BOBBY JINDAL

GOVERNOR

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PEGGY M. HATCH

SECRETARY

Dr. Al Armendariz, Administrator

US EPA Region 6 (6-RA)

1445 Ross Avenue, Suite 1200

Dallas, TX 75202-2733

RE:

DEPARTMENT OF ENVIRONMENTAL QUALITY

ENVIRONMENTAL SERVICES

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State of Louisiana Request for Redesignation and Maintenance Plan

Addendum to Appendix F: RACT Determinations

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Dear Dr. Armendariz:

As per your request, the department has prepared an addendum to Appendix F which outlines the

specific facilities that have rule applicability issues for State Implementation Plan purposes. The

addendum addresses all facilities and the rule applicability as it relates to LAC 33:I1I Chapters

21 and 22.

It is our understanding that this document will help your staff to finalize the technical support

document that will accompany the ·final draft ofthe Federal Register notice which will propose

to redesignate the Baton Rouge Ozone Nonattaimnent Area as an attaimnent area for the 1997 8-

hour Ozone Standard.

If you or your staff have questions concerning this submittal, please contact Timothy Bergeron,

Air Permits Division, at (225) 219-3410 or timothy,bergeron@la,gov.

Sincerely,

c: Guy Donaldson, EPA Region 6

Date:+-.l-+IoAAl4"'-"'I--'*'-+--=---'- ~OtJ

Post Office Box 4313' Baton Rouge, Louisiana 7082t-4313· Phone 225-2t9-3t81 • Fax 225-2t9-3309

www;dea.louisiana.~ov
LOUISIANA DEPARTMENT OF ENVIRONMENTAL QUALITY

Addendum to Appendix F

Redesignation and Maintenance Plan

Timothy Bergeron

5/16/2011
Appendix FAddendum

Summary of VOC and NOx RACT for Certain Facilities

Appendix F is a summary of RACT rule applicability for each major source of NOx and VOC in the

5 parish Baton Rouge area. The table lists each RACT rule that is applicable to sources of 25 tons per

year of NOx and/or VOC. The table includes:

• each facility's permitted tons per year of NOx and/or VOC,

• which state RACT rules apply to the facility,

• the parish where the facility is located, and;

• the agency interest number which is an identification number given to each permitted

facility in Louisiana.

Facilities that are major sources of NOx or VOC that are not subject to state RACT rules are

further explained in the following pages.

2
vae Major Sources with comments

Cora Texas Manufacturing Co., AI 1306

• Cora Texas is a sugar mill in Iberville Parish that only operates during the months of OctoberJanuary and not during the traditional ozone season. The main sources of VOC at this facility are

from the combustion of natural gas and baggasse and storage tanks. The storage tanks are

subject VOC RACT rule LAC 33:111.2103.

PCS Nitrogen Fertilizer LP - Geismar Agricultural Nitrogen & Phosphate Plant. AI 3732

• PCS Nitrogen manufactures fertilizer products. The source of VOC emissions at this facility is

from the combustion of natural gas.

BASF Corp - Port Allen Works, AI 9495

• BASF produces alumina catalyst. The catalyst production process includes 4 ball activators

where acetic acid is added. When activated, the acetic acid is released as VOe. These 4 ball

activators are permitted under a special VOC emissions cap that limits the total emissions that

may be emitted. Each ball activator is permitted to emit a maximum of 76.11lb/hr.

Cumulatively the ball activators are permitted to emit an average of 16.20 Ib/hr and 70.96 tpy.

Throughput of product material containing acetic acid is limited to 8.40 MM Ibs/yr. The

concentration of the VOC emissions is less than 3,000 ppm. LAC 33:111.2115.H.d exempts sources

with VOC concentrations less than 3000 ppm because they are too dilute to reasonably control.

It is cost prohibitive for more VOe's to be emitted than necessary.

Petroleum Fuel & Terminal Co - Port Allen Terminal. AI 19338

• The Port Allen Terminal stores and loads heavy material, such as asphalt, that because of its

vapor pressure is not subject to Louisiana's VOC loading or marine loading rules. Currently this

facility is permitted to emit 25.01 tpy ofVOe. The permit is in the process of being modified to

reduce VOC emissions to 19.36 tpy. Once the permit is modified this facility will no longer be a

VOC major source.

EDO Specialty Plastics - Perkins Road Facility, AI 22750

• EDO is a fiberglass composite pipe manufacturing facility. This facility's VOC emissions are

controlled by meeting the requirements of 40 CFR 63 Subpart WWWW for reinforced plastics

composite production.

East Baton Rouge Parish North Landfill, AI 31128

• EBR Parish North Landfill is a municipal solid waste landfill whose VOC emissions are regulated

by 40 CFR 60 Subpart WWW and 40 CFR 63 Subpart AAAA.

3
Air Liquide Large industries US LP - Geismar, AI 31513

• Air Liquide operates a cogen unit. The main source of the facility's VOC emissions is from the

combustion of natural gas in the cogen unit.

Dow Chemical Co - Plaquemine Cogeneration Plant. AI 85652

• Dow Chemical operates 4 cogen units. The main source of the facility's VOC emissions is from

the combustion of natural gas in the cogen units.

Genesis Crude Oil LP - Truck Loading Facility. AI 3991

• Genesis is subject to RACT rule LAC 33:111.2103.

North Burtville Field Facility - North Burtville Field. AI 138716

• North Burtville is an oii and gas production facility. This facility's VOC emissions are controlled by

meeting the requirements of 40 CFR 63 Subpart HH.

4
NOx Major Sources with comments

Cora Texas Manufacturing Co, AI 1306

• Combustion sources at this facility do not operate during the traditional ozone season, The

facility is a sugar mill that operates in October - January,

Rhodia Inc, AI 1314

• NOx emissions from combustion sources at this facility are regulated by 40 CFR 60 Subpart Db,

UOP LLC - Baton Rouge Plant. AI 1413

• UOP is an alumina production facility. Sources of NOx include 2 spray dryers and a calciner.

After a review of STAPPAIALAPCO's Controlling Nitrogen Oxides Under the Clean Air Act: A

Menu of Options, the CARB NOx control database, and a summary of state NOx regulations at

hltp:llwww,epa,gov/ttn/naags/ozone/ozonetech/statenoxregs518,pdf it has been determined that

RACT controls are not available for these sources,

Rubicon LLC - Geismar Plant, AI 1468

• The Aniline 2 Boiler, DPA 1 and 2 Superheaters meet two exemptions in LAC 33:III.Chapter 22:

1) LAC 33:111,2201 ,C,1 - boilers and process heater/furnaces with a maximum rated capacity of

less than 40 MMBtu/hr in the Baton Rouge Nonaltainment Area (Aniline 2 Boiler - 25 MMBtu/hr,

DPA 1 Superheater - 27 MMBtu/hr, and DPA 2 Superheater - 12 MMBtu/hr) and 2) LAC

33:111.2201 ,C, 19 - boilers and industrial furnaces treating hazardous waste and regulated under ",

40 CFR Part 266,

NOx emissions can be attributed to the high nitrogen content of the organic waste stream being

combusted in the units,

The Hazardous Waste Combustor (HWC) Maximum Achievable Control Technology (MACT)

regulations require units to pick a parameter to monitor in order to demonstrate good combustion

practices, In the EPA and LDEQ-approved Comprehensive Performance Test (CPT) Plans,

Rubicon proposed the use of continuously measured carbon monoxide (CO) emissions as an

indicator of proper operation of the waste firing system, The CPT Plans referred to Volume III of

the Final Technical Support Document for the HWC MACT Standards which discussed the

appropriateness of using CO monitoring as an indication of good combustion, The guidance

indicated that CO is usually a very conservative indicator for ensuring good combustion

conditions, In order to continuously control CO emissions below the HWC National Emission

Standards for Hazardous Air Pollutant (NESHAP) limit, facilities need to maintain good

combustion design, operating, and maintenance practices,

Some of the practices identified in the guidance document include factors related to operation of the

waste firing system, such as:

o Maintaining a sufficient stoichiometric fuel/air ratio;

o ProViding adequate combustion air distribution, which results in good fuel and air mixing;

o Maintaining adequate liqUid atomization; and

5
o Operation of the facility by qualified operators and periodic maintenance of burners and

fuel and supply lines and injection nozzles to the recommended standards.

Rubicon utilizes these practices to maintain CO emissions below the HWC NESHAP

emission standard. Therefore, by continuously monitoring CO emissions, Rubicon is ensuring

that the waste firing system is being properly operated, and that the above practices are

being maintained.

Georgia-Pacific Consumer Operations LLC - Port Hudson Operations, AI 2617

• Combustion sources at Georgia-Pacific are regulated by a BACT NOx limit of 0.10 Ib/MMBtu.

Novolvte Technologies Inc, AI 3387

• NOx emissions from combustion sources at this facility are regulated by 40 CFR 60 Subpart Dc.

Ormet Primary Aluminum Corp - Burnside Alumina Plant. AI 3420

• Another review of the Ormet facility found that NOx emissions are regulated by LAC 33:111.2201.

Sid Richardson Carbon & Energy Co, AI 4174

• Sid Richardson is a carbon black production facility. Sources of NOx include 3 fiares and 2

dryers. After a review of STAPPAIALAPCO's Controlling Nitrogen Oxides Under the Clean Air

Act: A Menu of Options, the CARB NOx control database, and a summary of state NOx

regulations at htlp:/Iwww.epa.gov/tln/naaqs/ozone/ozonetech/statenoxregs518.pdf it has been

determined that RACf controls are not available for these sources.

BFI - Colonial Landfill. AI 4803

• BFI is a landfill whose sources of NOx include a fiare, earthmoving equipment, and a solidification

process. After a review of STAPPAIALAPCO's Controlling Nitrogen Oxides Under the Clean Air

Act: A Menu of Options, the CARB NOx control database, and a summary of state NOx

regulations at htlp:/Iwww.epa.gov/tln/naaqs/ozone/ozonetech/statenoxregs518.pdf it has been

determined that RACf controls are not available for these sources.

State of Louisiana Military - Gillis W Long Center. AI 8055

• NOx emissions from combustion sources at this facility are regulated by 40 CFR 60 Subpart Db.

Plaquemine Point Shipyard. AI 8056

• NOx emissions from Plaquemine Point Shipyard are from 2 diesel air compressor engines. After

a review of STAPPAIALAPCO's Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of

Options, the CARB NOx control database, and a summary of state NOx regulations at

htlp:/Iwww.epa.gov/tln/naaqs/ozone/ozonetech/statenoxregs518.pdf it has been determined that

RACf controls are not available for these sources.

6
BASF Corp - Port Allen Works, AI 9495

• BASF is an alumina catalyst production facility. Sources of NOx emissions include small rotary

kilns and heaters. All sources are less than 13 MMBtu/hr. After a review of STAPPAIALAPCO's

Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of Options, the CARB NOx control

database, and a summary of state NOx regulations at

http://www.epa.gov/ttn/naaqs/ozonelozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not available for these sources.

Waste Manaqement of Louisiana LLC - Woodside Sanitary Landfill & Recycling Center. AI 11767

• Woodside is a landfill whose source of NOx is a flare. After a review of STAPPAIALAPCO's

Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of Options, the CARB NOx control

database, and a summary of state NOx regulations at

http://www.epa.gov/ttn/naaqs/ozonelozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not available for these sources.

Petroleum Fuel & Terminal Co - Port Allen Terminal, AI 19338

• The Port Allen Terminal sources of NOx emissions include a small boiier less than 26 MMBtu/hr

and small heaters all less than or equal to 12 MMBtu/hr. These combustion sources are below

the 40 MMBtu/hr minimum threshold for NOx control in LAC 33:111,2201. After a review of

STAPPAIALAPCO's Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of Options, the

CARB NOx control database, and a summary of state NOx regulations at

http://www.epa.gov/ttn/naaqs/ozonelozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not available for these sources.

Weyerhaeuser NR Co - Holden Wood Products, AI 19875

• Weyerhaeuser is a lumber production mill, Sources of NOx emissions are from 5 kilns, All 5 kilns

emit less than 12 tpy of NOx. After a review of STAPPAIALAPCO's Controlling Nitrogen Oxides

Under the Clean Air Act: A Menu of Options, the CARB NOx control database, and a summary of

state NOx regulations at http://www.epa.gov/ttn/naaqs/ozonelozonetech/statenoxregs518.pdf it

has been determined that RACT controls are not available for these sources.

Criterion Catalysts & Technologies LP - Port Allen Plant. AI 25344

• NOx emissions from combustion sources at this faciiity are regulated by 40 CFR 60 Subpart Dc.

Louisiana Energy & Power Authority (LEPAl - Plaquemine Steam Electric Power Plant, AI 26034

• NOx emissions from combustion sources at this facility are regulated by 40 CFR 60 SUbpart D.

Oxbow Calcining LLC - Baton Rouge Calcined Coke Plant, AI 29884

• NOx emission sources from the coke calcining process include 4 coke calcining kilns. After a

review of STAPPAIALAPCO's Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of

Options, the CARB NOx control database, and a summary of state NOx regulations at

http://www.epa.gov/ttn/naags/ozonelozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not availabie for these sources.

7
East Baton Rouge Parish North Landfill. AI 31128

• The EBR Parish North Landfill's source of NOx is a flare. After a review of STAPPAIALAPCO's

Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of Options, the CARB NOx control

database, and a summary of state NOx regulations at

hltp:llwww.epa.gov/ltn/naags/ozone/ozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not available for these sources.

Air Liguide Large Industries US LP - Geismar

• NOx emissions from combustion sources at this facility are regulated by 40 CFR 60 Subparts Db

and Dc.

Bayou Choctaw Field Production Facility, AI 32146

• This facility's permit has been rescinded.

Bayou Henry Field Production Facility, AI 32161

• NOx emissions at this facility are from diesel engines. After a review of STAPPAIALAPCO's

Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of Options, the CARB NOx control

database, and a summary of state NOx regulations at

hltp:llwww.epa.gov/ltn/naags/ozone/ozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not available for these sources.

Cooper T Smith Stevedoring Co - America Weigh Rig Loading & Transfer Facility. AI 33564

• NOx emissions at this facility are from diesel engines. After a review of STAPPAIALAPCO's

Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of Options, the CARB NOx control

database, and a summary of state NOx regulations at

hltp:llwww.epa.gov/ltn/naags/ozone/ozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not available for these sources.

Cooper T Smith Stevedoring Co - Terrence Derrick, AI 33687

• NOx emissions at this facility are from diesel engines. After a review of STAPPAIALAPCO's

Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of Options, the CARB NOx control

database, and a summary of state NOx reguiations at

hltp:llwww.epa.gov/ltn/naags/ozone/ozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not available for these sources.

Ports America Louisiana LLC - Derrick Barge Mickey, AI 33689

• NOx emissions at this facility are from diesel engines. After a review of STAPPAIALAPCO's

Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of Options, the CARB NOx controi

database, and a summary of state NOx regulations at

hltp:llwww.epa.gov/ltn/naags/ozone/ozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not available for these sources.

Ormet Corp - Burnside Bulk Marine Terminal - Division of Ormet Primarv Aluminum Corp, AI 39945

8
• NOx emissions at this facility are from diesel engines. After a review of STAPPAIALAPCO's

Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of Options, the CARB NOx control

database, and a summary of state NOx regulations at

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not available for these sources.

Enterprise Products Operating LLC - Baton Rouge Act Frac/PCU, AI 40198

• NOx emissions from combustion sources at this facility are regulated by 40 CFR 60 Subparts GG

and Db.

Trinity Marine Products Inc - Plant #48, AI 43634

• NOx emissions at this facility are from plasma cutters. After a review of STAPPAIALAPCO's

Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of Options, the CARB NOx control

database, and a summary of state NOx regulations at

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not available for these sources.

Carville Energy LLC - Carville Energy Center, AI 51854

• NOx emissions from combustion sources at this facility are regulated by 40 CFR 60 Subparts GG

and Da.

E I Dupont de Nemours & Co Inc - Burnside Plant A H2S04 Contact Facility, AI 67572

• NOx emissions from combustion sources at this facility are regulated by 40 CFR 60 Subpart Dc,

LDH Energy Refinerv Services LLC - Geismar Fractionation Plant. AI 83718

• NOx emissions from combustion sources at this facility are regulated by 40 CFR 60 Subparts GG

and Dc.

Dow Chemical Co - Plaquemine Cogeneration Plant. AI 85652

• NOx emissions from combustion sources at this facility are regUlated by 40 CFR 60 Subparts GG

and Da,

Industrial Coatings Contractors Inc, AI 85899

• NOx emissions from combustion sources at this facility are regulated by 40 CFR 60 Subpart 1111.

Associated Terminals of Baton Rouge LLC, AI 121482

• NOx emissions at this facility are from diesel engines. After a review of STAPPAIALAPCO's

Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of Options, the CARB NOx control

database, and a summary of state NOx regulations at

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not available for these sources.

Wilbert #4 Tank Battery - White Castle Field, AI 152442

9
• NOx emissions at this facility are from liquid propane engine. After a review of

STAPPAIALAPCO's Controlling Nitrogen Oxides Under the Clean Air Act: A Menu of Options, the

CARB NOx control database, and a summary of state NOx regulations at

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/statenoxregs518.pdf it has been determined that

RACT controls are not available for these sources.

A Wilbert's Sons LLC 88 #2 Production Facility. AI 156077

• NOx emissions from combustion sources at this facility are regulated by 40 CFR 60 Subpart JJJJ.

Flopam Inc - Flopam Facility. AI 166443

• NOx emissions from combustion sources at this facility are regulated by 40 CFR 60 SUbpart Dc.

10