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Statement of Basis

Title V Renewal
AKZO Nobel Functional Chemicals LLC
503-5009
Background
Akzo Nobel Functional Chemicals LLC is a Synthetic Organic Chemical Manufacturing
Industry facility located near Axis, Alabama that manufactures several types of
chemicals. The facilitys main product is Carbon Disulfide (CS2). Akzo ships CS2
offsite in railcars, drums, and iso-containers. The facility was originally constructed in
the mid-1950s, and has been modified over the last 50+ years. The facility is a major
source with respect to PSD, Title V, and the MACT/NESHAP standards. The main
pollutant emitted from this facility is SO2. The main source of SO2 emissions are from
the Sulfuric Acid and the Carbon Disulfide Plants. Modifications since the PSD
regulations were adopted have not been significant for SO2 or any other criteria
pollutants. PSD synthetic minor limits have been accepted for HAPs, PM and SO2 by the
company.
Basis for limits and monitoring
Combustion Systems
This facility has a 12 MMBTU/hr process heater (CX-1), a 25.3 MMBTU/hr process
boiler (CX-3), a 32.8 MMBTU/hr backup boiler (CX-9), and two 35 MMBTU/hr
furnaces (CS-3a and CS-3b) used in the manufacture of carbon disulfide. Theses sources
are subject to the Boilers and Process Heaters MACT (40 CFR Part 63 Subpart
DDDDD). Since these units meet the definition of an existing large and limited use
gaseous fuel unit; these units are subject only to initial notification requirements. An
initial notification for these units was submitted to the Department in March 2005. CX-9
is subject to the New Source Performance Standard for steam generating units (40 CFR
Part 60 Subpart Dc). However, since this unit fires only natural gas, it is only subject to
initial notification requirements, and recordkeeping concerning the amount of gas fired
daily. An initial notification for CX-9 was submitted to the Department in September
1994. CX-1 and CX-3 were constructed prior to the PSD regulations, and are therefore
subject only to the state SO2, opacity, and particulate regulations. CX-9, CS-3a, and CS3b are also subject to the state opacity regulations and each have synthetic minor (PSD)
emission limits for SO2 and PM of 2.7 lbs/hr and 1.0 lbs/hr respectively. Since all of
these units are restricted to firing only natural gas, and the expected emissions are well
below the allowables, no periodic monitoring is deemed necessary.
Sulfuric Acid Plant
The Sulfuric Acid Plant is a continuous contact process, which was originally constructed
in 1956, and now operates with a capacity of 850 tons per day. Because of its age, this
unit is subject to the state regulations for existing sulfuric acid plants found in 335-3-5-

.02 (1)(a), which limits emissions to 27 lbs SO2/ton of 100% Sulfuric Acid produced, 0.5
lbs H2SO4 mist/ton of 100% Sulfuric Acid produced, and 0.2 lbs SO3/ton of 100%
Sulfuric Acid produced. This regulation also requires a Continuous Emissions Monitor
(CEM) to measure the SO2 emissions. No further periodic monitoring should be
necessary for SO2. For H2SO4 and SO3, Akzo has proposed annual stack testing of the
unit to indicate compliance. Recent stack testing (2006) has indicated that actual
emissions are well below the regulatory limits, therefore, the Department concurs that
annual stack testing would be appropriate periodic monitoring. The Compliance
Assurance Monitoring (CAM) Rule is applicable to this unit for the Brinks Mist
Eliminator control equipment. The Department concurs with Akzos CAM plan which
states that CEMs and annual stack testing required by the state regulations for existing
sulfuric acid plants (335-3-5-.02(2)) fulfills the requirements of the CAM. The fugitive
emissions associated with this process are insignificant. The unit is subject to the state
opacity standard of 20%, as determined by a six-minute average.
Crystex Production Unit
The Crystex Production unit was constructed in 1975 and produces Crystex, which is
used as an additive for several different products. This unit has accepted emission limits
to remain synthetic minor for PSD modification. The unit has four baghouses (CX-5,
CX-6, CX-7, and CX-8) which have a combined PM limit of 3.6 lbs/hr. Akzo inspects
these baghouses for visible emissions on a weekly basis while the plant is operating. The
Crystex unit also has a vent (CX-4) which vents to the incinerator (CS-1) in the CS2
plant. Although this vent does not contain SO2, the sulfur compounds it contains are
burned in CS-1 and converted to SO2. Therefore, Akzo has accepted limitations of the
amount of sulfur compounds that it may vent to CS-1. Through testing, Akzo has
established that the Stripper Bottoms Temperature can be an indicator of sulfur
emissions, and has established a range of 125C to 165C in which the sulfur emissions
are less than the allowable from the unit. The facility currently monitors the temperature
of the stripper bottoms while the unit is in operation, and the temperatures are taken at
least once every two hours. The Department concurs that this should be sufficient
periodic monitoring. The fugitive emissions for this process are insignificant. This unit
is subject to the state opacity standard of 20%, as determined by a six-minute average.
CS2 Production Unit
The CS2 production unit was originally constructed in 1953, and also contains a Claus
sulfur recovery unit, which converts the sulfurous off-gases back to sulfur. The
remaining off-gases are then incinerated in a Tail-gas Incinerator (CS-1). Because the
CS2 production unit was constructed prior to the adoption of the PSD regulations, it has
no specific limits on SO2 emissions. Since there are no limits for SO2, periodic
monitoring is not necessary for this unit. This unit is, however, subject to the Hazardous
Organic NESHAP (HON) as listed in 40 CFR Part 63 Subpart F, G, and H. This unit has
a Group II process vent and a Group I transfer rack (railcar loading system) that are
subject to Subpart G. The CAM Rule is applicable to this unit for the condenser used to
control the Group 1 CS2 transfer rack (railcar loading system). However, the unit would

comply with the CAM requirements by meeting the requirements of the HON. The CS2
Drum Loading and Iso-container Loading facilities shall load a maximum of 5,148,000
and 7,844,570 gallons of CS2, respectively during any consecutive twelve-month period.
The fugitive emissions from this unit are insignificant. This unit is subject to the state
opacity standard of 20%, as determined by a six-minute average.
NaSH Production Unit
The NaSH manufacturing unit was originally constructed in 2001 and operates as a
continuous process at a maximum rated capacity of 18,000 tons per year. Before entering
the Claus unit a portion of the H2S tailgas from the CS2 production unit is used as raw
material and combined with caustic in a reactor for the production of NaSH. The process
is designed to be closed loop and has no atmospheric emission points. Process vents
from the reactor and product storage tanks are returned to the existing Claus sulfur
recovery unit. SO2 emissions from the Claus process are reduced because H2S diverted
to the NaSH process is consumed during the reaction. Assuming the NaSH units high
production rate sulfur dioxide emissions from the CS2 Plant Incinerator are reduced by
823 tons annually. The fugitive emissions from this process are deemed insignificant.
Since the expected emissions associated with this unit are considered insignificant, no
periodic monitoring is necessary. This unit will be added to the Additional Processes
portion of Akzos Title V. The unit is subject to the state opacity standard of 20%, as
determined by a six-minute average.
Storage Tanks
The CS2 production unit has seven large storage tanks that are subject to the HON as
listed in 40 CFR Part 63 Subpart G. Since these tanks are designated as Group 1 storage
tanks, and store a liquid with a vapor pressure of less than 76.6 kilopascals, Akzo has
elected to control emissions from these tanks by operating and maintaining tanks with a
fixed roof and an internal floating roof. Therefore, Akzo shall comply with the periodic
monitoring, recordkeeping and reporting requirements, and control technology
requirements found in Subpart G for internal floating roof tanks.
Emergency Generators and Firewater Pumps
The facility has two emergency diesel generators (the CS2 Generator and the CTX
Generator) and three emergency diesel fire water pumps (East, Middle, and West) that
have the potential to fall under 40 CFR Part 63, Subpart ZZZZ.
The CS2 Generator (8EG631) is an existing (manufactured prior to 12/19/2002 for > 500
hp) 600 brake horse power (hp) compression ignition (CI) 4-stroke Reciprocating Internal
Combustion Engine (RICE) and is used for emergency purposes only. According to 40
CFR 63.6590(b)(3)(iii), since the CS2 generator is an existing emergency stationary
RICE with a site rating of more than 500 break HP located at a major source of HAP
emissions, the generator is not subject to 40 CFR Part 63 Subpart ZZZZ or Subpart A.
However, under 40 CFR 63.6675, the definition of an Emergency Stationary RICE

states that all emergency stationary RICE must comply with the requirements specified
in 63.6640(f) in order to be considered emergency stationary RICE. Therefore, the
Area 19 generator is subject to 40 CFR 63.6640(f).
The CTX Generator (6EG412) is an existing (manufactured before 6/12/2006 for < 500
hp) 465 brake horse power (hp) compression ignition (CI) 4-stroke Reciprocating Internal
Combustion Engine (RICE) and is used for emergency purposes only. The East
Emergency Fire Water Pump (1P101E), the Middle Emergency Fire Water Pump
(1P101E), and the West Emergency Fire Water Pump (1P101W) are existing 482 brake
horse power (hp) compression ignition (CI) 4-stroke Reciprocating Internal Combustion
Engines (RICE) and are used for emergency purposes only. According to 40 CFR
63.6602, an existing stationary RICE with a site rating of equal to or less than 500
brake hp located at a major source of HAP emissions must comply with the emission
limitation in Table 2c to this subpart. According to Table 2c, for Emergency
Stationary CI RICE, the following requirements must be met: a) Change oil and filter
every 500 hours of operation or annually, whichever comes first; b) Inspect air cleaner
every 1,000 hours of operation or annually, whichever comes first; and c) Inspect all
hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.
Both emergency generators and all three fire water pumps are subject to ADEM Admin.
Code 335-3-4-.01(1)(a and b) which states the pumps may not emit an opacity greater
than 20%, as determined by a 6-minute average, except for one 6-minute period per 60minute period where they are not allowed to emit an opacity greater than 40%.
Additional Processes
The Monochloroacetic Acid (MCA) process was constructed in 1994, and takes ~100%
MCA and dilutes it to ~80% using water. The new solution is shipped to offsite
customers. Since the emissions from the MCA production process will be less than 5.0
tpy for particulates and VOCs, the emissions for the MCA plants can be classified as an
insignificant activity as defined in ADEM Admin Code 335-3-16-.01(o). However
uncontrolled HAP emissions are greater than 1,000 lbs/yr; therefore the MCA production
unit can not be added to Akzos Trivial and Insignificant Activities list, and is required to
vent to the process scrubber.
The Sulfur Chlorides unit began operation in 1977 and produces sulfur monochloride and
sulfur dichloride in a series of batch reactors. Because of the low amount of potential
emissions from the Sulfur Chlorides units, this unit does not have specific emission
limits. Recordkeeping and reporting requirements for these units are listed in the Title V
permit. The additional processes units are subject to the state opacity standard of 20%, as
determined by a six-minute average.

Recommendations

I recommend that Akzo be issued a Title V permit with the attached requirements.

___________________
Adam D. George
Industrial Chemicals Section
Chemical Branch
Air Division
Alabama Dept. of Environmental Management

October 5, 2012
Date

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