Amy this is a summary of the modifications Croda requests to Permit AQM-003/00426 - Renewal 2. Please 

contact me if there are any questions. 

o Delete Condition 3 - Table 1 a. from the permit. Croda is in the process of 

demolishing Boiler #1. 

o Condition 1 a. Page 4 the Emission Unit Description for EU 3 & 4 should read "Blend 

Tank Area - Two Blend Tanks, .... u. 

o Condition 1 a. Page 4 the Emission Unit Description for EU 14 should include the 3A 

autoclave hotwell. 

o Condition 1 a. Page 4 the Emission Unit Description for EU 31 through EU 35 should 

read "Unloading Station Tanks". 

o Condition 1 a. Page 4 the Emission Units for MPl EU 18 & 19 should refer to a third 

vacuum pump. Perhaps MPl EU 20. Note there is a discrepancy between the 

designation of the emission points in the table on page 4 and how the points are 

described on page 51 Condition 3 - Table 1 k. 

o Condition 3 Table 1 a. 2. vi. B. Page 20 should refer to Condition 3 - Table l(o)~not 

Table 1 (0)(3) as written. 

o Condition 3 Table 1 b. 2. vii. A. Page 24 should refer to Condition 3 - Table l(o)~not 

Table 1(0)(3) as written. 

o Condition 3 Table 1 c. 2. vii. A. Page 27 should refer to Condition 3 - Table l(o)~not 

Table 1(0)(3) as written. 

o Condition 3 Table 1 h. 1. iv. D . .1. Page 43 should read "The pressure drop across the 

scrubber shall be less than 19 inches water gauge." 

o Delete Condition 3 Table 1 i. 1. vi. C. Page 46. The spray condenser on 7 kettle 

operates at atmospheric conditions with no packing or other means of creating a 

pressure drop so monitoring of pressure drop is not a meaningful measure of its 

operation. 

o Delete Condition 3 Table 1 j. l. vi. C. Page 49. The spray condenser on 4 kettle also 

operates at atmospheric conditions with no packing or other means of creating a 

pressure drop so monitoring of pressure drop is not a meaningful measure of its 

operation. 

o Condition 3 Table 1 I. 1. i. B. Page 55 please delete Multi-Purpose Plant and insert 

Unloading Station Tanks. 

o Condition 3 Table 1 m.l.vi.C. Page 56 please delete the words " ... and kettles." The 

oxide detection system does not involve the kettles. 

o Condition 3 Appendix "A" Page 73 Multi-Purpose Plant Insignificant sources. The first 

item should read Three vacuum pumps. 

In addition, Croda requests that the General Emission Limitation from APC-2004/0723 for Oxides of Sulfur not 

to exceed 0.1 ton per 12-month rolling period be transferred to AQM-003/00426 - Renewal 2. 

In addition, Croda requests that the Emission Limitation from APC-2004/0723 for Carbon Monoxide of 34.0 

pounds per batch for the 'Kettles Area' be transferred to AQM-003/00426 - Renewal 2 and while we 

request 34.0 pounds per batch be retained for 7 kettle the emission the limitation for 4 kettle may be 

reduced to 30.0 pounds per batch. . 
Amy this is a summary of the modifications Croda requests to Permit AQM-003/00426 - Renewal 2. Please 

contact me if there are any questions. 

• Delete Condition 3 - Table 1 a. from the permit. Croda is in the process of 

demolishing Boiler #1. 

• Condition 1 a. Page 4 the Emission Unit Description for EU 3 & 4 should read "Blend 

Tank Area - Two Blend Tanks .... .". 

• Condition 1 a. Page 4 the Emission Unit Description for EU 14 should include the 3A 

autoclave hotwell. 

• Condition 1 a. Page 4 the Emission Unit Description for EU 31 through EU 35 should 

read "Unloading Station Tanks". 

• Condition 1 a. Page 4 the Emission Units for MP1 EU 18 & 19 should refer to a third 

vacuum pump. Perhaps MP1 EU 20. Note there is a discrepancy between the 

designation of the emission points in the table on page 4 and how the points are 

described on page 51 Condition 3 - Table 1 k. 

• Condition 3 Table 1 a. 2. vi. B. Page 20 should refer to Condition 3 - Table 1(0)M}.not 

Table 1(0)(3) as written. 

• Condition 3 Table 1 b. 2. vii. A. Page 24 should refer to Condition 3 - Table 1(o)M}.not 

Table 1(0)(3) as written. 

• Condition 3 Table 1 c. 2. vii. A. Page 27 should refer to Condition 3 - Table 1(0)M}.not 

Table 1(0)(3) as written. 

• Condition 3 Table 1 h. 1. iv. D . .1. Page 43 should read "The pressure drop across the 

scrubber shall be less than 19 inches water gauge." 

• Delete Condition 3 Table 1 i. 1. vi. C. Page 46. The spray condenser on 7 kettle 

operates at atmospheric conditions with no packing or other means of creating a 

pressure drop so monitoring of pressure drop is not a meaningful measure of its 

operation. 

• Delete Condition 3 Table 1 j . . 1. vi. C. Page 49. The spray condenser on 4 kettle also 

operates at atmospheric conditions with no packing or other means of creating a 

pressure drop so monitoring of pressure drop is not a meaningful measure of its 

operation. 

• Condition 3 Table 1 I. 1. i. B. Page 55 please delete Multi-Purpose Plant and insert 

Unloading Station Tanks. 

• Condition 3 Table 1 m.1 .vi.C. Page 56 please delete the words ..... and kettles." The 

oxide detection system does not involve the kettles, 

• Condition 3 Appendix"N Page 73 Multi-Purpose Plant InSignificant sources. The first 

item should read Three vacuum pumps. 

In addition. Croda requests that the General Emission Limitation from APC-2004/0723 for Oxides of Sulfur not 

to exceed 0,1 ton per 12-month rolling period be transferred to AQM-003/00426 - Renewal 2, 

In addition. Croda requests that the EmiSSion Limitation from APC-2004/0723 for Carbon Monoxide of 34.0 

pounds per batch for the 'Kettles Area' be transferred to AQM-003/00426 - Renewal 2 and while w e 

request 34,0 pounds per batch be retained for 7 kettle the emission the limitation for 4 kettle may be 

reduced to 30.0 pourids per batch,