BOBBY JINDAL GOVERNOR 

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### Dr. Al Armendariz, Administrator US EPARegion 6 (6-RA) 1445 Ross Avenue, Suite 1200 Dallas, TX 75202-2733 

## RE: DEPARTMENT OFENVIRONMENTAL QUALITY 

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### State ofLouisianaRequestforRedesignation and MaintenancePlan Addendumto AppendixF: RACT Determinations 

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### DearDr. Armendariz: Asperyourrequest, the departmenthasprepared an addendumto AppendixFwhichoutlinesthe specific facilities thathaverule applicabilityissues for StateImplementationPlanpurposes. The addendum addresses all facilities andtherule applicabilityas itrelates to LAC 33:I1IChapters 21 and 22. 

### Itis ourunderstandingthatthis documentwillhelp yourstaffto finalize the technical support documentthatwill accompanythe·finaldraftoftheFederalRegisternotice whichwillpropose to redesignatetheBatonRouge OzoneNonattaimnentAreaas an attaimnent areaforthe 1997 8- hourOzone Standard. Ifyouoryour staffhavequestions concerningthis submittal, pleasecontactTimothyBergeron, AirPermitsDivision, at(225) 219-3410 ortimothy,bergeron@la,gov. Sincerely,

c: GuyDonaldson, EPARegion 6 Date:

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Post Office Box4313' BatonRouge, Louisiana7082t-4313· Phone 225-2t9-3t81 • Fax 225-2t9-3309**www;dea.louisiana.~ov**

# LOUISIANADEPARTMENT OFENVIRONMENTAL QUALITY 

# AddendumtoAppendixF Redesignation and Maintenance Plan Timothy Bergeron 

### 5/16/2011

### Appendix FAddendum SummaryofVOC and NOx RACTfor Certain Facilities Appendix Fis asummary of RACT rule applicability foreach major source of NOx and VOC in the 5 parish Baton Rouge area. The table lists each RACT rule that is applicable to sources of25 tons per yearof NOx and/orVOC. The table includes:

• each facility's permitted tons peryearof NOx and/orVOC, • which state RACT rules apply to the facility, • the parish where the facility is located, and; • the agency interest numberwhich is an identification number given to each permitted facility in Louisiana. Facilities that are majorsources of NOx orVOC that are notsubjectto 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 asugar mill in Iberville Parish that only operates during the months ofOctoberJanuary and not during the traditional ozone season. The main sources ofVOC 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 - GeismarAgricultural Nitrogen & Phosphate Plant. AI 3732

• PCS Nitrogen manufactures fertilizer products. The source ofVOC 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 aspecial VOC emissions cap that limitsthe total emissions that may be emitted. Each ball activator is permitted to emit a maximum of76.11lb/hr. Cumulatively the ball activators are permitted to emit an average of 16.20 Ib/hr and 70.96tpy. Throughput of product material containing acetic acid is limited to 8.40 MM Ibs/yr. The concentration ofthe 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 - PortAllen 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. Currentlythis facility is permitted to emit 25.01 tpy ofVOe. The permit is in the process of being modified to reduce VOC emissions to 19.36tpy. Once the permit is modified thisfacility will no longerbe a VOC majorsource. EDO Specialty Plastics - Perkins Road Facility, AI 22750

• EDO is afiberglass composite pipe manufacturing facility. This facility's VOC emissions are controlled by meeting the requirements of40 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 by40 CFR 60 Subpart WWW and 40 CFR 63 Subpart AAAA. 

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

• Air Liquide operates a cogen unit. The main source ofthe facility's VOC emissions is from the combustion of natural gas in the cogen unit. Dow Chemical Co - Plaquemine Cogeneration Plant. AI 85652

• DowChemical operates 4 cogen units. The main source ofthe facility's VOC emissions isfrom the combustion of natural gas in the cogen units. Genesis Crude Oil LP - Truck Loading Facility. AI 3991

• Genesis is subjectto 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 of40 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 AirAct: A Menu ofOptions, the CARB NOx control database, and a summaryofstate NOx regulations at hltp:llwww,epa,gov/ttn/naags/ozone/ozonetech/statenoxregs5

### 18,pdfit has been determined that RACT controls are not available forthese sources, Rubicon LLC - Geismar Plant, AI 1468

• The Aniline 2 Boiler, DPA 1 and 2 Superheaters meettwo 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 ofthe organicwaste 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 EPAand LDEQ-approved Comprehensive Performance Test (CPT) Plans, Rubicon proposed the use ofcontinuously measured carbon monoxide (CO) emissions as an indicator of proper operation ofthe 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 avery conservative indicatorfor 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 ofthe practices identified in the guidance document includefactors related to operation ofthe waste firing system, such as: o Maintaining asufficient stoichiometric fuel/air ratio; o ProViding adequate combustion air distribution, which results in good fuel and air mixing; o Maintaining adequate liqUid atomization; and 

### 5o 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 properlyoperated, and that the above practices are being maintained. Georgia-Pacific ConsumerOperations 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 PrimaryAluminum Corp - Burnside Alumina Plant. AI 3420

• Another review ofthe Ormetfacility 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 3fiares and 2 dryers. After a review of STAPPAIALAPCO's Controlling Nitrogen Oxides Underthe Clean Air Act: A Menu of Options, the CARB NOx control database, and a summaryofstate NOx regulations at htlp:/Iwww.epa.gov/tln/naaqs/ozone/ozonetech/statenoxregs518.pdfit has been determined that RACfcontrols are not available forthese sources. BFI - Colonial Landfill. AI 4803

• BFI is a landfill whose sources of NOx include afiare, earthmoving equipment, and a solidification process. Aftera review of STAPPAIALAPCO's Controlling Nitrogen Oxides Underthe Clean Air Act: A Menu of Options, the CARB NOx control database, and a summary ofstate NOx regulations at htlp:/Iwww.epa.gov/tln/naaqs/ozone/ozonetech/statenoxregs518.pdf it has been determined that RACfcontrols are not available forthese 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 aircompressor engines. After a review of STAPPAIALAPCO's Controlling Nitrogen Oxides Underthe Clean AirAct: A Menu of Options, the CARB NOx control database, and a summaryofstate NOx regulations at htlp:/Iwww.epa.gov/tln/naaqs/ozone/ozonetech/statenoxregs518.pdf it has been determined that RACfcontrols are not available forthese sources.



### 6BASF 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 Underthe 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 forthese 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 Underthe 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 forthese 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 orequal to 12 MMBtu/hr. These combustion sources are below the 40 MMBtu/hr minimum threshold for NOx control in LAC 33:111,2201. Aftera review of STAPPAIALAPCO's Controlling Nitrogen Oxides Underthe Clean AirAct: A Menu of Options, the CARB NOx control database, and a summary ofstate NOx regulations at http://www.epa.gov/ttn/naaqs/ozonelozonetech/statenoxregs518.pdf it has been determined that RACT controls are not available forthese 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. Aftera review of STAPPAIALAPCO's Controlling Nitrogen Oxides Underthe Clean Air Act: A Menu of Options, the CARB NOx control database, and a summaryof state NOx regulations at http://www.epa.gov/ttn/naaqs/ozonelozonetech/statenoxregs518.pdf it has been determined that RACTcontrols are not available forthese sources. Criterion Catalysts & Technologies LP - Port Allen Plant. AI 25344

• NOx emissions from combustion sources at this faciiity are regulated by40 CFR 60 Subpart Dc. Louisiana Energy & PowerAuthority (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. Aftera review of STAPPAIALAPCO's Controlling Nitrogen Oxides Underthe 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 forthese sources. 

### 7East Baton Rouge Parish North Landfill. AI 31128

• The EBR Parish North Landfill's source of NOx is aflare. Aftera review of STAPPAIALAPCO's Controlling Nitrogen Oxides Underthe Clean AirAct: A Menu ofOptions, the CARB NOx control database, and asummary ofstate NOx regulations at hltp:llwww.epa.gov/ltn/naags/ozone/ozonetech/statenoxregs518.pdf it has been determined that RACT controls are not available forthese 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 Underthe Clean Air Act: A Menu ofOptions, the CARB NOx control database, and a summaryofstate NOx regulations at hltp:llwww.epa.gov/ltn/naags/ozone/ozonetech/statenoxregs518.pdf it has been determined that RACT controls are not available forthese sources. CooperT 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 Underthe Clean Air Act: A Menu ofOptions, the CARB NOx control database, and a summaryofstate NOx regulations at hltp:llwww.epa.gov/ltn/naags/ozone/ozonetech/statenoxregs518.pdf it has been determined that RACT controls are not available forthese sources. CooperT 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 Underthe Clean Air Act: A Menu ofOptions, the CARB NOx control database, and a summaryofstate NOx reguiations at hltp:llwww.epa.gov/ltn/naags/ozone/ozonetech/statenoxregs518.pdf it has been determined that RACT controls are not available forthese 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 Underthe Clean Air Act: A Menu ofOptions, the CARB NOx controi database, and a summaryofstate NOx regulations at hltp:llwww.epa.gov/ltn/naags/ozone/ozonetech/statenoxregs518.pdf it has been determined that RACT controls are not available forthese sources. Ormet Corp - Burnside Bulk MarineTerminal - Division of Ormet PrimarvAluminum Corp, AI 39945 

### 8• NOx emissions at this facility are from diesel engines. After a review of STAPPAIALAPCO's Controlling Nitrogen Oxides Underthe Clean AirAct: A Menu of Options, the CARB NOx control database, and a summary ofstate NOx regulations at http://www.epa.gov/ttn/naaqs/ozone/ozonetech/statenoxregs518.pdf it has been determined that RACTcontrols 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 Underthe Clean AirAct: A Menu of Options, the CARB NOx control database, and a summaryof state NOx regulations at http://www.epa.gov/ttn/naaqs/ozone/ozonetech/statenoxregs518.pdf it has been determined that RACTcontrols are not available forthese 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 Underthe Clean AirAct: A Menu of Options, the CARB NOxcontrol 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 forthese 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 Underthe Clean AirAct: 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 forthese sources. AWilbert'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