Borden Chemical Fayetteville (2600009)
Notes from DAQ meeting with Borden Chemical
January 11, 2005
(Notes prepared by Tom McKinney)
Attendees from Borden Chemical: Craig Pryzgoda, Michelle Serrian, Bud Lafferty, and Rick Springer.
Attendees from Trinity Consultants: Jessica Idzerda, Paul Greywall
Attendees from DAQ: Michael Brandon, Mike Aldridge, Don van der Vaart, Willam Willets, Jay Evans, Betty Gatano, and Tom McKinney
1. In 2003, the facility contacted DAQ and indicated that they had, or were about to, exceed the Title V and Title III threshold levels for HAPs. As a result, a 2D .0300 permit with Title V classification was issued in October 2003, with general requirements to comply with the HON rule and the Resins MACT.
2. During the past year the facility has been submitting quarterly reports on the status of their efforts to achieve compliance. The DAQ recommended that the key information contained in the status reports be submitted as an addendum to their Title V application.
3. The facility expressed concern about the Title V permit being issued before they have achieved compliance with the MACT standards. However, the DAQ indicated that the EPA looks favorable upon a Title V permit that specifies corrective actions, as opposed to holding a 2Q .0300 permit with no clear indication of the strategies to achieve compliance.
4. The facility indicated that they expect to achieve compliance with the HON by the end of April 2005. They expect to achieve compliance with the Resins MACT by the end of July 2005.
5. The DAQ is reviewing file records to determine if the facility should have requested a PSD avoidance condition for VOCs in 1989. The DAQ will be assessing how to correct any such permit deficiency.
6. The facility conducted modeling for formaldehyde several years ago in accordance with 2D .1100. However, since that time they have determined that the emission inputs used in the modeling were both incomplete and inaccurate. As a result, after the facility achieves compliance with the MACT standards they will be required to conduct facility-wide formaldehyde modeling that accurately reflects all of the emission sources and rates.
7. The facility is expecting a new business opportunity in the near future with a change in equipment that will increase the actual emissions of formaldehyde from the resins reactor process. This change could potentially trigger a toxics evaluation per 2D .1100. The DAQ and the facility will review the inputs to the previous modeling, the current accounting of facility-wide formaldehyde emission sources and rates, and the increase in actual emissions from the proposed modification to determine if any interim modeling is needed prior to the modeling to be conducted after compliance with the MACT standards.
8. The facility presented their request that DAQ allow the use of a catalyst monitoring procedure, similar but not identical to that specified in the Miscellaneous Organic NESHAP, as a substitute for the monitoring of the temperature change across catalyst bed of the control device at formaldehyde plant no. 4. The requirement to monitor temperature change is specified in both the HON rule and NSPS Subpart III . The DAQ will study this issue further and may allow the catalyst monitoring procedure proposed by the facility to be used as “supplemental monitoring” in addition to the existing temperature monitoring requirement.