Public Notice
PROPOSED PART 70 AIR OPERATING PERMIT MODIFICATION/RENEWAL
RHODIA, INC. - SULFURIC ACID PLANT AI Number 1314
VIEW ATTACHMENTS FOLLOWING PUBLIC NOTICE
The LDEQ, Office of Environmental Services, is accepting written comments on the Part 70 Air Operating Permit modification/renewal for Rhodia, Inc., 1275 Airline Hwy, Baton Rouge, Louisiana 70805 for the Sulfuric Acid Plant. The facility is located at 1275 Airline Hwy, Baton Rouge, East Baton Rouge Parish.
Rhodia, Inc. requested a permit modification to include the following changes.
As part of Rhodia’s consent decree for the Baton Rouge facility, Rhodia will install packed bed scrubbers on Sulfuric Acid Unit No. 1 and Unit No. 2 to control SO2 emissions, which will be reduced by more than 10,000 TPY by the completion of Phase III of the project. Also as part of the consent decree, the Environmental Protection Agency (EPA) agreed to allow the Sulfuric Acid Plant to undergo an expansion project. This project will allow the facility to increase its total Sulfuric Acid (H2SO4) production from 2,200 tons/day to 2,800 tons/day. Specifically, the capacity of Sulfuric Acid Unit No.1 (EPN 3) will increase from 700 tons/day to 900 tons/day of sulfuric acid, and the capacity of Sulfuric Acid Unit No. 2 (EPN 2) will increase from 1,500 tons/day to 1,900 tons/day. The capacity increase will be accomplished with a series of debottlenecking projects.
In addition to the emission changes resulting from the abatement/debottlenecking project, Rhodia is requesting the following changes with this permit renewal/modification.
· Create a new emissions cap, Cap-Comb, for overall combustion emissions from the Rental Boiler, Sulfuric Acid Unit No. 1, and Sulfuric Acid Unit No. 2;
· Create Process Groups to better manage speciation of toxic air pollutants;
· Add Treatment Services Sumps (EPN M3) into the Title V Permit;
· Incorporate requirements of Rhodia’s consent decree into the Title V Permit;
· Reconcile certain emission rates based on new guidance regarding rounding and maximum hourly emission rates;
· Replace Unit 1 cooling tower (EPN M1b) due to structural integrity concerns. The new tower is of similar design and identical capacity and emissions;
· Revise PM10 emissions to include sulfuric acid mist emissions;
· Add a new caustic tank as an insignificant activity;
· Incorporate an insignificant case-by-case activity (approved June 2008) into the permit’s GCXVII emissions;
· Revise metals emission rates for consistency with the BIF permit. This change results in 9 TAP metals being permitted above their respective minimum emission rates (MERs) per LAC 33:III.Chapter 51;
· Revise emissions for GCXVII activity regarding stack washings;
· Incorporate three new permit shield requests; and
· Reconcile hydrogen sulfide emissions from the sulfur feed tank in light of data collected at a similar Houston facility.
The revised application submitted on April 8, 2009 adjusted projected sulfuric acid mist emissions and incorporated an updated PSD analysis.
This permit contains a permit shield.
Estimated emissions in tons per year are as follows:
|
Pollutant
|
Before
|
After
|
Change
|
|
PM10
|
7.13
|
54.52*
|
+47.39
|
|
SO2 (Phase I)
|
12,482.61
|
12449.35
|
-33.26
|
|
SO2 (Phase II)
|
12449.35
|
4725.98
|
-7723.37
|
|
SO2 (Phase III)
|
4725.98
|
1077.79
|
-3648.19
|
|
NOx
|
284.63
|
115.58
|
–169.05
|
|
CO
|
109.08
|
95.43
|
–13.65
|
|
VOC
|
25.84
|
26.16
|
+0.32
|
|
*Includes sulfuric acid mist
|
|
Phase I is effective from issuance of this permit through December 31, 2010.
|
|
Phase II is effective from January 1, 2011 through April 30, 2012.
|
|
Phase III becomes effective on May 1, 2012.
|
Total HAP emissions are capped under 8.92 TPY.
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., Thursday, November 12, 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 application, addendums, proposed permit and statement of basis are available for review at the LDEQ, Public Records Center, Room 127, 602 North 5
th 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.
An additional copy may be reviewed at the East Baton Rouge Parish, Scotlandville Branch, 7373 Scenic Highway, Baton Rouge, LA 70807.
Inquiries or requests for additional information regarding this permit action should be directed to Scott J. Templet, LDEQ, Air Permits Division, P.O. Box 4313, Baton Rouge, LA 70821-4313, phone (225) 219-3059.
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).
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 1314, Permit Number 0840-00033-V2, and Activity Number PER20070006.
Scheduled Publication Date: October 8, 2009
Attachments: