Borden Chemical Fayetteville - Application 2004 (2600009)

The following are excerpts from the permit review by Michael Brandon dated 12/13/04 for permit R25:

Purpose of Application:

The purpose of the application is to come into compliance with the Hazardous Organic NESHAP (HON) and the Polymers & Resins (III) Amino/Phenolic Resins MACT by installing a new scrubber (CD-200) and routing various exhaust streams to the front end of the formaldehyde silver process. Two resin batch reactors (ID Nos. ES-BR1 and ESBR5) and associated support equipment have been removed from service.

New Equipment, Change in Emissions, and Regulatory Review:

There are no new emissions sources associated with the application. The new scrubber (ID NO. CD200) will be required to achieve 83 percent control efficiency for organic HAPs to comply with the Amino/Phenolic Resins MACT for the reactor batch process vents. The permit modifications are summarized below:

a. Scrubber control (ID No. CD33) for five rail car and tank truck loading racks (ID Nos . RLOAD1, RLOAD2, TLOAD1, RLOAD3 and TLOAD2, previously ES-RTLoad) will be removed and replaced as follows:

i. RLOAD1, RLOAD2, and TLOAD1 will be routed to front end of silver formaldehyde plants (ID Nos. FORM12 , and FORM3) as Group 1 transfer operations under HON.

ii. RLOAD3 and TLOAD2 (Group 2 transfer operations under HON) will be routed to the new scrubber (CD-200). However, no control is required.

b. Scrubber control (ID No. CD31) for 14 formaldehyde tanks and three methaform tanks (ID Nos. STORE1FORM1 through STORE1FORM14, and STORE 1MAF1 through SOTRE1MAF3, previously ES-Store1) will be removed and all emissions to front end of silver formaldehyde plant. The formaldehyde plant No. 3 raw column feed tank ES Store1RawFeed is listed as ID No. ISTOREA. It was determined to be an insignificant surge tank. The overflow vent tank for plant FORM12 (ID No. ES-Store1Overflow) will be listed as an insignificant activity (ID No. ISTORE1B) pending a review as to whether it receives process emissions from the formaldehyde plant. Emissions from both of these insignificant sources are slated to be routed back to the process.

c. The column raw feed tank for formaldehyde plants 1 and 2 (ID No. ESCRF) is not significant and has been determined to be a surge tank of insufficient size for regulations. It is listed in the insignificant activities list as ID No. ICFR

d. Five 50,000-gallons formaldehyde tanks (ID Nos. MOSTORE1A through MOSOTRE1E) and a 25,000-gallons formaldehyde tank (ID No. MOSOTRE2) previously listed as ID Nos. ES-MOStore1 and ES-MOStore2 currently controlled by scrubber CD-35 will be routed to the new scrubber (CD-200) and the existing scrubber removed

e. Dilute tank for start-up (ID Nos. ES-DTS) is an uncontrolled surge tank and is listed as an insignificant activity as IDTS. It is slated for control by the new scrubber (CD-200).

f. The uncontrolled distillate tank for the formaldehyde plant No. 4 process (ID No. ES DTP)will be listed as a surge tank and insignificant activity (ID No. IDTP) pending determination as to whether process emissions are routed through this tank. It is slated for control by the new scrubber (CD-200).

g. Three formaldehyde weigh tanks associated with batch reactors (ID Nos. ES-FWT) are listed as FWTBR2 and FWBR3) are currently controlled by scrubbers CD-29 and CD-14, respectively. They will be controlled by existing scrubbers in series the new scrubber CD 200. Scrubber CD-25 is listed as optional and may be removed.

h. Urea-formaldehyde batch reactor No. 2. (ID No. ES-BR2) is currently controlled by existing scrubber CD-29 and will be routed to the new scrubber (CD-200) in series or CD29 may be removed. It is listed as ID No. BR2)

i. Urea-formaldehyde batch reactor No. 3. (ID No. ES-BR3) is currently controlled by existing scrubber CD-14 and will be routed to the new scrubber (CD-200) in series. It is listed as ID No. BR3)

j. Phenol-formaldehyde batch reactor No. 4. (ID Nos. ES-BR4) is currently controlled by existing scrubber CD-19 and will be routed to the new scrubber (CD-200) in series. It is listed as ID No. BR4)

k. R-2 and R-3 Vacuum seal water tank (ID Nos. ES-VSWT2) is currently controlled by existing scrubber CD-39 and will be routed to the new scrubber (CD-200) in series. It is listed as ID No. VST2/3 and may be classified as a non reactor process vent pending determination of applicability status for the receipt of batch reactor process vent gasses.

l. Distillate receiving tank (ID No. BR4DRT) associated with batch reactor no. 4. p[resently uncontrolled will be routed to the new scrubber CD200.

m. RTU mixing unit and wash water tank (ID Nos. ES-103 and ES-WWT) will be listed as ES103 and IWWT. ES103 is currently listed as controlled by a scrubber (ID No. CD104) and will be routed to the new scrubber (CD-200) in series with CD104. The wash water tank is listed as an insignificant activity.

Jessica Idzerda, registered professional engineer in the State of North Carolina, certified the new control device (ID No. CD200). No operating parameters were provided. MACT compliance testing will be conducted to ensure compliance and establish operating parameters.