubpart Kb

Inlet toFormaldehyde

Process

T-81 Sodium Hydroxide 0 0 1996 Insignificant Atmosphere

T-82 Potassium Hydroxide 0 0 1996 Insignificant Atmosphere


FormaldehydeProcess


FormaldehydeProcess

T-101 Methanol 250,000 2.5 1996 NSPSSubpart Kb

Atmosphere

V-12 Seal Water Storage 28,000 <0.1 1996 Insignificant Atmosphere


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SECTION V: INSIGNIFICANT ACTIVITIES

The following types of activities or emissions are deemed insignificant on the basis of size,emission rate, production rate, or activity in accordance with Group A of the InsignificantActivities list found in Regulation 18 and 19 Appendix A. Insignificant activity emissiondeterminations rely upon the information submitted by the permittee in an application dated08/28/98.

Description Category

Emergency Generator Regulation 19, Appendix A, Group A1.


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SECTION VI: GENERAL CONDITIONS

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.

2. Pursuant to A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, this permitshall not relieve the owner or operator of the equipment and/or the facility fromcompliance with all applicable provisions of the Arkansas Water and Air PollutionControl Act and the regulations promulgated thereunder.

3. Pursuant to §19.704 of the Regulations of the Arkansas Plan of Implementation for AirPollution Control (Regulation 19) and/or A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, the Department shall be notified in writing within thirty (30) days afterconstruction has commenced, construction is complete, the equipment and/or facility isfirst placed in operation, and the equipment and/or facility first reaches the targetproduction rate.

4. Pursuant to §19.410(B) of Regulation 19 and/or §18.309(B) of the Arkansas Air PollutionControl Code (Regulation 18) and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304and §8-4-311, construction or modification must commence within eighteen (18) monthsfrom the date of permit issuance.

5. Pursuant to §19.705 of Regulation 19 and/or §18.1004 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, records must be kept for fiveyears which will enable the Department to determine compliance with the terms of thispermit--such as hours of operation, throughput, upset conditions, and continuousmonitoring data. The records may be used, at the discretion of the Department, todetermine compliance with the conditions of the permit.


22

6. Pursuant to §19.705 of Regulation 19 and/or §18.1004 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, any reports required by anycondition contained in this permit shall be certified by a responsible official andsubmitted to the Department at the address below.

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

7. 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. The permittee shall notify the Department of the scheduled dateof compliance testing at least fifteen (15) days in advance of such test. Compliance testresults shall be submitted to the Department within thirty (30) days after the completedtesting.

8. 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

9. Pursuant to §19.303 of Regulation 19 and/or §18.1104 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, the equipment, controlapparatus and emission monitoring equipment shall be operated within their designlimitations and maintained in good condition at all times.


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10. Pursuant to §19.601 of Regulation 19 and/or §18.1101 of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, if the permittee exceeds anemission limit established by this permit, they shall be deemed in violation of said permitand shall be subject to enforcement action. The Department may forego enforcementaction for emissions exceeding any limits established by this permit provided thefollowing requirements are met:

a. The permittee demonstrates to the satisfaction of the Department that theemissions resulted from an equipment malfunction or upset and are not the resultof negligence or improper maintenance, and that all reasonable measures havebeen taken to immediately minimize or eliminate the excess emissions.

b. The permittee reports the occurrence or upset or breakdown of equipment (bytelephone, facsimile, or overnight delivery) to the Department by the end of thenext business day after the occurrence or the discovery of the occurrence.

c. The permittee shall submit to the Department, within five business days after theoccurrence or the discovery of the occurrence, a full, written report of suchoccurrence, including a statement of all known causes and of the scheduling andnature of the actions to be taken to minimize or eliminate future occurrences,including, but not limited to, action to reduce the frequency of occurrence of suchconditions, to minimize the amount by which said limits are exceeded, and toreduce the length of time for which said limits are exceeded. If the information isincluded in the initial report, it need not be submitted again.

11. Pursuant to A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, thepermittee shall allow representatives of the Department upon the presentation ofcredentials:

a. To enter upon the permittee's premises, or other premises under the control of thepermittee, where an air pollutant source is located or in which any records arerequired to be kept under the terms and conditions of this permit

b. To have access to and copy any records required to be kept under the terms andconditions of this permit, or the Act

c. To inspect any monitoring equipment or monitoring method required in thispermit

d. To sample any emission of pollutantse. To perform an operation and maintenance inspection of the permitted source


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12. Pursuant to A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, this permitis issued in reliance upon the statements and presentations made in the permit application.The Department has no responsibility for the adequacy or proper functioning of theequipment or control apparatus.

13. Pursuant to §19.410(A) of Regulation 19 and/or §18.309(A) of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, this permit shall be subject torevocation or modification when, in the judgment of the Department, such revocation ormodification shall become necessary to comply with the applicable provisions of theArkansas Water and Air Pollution Control Act and the regulations promulgatedthereunder.

14. Pursuant to §19.407(B) of Regulation 19 and/or §18.307(B) of Regulation 18 and A.C.A.§8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, this permit may be transferred. An applicant for a transfer shall submit a written request for transfer of the permit on aform provided by the Department and submit the disclosure statement required byArkansas Code Annotated §8-1-106 at least thirty (30) days in advance of the proposedtransfer date. The permit will be automatically transferred to the new permittee unless theDepartment denies the request to transfer within thirty (30) days of the receipt of thedisclosure statement. A transfer may be denied on the basis of the information revealedin the disclosure statement or other investigation or, if there is deliberate falsification oromission of relevant information.

15. Pursuant to A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311, this permitshall be available for inspection on the premises where the control apparatus is located.

16. 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.

17. Pursuant to Regulation 18 and 19 and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, this permit supersedes and voids all previously issued air permits for this facility.

APPENDIX E

APPENDIX B

APPENDIX C

Route To: FELICIA INMANAdministration

AIR DIVISION

INVOICE REQUEST FORM

(3-99)

Facility Name & Address:Borden Chemical, Inc.P. O. Box 1956Hope, Arkansas71802-1956

CSN: 29-0125 Permit No: 1590-AR-3

Minor Source Permit Description: MS

Initial Fee Calculations:

Minor Source = 3333($18.08)(TPY predominant pollutant, except CO)

No less than $500

Mod Fee Calculations:

Minor Source = 3333 ($18.08)(TPY increase predominant pollutant, except CO)

No less than $400

F = $400

Fee Amount: $400

Engineer: Derrick BrownDate: October 12, 2001

Public Notice

Pursuant to A.C.A. §8-4-203, and the regulations promulgated thereunder, the Air Division of theArkansas Department of Environmental Quality gives the following notice:

Borden Chemical, Inc. owns and operates a resin and formaldehyde production facility located at185 North Industrial Drive, Hope, Hempstead County, Arkansas. Permit #1590-AR-3 is beingissued to the facility to incorporate a increase in production, emission rates based on testing, andthe removal of a spray dry resin plant.

This facility is subject to regulations under the Arkansas Air Pollution Control Code (Air Code),the Arkansas Plan of Implementation for Air Pollution Control (SIP). The facility is also subjectto applicable provisions of 40 CFR Part 60 Subpart Dc - Standards of Performance for SmallIndustrial-Commercial-Institutional Steam Generating Units, Subpart Kb - Standards ofPerformance for Volatile Organic Liquid Storage Vessels, Subpart III - Standards ofPerformance for Volatile Organic Compound (VOC) Emissions from the Synthetic OrganicChemical Manufacturing Industry (SOCMI) Air Oxidation Process, and Subpart VV - Standardsof Performance for equipment Leaks of VOC in the Synthetic Organic Chemicals ManufacturingIndustry.

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

Citizens wishing to examine the permit application and staff findings and recommendations maydo so by contacting Rhonda Sharp, Information Officer. Citizens desiring technical informationconcerning the application or permit should contact Derrick Brown, Engineer. Both RhondaSharp and Derrick Brown can be reached at the Department's central office, 8001 National Drive,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 theHempstead County Public Library, Fifth & ElmStreets, Hope, Arkansas 71801 . This information may be reviewed during normal businesshours. Interested or affected persons may also submit written comments or request a hearing on theproposal, or the proposed modification, to the Department at the above address - Attention:Rhonda Sharp. In order to be considered, the comments must be submitted within thirty (30)days of publication of this notice. Although the Department is not proposing to conduct a publichearing, one will be scheduled if significant comments on the permit provisions are received. If ahearing is scheduled, adequate public notice will be given in the newspaper of largest circulationin the county in which the facility in question is, or will be, located.

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

Dated this

Randall Mathis Director

ADEQ MINOR SOURCE AIR PERMIT MINOR SOURCE AIR PERMIT Permit #: ... are located on the shell side....

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