Air Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
A4043 / STAFF REPORT / MI-ROP-A4043-2008
Dow Corning Corporation
and
Midland Chemical Conversion
SRN: A4043
Located at
3901 South Saginaw Road, Midland, Michigan 48686
Permit Number: MI-ROP-A4043-2008
Staff Report Date: June 23, 2008
Amended Date:
This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions of the Renewable Operating Permit (ROP).
TABLE OF CONTENTS
STAFF REPORT 3
/ Michigan Department of Environmental QualityAir Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
A4043 /
June 23, 2008 STAFF REPORT
/ MI-ROP-A4043-2008Purpose
Major stationary sources of air pollutants, and some non-major sources, are required to obtain and operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a stationary source’s applicable requirements and compliance with them by consolidating all state and federal air quality requirements into one document.
This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the draft permit terms and conditions including citations of the underlying applicable requirements, an explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the stationary source.
General Information
Stationary Source Mailing Address: / 3901 South Saginaw RoadMidland, Michigan 48686
Source Registration Number (SRN): / A4043
Standard Industrial Classification (SIC) Code: / 2899
Number of Stationary Source Sections: / 2
Is Application for a Renewal or Initial Issuance? / RenewalInitial Issuance
Application Number: / 200600176
Responsible Official: / Section 1
James Smith, Midland Site Plant Manager
(989) 496-4439
Section 2
David Lamar, Vice President Engineering
(509) 946-5700
AQD Contact: / Scott Klipa, Environmental Engineer
(989) 686-8025 ext 8253
Date Permit Application Submitted: / November 11, 2006
Date Application Was Administratively Complete: / Yes
Is Application Shield In Effect? / YesNo
Date Public Comment Begins: / June 23, 2008
Deadline for Public Comment: / July 23, 2008
Source Description
Dow Corning Corporation is a chemical manufacturer located at 3901 South Saginaw Road, Midland, Michigan. This facility is located in a relatively flat area with the nearest residence being approximately one quarter mile from the facility. Section 1 of the ROP covers the Dow Corning Miland Plant operations. The plant uses a variety of process equipment in the manufacture of products including, reactors, distillation columns, evaporators, fractionators, condensers, scrubbers, etc. Section 2 of the ROP was established for the Midland Chemical Conversion operations located at the Dow Corning Midland Plant. Midland Chemical Conversion installed, owns and intends to operate a plasma enhanced melter at the facility. The plasma enhanced melter is a waste conversion process that will process wastes generated at the Dow Corning Plant.
The following table lists stationary source emission information as reported in Michigan Air Emissions Reporting System for 2006 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant / Tons per Year /Carbon Monoxide (CO) / 25.7
Lead (Pb) / 0
Nitrogen Oxides (NOx) / 37.9
Particulate Matter (PM) / 8.2
Sulfur Dioxide (SO2) / 0
Volatile Organic Compounds (VOCs) / 209.8
**As listed pursuant to Section 112(b) of the Clean Air Act.
See Parts C and D in the draft ROP for summary tables of all processes at the stationary source that are subject to process-specific emission limits or standards.
Regulatory Analysis
The following is a general description and history of the source. Any determinations of regulatory non-applicability for this source are addressed in the non-applicable requirement part of the Staff Report and Part E of the ROP.
The stationary source is located in Midland County, which is currently designated as attainment/unclassified for all criteria pollutants.
The stationary source is subject to Title 40 of the Code of Federal Regulations, Part 70, because the potential to emit NOx, PM and VOC exceed 100 tons.
The stationary source is not considered a major source of Hazardous Air Pollutant (HAP) emissions because the potential to emit of any single HAP regulated by the federal Clean Air Act, Section 112 is less than 10 tons per year and the potential to emit of all HAPs combined is less than 25 tons per year.
The stationary source is subject to Prevention of Significant Deterioration of Title 40 of the Code of Federal Regulations, Part 52.21, regulations because its potential to emit of volatile organic compounds is greater than 100 tons per year.
The stationary source is subject to the New Source Performance Standards for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) promulgated in Title 40 of the Code of Federal Regulations, Part 60, Subparts A and Kb.
The stationary source is subject to the Maximum Achievable Control Technology Standards for Organic Liquid Distribution (Non-gasoline) promulgated in Title 40 of the Code of Federal Regulations, Part 63, Subparts A and EEEE.
The facility is subject to National Emission Standards for Hazardous Air Pollutants (NESHAP) including 40 CFR Part 61, Subpart J (National Emission Standard for Equipment Leaks (Fugitive Emission Sources) of Benzene), Subpart M (National Emission Standard for Asbestos), Subpart V (National Emission Standard for Equipment Leaks (Fugitive Emission Sources)), Subpart Y (National Emission Standard for Benzene Emissions From Benzene Storage Vessels) and Subpart FF (National Emission Standard for Benzene Waste Operations).
The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all applicable requirements and are consistent with the DEQ's "Procedure for Evaluating Periodic Monitoring Submittals."
The stationary source is subject to the federal Compliance Assurance Monitoring (CAM) rule under Title 40 of the Code of Federal Regulations, Part 64, because several emission units have both a control device and potential pre-control emissions of volatile organic compounds greater than the major source threshold level. CAM requirements are included in this ROP.
Please refer to Parts B, C and D in the enclosed draft ROP for detailed regulatory citations for the stationary source. Part A contains regulatory citations for general conditions.
Source-wide Permit to Install (PTI)
Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a footnote designation in the integrated ROP/PTI document. PTIs that are being incorporated through this current permit action into the Source-wide PTI are listed in Appendix 6 of the permit.
The following table lists all individual PTIs that were incorporated into previous ROP/Source-wide PTIs and subsequently voided.
PTI Number /206-00 / 308-94 / 338-99A / 1045-80
232-89E / 34-04A / 158-87B / 126-03
437-90A / 731-92C / 370-97A / 930-78O
209-70J / 812-91A / 534-77F / 466-73E
334-88C / 44-06 / 156-06 / 112-06
185-07 / 29-07 / 242-07 / 91-07
ROP Modifications
Dow Corning and Midland Chemical Conversion have submitted the following ROP Modification Applications.
ROP Modifications /200800038 / 200800041 / 200800042 / 200800043
200800016 / 200700153 / 200800001
These applications were processed and included into the ROP Renewal.
Equivalent Requirements
This permit does not include any equivalent requirements or significant changes pursuant to Rule 212(5). Equivalent requirements are enforceable applicable requirements that are equivalent to the applicable requirements contained in the original New Source Review permit, a Consent Order/Judgment, and/or the State Implementation Plan.
Non-applicable Requirements
Part E of the draft ROP lists requirements that are not applicable to this source as determined by the AQD, if any were proposed in the application. These determinations are incorporated into the permit shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to
Rule 213(6)(a)(ii).
Processes in Application Not Identified in Draft ROP
The following table lists processes that were included in the ROP application as exempt devices under Rule 212(4). These processes are not subject to any process-specific emission limits or standards in any applicable requirement.
ExemptEmission Unit ID / Description of
Exempt Emission Unit / ROP
Exemption / NSR Permit
Exemption /
EU2409-02 / 20,000 gal. gasoline storage tank / R212(4)(c) / R284(i)
EU510-01 / Vapor degreaser used as cold cleaner / R212(4)(c) / R284(i)
EU212-13 / 12,400 gal storage tank / R212(4)(c) / R284(i)
EU212-14 / 20,000 gal storage tank / R212(4)(c) / R284(i)
EU303-04 / 12.5 MMBTU/hr Dow Therm Boiler / R212(4)(b) / R282(b)(i)
EU303-11 / 2-22,000 gal, 2-13,000 gal, 1-10,000 gal and 2-1,000 gal storage tanks / R212(4)(b) / R282(b)(i)
EU304-04 / Cracker Furnace / R212(4)(b) / R282(b)(i)
EU304-06 / 2 7 gal oil tanks / R212(4)(c) / R284(i)
EU324-05 / 2-20,000 gal, 6-10,000 gal, 2-5,500 gal and 3- 5,000 gal storage tanks / R212(4)(c) / R284(i)
EU340-02 / 1-6,000gal, 2-150 gal, 1- 30 gal storage tank / R212(4)(c) / R284(i)
EU325-04 / 2 5 MMBTU/hr NG heat exchangers / R212(4)(b) / R282(b)(i)
EU501-15 / 2-20Mgal, 1-10Mgal, 11-6.8Mgal, 2-5Mgal, 1-6Mgal, 1-2.2Mgal, 1-2Mgal, 1-1.9Mgal, 2-1.7Mgal, 4-1Mgal and 1-100gal storage tanks / R212(4)(c) / R284(i)
EU501-16 / 1-20Mgal, 4-10Mgal, 2-6.8Mgal, 1-2Mgal, 3-1.7Mgal and 1-500 gal storage tanks / R212(4)(c) / R284(i)
EU501-17 / 1-6.8Mgal, 3-750gal and 3-200 gal storage tanks / R212(4)(c) / R284(i)
EU501-18 / 1-6.8Mgal, 2-6Mgal, 3-5Mgal, 2-2.6Mgal, 2-2.36Mgal and 3 1Mgal storage tanks / R212(4)(c) / R284(i)
EU501-19 / 1-6.8Mgal and 1-5Mgal storage tanks / R212(4)(c) / R284(i)
EU501-40 / 10 MMBTU/hr Dow Therm boiler / R212(4)(b) / R282(b)(i)
EU502-05 / 3-1.5Mgal and 1-750gal storage tank / R212(4)(c) / R284(i)
EU515-02 / 4-5Mgal storage tanks / R212(4)(c) / R284(i)
EU602-11 / 3-7.5Mgal, 13-1.7Mgal and 6-200 gal storage tanks / R212(4)(c) / R284(i)
EU508-03 / 10.6 MMBTU/hr Dowtherm boiler / R212(4)(b) / R282(b)(i)
EU604-09 / 1-3Mgal, 3-1.9Mgal, 2-750 gal, 1-1.2Mgal, 1-250 gal and 2-117 gal storage tanks / R212(4)(c) / R284(i)
EU2504-03 / 1-30Mgal, 2-20Mgal, 10-10Mgal, 2-9.2Mgal, 1-7.5Mgal, 9-6.7Mgal, 15-5Mgal storage tanks / R212(4)(c) / R284(i)
EU212-16 / 1-5.4Mgal and 2-750 gal storage tanks / R212(4)(c) / R284(i)
EU303-05 / 7-1,000 gal storage tanks / R212(4)(c) / R284(i)
EU311-02 / 1,000 gal storage tank / R212(4)(c) / R284(i)
EU106-12 / Equilbrator process / R212(4)(g) / R290
EU304-01 / Hexenyl process including reactor, distillation column, vacuum system, storage tanks, condensers and related equipment / R212(4)(g) / R290
EU308-01 / Chlorophenylsilane pilot plant process including columns, reactors, storage tanks, condensers and scrubbers / R212(4)(g) / R290
EU324-02 / 324 Building exhaust for filters, strainers, drum-off stations and filter presses for a variety of products. / R212(4)(g) / R290
EU2703-06 / 9260 Kettle production of various chlorosilane products. Includes kettle, condensers, tanks, vacuum jet, methyl chloride recovery system and related equipment. / R212(4)(g) / R290
EU304-03 / MCDS cracker process including reactor, heat exchangers, storage tanks, scrubber and related equipment. / R212(4)(g) / R290
EU602-04 / Batch Kettle / R212(4)(g) / R290
EU501-08 / Grandfathered dimethyl hydrolysis process including reactors, tanks, condensers, distillation scrubber and related equipment. / R212(4)(g) / R290
EU501-14 / Grandfathered KP fluid process / R212(4)(g) / R290
EU502-02 / Phenylchlorosilanes manufacturing process including distillation columns, reactors, storage tanks, related equipment, condensers and scrubbers. / R212(4)(g) / R290
EU505-03 / Grandfathered Filter press / R212(4)(g) / R290
EU602-01 / Reinforced resin process including tanks, condensers, vacuum system, strippers and related equipment / R212(4)(g) / R290
EU602-03 / 95 Filter Unit / R212(4)(g) / R290
EU602-07 / Grandfathered 63 gum unit / R212(4)(g) / R290
EU602-08 / 900 mixer / R212(4)(g) / R290
EUsite-04 / Site cold cleaners / R212(4)(a) / R281(h)
EU109-08 / 4431 process / R212(4)(g) / R290
EU109-04 / 2262 Process / R212(4)(g) / R290
EU109-05 / 2284 Process / R212(4)(g) / R290
EU109-01 / 2206 Process / R212(4)(g) / R290
EU109-02 / 2207 Process / R212(4)(g) / R290
EU109-03 / 2219 Process / R212(4)(g) / R290
EU106-02 / 1302 Process / R212(4)(g) / R290
EU106-01 / 1300 Process / R212(4)(g) / R290
EU106-04 / 1318 Process / R212(4)(g) / R290
EU106-06 / 4000 Process / R212(4)(g) / R290
EU106-07 / 4070 Process / R212(4)(g) / R290
EU106-08 / 4075 Process / R212(4)(g) / R290
EU106-09 / 4985 Process / R212(4)(g) / R290
EU106-10 / 5119 Process / R212(4)(g) / R290
EU106-11 / WFE Process / R212(4)(g) / R290
EU106-03 / 1308 Process / R212(4)(g) / R290
EU106-05 / 1333 Process / R212(4)(g) / R290
EU109-06 / 2288 Process / R212(4)(g) / R290
EU109-07 / 4400 Process / R212(4)(g) / R290
EU109-09 / LOOP Process / R212(4)(g) / R290
EU109-10 / Drum Roll process / R212(4)(g) / R290
EU212-01 / Solventless Coating Process / R212(4)(g) / R290
EU212-02 / Hexenyl polymer process / R212(4)(g) / R290
EU212-03 / 6019 Blend Tank / R212(4)(g) / R290
EU212-04 / 6014 Blend Tank / R212(4)(g) / R290
EU212-05 / 6009 Blend Tank / R212(4)(g) / R290
EU212-06 / 6072 Blend Tank / R212(4)(g) / R290
EU212-07 / 6035 Blend Tank / R212(4)(g) / R290
EU212-08 / 6036 Blend Tank / R212(4)(g) / R290
EU212-09 / 6087 Blend Tank / R212(4)(g) / R290
EU212-10 / 20600 Blend Tank / R212(4)(g) / R290
EU212-11 / 2500 Blend Tank / R212(4)(g) / R290
EU212-12 / 20400 Blend Tank / R212(4)(g) / R290
EU212-15 / High Volume Blend Tank / R212(4)(g) / R290
EU2703-02 / Acetoxy Process / R212(4)(g) / R290
EU2703-04 / Alkoxylation Process / R212(4)(g) / R290
EU2703-05 / Amination Process / R212(4)(g) / R290
EU2703-07 / 9011/9013 Storage tanks / R212(4)(g) / R290
EU2703-08 / 9140 Kettle / R212(4)(g) / R290
EU2703-09 / 9250 Kettle / R212(4)(g) / R290
EU2703-10 / Drum off Equipment / R212(4)(g) / R290
EU2703-12 / Amine Process / R212(4)(g) / R290
EU2703-13 / 22270 Kettle / R212(4)(g) / R290
EU2901-02 / Module A / R212(4)(g) / R290
EU2901-04 / C-mixer / R212(4)(g) / R290
EU2901-05 / C-Reactor / R212(4)(g) / R290