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Public Notice

PROPOSED PART 70 AIR OPERATING PERMIT MAJOR MODIFICATION AND USE OF NITROGEN OXIDE (NOx) CREDITS

BASF CORPORATION / GEISMAR SITE, SPECIALTY AMINES COMPLEX AI Number 2049

VIEW ATTACHMENTS FOLLOWING PUBLIC NOTICE

The LDEQ, Office of Environmental Services, is accepting written comments on a proposed Part 70 air operating permit major modification and use of nitrogen oxide  (NOx) credits for BASF Corporation, P. O. Box 457 Geismar, LA 70734-0457 for the Specialty Aminex Complex. The facility is located at 8404 Highway 75, Geismar, Ascension Parish.
 
In this proposed permit modification, BASF Corporation requested to install and operate a new Methyl Amines (MA) Plant, the Amines Plant VII, within the Specialty Amines Complex. The current Specialty Amines Complex Part 70 Operating Permit will be modified by adding new emission sources and modifying existing emission sources associated with the proposed MA Plant. The proposed changes are as follows:
 
1.         To add an additional 8,200 gpm recirculating cooling tower, MA Cooling Tower (Emission Point No. (EPN) AME13). 
2.         To add a fugitives emission source, MA Process Fugitives (EPN AME14).
3.         To add a loading source, MMA/DMA/TMA Loading (EPN AME15).
4.         To add a two-stage T-6500/T-6600 Absorber/Desorber recovery system so that MA reactants and products can be recovered from MA process offgas and certain MA tank vents. The recovered materials will be recycled back to the MA Synthesis Reactor. 
5.         To add a Dewatering Product Recovery System which recovers methanol and recycles it back to the MA Synthesis Reactor.
6.         To use the existing 28,000 gallon Pressure Vessel TK-1201 (EPN AME02(a)) as the ammonia feed tank for the MA process. This tank, which is already in ammonia service in the Specialty Amines Unit, is vented to the Amines Waste Destruct System (WDS) for air emissions control.
7.         To use the existing 57,000 gallon storage tank, TK-799, which is physically located in BASF’s Diols Unit, as the Methanol Feed Tank for the MA process. This tank will remain as part of the Diols Title V permit.
8.         To add a 33,000 gallon storage vessel, the MA Plant Mixed Amines Tank D-6840 (EPN AME04(c1)) to store recycled MA products prior to their being recycled to the Synthesis Reactor. This vessel is vented to the T-6500 Absorber Recovery System.
9.         To use the existing 30,500 gallon Pressure Vessel TK-1203 (EPN AME02(b)) as the DMA Run Tank for the MA process unit. 
10.       To use the existing 30,500 gallon Pressure Vessel TK-1205 (EPN AME02(c)) as the TMA Product Tank for the MA Process unit. 
11.       To use the existing 63,000 gallon storage tank, D-695, which is physically located in BASF’s Diols Unit, as the MMA Product Tank for the MA Process unit. 
12.       To supply the required steam to operate the MA process unit from existing boilers and steam generating units from BASF’s Utilities Plant.
 
The Specialty Aminex Complex is located in Ascension Parish which is designated as non-attainment for ozone. The project associated emissions increase for NOx is above the Non-Attainment New Source Review (NNSR) trigger level of 25 tons per year (TPY). Consequently, a NOx NNSR 5-year contemporaneous netting analysis was performed. The netting analysis revealed that the net increase in NOx emissions during the 2007 – 2011 contemporaneous period exceeded the NNSR trigger value of 25 TPY, resulting in the applicability of NNSR regulations. Therefore, BASF shall implement lowest achievable emission rate (LAER) technology for new units and modified existing units where an increase in NOx emissions will occur as a result of the MA project.  However, since no new units are being added and since no existing units are being modified that will have an increase in NOx emissions, LAER will not apply. In addition, BASF shall use internal offsets at a ratio of 1.3 to 1 from the Utilities No. 3 Boiler (EPN UTL15) which is currently permitted under Part 70 Operating Permit No. 2564-V3 issued on May 29, 2009; BASF installed dry low NOx burners on the No. 3 Boiler and banked NOx credits in a submittal dated March 30, 2007.
 
BASF Corporation proposes to withdraw emission reduction credits (ERC) of NOx from the LDEQ Emission Reduction Credits Banking System. The total estimated credit emissions withdrawn in tons per year (TPY) are as follows.
 
 
NOx Balance Before
NOx Offset
NOx Balance After
Total (tons NOx)
138.8
66.7
72.1
 
Estimated emissions in tons per year for the Specialty Amines Complex are as follows:
 
Pollutant
Before
After
Change
PM10
3.20
4.00
+ 0.80
SO2
0.15
0.14
- 0.01
NOX
23.13
21.77
- 1.36
CO
25.50
24.36
- 1.14
VOC*
16.14
25.79
+ 9.65
                
A technical review of the working draft of the proposed permit was submitted to the facility representative and the LDEQ Surveillance Division. Any remarks received during the technical review will be addressed in the “Worksheet for Technical Review of Working Draft of Proposed Permit”.  All remarks received by LDEQ are included in the record that is available for public review.
 
Written comments, written requests for a public hearing or written requests for notification of the final decision regarding this permit action may be submitted to Ms. Soumaya Ghosn at LDEQ, Public Participation Group, P.O. Box 4313, Baton Rouge, LA 70821-4313. Written comments and/or written requests must be received by 12:30 p.m., Wednesday, October 21, 2009.  Written comments will be considered prior to a final permit decision.
 
If LDEQ finds a significant degree of public interest, a public hearing will be held. LDEQ will send notification of the final permit decision to the applicant and to each person who has submitted written comments or a written request for notification of the final decision.
 
The permit application updated with all additional information received, proposed draft permit, and statement of basis are available for review at the LDEQ, Public Records Center, Room 127, 602 North 5th Street, Baton Rouge, LA. Viewing hours are from 8:00 a.m. to 4:30 p.m., Monday through Friday (except holidays). The available information can also be accessed electronically on the Electronic Document Management System (EDMS) on the DEQ public website at www.deq.louisiana.gov.
 
Additional copies may be reviewed at the Ascension Parish Library-Gonzales Branch, 708 South Irma Blvd, Gonzales, LA and the Iberville Parish Library-East Iberville Branch, 5715 Monticello Street, St. Gabriel, LA.
 
Inquiries or requests for additional information regarding this permit action should be directed to Kyle A. Prestenbach, LDEQ, Air Permits Division, P.O. Box 4313, Baton Rouge, LA 70821-4313, phone (225) 219-3132.
 
Persons wishing to be included on the LDEQ permit public notice mailing list or for other public participation related questions should contact the Public Participation Group in writing at LDEQ, P.O. Box 4313, Baton Rouge, LA 70821-4313, by email at deqmaillistrequest@la.gov or contact the LDEQ Customer Service Center at (225) 219-LDEQ (219-5337).
 
Permit public notices including electronic access to the proposed permit and statement of basis can be viewed at the LDEQ permits public notice webpage at www.deq.louisiana.gov/apps/pubNotice/default.asp and general information related to the public participation in permitting activities can be viewed at www.deq.louisiana.gov/portal/tabid/2198/Default.aspx.
 
Alternatively, individuals may elect to receive the permit public notices via email by subscribing to the LDEQ permits public notice List Server at http://www.doa.louisiana.gov/oes/listservpage/ldeq_pn_listserv.htm.
 
All correspondence should specify AI Number 2049, Permit Number 2028-V4, and Activity Number PER20090004.
 
Publication date: September 16, 2009 - The Advocate
                         September 18, 2009 - Gonzales Weekly Citizen

Attachments:

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