Document 8O2dd8kXOGzkgxr8Yve3RY6Dm

CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) NEICVP1446E01 NEIC CIVIL INVESTIGATION REPORT Indorama Ventures Oxides LLC Port Neches Operations Port Neches, Texas 77651 Investigation Dates: October 17-21, 2022 Armando Bustamante, Project Manager, NEIC Authorized for Release by: Linda TeKrony, Acting Field Branch Chief, NEIC Report Prepared for: EPA Region 6 1201 Elm Street Dallas, Texas 75270 NATIONAL ENFORCEMENT INVESTIGATIONS CENTER P.O. Box 25227 Building 25, Denver Federal Center Denver, Colorado 80225 Page 1 of 35 CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) CONTENTS INVESTIGATION OVERVIEW ............................................................................................................ 3 PROJECT OBJECTIVE .................................................................................................................... 3 FACILITY CONTACT INFORMATION ............................................................................................. 3 FACILITY OVERVIEW.................................................................................................................... 3 FACILITY OPERATIONS SUMMARY .............................................................................................. 4 FIELD ACTIVITIES SUMMARY....................................................................................................... 4 BWON...................................................................................................................................... 5 Storage Tanks.......................................................................................................................... 5 Flaring...................................................................................................................................... 6 Measurement Activities.......................................................................................................... 6 INVESTIGATION OBSERVATIONS..................................................................................................... 8 TABLES Table 1. PROJECT TEAM MEMBERS ................................................................................................ 3 Table 2. FACILITY CONTACT INFORMATION ................................................................................... 3 Table 3. APPLICABLE NAICS CODES................................................................................................. 4 Table 4. FIELD MEASUREMENT ACTIVITIES .................................................................................... 7 APPENDICES (*NEIC-created document) A Process Description* (4 pages) [Contains Company-claimed Confidential Business Information (CBI)] B LDAR Monitoring Summary* (2 pages) C OGI Survey Images and Videos (file containing multiple videos and still images) D 2018-2021 BWON TAB Reports (7 pages) E 2021 TRI Report (12 pages) F Monthly Visual Inspection Records (74 pages) G 2021 BWON LDAR Monitoring Records (12 pages) H Aromatic Distillate Sales Data from November 2, 2021-November 3, 2022 (14 pages) I Composition Data for Aromatic Distillate (2 pages) J November 3, 2022, Email from Indorama Re: Follow-up Records Request (8 pages) K Third-Party Compliance Audit (8 pages) [Contains Company-claimed CBI] L June 2022 Quarterly Audit Update to TCEQ (13 pages) M NOCS for A3 Olefins Unit (60 pages) N Title V Permit for A3 Olefins Unit (148 pages) O Storage Tank Data (16 pages) P New Source Review Permit 19823: Special Conditions and Technical Review (28 pages) Q Flare Continuous Monitoring Data (Microsoft Excel spreadsheet) R NEIC Calculation of Indorama NHVcz Based on Flare Data Adjusted for H2* (Microsoft Excel spreadsheet) This Contents page shows all the sections contained in this report and provides a clear indication of the end of this report. NEICVP1446E01 Page 2 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) INVESTIGATION OVERVIEW PROJECT OBJECTIVE At the request of U.S. Environmental Protection Agency (EPA) Region 6 (Region), EPA's National Enforcement Investigations Center (NEIC) conducted a compliance investigation of the Indorama Ventures Oxides LLC - Port Neches Operations (Indorama) facility located at 2701 Spur 136, Port Neches, Texas 77651. The scope of the investigation included a review of Indorama's compliance with the Clean Air Act (CAA). The investigation focused on the ethylene and ethylene oxide production areas of the Indorama facility. Table 1 lists the project team members. Team Member Armando Bustamante Brianna Leiker Zel Nabiyar Cindy Schafer Matthew Schneider Justin Chen Benjamin Donaldson Colleen McCarthy Table 1. PROJECT TEAM MEMBERS Organization NEIC NEIC NEIC NEIC NEIC REGIONAL AND OTHER CONTACTS EPA Region 6 EPA Region 6 EPA Region 6 Project Role Project manager (PM) Field team member Field team member Field team member Field team member Regional field team member Regional field team member Regional field team member FACILITY CONTACT INFORMATION Table 2 lists the primary facility contacts. Table 2. FACILITY CONTACT INFORMATION Name, Title Email Address Michael Dubois, Environmental Manager michael.dubois@us.indorama.net Kim Hoyt, Site Director kim.hoyt@us.indorama.net Adam Brown, Regional EHS Representative adam.r.brown@us.indorama.net Leslie Stuart, Integrated Oxides and Derivatives Corporate Environmental Manager leslie.stuart@us.indorama.net James Kalathra, Environmental Team Lead james.kalathra@us.indorama.net Rachel Lavergne, Environmental Team Lead rachel.lavergne@us.indorama.net Allison Broussard, Environmental Specialist allison.broussard@us.indorama.net FACILITY OVERVIEW According to the EPA Envirofacts database, this facility has the following North American Industry Classification System (NAICS) codes (Table 3): NEICVP1446E01 Page 3 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) NAICS Code 325110 325199 Table 3. APPLICABLE NAICS CODES Description Petrochemical manufacturing All other basic organic chemical manufacturing Indorama is a chemical manufacturer located in Port Neches, Texas, whose primary products include ethanolamines, ethylene glycols, ethylene oxide (EO), methyl tertiary butyl ether (MTBE), propylene, propylene glycol, and surfactants. Huntsman Petrochemical LLC previously owned and operated the facility, which Indorama purchased in 2020. One of the facility's primary raw materials is ethane, which is processed in the cracking furnaces to produce ethylene, which is then used in the production of ethylene oxide. Saleable byproducts of the ethylene manufacturing process include propylene, a C4-rich stream, and aromatic distillate (AD). Indorama currently employs 600 full-time employees and approximately 450 contract employees at the Port Neches facility. FACILITY OPERATIONS SUMMARY Indorama operates an ethylene production unit (A3 olefins unit) that utilizes eight furnaces to crack ethane, received via pipeline, into ethylene and other byproducts. The ethylene is recovered from the cracked gas after quenching, compression, drying, and separation from other byproducts. The ethylene product is then sent to the ethylene oxide production units. The A3 olefins unit produces 50% of the ethylene feed with the remainder coming from off-site sources via pipeline. Indorama operates three ethylene oxide production units (F4, F6, and F8 units) to produce ethylene oxide, which is then used in the production of ethylene glycols, ethanolamines, and surfactants. Indorama also ships some of the produced ethylene oxide offsite via railcar. At the time of the NEIC inspection, unit F4 was not operating due to maintenance activities. A process description containing confidential business information is included in Appendix A. FIELD ACTIVITIES SUMMARY The NEIC field team consisted of Armando Bustamante, Brianna Leiker, Zel Nabiyar, Cindy Schafer, and Matthew Schneider. The NEIC field team was joined by Justin Chen, Benjamin Donaldson, and Colleen McCarthy of EPA Region 6 during the on-site inspection. On October 17, 2022, the NEIC field team conducted an opening meeting and presented credentials to Adam Brown, Indorama's regional representative for environmental, health, and safety. The compliance evaluation included: Conducting a detailed process review Interviewing plant personnel NEICVP1446E01 Page 4 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Conducting a process area walkthrough and inspection Reviewing reports and records Conducting leak detection and repair (LDAR) monitoring and data evaluation (data evaluation ongoing as of the date of this report) Identifying and recording volatile organic compound (VOC) emissions using optical gas imaging (OGI) Evaluating compliance with the following applicable regulations: 40 Code of Federal Regulations (CFR) Part 63 Subpart YY - National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories: Generic Maximum Achievable Control Technology Standards (Ethylene Production) 40 CFR Part 63 Subpart XX - National Emission Standards for Ethylene Manufacturing Process Units: Heat Exchange Systems and Waste Operations 40 CFR Part 63 Subpart G - National Emission Standards for Organic Hazardous Air Pollutants From the Synthetic Organic Chemical Manufacturing Industry for Process Vents, Storage Vessels, Transfer Operations, and Wastewater 40 CFR Part 63 Subpart H - National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks 40 CFR Part 60 Subpart VV - Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry for Which Construction, Reconstruction, or Modification Commenced After January 5, 1981, and on or Before November 7, 2006 40 CFR Part 61 Subpart FF - National Emission Standard for Benzene Waste Operations (BWON) BWON Indorama is a chemical plant subject to the BWON and has reported that its aqueous waste contains more than 10 megagrams (Mg) of benzene per year; therefore, it is required to implement a strategy to control benzene emissions from facility waste operations. Indorama has selected the compliance option as described in 40 CFR 61.342(c), also known as the "2 Mg" option. The 2 Mg compliance option requires the control of all organic and aqueous waste streams that contain benzene. Indorama can exempt waste streams from control that contain less than 10 parts per million (ppm) benzene and exempt additional waste streams, but the total annual benzene quantity of the additional exempted waste streams must be less than or equal to 2 Mg per year. Storage Tanks Indorama operates four main atmospheric tanks that collect process streams and saleable product from the A3 olefins unit and four chilled, pressurized spheres that store ethylene oxide. NEICVP1446E01 Page 5 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) These storage tanks are associated with process areas inspected by NEIC (A3 and F6 units). As described in Appendix A, these include two internal floating roof AD tanks (T-O-87 and T-O-88) and two fixed-roof AD tanks (T-O-126 and T-O-127). All four AD tanks vent to one of two bladder tanks, which then vent to a flare. The NEIC field team inspected each of the four AD tanks, two bladder tanks, and two of the ethylene oxide storage spheres using toxic vapor analyzers (TVAs) and infrared (IR) cameras from ground level and from the platform at the tank tops. In addition, the NEIC field team requested inspection records of the AD tanks and internal floating roofs. Flaring Indorama operates three plant flares: north flare (flare No. 1), central flare (flare No. 2), and south flare (flare No. 3). The north and central flares are low-pressure flares, and the south flare is a high-pressure flare. All three flares are steam-assisted, and each flare is equipped with a gas flow meter, a steam flow meter, a British thermal unit (BTU) analyzer, and three thermocouples and a flame sensor camera for pilot flame verification. The NEIC field team requested the continuous data collected by these monitors at hourly intervals from April 16October 21, 2022. Indorama representatives stated that the only continuous flow to flares is residue gas as sweep gas and that no other processes continuously vent to flares. Indorama representatives stated that the flare sources are mainly the A3 olefins unit (ethylene production unit), with some contribution from loading operations (receiving and shipping [R&S]). In addition, emissions from the AD tanks are controlled by the north and central flares. Natural gas is added as supplemental fuel for each flare. Measurement Activities The NEIC field team provided support to this investigation by conducting LDAR monitoring and OGI. Table 4 summarizes field measurement activities; additional information can be found in the LDAR monitoring summary (Appendix B), the OGI survey images and videos (Appendix C), and the project file. All environmental measurement activities were performed in accordance with the NEIC quality system. All field measurements/monitoring described in this report are within the scope of NEIC's ISO/IEC 17025 accreditation issued by the ANSI National Accreditation Board (certificate No. FT-0303). NEICVP1446E01 Page 6 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Location Identifier Process areas and regulated LDAR equipment Table 4. FIELD MEASUREMENT ACTIVITIES Dates Method and/or Procedure1, and Equipment October 18 and 20, 2022 Method: EPA Method 21: Determination of Volatile Organic Compound Leaks NEIC Procedure: Toxic Vapor Analyzer (TVA), NEICPROC/00-016 Equipment: Thermo Scientific TVA 2020 toxic vapor analyzer, NEIC ID Nos. B24213, B24309, and B24311 Used to screen location for safety October 18 and 20, 2022 NEIC procedure: Safety and Sample Screening Instruments, NEICPROC/17-002 Instrument guide: MSA Altair 5X MultiGas Monitoring Equipment Equipment: MSA Altair 5x multiple-gas monitor, NEIC ID No. SN2624 1 The current version of each procedure, at the time of the investigation, was followed. Measurer Name Cindy Schafer (B24311) Matthew Schneider (B24309) (B24213) Armando Bustamante NEICVP1446E01 Page 7 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) INVESTIGATION OBSERVATIONS NEIC identified the following observations during the Clean Air Act compliance inspection. NEIC field team members discussed all observations made at the time of the site inspection with facility representatives during the closeout meeting. These observations are not final compliance determinations. EPA Region 6 will make the final compliance determinations based on its review of this report and other technical, regulatory, and facility information. Observation 1 Observation Summary: Indorama did not identify and report all points of benzene waste generation and did not identify and report points of benzene waste generation in the correct locations. Citation: 40 CFR Part 63 Subpart XX - National Emission Standards for Ethylene Manufacturing Process Units: Heat Exchange Systems and Waste Operations 40 CFR 63.1091 What do the waste requirements do? This subpart requires you to comply with 40 CFR part 61, subpart FF, National Emission Standards for Benzene Waste Operations... 40 CFR Part 61 Subpart FF - National Emission Standard for Benzene Waste Operations 40 CFR 61.342 - Standards: General. (a) An owner or operator of a facility at which the total annual benzene quantity from facility waste is less than 10 megagrams per year (Mg/yr) (11 ton/yr) shall be exempt from the requirements of paragraphs (b) and (c) of this section. The total annual benzene quantity from facility waste is the sum of the annual benzene quantity for each waste stream at the facility that has a flow-weighted annual average water content greater than 10 percent or that is mixed with water, or other wastes, at any time and the mixture has an annual average water content greater than 10 percent. The benzene quantity in a waste stream is to be counted only once without multiple counting if other waste streams are mixed with or generated from the original waste stream. Other specific requirements for calculating the total annual benzene waste quantity are as follows: (4) The total annual benzene quantity is determined based upon the quantity of benzene in the waste before any waste treatment occurs to remove the benzene except as specified in 61.355(c)(1)(i) (A) through (C). 40 CFR 61.357 Reporting requirements. (a) Each owner or operator of a chemical plant, petroleum refinery, coke by-product recovery plant, and any facility managing wastes from these industries shall submit to the Administrator within 90 days after January 7, 1993, or by the initial startup for a new source with an initial startup after the effective date, a report that summarizes the regulatory status of each waste stream subject to 61.342 and is determined by the procedures specified in NEICVP1446E01 Page 8 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 1 61.355(c) to contain benzene. Each owner or operator subject to this subpart who has no benzene onsite in wastes, products, by-products, or intermediates shall submit an initial report that is a statement to this effect. For all other owners or operators subject to this subpart, the report shall include the following information: (1) Total annual benzene quantity from facility waste determined in accordance with 61.355(a) of this subpart. (2) A table identifying each waste stream and whether or not the waste stream will be controlled for benzene emissions in accordance with the requirements of this subpart. (3) For each waste stream identified as not being controlled for benzene emissions in accordance with the requirements of this subpart the following information shall be added to the table: (i) Whether or not the water content of the waste stream is greater than 10 percent; (ii) Whether or not the waste stream is a process wastewater stream, product tank drawdown, or landfill leachate; (iii) Annual waste quantity for the waste stream; (iv) Range of benzene concentrations for the waste stream; (v) Annual average flow-weighted benzene concentration for the waste stream; and (vi) Annual benzene quantity for the waste stream. (4) The information required in paragraphs (a) (1), (2), and (3) of this section should represent the waste stream characteristics based on current configuration and operating conditions. An owner or operator only needs to list in the report those waste streams that contact materials containing benzene. The report does not need to include a description of the controls to be installed to comply with the standard or other information required in 61.10(a). (d) If the total annual benzene quantity from facility waste is equal to or greater than 10 Mg/yr (11 ton/yr), then the owner or operator shall submit to the Administrator the following reports: (2) Beginning on the date that the equipment necessary to comply with these standards has been certified in accordance with paragraph (d)(1) of this section, the owner or operator shall submit annually to the Administrator a report that updates the information listed in paragraphs (a)(1) through (a)(3) of this section. If the information in the annual report required by paragraphs (a)(1) through (a)(3) of this NEICVP1446E01 Page 9 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 1 section is not changed in the following year, the owner or operator may submit a statement to that effect. 40 CFR 61.341 Definitions. Point of waste generation means the location where the waste stream exits the process unit component or storage tank prior to handling or treatment in an operation that is not an integral part of the production process, or in the case of waste management units that generate new wastes after treatment, the location where the waste stream exits the waste management unit component. Waste stream means the waste generated by a particular process unit, product tank, or waste management unit. The characteristics of the waste stream (e.g., flow rate, benzene concentration, water content) are determined at the point of waste generation. Examples of a waste stream include process wastewater, product tank drawdown, sludge and slop oil removed from waste management units, and landfill leachate. Waste means any material resulting from industrial, commercial, mining or agricultural operations, or from community activities that is discarded or is being accumulated, stored, or physically, chemically, thermally, or biologically treated prior to being discarded, recycled, or discharged. 40 CFR Part 63 Subpart XX - National Emission Standards for Ethylene Manufacturing Process Units: Heat Exchange Systems and Waste Operations 40 CFR 63.1082 What definitions do I need to know? Dilution steam blowdown waste stream means any continuously flowing process wastewater stream resulting from the quench and compression of cracked gas (the cracking furnace effluent) at an ethylene production unit and is discharged from the unit. This stream typically includes the aqueous or oily-water stream that results from condensation of dilution steam (in the cracking furnace quench system), blowdown from dilution steam generation systems, and aqueous streams separated from the process between the cracking furnace and the cracked gas dehydrators. The dilution steam blowdown waste stream does not include blowdown that has not contacted HAP-containing process materials... Evidence: Appendix D - 2018-2021 BWON TAB Reports Appendix A - Process Description [Contains CBI] Appendix E - 2021 TRI Report Field logbooks Description of Observation: Based on an in-depth review of the production processes and inspection of the site operations, Indorama did not identify all points of waste generation in its total annual benzene (TAB) reports (Appendix D). As described in the "Process Description" (Appendix A [Contains CBI]), ethylene gas and reaction byproducts from the cracking furnaces are quenched with water in the quench tower (F-101), and the condensed materials are collected in the quench drum (F-3). The NEICVP1446E01 Page 10 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 1 material collected in F-3 meets the definition of dilution steam blowdown waste because it is the continuously flowing wastewater stream from the cracking furnace quench system; therefore, the point of waste generation of the waste stream is the material being discharged from F-101 into F-3. Indorama has reported a waste stream called "O&O Quench Drum to WW Stripper," which, after a detailed process review, was determined to be the aqueous discharge from the wastewater coalescer to the stripper. The coalescer receives aqueous waste from the wastewater separator (F-58), which receives aqueous waste from F-3 and is located downstream of the point of waste generation after waste treatment had occurred (in a series of oil-water separators) to remove the benzene. The overhead gas stream from F-101 is compressed in a three-stage compressor, and for several stages of compression, vapors are condensed into suction drums or knockout drums. The first-stage suction drum discharges directly into F-3. The second-stage suction drum collects condensate from the second- and third-stage discharge drums, the third-stage suction drum, and the caustic tower knockout drum (located between the second and third compressor stages). The second-stage suction drum is equipped with a weir that separates oil and water; the aqueous phase is sent to F-3, and the organic phase is sent to the AD storage tanks. The materials condensed and discharged from each of the suction drums, discharge drums, and caustic tower knockout drum also meet the definition of dilution steam blowdown waste because they are continuously flowing wastewater streams generated from the compression of cracked gas and located between the cracking furnace and the cracked gas dehydrators; therefore, these waste streams should each be individual points of waste generation. An inspection of the process unit and review of the TAB reports from 2018-2021 indicated additional points of benzene waste generation were not included in the TAB reports. The following potential points of benzene waste generation were not included in the TAB reports: Flare knockout tanks: Two low-pressure flares and one high-pressure flare are used to control vent streams that are expected to contain benzene. In the R&S area, a flare knockout tank collects liquids, and the collected liquids are pumped into the AD storage tanks. Additionally, one knockout tank for each flare is located at the flares themselves; each knockout tank collects liquids and sends the collected liquid to the AD storage tanks. Therefore, there are likely four points of waste generation associated with flare knockout pots that should be reported in the TAB report. Tank water draws (A-3 sump/wash oil/quench to T-O-88/126): This waste stream listed in the TAB reports is not described accurately, and after discussions with Indorama personnel, it appears to be several waste streams reported as a combined stream. The A3 sump collects mainly rainwater and process area drainage, and the material collected in the sump is sent to AD storage and is expected to contain benzene. According to Indorama personnel, the wash oil/quench to T-O-88/128 waste stream is likely the tank water draws from the AD storage tanks. However, there are four AD storage tanks, each with water draws that are sent to F-3. The benzene concentration reported for the combined stream is an average of 19.67 ppm. Because the AD is approximately 40% benzene, the water drawn off the bottom of the tanks (mixed with the AD in previous NEICVP1446E01 Page 11 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 1 processing steps) likely has a benzene concentration significantly higher than 20 ppm, and Indorama has not provided NEIC with analytical data to support the reported concentration. Each of these points of waste generation should be reported separately in the TAB report. The combined waste stream has been reported as an uncontrolled waste stream contributing to the 2Mg benzene/year that is exempt from control. Fuel gas knockout drum and coalescer: Wastewater generated in the ethylene process area and drawn off the AD storage tanks is stripped in a steam stripper. The stripped gas is used in the cracking furnaces but is first passed through a knockout drum and coalescer to remove entrained liquids. The liquids generated in the fuel gas knockout drum and coalescer are discharged to the quench tower and are expected to contain benzene. F-3 blowdown to tar tank: Liquid from the bottom of F-3 is blown down to the tar tank several times a day. The tar tank is vented to carbon drums as a control device. Tar that is entrained in the liquid is allowed to settle, and then the tar tank is periodically decanted into an open drain without a water seal. The TAB reports list the tar tank decant into the open drain, which is reported as uncontrolled, but a point of waste generation is where it is blown down from the F-3 quench drum prior to volatilization of the benzene in the tar tank. Low-point drains: NEIC field team members observed numerous low-point drains located on process vessels and piping throughout the A3 process area. Presumably, the drains may be used when maintenance is performed, or possibly during routine operations. The TAB reports did not list any equipment drains; if these drains are used, the resulting waste streams are discharged to uncontrolled individual drains (with a visible gap below the drain) or open concrete-lined trenches within the process area. Pump blowdowns: The TAB reports did not list any waste generated from pumps, but pumps are known to be drained for maintenance or have pump seal leaks. The pumps observed in the process area would be drained onto diked areas or into open trenches and would not be considered controlled. Spills: The TAB reports did not list any benzene waste generated from spills. NEIC did not investigate whether Indorama had any spills during the 4 years of TAB reports reviewed by the field team. Waste shipped off-site: The TAB reports list a "hazardous lab pack" waste stream; however, the 2021 TAB report did not report any benzene waste from this waste stream. A review of the facility's 2021 Toxic Release Inventory (TRI) report (Appendix E) revealed that approximately 2,000 pounds of benzene waste were shipped off-site to Clean Harbors for disposal as hazardous waste. It is not clear if the lab pack waste stream is the same waste stream that was listed as shipped off-site in the 2021 TRI report. Turnaround waste: Every 5 years, the ethylene process unit undergoes a turnaround during which all process fluid is drained, and the equipment is inspected and repaired. One of the known waste streams that is generated during process unit turnarounds is the tar that is removed from the process and collected in the tar tank, which is removed from the tank during the turnaround. Generally, a large quantity of miscellaneous waste is generated during facility turnarounds. A process unit turnaround last occurred in 2018, but no turnaround waste was reported in the 2018 TAB report. NEICVP1446E01 Page 12 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 1 Sample station purges: NEIC did not verify the locations of sample stations or how the purges are managed, but any purged material from the sampling stations should be considered waste and be reported in the TAB report. AD loading drips: The AD is loaded onto tank trucks, and the drips from the loading operations land in a concrete diked area and are collected in one of two open sumps. Vacuum trucks pump out the sumps and load the pumped material back into the AD tanks. Observation 2 Observation Summary: Indorama did not route all organic vapors from oil-water separators to a control device and did not operate or maintain the fixed roofs without detectable emissions. Citation: 40 CFR Part 61 Subpart FF - National Emission Standard for Benzene Waste Operations 61.341 Definitions. Oil-water separator means a waste management unit, generally a tank or surface impoundment, used to separate oil from water... 40 CFR 61.347 Standards: Oil-water separators. (a) Except as provided in 61.352 of this subpart, the owner or operator shall meet the following standards for each oil-water separator in which waste is placed in accordance with 61.342(c)(1)(ii) of this subpart: (1) The owner or operator shall install, operate, and maintain a fixed-roof and closedvent system that routes all organic vapors vented from the oil-water separator to a control device. (i) The fixed-roof shall meet the following requirements: (A) The cover and all openings (e.g., access hatches, sampling ports, and gauge wells) shall be designed to operate with no detectable emissions as indicated by an instrument reading of less than 500 ppmv above background, as determined initially and thereafter at least once per year by the methods specified in 61.355(h) of this subpart. Evidence: Appendix B - LDAR Monitoring Summary Appendix C - OGI Survey Images and Videos Field logbooks Description of Observation: The AD tanks collect aromatic distillate from the quench drum, wastewater separator, caustic separator, and various sumps throughout the ethylene process area. Water is brought over with the distillate and is separated in the AD tanks by periodically NEICVP1446E01 Page 13 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 2 draining water from the tanks back into F-3. Therefore, the AD tanks are operated as oilwater separators that are managing benzene waste. There are four AD tanks. Tanks 126 and 127 are each equipped with an internal floating roof and a fixed roof. Tanks 87 and 88 are only equipped with a fixed roof. Tank 87 was out of service at the time of the inspection. The fixed roofs of all four tanks are vented to one of two bladder tanks. When the level of the bladder reaches a certain height, a vacuum pump is used to pull vapors from the bladder to be destroyed by a low-pressure flare. NEIC field team members observed vapors being emitted from pressure relief devices and various hatches on the top of the tanks. NEIC field team members measured and observed detectable emissions, using a TVA and an IR camera, at the following locations on the tanks: Tank 127 (Appendix C, videos 330, 332, and 333): Level transmitter hatch leaking at 20,000 ppm Gauge hatch leaking at 8,000 ppm White, rectangular hatch leaking at 10,000 ppm Pressure relief device observed leaking with IR camera but was not safe to monitor with TVA Tank 126 (Appendix C, videos 330 and 331): Gauge hatch leaking at 30,000 ppm Small, rectangular hatch leaking at 600 ppm Pressure relief device leaking at 40,000 ppm then flameout Second pressure relief device observed leaking with IR camera but was not safe to monitor with TVA Tank 88 (Appendix C, videos 427 and 428): Vacuum-break side of conservation vent leaking at 10,100 ppm Thief hatch leaking at 37,200 ppm then flameout Observation 3 Observation Summary: Indorama did not operate a closed-vent system (CVS) that routes all organic vapors to a control device and did not operate or maintain the closed-vent system without detectable emissions. Citation: 40 CFR Part 61 Subpart FF - National Emission Standard for Benzene Waste Operations 40 CFR 61.347 Standards: Oil-water separators. (a) Except as provided in 61.352 of this subpart, the owner or operator shall meet the following standards for each oil-water separator in which waste is placed in accordance with 61.342(c)(1)(ii) of this subpart: NEICVP1446E01 Page 14 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 3 (1) The owner or operator shall install, operate, and maintain a fixed-roof and closedvent system that routes all organic vapors vented from the oil-water separator to a control device. (ii) The closed-vent system and control device shall be designed and operated in accordance with the requirements of 61.349 of this subpart. 40 CFR 61.349 Standards: Closed-vent systems and control devices. (a) For each closed-vent system and control device used to comply with standards in accordance with 61.343 through 61.348 of this subpart, the owner or operator shall properly design, install, operate, and maintain the closed-vent system and control device in accordance with the following requirements: (1) The closed-vent system shall: (i) Be designed to operate with no detectable emissions as indicated by an instrument reading of less than 500 ppmv above background, as determined initially and thereafter at least once per year by the methods specified in 61.355(h) of this subpart. Evidence: Appendix B - LDAR Monitoring Summary Appendix C - OGI Survey Images and Videos Field logbooks Description of Observation: As described previously, the AD tanks are vented to one of two bladder tanks; the vapors collected in the bladder tanks are discharged to one of the lowpressure flares. NEIC field team members observed emissions from both bladder tanks at the outlet of the vent stacks located on top of the tanks. Because the bladder tanks are collecting the vapors from the oil-water separators and then conveying the gas to a control device, the bladder tanks are part of the closed-vent system and are required to be operated with no detectable emissions. Using a TVA, NEIC field team members measured detectable emissions of 8,000 ppm from one of the three vent stacks on bladder tank F-114A and emissions of 4,200 ppm and 4,300 ppm from two of the three vent stacks on bladder tank F-114B. NEIC field team members also observed the emissions using an IR camera (Appendix C, videos 334 and 336). Observation 4 Observation Summary: Indorama likely did not conduct required inspections and monitoring of benzene waste management units and treatment processes. Citation: 40 CFR Part 61 Subpart FF - National Emission Standard for Benzene Waste Operations 40 CFR 61.341 Definitions. NEICVP1446E01 Page 15 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 4 Sewer line means a lateral, trunk line, branch line, or other enclosed conduit used to convey waste to a downstream waste management unit. Treatment process means a stream stripping unit, thin-film evaporation unit, waste incinerator, or any other process used to comply with 61.348 of this subpart. Waste management unit means a piece of equipment, structure, or transport mechanism used in handling, storage, treatment, or disposal of waste. Examples of a waste management unit include a tank, surface impoundment, container, oil-water separator, individual drain system, steam stripping unit, thin-film evaporation unit, waste incinerator, and landfill. Waste means any material resulting from industrial, commercial, mining or agricultural operations, or from community activities that is discarded or is being accumulated, stored, or physically, chemically, thermally, or biologically treated prior to being discarded, recycled, or discharged. Waste stream means the waste generated by a particular process unit, product tank, or waste management unit. The characteristics of the waste stream (e.g., flow rate, benzene concentration, water content) are determined at the point of waste generation. Examples of a waste stream include process wastewater, product tank drawdown, sludge and slop oil removed from waste management units, and landfill leachate. 40 CFR 61.343 Standards: Tanks. (a)(1) The owner or operator shall install, operate, and maintain a fixed-roof and closed-vent system that routes all organic vapors vented from the tank to a control device. (i) The fixed-roof shall meet the following requirements: (A) The cover and all openings (e.g., access hatches, sampling ports, and gauge wells) shall be designed to operate with no detectable emissions as indicated by an instrument reading of less than 500 ppmv above background, as determined initially and thereafter at least once per year by the methods specified in 61.355(h) of this subpart. 40 CFR 61.346 - Standards: Individual drain systems. (a) Except as provided in paragraph (b) of this section, the owner or operator shall meet the following standards for each individual drain system in which waste is placed in accordance with 61.342(c)(1)(ii) of this subpart: (1) The owner or operator shall install, operate, and maintain on each drain system opening a cover and closed-vent system that routes all organic vapors vented from the drain system to a control device. NEICVP1446E01 Page 16 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 4 (b) As an alternative to complying with paragraph (a) of this section, an owner or operator may elect to comply with the following requirements: (3) Each sewer line shall not be open to the atmosphere and shall be covered or enclosed in a manner so as to have no visual gaps or cracks in joints, seals, or other emission interfaces. (4) Equipment installed in accordance with paragraphs (b)(1), (b)(2), or (b)(3) of this section shall be inspected as follows: (iv) The unburied portion of each sewer line shall be visually inspected initially and thereafter quarterly for indication of cracks, gaps, or other problems that could result in benzene emissions. 40 CFR 61.347 Standards: Oil-water separators. (a)(1) The owner or operator shall install, operate, and maintain a fixed-roof and closed-vent system that routes all organic vapors vented from the oil-water separator to a control device. (i) The fixed-roof shall meet the following requirements: (A) The cover and all openings (e.g., access hatches, sampling ports, and gauge wells) shall be designed to operate with no detectable emissions as indicated by an instrument reading of less than 500 ppmv above background, as determined initially and thereafter at least once per year by the methods specified in 61.355(h) of this subpart. (b) Each cover seal, access hatch, and all other openings shall be checked by visual inspection initially and quarterly thereafter to ensure that no cracks or gaps occur between the cover and oil-water separator wall and that access hatches and other openings are closed and gasketed properly. 40 CFR 61.348 - Standards: Treatment processes. (e) Except as specified in paragraph (e)(3) of this section, if the treatment process or wastewater treatment system unit has any openings (e.g., access doors, hatches, etc.), all such openings shall be sealed (e.g., gasketed, latched, etc.) and kept closed at all times when waste is being treated, except during inspection and maintenance. (1) Each seal, access door, and all other openings shall be checked by visual inspections initially and quarterly thereafter to ensure that no cracks or gaps occur and that openings are closed and gasketed properly. Evidence: Appendix F - Monthly Visual Inspection Records Appendix G - 2021 BWON LDAR Monitoring Records Description of Observation: Waste management units have inspection and monitoring requirements, which depend on the type of unit managing benzene waste. NEIC requested NEICVP1446E01 Page 17 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 4 BWON-specific inspection records for the various types of waste management units at the site. Based on discussions with facility personnel, Indorama has not implemented a monitoring and inspection program specific to BWON, but the facility provided NEIC records of monthly visual inspections conducted within the ethylene process unit (presumably to demonstrate that quarterly visual inspections are taking place), as well as records of LDAR monitoring performed within the unit that have been categorized as subject to BWON monitoring requirements (Appendices F and G). Based on historical records of leaking components, it appears Indorama is conducting EPA Method 21 monitoring on some equipment subject to BWON monitoring requirements; however, it is not possible to determine if monitoring has been conducted on all required waste management units. The BWON waste management units also have a quarterly visual inspection requirement. NEIC requested records of the quarterly inspections, and Indorama provided a checklist of equipment that is inspected monthly. The inspection checklist does not specify which pieces of equipment are being inspected or that any of the equipment is specifically inspected for evidence of gaps, cracks, defects, or other problems that could result in benzene emissions. Because NEIC is unable to determine whether all required inspections are being performed, NEIC identified the following list of waste management units as equipment subject to the BWON inspection requirements that may not have been inspected. Oil-water separators managing waste that NEIC field team members identified, but that Indorama may not have inspected (annual EPA Method 21 and quarterly visual inspections), include: F-58 waste water separator Wastewater coalescer F-59 caustic phase separator F-3 quench drum F-5 second-stage suction drum AD tanks F-36 aromatic distillate coalescer The following tanks managing benzene waste may not have been included in the annual EPA Method 21 monitoring required by the BWON: Tar tank F-4 first-stage suction drum F-6 second-stage discharge drum F-16 caustic tower knockout drum F-8 third-stage suction drum F-9 third-stage discharge drum F-51 fuel gas knockout drum F-120 A/B coalescers Flare knockout tanks NEICVP1446E01 Page 18 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 4 The unburied portions of the following sewer lines may not have been included in the quarterly visual inspections required by the BWON: Line from F-3 quench drum to F-58 waste water separator Line from F-3 quench drum to tar tank Line from F-3 quench drum to AD tanks Line from F-58 waste water separator to D-8 A/B pre-filters Line from D-8 A/B pre-filters to wastewater coalescer Line from wastewater coalescer to F-205 A/B wastewater stripper Line from F-59 caustic phase separator to F-205 A/B wastewater stripper Line from F-58 wastewater separator to AD tanks Line from F-59 caustic phase separator to AD tanks Line from F-51 fuel gas knockout drum to quench tower Line from F-120 A/B coalescers to quench tower Line from F-4 first-stage suction drum to AD tanks Line from F-5 second-stage suction drum to quench drum Line from F-5 second-stage suction drum to AD tanks Line from F-6 second-stage discharge drum to F-5 second-stage suction drum Line from F-16 caustic tower knockout drum to F-5 second-stage suction drum Line from F-8 third-stage suction drum to F-5 second-stage suction drum Line from F-9 third-stage discharge drum to F-6 second-stage discharge drum Line from F-51 fuel gas knockout drum to quench tower Line from F-120 A/B fuel gas coalescers to quench tower Line from F-114 debutanizer to AD tanks The following treatment process may not have been included in the quarterly visual inspections required by the BWON: F-205 A/B wastewater stripper Observation 5 Observation Summary: Indorama failed to comply with the 2 Mg compliance option because the facility managed more than 2 Mg of benzene waste in non-compliant waste management units. Citation: 40 CFR Part 61 Subpart FF - National Emission Standard for Benzene Waste Operations 40 CFR 61.342 Standards: General. (c) Each owner or operator of a facility at which the total annual benzene quantity from facility waste is equal to or greater than 10 Mg/yr (11 ton/yr) as determined in paragraph (a) of this section shall manage and treat the facility waste as follows: NEICVP1446E01 Page 19 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 5 (1) For each waste stream that contains benzene, including (but not limited to) organic waste streams that contain less than 10 percent water and aqueous waste streams, even if the wastes are not discharged to an individual drain system, the owner or operator shall: (i) Remove or destroy the benzene contained in the waste using a treatment process or wastewater treatment system that complies with the standards specified in 61.348 of this subpart. (ii) Comply with the standards specified in 61.343 through 61.347 of this subpart for each waste management unit that receives or manages the waste stream prior to and during treatment of the waste stream in accordance with paragraph (c)(1)(i) of this section. (iii) Each waste management unit used to manage or treat waste streams that will be recycled to a process shall comply with the standards specified in 61.343 through 61.347. Once the waste stream is recycled to a process, including to a tank used for the storage of production process feed, product, or product intermediates, unless this tank is used primarily for the storage of wastes, the material is no longer subject to paragraph (c) of this section. (2) A waste stream is exempt from paragraph (c)(1) of this section provided that the owner or operator demonstrates initially and, thereafter, at least once per year that the flow-weighted annual average benzene concentration for the waste stream is less than 10 ppmw as determined by the procedures specified in 61.355(c)(2) or 61.355(c)(3). (3) A waste stream is exempt from paragraph (c)(1) of this section provided that the owner or operator demonstrates initially and, thereafter, at least once per year that the conditions specified in either paragraph (c)(3)(i) or (c)(3)(ii) of this section are met. (i) The waste stream is process wastewater that has a flow rate less than 0.02 liters per minute (0.005 gallons per minute) or an annual wastewater quantity of less than 10 Mg/yr (11 ton/yr); or (ii) All of the following conditions are met: (A) The owner or operator does not choose to exempt process wastewater under paragraph (c)(3)(i) of this section, (B) The total annual benzene quantity in all waste streams chosen for exemption in paragraph (c)(3)(ii) of this section does not exceed 2.0 Mg/yr (2.2 ton/yr) as determined in the procedures in 61.355(j), and (C) The total annual benzene quantity in a waste stream chosen for exemption, including process unit turnaround waste, is determined for the year in which the waste is generated. NEICVP1446E01 Page 20 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 5 40 CFR 61.355 (a) An owner or operator shall determine the total annual benzene quantity from facility waste by the following procedure: (1) For each waste stream subject to this subpart having a flow-weighted annual average water content greater than 10 percent water, on a volume basis as total water, or is mixed with water or other wastes at any time and the resulting mixture has an annual average water content greater than 10 percent as specified in 61.342(a), the owner or operator shall: (i) Determine the annual waste quantity for each waste stream using the procedures specified in paragraph (b) of this section. (ii) Determine the flow-weighted annual average benzene concentration for each waste stream using the procedures specified in paragraph (c) of this section. (iii) Calculate the annual benzene quantity for each waste stream by multiplying the annual waste quantity of the waste stream times the flow-weighted annual average benzene concentration. (b) For purposes of the calculation required by paragraph (a) of this section, an owner or operator shall determine the annual waste quantity at the point of waste generation... (j) An owner or operator shall determine the benzene quantity for the purposes of the calculation required by 61.342 (c)(3)(ii)(B) according to the provisions of paragraph (a) of this section, except that the procedures in paragraph (a) of this section shall also apply to wastes with a water content of 10 percent or less. Evidence: See Observations 2, 3, and 4. Appendix H - Aromatic Distillate Sales Data from November 2, 2021-November 3, 2022 Appendix I - Composition Data for Aromatic Distillate Description of Observation: Indorama has chosen the compliance option in 40 CFR 61.342(c), which requires either the management and treatment of all benzene-containing waste streams such that 99% of the benzene is removed from or destroyed in the waste stream or the waste stream is treated such that the benzene concentration is less than 10 parts per million by weight (ppmw). Waste streams with benzene concentrations less than 10 ppmw are exempt from this control requirement, and Indorama may exempt waste streams containing a total (cumulative) annual benzene quantity less than or equal to 2.0 Mg/yr. This is known as the 2 Mg compliance option. Under the 2 Mg compliance option, Indorama is required to determine the benzene quantity in waste streams based on the calculation specified in 40 CFR 61.355(j); specifically, the benzene quantity is determined at each location where a waste stream is generated, before it is treated, and before any other wastes are mixed with or dilute the waste stream. Each benzene-containing waste stream must be managed in waste management units complying with the applicable requirements in 40 CFR 61.343-61.347. Only 2 Mg of benzene may be exempted from the control requirement, as well as any waste streams containing less than 10 ppm benzene. NEICVP1446E01 Page 21 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 5 Indorama failed to manage benzene waste in compliant waste management units as required in 40 CFR 61.342(c). The waste streams entering each non-compliant waste management unit should be considered uncontrolled, and the benzene quantity within the waste should count toward the allowable 2 Mg benzene per year exempted from control. Indorama did not route all the organic vapors from the AD tanks to a control device, as required (see Observations 2 and 3). Based on AD sales data from November 2, 2021November 3, 2022 (Appendix H), 33,299,120 pounds of AD were sold during the past year. Analytical data for the AD composition also provided by Indorama (Appendix I) indicate the AD is approximately 43% benzene by weight. Therefore, at least 14,318,622 pounds (6,495 Mg) of benzene were managed in the AD tanks during the past year. This quantity of benzene underestimates the total benzene managed in the AD tanks because it only includes the benzene contained in the organic phase of the oil-water separators. Because Indorama did not route all organic vapors from oil-water separators to a control device, all benzene entering the AD tanks is considered uncontrolled, substantially exceeding the 2 Mg per year limit. Observation 6 Observation Summary: NEIC field team members observed emissions from portions of the ethylene process area individual drain system. Citation: 40 CFR Part 61 Subpart FF - National Emission Standard for Benzene Waste Operations 40 CFR 61.341 - Definitions. Individual drain system means the system used to convey waste from a process unit, product storage tank, or waste management unit to a waste management unit. The term includes all process drains and common junction boxes, together with their associated sewer lines and other junction boxes, down to the receiving waste management unit. Sewer line means a lateral, trunk line, branch line, or other enclosed conduit used to convey waste to a downstream waste management unit. Waste management unit means a piece of equipment, structure, or transport mechanism used in handling, storage, treatment, or disposal of waste. Examples of a waste management unit include a tank, surface impoundment, container, oil-water separator, individual drain system, steam stripping unit, thin-film evaporation unit, waste incinerator, and landfill. NEICVP1446E01 Page 22 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) 40 CFR 61.346 Standards: Individual drain systems. (a) Except as provided in paragraph (b) of this section, the owner or operator shall meet the following standards for each individual drain system in which waste is placed in accordance with 61.342(c)(1)(ii) of this subpart: (1) The owner or operator shall install, operate, and maintain on each drain system opening a cover and closed-vent system that routes all organic vapors vented from the drain system to a control device. (b) As an alternative to complying with paragraph (a) of this section, an owner or operator may elect to comply with the following requirements: (1) Each drain shall be equipped with water seal controls or a tightly sealed cap or plug. (3) Each sewer line shall not be open to the atmosphere and shall be covered or enclosed in a manner so as to have no visual gaps or cracks in joints, seals, or other emission interfaces. (4) Equipment installed in accordance with paragraphs (b)(1), (b)(2), or (b)(3) of this section shall be inspected as follows: (i) Each drain using water seal controls shall be checked by visual or physical inspection initially and thereafter quarterly for indications of low water levels or other conditions that would reduce the effectiveness of water seal controls. (iv) The unburied portion of each sewer line shall be visually inspected initially and thereafter quarterly for indication of cracks, gaps, or other problems that could result in benzene emissions. (5) Except as provided in 61.350 of this subpart, when a broken seal, gap, crack or other problem is identified, first efforts at repair shall be made as soon as practicable, but not later than 15 calendar days after identification. 40 CFR Part 61 Subpart A - General Provisions 40 CFR 61.01 Lists of pollutants and applicability of part 61. (c) This part applies to the owner or operator of any stationary source for which a standard is prescribed under this part. 40 CFR 61.12 Compliance with standards and maintenance requirements. (c) The owner or operator of each stationary source shall maintain and operate the source, including associated equipment for air pollution control, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available NEICVP1446E01 Page 23 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 6 to the Administrator which may include, but is not limited to, monitoring results, review of operating and maintenance procedures, and inspection of the source. Evidence: Appendix B - LDAR Monitoring Summary Appendix C - OGI Survey Images and Videos Field logbooks Description of Observation: NEIC field team members observed several drain system openings, trenches, and wastewater piping and conveyance equipment within the ethylene process area. In several locations, using a TVA, NEIC field team members measured elevated organic vapor emissions from the individual drain system. An example is a drain system opening located below the A3 olefins unit low-pressure flare knockout tank (F-45). NEIC field team members traced the three individual drain lines that discharge to the drain system opening below F-45 and observed that two of them were from decommissioned process equipment (not in service). The third drain was for condensate from a non-contact steam tracing line (not expected to contain organic compounds) that is used to vaporize the contents of the knockout pot. However, organic vapors were coming from the drain system opening and overwhelmed the TVA, causing it to flame out. NEIC field team members could not verify the presence of a water seal in the drain system opening, and, based on the emissions from the drain system opening, there likely was not a water seal control installed at the time of inspection. Another concern was a seal vent installed on the debutanizer bottoms pump (AD pump A338A), which, at the time of the NEIC inspection, was open to atmosphere and venting emissions measured at 87,000 ppm (Appendix C, video 328). A drain located on the piping connected to the pump was designed to discharge material into an uncovered concrete ditch; the plug at the end of the drain measured emissions of 1,900 ppm (Indorama personnel confirmed with the facility's TVA that it was leaking at 10,000 ppm). The pump is used to convey aromatic distillate (high in benzene) to the AD tanks from the bottoms of the debutanizer and is part of the individual drain system. As described previously in Observation 1, Indorama's TAB reports did not report any waste from pump drains. The pump itself is a waste management unit because it is a piece of equipment or transport mechanism used in handling waste, but there are no specific standards for this type of waste management unit in Subpart FF. However, the general provisions (Subpart A) of 40 CFR Part 61 apply to Subpart FF and require Indorama to operate the source, including associated equipment for air pollution control, in a manner consistent with good air pollution control practice for minimizing emissions. The open seal vent (that was subsequently plugged following the on-site inspection) was indicative of the pump not being operated in a manner that minimized emissions of benzene from the waste. Observation 7 Observation Summary: Indorama did not maintain records of the underlying calculations and analytical data to support the information reported in the TAB reports. Information NEICVP1446E01 Page 24 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 7 presented in the TAB reports does not appear to be based on current configuration or operating conditions. Citation: 40 CFR Part 61 Subpart FF - National Emission Standard for Benzene Waste Operations 40 CFR 61.357 Reporting requirements. (a) Each owner or operator of a chemical plant, petroleum refinery, coke by-product recovery plant, and any facility managing wastes from these industries shall submit to the Administrator within 90 days after January 7, 1993, or by the initial startup for a new source with an initial startup after the effective date, a report that summarizes the regulatory status of each waste stream subject to 61.342 and is determined by the procedures specified in 61.355(c) to contain benzene. Each owner or operator subject to this subpart who has no benzene onsite in wastes, products, by-products, or intermediates shall submit an initial report that is a statement to this effect. For all other owners or operators subject to this subpart, the report shall include the following information: (1) Total annual benzene quantity from facility waste determined in accordance with 61.355(a) of this subpart. (2) A table identifying each waste stream and whether or not the waste stream will be controlled for benzene emissions in accordance with the requirements of this subpart. (3) For each waste stream identified as not being controlled for benzene emissions in accordance with the requirements of this subpart the following information shall be added to the table: (i) Whether or not the water content of the waste stream is greater than 10 percent; (ii) Whether or not the waste stream is a process wastewater stream, product tank drawdown, or landfill leachate; (iii) Annual waste quantity for the waste stream; (iv) Range of benzene concentrations for the waste stream; (v) Annual average flow-weighted benzene concentration for the waste stream; and (vi) Annual benzene quantity for the waste stream. (4) The information required in paragraphs (a) (1), (2), and (3) of this section should represent the waste stream characteristics based on current configuration and operating conditions. An owner or operator only needs to list in the report those waste streams that contact materials containing benzene. The report does not need NEICVP1446E01 Page 25 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 7 to include a description of the controls to be installed to comply with the standard or other information required in 61.10(a). 40 CFR 61.356 Recordkeeping requirements. (a) Each owner or operator of a facility subject to the provisions of this subpart shall comply with the recordkeeping requirements of this section. Each record shall be maintained in a readily accessible location at the facility site for a period not less than two years from the date the information is recorded unless otherwise specified. (b) Each owner or operator shall maintain records that identify each waste stream at the facility subject to this subpart, and indicate whether or not the waste stream is controlled for benzene emissions in accordance with this subpart. In addition the owner or operator shall maintain the following records: (1) For each waste stream not controlled for benzene emissions in accordance with this subpart, the records shall include all test results, measurements, calculations, and other documentation used to determine the following information for the waste stream: waste stream identification, water content, whether or not the waste stream is a process wastewater stream, annual waste quantity, range of benzene concentrations, annual average flow-weighted benzene concentration, and annual benzene quantity. (2) For each waste stream exempt from 61.342(c)(1) in accordance with 61.342(c)(3), the records shall include: (ii) All measurements, calculations, and other documentation used to determine that the sum of the total annual benzene quantity in all exempt waste streams does not exceed 2.0 Mg/yr (2.2 ton/yr) in accordance with 61.342(c)(3)(ii). Evidence: Appendix D - 2018-2021 TAB Reports Appendix J - November 3, 2022, Email from Indorama Re: Follow-up Records Request Field logbooks Description of Observation: The NEIC field team requested the supporting information for the uncontrolled waste streams and their benzene quantities reported in the TAB reports (Appendix D). The information requested includes test results, measurements, calculations, and any other documentation used to determine the characteristics of the waste streams. Indorama could not locate any of the supporting documentation during the site visit and subsequently sent an email to NEIC that confirmed that the facility had used the reported waste stream characteristics since 2004 and could not locate the underlying supporting documentation (Appendix J). While Indorama is only required to keep this information in a readily accessible location for 2 years from the date the information is recorded, the information is required to be maintained by Indorama, with no time limit specified in the rule. NEICVP1446E01 Page 26 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 7 One specific concern is that the TAB reports need to reflect current configuration and operating conditions. An example is the combined waste stream "A-3 Sump/wash oil/quench to T-O-88/126," reported as uncontrolled in the TAB reports. As described in Observation 1, there is a concern that the reported benzene concentration may underrepresent the true concentration based on the solubility of benzene in water that has been mixed with AD. Additionally, for the reported waste stream, the TAB reports only mention T-O-88/126, which appears to describe two AD tanks (tanks 88 and 126). However, there are currently four AD tanks, and, therefore, the waste stream as reported is likely not based on the current configuration of the facility. Observation: 8 Observation Summary: In October 2019, a third-party compliance audit was performed and potential violations of 40 CFR Part 63, Subparts A, G, and FFFF, and 40 CFR Part 60, Subparts NNN, RRR, and VVa were identified. NEIC is not aware of disclosure of these potential violations to the EPA. Citation: Volume 65, Federal Register 19618 - 19627, April 11, 2000, Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations (EPA Audit Policy) Evidence: Appendix K - Third-Party Compliance Audit [Contains CBI] Appendix L - June 2022 Quarterly Audit Update to TCEQ Description of Observation: From October 28-30, 2019, Trinity Consultants conducted a third-party audit of the Indorama (was Huntsman at the time of the audit) Port Neches facility. The audit focused on the facility's compliance with 40 CFR Part 63, Subparts F and G, at the ethylene oxide, methyl tertiary butyl ether (MTBE), and propylene oxide chemical manufacturing operations (Appendix K). The third-party audit identified 12 areas of potential noncompliance and made recommendations for corrective actions. The following is a summary of the areas of potential noncompliance identified in the third-party audit; see the third-party audit report (Appendix K) for additional details: 1. Failure to maintain records of Hazardous Organic NESHAP (HON) applicability and update the notification of compliance status (NOCS) to reflect physical and operational changes to the affected facilities for F4, F5, and F6. 2. Failure to perform HON applicability determinations and submit a NOCS for F8. 3. Failure to identify group status and to maintain records of the determination for continuous process vents associated with the carbon dioxide (CO2) removal system for F4, F6, and F8. 4. Failure to identify all wastewater streams and conduct group status determinations under HON for F4, F5, F6, and F8. 5. Failure to identify and inspect all HON waste management units in F5. 6. Failure to identify process units subject to 40 CFR Part 60, Subparts NNN and RRR. 7. Failure to comply with 40 CFR Part 60, Subpart VVa (New Source Performance Standards [NSPS] VVa), after modifying affected facilities or to document that modifications did not trigger NSPS VVa applicability. NEICVP1446E01 Page 27 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation: 8 8. CVS inspections do not identify each portion of the closed-vent systems. 9. Documentation that the facility is meeting requirements applicable to bypass lines subject to 40 CFR Part 63, Subpart G. 10. Documentation demonstrating that 40 CFR Part 63, Subpart FFFF, does not apply to F5. 11. Startup, shutdown, and malfunction procedures not adequate to minimize releases from the recycle gas loop or the CO2 removal system. Indorama has had releases of ethylene oxide above the reportable quantity from the reclaim compressor gas and reabsorber towers from F4, F6, and F8. 12. Permitted potential to emit values do not support group 2 determinations for the CO2 vents and process wastewater for F4, F6, and F8. Indorama disclosed the potential violations to the Texas Commission on Environmental Quality (TCEQ) at some point. While the NEIC field team did not ascertain exactly when this disclosure was made, it appears there was periodic written correspondence between Indorama and TCEQ regarding the audit and the findings starting as far back September 27, 2019. The Federal Register notice for the EPA Audit Policy states that EPA will generally defer to state penalty mitigation for self-disclosures if the state policy meets minimum requirements. The notice also states that EPA is opposed to state statutory and regulatory audit laws that provide immunity, privilege, or shield evidence of wrongdoing and inhibit investigations. The NEIC field team did not find any evidence that disclosure to EPA had been made, or that EPA's audit policy was invoked. NEIC requested information about disclosure of the violations in the third-party audit to EPA during and following the on-site inspection. According to the April 11, 2000, Federal Register notice on the EPA Audit Policy, to take advantage of the EPA audit policy, a facility is required to: 1. Discover the violation through an environmental audit or the implementation of a compliance management system. 2. Discover the violation voluntarily and not as a result of a legally required monitoring, sampling, or auditing procedure. 3. Disclose the violation to EPA within 21 days of discovery. 4. Independently discover and disclose the violation before EPA or another regulator would likely have identified the violation. 5. Correct the violation within 60 days from the date of discovery. 6. Take actions to prevent the recurrence of the violation. 7. The violations may not be repeat violations. 8. The violations may not have resulted in serious actual harm, presented an imminent and substantial endangerment, or violated specific terms of an administrative or judicial order or consent agreement. 9. Cooperate with EPA's investigation of the disclosure. As of at least June 30, 2022, there are outstanding potential violations identified by the thirdparty audit that Indorama has not corrected (Appendix L). Based on this and the lack of disclosure of the violations to the EPA, Indorama does not meet requirements 3 and 5 above. NEICVP1446E01 Page 28 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 9 Observation Summary: The NOCS submitted for the A3 olefins and oxides process has not been updated to reflect current operating scenarios. Citation: 40 CFR Part 63 Subpart YY - National Emission Standards for Hazardous Air Pollutants for Source Categories: Generic Maximum Achievable Control Technology Standards 40 CFR 63.1110 Reporting requirements. (d) Notification of Compliance Status - (1) Contents. The owner or operator shall submit a Notification of Compliance Status for each affected source subject to this subpart containing the information specified in paragraphs (d)(1)(i) and (ii) of this section. ... For flares subject to the requirements of 63.1103(e)(4), the owner or operator of an ethylene production affected source shall also submit the information listed in paragraph (d)(1)(iv) of this section in a supplement to the Notification of Compliance Status within 150 days after the first applicable compliance date for flare monitoring. ... (i) Except as specified in paragraphs (d)(1)(iv) and (v) of this section, the Notification of Compliance Status shall include the information specified in this subpart and the subparts referenced by this subpart. Alternatively, this information can be submitted as part of a title V permit application or amendment. (ii) The Notification of Compliance Status shall include a statement from the owner or operator identifying which subpart he or she has elected to comply with, where given a choice, as provided for in 63.1100(g). (2) Due Date. The owner or operator shall submit the Notification of Compliance Status for each affected source 240 days after the compliance date specified for the affected source under this subpart, or 60 days after completion of the initial performance test or initial compliance assessment/subsequent required performance test or subsequent compliance assessment, whichever is earlier. Notification of Compliance Status reports may be combined for multiple affected sources as long as the due date requirements for all sources covered in the combined report are met. [Emphasis added] Evidence: Appendix M - NOCS for A3 Olefins Unit Appendix N - Title V Permit for A3 Olefins Unit Field logbooks Description of Observation: NEIC compared the NOCS (Appendix M) submitted in March 2006 for the A3 olefins unit with the actual operations of the facility and identified several differences, including: The NOCS states that AD tank T-O-126 is controlled by a carbon adsorber that complies with 40 CFR Part 63, Subpart SS. At the time of the inspection, emissions from T-O-126 were routed to a bladder tank and then to a flare (see the storage tanks description on NEICVP1446E01 Page 29 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 9 pages 5-6). The NOCS also states that the facility elected to comply with 40 CFR Part 63.985(b)(1)(i) by submitting a design evaluation. The NOCS also indicates the monitoring parameters for the carbon adsorber, including monitoring for breakthrough, which was determined to be 100 ppm VOCs. The NOCS states that AD tank T-O-127 is controlled by a flare that complies with 40 CFR Part 63, Subpart SS. At the time of the inspection, emissions from T-O-127 were routed to a bladder tank and then to a flare (see the storage tanks description on pages 5-6). The NOCS does not mention the bladder tank. The NOCS states that AD tank T-O-87 is controlled by an internal floating roof complying with 40 CFR Part 63, Subpart WW. At the time of the inspection, T-O-87 had both an internal floating roof and a closed-vent system that routes emissions to a bladder tank and then a flare. The NOCS states that AD tank T-O-87 is controlled by an internal floating roof complying with 40 CFR Part 63, Subpart WW. At the time of the inspection, T-O-87 had both an internal floating roof and a closed-vent system that routes emissions to a bladder tank and then a flare. The NOCS states that no transfer racks are associated with the A3 olefins unit. The Title V permit for the A3 olefins unit (Appendix N) includes RSELRTRKW, which is an aboveground loading rack subject to 40 CFR Part 63, Subpart YY. Additionally, the NOCS submitted for the A3 olefins unit, which includes the AD tanks, indicates that tanks T-O-126 and T-O-127 meet the requirements of 40 CFR Part 63, Subpart YY, by complying with 40 CFR Part 63, Subpart SS, and that AD tanks T-O-87 and T-O-88 meet the requirements of 40 CFR Part 63, Subpart YY, by complying with 40 CFR Part 63, Subpart WW. The applicability for these tanks appears to be incorrectly determined. The AD tanks store wastewater as defined by 40 CFR 63.1101 because the annual average concentration of benzene is greater than 10,000 ppm and it is discarded from the ethylene production process, which is subject to 40 CFR Part 63, Subpart YY. Analytical data provided by Indorama shows the benzene concentration in the organic phase of the AD tanks to be >43% by weight (>430,000 ppm), and at least 50% of the material managed in the AD tanks is the organic aromatic distillate. As a result, the AD storage tanks are subject to the wastewater provisions in 40 CFR 63.1106. Note, the Table 9 reference in 40 CFR 63.1101 points to Table 9 of 40 CFR Part 63, Subpart G. 40 CFR 63.1106 requires the AD tanks to comply with the HON process wastewater requirements in 40 CFR 63.132-63.148. Per 40 CFR 63.132(a)(1)(i); the wastewater stream is a group 1 wastewater stream because the concentration of benzene in the AD tanks is greater than 10,000 ppm. Requirements for group 1 wastewater streams are in 40 CFR 63.133. Additionally, 40 CFR 63.132(a)(2)(ii)-(iv) requires compliance with 40 CFR 63.138, 63.143, 63.146, and 63.147. 40 CFR 63.133 provides multiple compliance options, including using a fixed-roof tank, a fixed-roof tank with a closed-vent system that routes emissions to a control device, an internal floating roof tank, or an external floating roof tank. At the time of the inspection, NEICVP1446E01 Page 30 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 9 Indorama was relying on both (1) a fixed-roof tank with a CVS that routes emissions to a control device and an internal floating roof tank for tanks T-O-126 and T-O-127 and (2) a fixed roof that routes emissions via a CVS to a control device for tanks T-O-87 and T-O-88. The changes made to the operations at the A3 olefins unit may have required that the compliance demonstration (e.g., performance test or design evaluation) for the chosen compliance option to have been updated, along with required monitoring parameters and monitoring parameter ranges for the AD tanks per 40 CFR 63.1110(d)(2). Observation 10 Observation Summary: Continuous parameter monitoring data indicate Indorama has been over-steaming the north, central, and south flares. As a result, the combustion gas mixture (vent gas, sweep gas, steam assist) has had insufficient heat content (less than 300 Btu/standard cubic foot [SCF]) to ensure adequate combustion. Indorama thus has not operated and maintained the three flares in conformance with their design and applicable performance standards. Citation: 40 CFR Part 60 - Standards of Performance for New Stationary Sources 40 CFR Part 60 Subpart A - General Provisions 40 CFR 60.18 General control device and work practice requirements. (b) Flares. Paragraphs (c) through (f) apply to flares. (c)(3) An owner/operator has the choice of adhering to either the heat content specifications in paragraph (c)(3)(ii) of this section and the maximum tip velocity specifications in paragraph (c)(4) of this section, or adhering to the requirements in paragraph (c)(3)(i) of this section. (ii) Flares shall be used only with the net heating value of the gas being combusted being 11.2 MJ/scm (300 Btu/scf) or greater if the flare is steam-assisted or airassisted... The net heating value of the gas being combusted shall be determined by the methods specified in paragraph (f)(3) of this section. 40 CFR Part 61 Subpart FF - National Emission Standard for Benzene Waste Operations 61.341 Definitions. Oil-water separator means a waste management unit, generally a tank or surface impoundment, used to separate oil from water... 61.347 Standards: Oil-water separators. NEICVP1446E01 Page 31 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 10 (a) Except as provided in 61.352 of this subpart, the owner or operator shall meet the following standards for each oil-water separator in which waste is placed in accordance with 61.342(c)(1)(ii) of this subpart: (1) The owner or operator shall install, operate, and maintain a fixed-roof and closedvent system that routes all organic vapors vented from the oil-water separator to a control device. (ii) The closed-vent system and control device shall be designated and operated in accordance with the requirements of 61.349 of this subpart. 40 CFR 61.349 Standards: Closed-vent systems and control devices. (a)(2) The control device shall be designed and operated in accordance with the following conditions: (iii) A flare shall comply with the requirements of 40 CFR 60.18. New Source Review Permit 19823 - Special Conditions 10. Flares shall be designed and operated in accordance with the following requirements: D. The permit holder shall install a continuous flow monitor and calorimeter that provide a record of the vent stream flow and Btu content to the flare. The flow monitor sensor and analyzer sample points shall be installed in the vent stream as near as possible to the flare inlet such that the total vent stream to the flare is measured and analyzed. Evidence: See Observation 2. Appendix N - Title V Permit for the A3 Olefins Unit Appendix O - Storage Tank Data Appendix P - New Source Review Permit 19823: Special Conditions and Technical Review Appendix Q - Flare Continuous Monitoring Data Appendix R - NEIC Calculation of Indorama NHVcz Based on Flare Data Adjusted for H2 Description of Observation: As described in Observation 2, the AD tanks are operated as oilwater separators that are managing benzene waste. According to the "Applicable Requirements Summary" table in the A3 olefins unit Title V permit (permit No. O2288) (Appendix N), the AD tanks (RSET087, RSET088, RSET0126, and RSET0127) are subject to 40 CFR Part 61, Subpart FF, specifically the control requirements in 40 CFR 61.343, 40 CFR 61.349, and, by reference, 40 CFR 60.18. 40 CFR 61.343 covers standards for tanks. While NEIC has determined the AD tanks are functioning as oil-water separators, the requirements to design a closed-vent system and control device pursuant to 40 CFR 61.349 (which references 40 CFR 60.18) appear in the standards for both tanks (40 CFR 61.343(a)(1)(ii)) and oil-water separators (40 CFR 61.347(a)(1)(ii)). In addition, the "Applicable Requirements Summary" table of the A3 olefins unit Title V permit (Appendix N) states the AD tanks also are subject to the "applicable limitation, standard and/or equipment specification requirements of 40 CFR Part 63, Subpart YY." NEICVP1446E01 Page 32 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 10 Applicability of 40 CFR Part 61, Subpart FF and 40 CFR Part 63, Subpart YY to the AD tanks is also stated in the storage tank data provided by Indorama (Appendix O). In the storage tank data (Appendix O) table, applicable Clean Air Act regulations for tanks T-O-126 and T-O-127 are FF and YY, understood to be 40 CFR Part 61, Subpart FF, and 40 CFR Part 63, Subpart YY. In the storage tank data (Appendix O) table, applicable Clean Air Act regulations for tanks TO-87 and T-O-88 are Kb, FF, and YY, understood to be 40 CFR Part 60, Subpart Kb; 40 CFR Part 61, Subpart FF; and 40 CFR Part 63, Subpart YY. The north and central flares that control emissions from the AD tanks are, therefore, subject to the control requirements in 40 CFR 60.18, incorporated by reference in 40 CFR 61.349(a)(2)(iii). The flares are also subject to control requirements in 40 CFR Part 63, Subpart YY, but for simplicity, this observation focuses on BWON applicability since the current flare requirements are the same or very similar to those in Subpart YY and are crossreferenced from Subpart YY. Although only the north and central flares control emission from the AD tanks, all three flares are subject to the control requirements in 40 CFR 60.18, according to the "Applicable Requirements Summary" table of the A3 olefins unit Title V permit (Appendix N). UER037 (flare No. 3, south flare), UER044 (flare No. 1, north flare), and UER046 (flare No. 2, central flare) "shall comply with paragraphs (c)-(f) of 60.18," including the heat content requirement in 40 CFR 60.18(c)(3)(ii) (Appendix N). The north, central, and south flares have continuous monitoring data for flow and heat input of vent gas as required by New Source Review permit 19823 special condition 10D (Appendix Q). The technical review document for New Source Review permit 19823 describes the north (flare No. 1) and central (flare No. 2) flares as "flares that receive captured VOC vapors from several process streams" (page 6) (Appendix R). NEIC requested and received available continuous parameter monitoring data for the period April 16-October 21, 2022, for the north, central, and south flares (Appendix Q). Indorama representatives stated that heat input at the flares is measured before steam addition. NEIC used equations from 40 CFR 63.670 (l) and (m) and the provided monitoring data to calculate the net heating value (adjusted for hydrogen content) of the combined vent gas, sweep gas, and steam assist for each hour during this period (Appendix R). Based on these calculations, the net heating value of the combined gases (process gas, natural gas, and steam assist) being combusted at the north, central, and south flares was less than the currently applicable 300 Btu/SCF specified in 40 CFR 60.18(c)(3) more than 71%, 14%, and 96%, respectively, of operating hours during the period for which NEIC received data (April 16-October 21, 2022) (Appendix R). The north, central, and south flares are not currently subject to the equations cited above in 40 CFR 63.670 (l) and (m) and the 270 Btu/SCF net heat value of combustion zone gas (15-minute average) requirement specified in 40 CFR 63.1103(e)(4) until July 6, 2023. The 270 Btu/SCF requirement and associated equations were originally set forth in the National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries (40 CFR Part 63, Subpart CC) as an indicator of whether a steam-assisted flare is adding excessive assist steam, which would indicate the flare is not being operated properly to achieve the required NEICVP1446E01 Page 33 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 10 control. These requirements were later incorporated in the Generic Maximum Achievable Control Technology Standards for ethylene plants (40 CFR Part 63, Subpart YY) for the same purpose with an applicability date of July 6, 2023. Based on NEIC's calculations, the net heating value of the combined gases (process gas, natural gas, and steam assist) combusted at the north, central, and south flares was less than the 270 Btu/SCF value more than 61%, 10%, and 95%, respectively, of operating hours during the period for which NEIC received data (April 16-October 21, 2022) (Appendix R). These data indicate that the north, central, and south flares have been operated with excessive amounts of assist steam and have not maintained adequate heat content for the gases being combusted, resulting in reduced combustion efficiency and destruction efficiency. Observation 11 Observation Summary: NEIC field team members observed emissions from a propane bullet tank during the on-site inspection. Citation: Title V Permit No. O2288 Special Terms and Conditions: Emission Limitations and Standards, Monitoring and Testing, Recordkeeping and Reporting 4. For storage vessels maintaining working pressure as specified in 30 TAC Chapter 115, Subchapter B, Division 1: "Storage of Volatile Organic Compounds," the permit holder shall comply with the requirements of 30 TAC 115.112(a)(1). Title 30 Texas Administrative Code (TAC) 115.112 Control Requirements (a) The following requirements apply in the Beaumont-Port Arthur, Dallas-Fort Worth, and El Paso areas, as defined in 30 TAC 115.10. ... (1) No person shall place, store, or hold in any storage tank any volatile organic compounds (VOC) unless the storage tank is capable of maintaining working pressure sufficient at all times to prevent any vapor or gas loss to the atmosphere or is in compliance with the control requirements specified in Table I(a) of this paragraph for VOC other than crude oil and condensate or Table II(a) of this paragraph for crude oil and condensate. Title 30 TAC 115.112(a)(1) Table I(a) True Vapor Pressure (pounds per square inch absolute (psia)) 11 psia Storage Capacity (gallon (gal)) > 25,000 gal Evidence: Appendix C - OGI Survey Images and Videos Appendix N - Title V Permit for the A3 Olefins Unit Field logbooks Control Requirements Submerged fill pipe and Vapor control system NEICVP1446E01 Page 34 of 35 Indorama Ventures Oxides LLC Port Neches, Texas CONTAINS COMPANY-CLAIMED CONFIDENTIAL BUSINESS INFORMATION (CBI) Observation 11 Description of Observation: During the on-site inspection, NEIC field team members observed emissions from a bullet tank, described as a propane bullet tank by Indorama representatives, using an IR camera (Appendix C, videos 335 and 337). The propane bullet tank is located in the R&S area. At the time of observation, NEIC field team members notified the facility's operators, who also confirmed the emissions using their own IR camera. Operators were then sent to close the valve on the propane bullet, and the emissions from the vent pipe ceased, demonstrating observed emissions were not the result of an upset that caused the pressure relief valve to be in the open position. Propane bullet tanks are designed to be operated under significant pressure to keep propane in a liquid state and without emissions to the atmosphere. Based on a November 21, 2022, email to NEIC from Indorama, the propane bullets do not require permitting because they have no emissions. Presumably, this is because the tanks are intended to be operated under significant positive pressure and are not open to atmosphere. According to the Title V permit and the Texas Administrative Code (30 TAC 115.112(a)(1)), the propane bullet tanks are required to maintain a working pressure sufficient at all times to prevent any vapor or gas loss to the atmosphere or have a vapor control system and are not permitted to vent emissions directly to the atmosphere. Based on NEIC's IR camera observations and the apparent open pressure relief valve, emissions were allowed to be vented to atmosphere from tank FO-50. NEICVP1446E01 Page 35 of 35 Indorama Ventures Oxides LLC Port Neches, Texas On-site Monitoring Results Indorama Ventures Oxides LLC - Port Neches Operations, Port Neches, Texas (VP1446) Method 21 Monitoring Summary - Leaks Identified per Method 21 - Ethylene Plant (A3) Component Type: Compressor Connector Connector Connector Pump Pump Valve Process Drain Connector PRD Connector Pump Openended line Plug Drain Connector Connector Connector Connector Leak Location: C-A3-5 C-A3-5 C-A3-5 C-A3-5 P-A3-33A P-A3-11B P-A3-11B F-A3-45 T-O-88 T-O-88 3rd stage lube oil line Ethylene tower AD Pump A3-38A AD Pump A3-38A F-A3-45 T-O-127 T-O-127 T-O-127 T-O-126 NEIC Leak Reading 8,700 ppm 1.9% 4,000 ppm 555 ppm 1.32% 3.73% then flameout 1,300 ppm 1,900 ppm then flameout 3.72% then flameout 1.01% >8,000 ppm >30,000 ppm 87,000 ppm 1,900 ppm 2,000 ppm then flameout 20,000 ppm 8,000 ppm 10,000 ppm 30,000 ppm Confirmation Reading 33% 35% 10,762 ppm 999 ppm 54,857 ppm 2,095 ppm then flameout 2,696 ppm 8,916 ppm 216,979 ppm 50,844 ppm 10,000 ppm 8,900 ppm then flameout Leak Description: Compressor seal leaking; Indorama identified the compressor seal leak on 8/7/2018 and placed the leak on delay of repair (DOR). Inlet connector on compressor. Leak on inlet flanged pipe to compressor. Leak on connector to pipe coming off flanged inlet line to compressor. #1 propylene tower reflux pump. Ethylene tower reflux pump. Valve behind pump P-A3-11B; valved covered in ice. Process drain under combined low pressure flare knockout. Thief hatch on top of tank T-O-88. Vacuum break side of the conservation vent on top of T-O-88. Leaks at 2 flanges on compressor 3rd stage lube oil line; both over 8,000 ppm Ethylene tower reflux pump leaking past insulation Open-ended line is from the pump drain to an open ditch. Plug on debutanizer bottoms AD pump A3-38A Drain hub under knockout tank F-A3-45 Level Transmitter Hatch (LT-6422) on top of tank T-O-127 Gauge hatch on top of tank T-O-127 White, rectangular hatch on top of tank T-O-127 Gauge hatch on top of tank T-O-126 FLIR Video/Photo No. 417 and 418 419 329 327 427 428 326 327 328 333 332 331 NEICVP1446E01 Appendix B Page 1 of 2 Indorama Ventures Oxides LLC Port Neches, Texas Connector PRD Vent Vent Vent T-O-126 T-O-126 F-O114A F-O-114B F-O-114B 600 ppm 40,000 ppm then flameout 8,000 ppm 4,200 ppm 4,300 ppm Small, rectangular hatch on top of tank TO-126 331 PRD on top of tank T-O-126 Vent on top of bladder tank F-O-114A 334 Vent on top of bladder tank F-O-114B 336 Vent on top of bladder tank F-O-114B 336 Method 21 Monitoring Summary - Leaks Identified per Method 21 - Ethylene Oxide Plant (F6) Component Type: Connector Connector Connector Plug Pump Connector Connector Plug Connector Leak Location: C-F6-131 C-F6-31 F6 Tower Receiving and Shipping P-51-B EO rail loading EO rail loading EO rail loading EO rail loading NEIC Leak Reading 10.52% then flameout 31,158 ppm 1,200 ppm 4,040 ppm 8,000 ppm 650 ppm >10,000 ppm >10,000 ppm >2,000 ppm Confirmation Reading 18,290 ppm 300,066 ppm 3,698 ppm 11,247 ppm 4,544 ppm 4,032 ppm 33,346 ppm 37,970 ppm 3,600 ppm Leak Description: Leak on connector on compressor C-F6-131. Connector line labeled "Non Drive End Leakage." Leak on connector on valve in front of gauge labeled F6-PT-3D Leak on connector on check valve inlet labeled "Inlet #6" and the line was labeled "Cycle Gas Inlet to 6 RXTR." Blue hose end on pyronaphtha truck loading area on the south side of the truck loading at the north end of 5th street near the AD washoil loadout sump. EO pump Leak on liquid loading connection to rail car Leak on vapor return connection from rail car Plug on valve near tag 02096 Leak on vapor return line for one of the EO rail loading bays FLIR Video No. 341 Open-Ended Lines Open-Ended Line Location: AD Pump A3-38A Description: Debutanizer bottoms AD pump. Open-ended line is from the pump drain to an open ditch. NEICVP1446E01 Appendix B Page 2 of 2 Indorama Ventures Oxides LLC Port Neches, Texas PNO.042 001 NEICVP1446E01 Appendix D Page 1 of 7 Indorama Ventures Oxides LLC Port Neches, Texas PNO.042 002 NEICVP1446E01 Appendix D Page 2 of 7 Indorama Ventures Oxides LLC Port Neches, Texas PNO.042 003 NEICVP1446E01 Appendix D Page 3 of 7 Indorama Ventures Oxides LLC Port Neches, Texas PNO.042 004 NEICVP1446E01 Appendix D Page 4 of 7 Indorama Ventures Oxides LLC Port Neches, Texas HUNTSMAN PETROCHEMICAL LLC 2019 BENZENE QUANTITIES FOR PNO FACILITY STREAM DESCRIPTION SUBPART FF CONTROLS (Ref. 4) STREAM TYPE 61.357(a)(2) Contaminated Sludge (1104519H) Hazardous Lab Pack (4703009H) Gasoline/Water (4168219H) Well Water (4317119H) Tank Bottoms (4315319H) Plant Residual Slop (5014219H) O&O A-3 Sump / Wash Oil / Quench to T-O-88/126 AD Washoil Loading Rack Sump (Controlled as of 09/09) F-A3-4 First Stage Suction Drum T-A3-46 Tar Tank Drain O&O Quench Drum to WW Stripper O&O Spent Caustic to WW Stripper 61.357(a)(2) exempt exempt exempt exempt exempt exempt exempt yes exempt exempt yes yes Ref # 2 2 2 2 2 2 2 2 2 - PWW PWW PWW PWW PWW Streams Excluded from TAB Calculation (H2O <10%) (61.342(a)(1)) N/A for 2019 REFERENCES: 1. Exempt from control requirements (<10 ppm benzene) (61.342(c)(2)) 2. Exempt from control requirements (benzene quantity sum <2 Mg/yr) (61.342(c)(3)(ii)) ==> 3. Exempt from control requirements (annual avg. water content < 10 % (61.342(a)(1)) 4. Process Wastewater (PWW); Product Tank Draw-down (PTD); Landfill Leachate (LL) WASTE QUANTITY RANGE OF CONC. (lbs/yr) 2,000 848 1,200 1,000 300 781,440 55,897,059.55 3,686.00 0.00 14,336,126.00 347,485,071.44 46,397,321.40 (Mg/yr) (ppm) 61.357(a)(3)(i-v) 0.91 1000 0.38 10000 0.54 10 0.45 10000 0.14 10000 354.77 1.21 25,377.27 1.0 - 24.0 1.67 300,000.00 0.00 47.0 - 132.0 6,508.60 19.23 - 65.18 157,758.22 69.6 - 184 21,064.38 31 - 370 FLOWWEIGHTED BENZENE CONC. (ppm) 1000.00 10000.00 10.00 10000.00 10000.00 1.21 19.67 300000.00 85.63 34.52 129.53 230.00 TAB BENZENE QUANTITY (Mg/yr) 0.0009 0.0038 0.0001 0.0005 0.0001 0.0004 0.4992 0.5020 0.0000 0.2247 20.4344 4.8448 26.51 Excluded from TAB 0.73 Mg 0.0000 NEICVP1446E01 Appendix D Page 5 of 7 Indorama Ventures Oxides LLC Port Neches, Texas Indorama Ventures Oxides LLC 2020 BENZENE QUANTITIES FOR PNO FACILITY STREAM DESCRIPTION SUBPART FF CONTROLS (Ref. 4) STREAM TYPE 61.357(a)(2) Contaminated Sludge (1104519H) Hazardous Lab Pack (4703009H) Dessicant (1140319H) Well Water (4317119H) Plant Residual Slop (5014219H) O&O A-3 Sump / Wash Oil / Quench to T-O-88/126 AD Washoil Loading Rack Sump (Controlled as of 09/09) F-A3-4 First Stage Suction Drum T-A3-46 Tar Tank Drain O&O Quench Drum to WW Stripper O&O Spent Caustic to WW Stripper 61.357(a)(2) exempt exempt exempt exempt exempt exempt yes exempt exempt yes yes Ref # 2 2 2 2 2 2 2 2 - PWW PWW PWW PWW PWW Streams Excluded from TAB Calculation (H2O <10%) (61.342(a)(1)) N/A for 2020 REFERENCES: 1. Exempt from control requirements (<10 ppm benzene) (61.342(c)(2)) 2. Exempt from control requirements (benzene quantity sum <2 Mg/yr) (61.342(c)(3)(ii)) ==> 3. Exempt from control requirements (annual avg. water content < 10 % (61.342(a)(1)) 4. Process Wastewater (PWW); Product Tank Draw-down (PTD); Landfill Leachate (LL) WASTE QUANTITY RANGE OF CONC. (lbs/yr) 5,300 650 87,182 1,200 387,780 50,387,721.98 3,686.00 0.00 14,336,126.00 329,391,042.42 41,097,181.20 (Mg/yr) (ppm) 61.357(a)(3)(i-v) 2.41 1000 0.30 10000 39.58 103.862 0.54 10000 176.05 1.21 22,876.03 1.0 - 24.0 1.67 300,000.00 0.00 47.0 - 132.0 6,508.60 19.23 - 65.18 149,543.53 69.6 - 184 18,658.12 31 - 370 FLOWWEIGHTED BENZENE CONC. (ppm) 1000.00 10000.00 103.86 10000.00 1.21 19.67 300000.00 85.63 34.52 129.53 230.00 TAB BENZENE QUANTITY (Mg/yr) 0.0024 0.0030 0.0411 0.0005 0.0002 0.4500 0.5020 0.0000 0.2247 19.3704 4.2914 24.89 Excluded from TAB 0.72 Mg 0.0000 NEICVP1446E01 Appendix D Page 6 of 7 Indorama Ventures Oxides LLC Port Neches, Texas Indorama Ventures Oxides LLC 2021 BENZENE QUANTITIES FOR INDORAMA VENTURES OXIDES STREAM DESCRIPTION SUBPART FF CONTROLS (Ref. 4) STREAM TYPE 61.357(a)(2) Contaminated Sludge (1104519H) Hazardous Lab Pack (4703009H) Dessicant (1140319H) Well Water (4317119H) Plant Residual Slop (5014219H) O&O A-3 Sump / Wash Oil / Quench to T-O-88/126 AD Washoil Loading Rack Sump (Controlled as of 09/09) F-A3-4 First Stage Suction Drum T-A3-46 Tar Tank Drain O&O Quench Drum to WW Stripper O&O Spent Caustic to WW Stripper 61.357(a)(2) exempt exempt exempt exempt exempt exempt yes exempt exempt yes yes Ref # 2 2 2 2 2 2 2 2 - PWW PWW PWW PWW PWW Streams Excluded from TAB Calculation (H2O <10%) (61.342(a)(1)) N/A for 2021 REFERENCES: 1. Exempt from control requirements (<10 ppm benzene) (61.342(c)(2)) 2. Exempt from control requirements (benzene quantity sum <2 Mg/yr) (61.342(c)(3)(ii)) ==> 3. Exempt from control requirements (annual avg. water content < 10 % (61.342(a)(1)) 4. Process Wastewater (PWW); Product Tank Draw-down (PTD); Landfill Leachate (LL) WASTE QUANTITY RANGE OF CONC. (lbs/yr) 2,600 0 0 0 509,400 196,771,985.69 3,686.00 0.00 516,362.76 118,911,697.25 44,978,213.40 (Mg/yr) (ppm) 61.357(a)(3)(i-v) 1.18 1000 0.00 10000 0.00 103.862 0.00 10000 231.27 353.473 89,334.48 1.0 - 24.0 1.67 300,000.00 0.00 47.0 - 132.0 234.43 19.23 - 65.18 53,985.91 69.6 - 184 20,420.11 31 - 370 FLOWWEIGHTED BENZENE CONC. (ppm) 1000.00 10000.00 103.86 10000.00 353.47 19.67 300000.00 85.63 34.52 129.53 230.00 TAB BENZENE QUANTITY (Mg/yr) 0.0012 0.0000 0.0000 0.0000 0.0817 1.7572 0.5020 0.0000 0.0081 6.9928 4.6966 14.04 Excluded from TAB 1.85 Mg 0.0000 NEICVP1446E01 Appendix D Page 7 of 7 Indorama Ventures Oxides LLC Port Neches, Texas TRI_FORM_R Search | US EPA Related Topics: Envirofacts Home | | | | Mobile | FORM R REPORTS | | MENU CONTACT US | | Reference Point/Description CENTER OF A FACILITY OR STATION RCRA ID NUMBER Latitude Longitude Collection Method 29.990148 -93.946735 INTERPOLATIONMAP Accuracy Value 30 NPDES PERMIT NUMBER TX0005070 UIC ID NUMBER . Collection of Latitude, Longitude and Program ID Data Has Been Discontinued. NEICVP1446E01 Appendix E Page 1 of 12 Indorama Ventures Oxides LLC Port Neches, Texas https://enviro.epa.gov/enviro/tri_formr_partone_v2.get_thisone?rpt_year=2021&dcn_num=1321219853912&ban_flag=Y[10/27/2022 8:14:18 AM] TRI_FORM_R Search | US EPA PART I. FACILITY IDENTIFICATION INFORMATION (FORM R) Section 1. Reporting Year 2021 DOCUMENT CONTROL NUMBER: 1321219853912 110000599567 Section 2. Trade Secret Information 2.1 NO 2.2 CERTIFYING OFFICIAL'S NAME KIMBERLY HOYT CERTIFYING OFFICIAL'S TITLE CERTIFYING OFFICIAL'S SIGNATURE DATE SIGNED 22-JUN-22 77651TXCCHHWY36 4.1 Facility Name and Address NAME HUNTSMAN PETROCHEMICAL LLC PORT NECHES FACILITY BIA Tribal Code Tribe STREET CITY 6001 HWY 366 PORT NECHES COUNTY STATE JEFFERSON TX ZIP CODE 77651 NAME HUNTSMAN PETROCHEMICAL LLC PORT NECHES FACILITY STREET PO BOX 847 CITY PORT NECHES STATE ZIP CODE TX 77651 PROVINCE COUNTRY (NON - US) NEICVP1446E01 Appendix E Page 2 of 12 Indorama Ventures Oxides LLC Port Neches, Texas https://enviro.epa.gov/enviro/tri_formr_partone_v2.get_thisone?rpt_year=2021&dcn_num=1321219853912&ban_flag=Y[10/27/2022 8:14:18 AM] TRI_FORM_R Search | US EPA ENTIRE FACILITY YES PARTIAL FACILITY NO FEDERAL FACILITY NO GOCO FACILITY NO 4.3 Technical Contact 4.4 Public Contact NAME KIMBERLY HOYT PHONE 4097233261 EXTENSION 4.5 NAICS Codes NAICS CODE 325199 PRIMARY YES NAICS CODE DESCRIPTION 4.7 Dun Numbers DUNS NUMBER NA 189049570 5. Parent Company Information HUNTSMAN INTERNATIONAL LLC 147173017 PART II. CHEMICAL - SPECIFIC INFORMATION DOCUMENT CONTROL NUMBER 1321219853912 Section 1. Toxic Chemical Identity 1.1 71-43-2 1.2 1.3 NA NEICVP1446E01 Appendix E Page 3 of 12 Indorama Ventures Oxides LLC Port Neches, Texas https://enviro.epa.gov/enviro/tri_formr_partone_v2.get_thisone?rpt_year=2021&dcn_num=1321219853912&ban_flag=Y[10/27/2022 8:14:18 AM] TRI_FORM_R Search | US EPA 1.4 NA 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NO Section 2. Mixture Component Identity 2.1 NA Section 3. Activities and Uses of the Toxic Chemical 3.1 YES NO NO YES NO NO 3.2 YES P103 NO NO NO NO NO 3.3 NO NO YES Z304 Fuel NEICVP1446E01 Appendix E Page 4 of 12 Indorama Ventures Oxides LLC Port Neches, Texas https://enviro.epa.gov/enviro/tri_formr_partone_v2.get_thisone?rpt_year=2021&dcn_num=1321219853912&ban_flag=Y[10/27/2022 8:14:18 AM] TRI_FORM_R Search | US EPA Section 4. Maximum Amount of the Toxic Chemical Onsite During the Calendar Year 1000000 to 9999999 Section 5. Quantity of the Toxic Chemical Entering each Environmental Medium Onsite 5.1 NA TOTAL RELEASE (per year) UNIT OF MEASURE BASIS OF ESTIMATE NO 160.57 O 5.2 NA TOTAL RELEASE (per year) UNIT OF MEASURE BASIS OF ESTIMATE NO 7391.92 O 5.3 STREAM/WATER NA REACH Code BODY NAME TOTAL RELEASE (per year) UNIT OF MEASURE BASIS OF ESTIMATE O NO NECHES RIVER 12020003000223 0 % FROM STORMWATER 0 5.4-5.5 Disposal to Land Onsite 5.4.1 NA TOTAL RELEASE (per year) UNIT OF MEASURE BASIS OF ESTIMATE YES 5.4.2 NA TOTAL RELEASE (per year) UNIT OF MEASURE BASIS OF ESTIMATE YES 5.5 Disposal to Land Onsite 5.5.1A NA TOTAL RELEASE (per year) UNIT OF MEASURE BASIS OF ESTIMATE NEICVP1446E01 Appendix E Page 5 of 12 Indorama Ventures Oxides LLC Port Neches, Texas https://enviro.epa.gov/enviro/tri_formr_partone_v2.get_thisone?rpt_year=2021&dcn_num=1321219853912&ban_flag=Y[10/27/2022 8:14:18 AM] TRI_FORM_R Search | US EPA YES 5.5.1B NA TOTAL RELEASE (per year) UNIT OF MEASURE BASIS OF ESTIMATE YES 5.5.2 NA TOTAL RELEASE (per year) UNIT OF MEASURE BASIS OF ESTIMATE YES 5.5.3A NA TOTAL RELEASE (per year) UNIT OF MEASURE BASIS OF ESTIMATE YES 5.5.3B NA TOTAL RELEASE (per year) UNIT OF MEASURE BASIS OF ESTIMATE YES 5.5.4 NA TOTAL RELEASE (per year) UNIT OF MEASURE BASIS OF ESTIMATE YES NO 6.1 1 - NAME CITY STATE NEICVP1446E01 Appendix E Page 6 of 12 Indorama Ventures Oxides LLC Port Neches, Texas https://enviro.epa.gov/enviro/tri_formr_partone_v2.get_thisone?rpt_year=2021&dcn_num=1321219853912&ban_flag=Y[10/27/2022 8:14:18 AM] TRI_FORM_R Search | US EPA COUNTY POTW AMOUNT SEQUENCE TOTAL TRANSFERS (per year) UNIT OF MEASURE BASIS OF ESTIMATE WASTE MANAGEMENT TYPE 6.2 1 City UNION NO 309 AMERICAN CIRCLE AR 71730 OFFSITE AMOUNT SEQUENCE 1 TOTAL TRANSFERS (per year) UNIT OF MEASURE .41 BASIS OF ESTIMATE O WASTE MANAGEMENT TYPE M50 - 2 City HARRIS NO TX 77536 OFFSITE AMOUNT SEQUENCE 1 TOTAL TRANSFERS (per year) UNIT OF MEASURE 2229.95 BASIS OF ESTIMATE O WASTE MANAGEMENT TYPE M50 - NEICVP1446E01 Appendix E Page 7 of 12 Indorama Ventures Oxides LLC Port Neches, Texas https://enviro.epa.gov/enviro/tri_formr_partone_v2.get_thisone?rpt_year=2021&dcn_num=1321219853912&ban_flag=Y[10/27/2022 8:14:18 AM] TRI_FORM_R Search | US EPA 3 CLEAN HARBORS LAPORTE City LA PORTE HARRIS NO TX 775719768 OFFSITE AMOUNT SEQUENCE 1 TOTAL TRANSFERS (per year) UNIT OF MEASURE 18 BASIS OF ESTIMATE O WASTE MANAGEMENT TYPE 7A.1a. WASTEWATER 7A.1b. 1 WASTE TREATMENT METHOD(S) SEQUENCE 7A.1d. 7A.2a. GASEOUS 7A.2b. 1 WASTE TREATMENT METHOD(S) SEQUENCE A01 - FLARE 7A.2d. Section 7B. On-Site Energy Recovery Processes ON SITE ENERGY RECOVERY PROCESSES Section 7C. On-Site Recycling Processes NEICVP1446E01 Appendix E Page 8 of 12 Indorama Ventures Oxides LLC Port Neches, Texas https://enviro.epa.gov/enviro/tri_formr_partone_v2.get_thisone?rpt_year=2021&dcn_num=1321219853912&ban_flag=Y[10/27/2022 8:14:18 AM] TRI_FORM_R Search | US EPA ON SITE RECYCLING PROCESSES NA Section 8. Source Reduction and Recycling Activities SECTION TYPE OF QUANTITY UNITS PRIOR YEAR CURRENT REPORTING YEAR FOLLOWING YEAR SECOND FOLLOWING YEAR 8.1a RCRA Subtitle C NA NA NA NA 8.1b 16399 7291.29 7291.29 7291.29 8.1c RCRA Subtitle C 10.46 NA NA NA 8.1d NA 18 18 18 8.2 15429 18848 18848 18848 8.3 NA NA NA NA 8.4 NA NA NA NA 8.5 NA NA NA NA NEICVP1446E01 Appendix E Page 9 of 12 Indorama Ventures Oxides LLC Port Neches, Texas https://enviro.epa.gov/enviro/tri_formr_partone_v2.get_thisone?rpt_year=2021&dcn_num=1321219853912&ban_flag=Y[10/27/2022 8:14:18 AM] TRI_FORM_R Search | US EPA 8.6 794950 362277 362277 362277 8.7 1992.35 2230.36 2230.36 2230.36 8.8 8.9 8.10 SOURCE REDUCTION ACTIVITIES NA 8.11 NO 1.25 METHOD 1 METHOD 2 METHOD 3 ESTIMATED ANNUAL REDUCTION 9.1 COMMENT TYPE DESCRIPTION COMMENT TEXT NEICVP1446E01 Appendix E Page 10 of 12 Indorama Ventures Oxides LLC Port Neches, Texas https://enviro.epa.gov/enviro/tri_formr_partone_v2.get_thisone?rpt_year=2021&dcn_num=1321219853912&ban_flag=Y[10/27/2022 8:14:18 AM] TRI_FORM_R Search | US EPA Jobs NEICVP1446E01 Appendix E Page 11 of 12 Indorama Ventures Oxides LLC Port Neches, Texas https://enviro.epa.gov/enviro/tri_formr_partone_v2.get_thisone?rpt_year=2021&dcn_num=1321219853912&ban_flag=Y[10/27/2022 8:14:18 AM] TRI_FORM_R Search | US EPA NEICVP1446E01 Appendix E Page 12 of 12 Indorama Ventures Oxides LLC Port Neches, Texas https://enviro.epa.gov/enviro/tri_formr_partone_v2.get_thisone?rpt_year=2021&dcn_num=1321219853912&ban_flag=Y[10/27/2022 8:14:18 AM] NEICVP1446E01 Appendix F Page 1 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 2 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 3 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 4 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 5 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 6 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 7 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 8 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 9 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 10 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 11 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 12 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 13 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 14 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 15 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 16 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 17 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 18 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 19 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 20 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 21 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 22 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 23 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 24 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 25 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 26 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 27 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 28 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 29 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 30 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 31 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 32 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 33 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 34 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 35 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 36 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 37 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 38 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 39 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 40 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 41 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 42 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 43 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 44 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 45 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 46 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 47 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 48 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 49 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 50 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 51 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 52 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 53 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 54 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 55 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 56 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 57 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 58 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 59 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 60 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 61 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 62 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 63 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 64 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 65 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 66 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 67 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 68 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 69 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 70 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 71 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 72 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 73 of 74 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 Appendix F Page 74 of 74 Indorama Ventures Oxides LLC Port Neches, Texas Leak Detail Report Indorama OO From: 1/1/2021 To: 3/31/2021 Include Leaks found while on DOR and IRO Leaks PNO.061 001 Tag Monitor Date Inspector Unit: OO-A3-W/W-SYS A3-2242-004 Comp Type: CONNECTOR Leak Source: connector 1/19/21 8:50 AM NRetherford 1/22/21 9:32 AM CMcGee A3-2251-004 Comp Type: CONNECTOR Leak Source: connector 1/19/21 8:56 AM NRetherford 1/22/21 9:38 AM CMcGee A3-2313-001 Comp Type: CONNECTOR Leak Source: 90 1/19/21 12:28 PM NRetherford 1/22/21 9:30 AM CMcGee A3-2672-003 Comp Type: CONNECTOR Leak Source: connector 1/19/21 12:53 PM NRetherford 1/22/21 9:34 AM CMcGee A3-2705-S1000 Comp Type: CONNECTOR Leak Source: valve 1/20/21 8:07 AM BMartindale 1/22/21 9:36 AM CMcGee A3-2753-S2000 Comp Type: CONNECTOR Leak Source: nipple 1/20/21 9:41 AM BMartindale 1/22/21 9:37 AM CMcGee A3-2862-002 Comp Type: CONNECTOR Leak Source: UNION 1/20/21 8:02 AM CCollins 1/22/21 9:29 AM CMcGee A3-2911-000 Comp Type: CONNECTOR Leak Source: SCREWED FITTING 1/20/21 9:13 AM CCollins 1/22/21 9:40 AM CMcGee A3-3082-001 Comp Type: CONNECTOR Leak Source: 90 1/20/21 8:56 AM GRowland 1/22/21 9:42 AM CMcGee Instrument PPM Thresh. Rep. Date Repaired By: Area: SUBPART-FF - A3 W/W SYS Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 3943 1189 500 0083 10 500 1/22/2021 STORK Repair Type 1.1' N SIDE OF H-A3-H (90) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 15356 500 54 500 1/22/2021 STORK 1.1' N SIDE OF H-A3-H (90) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 731 500 7 500 1/22/2021 STORK .2" N SIDE OF H-A3-H (90) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1112 500 26 500 1/22/2021 STORK 1.3 " S SIDE OF H-A3-1G (90) TIGHTEN CONNECTOR 0587 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1014 500 219 500 1/22/2021 STORK 1.1 " N SIDE OF H-A3-1F (Plug) TIGHTEN CONNECTOR 0587 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 16091 500 35 500 1/22/2021 STORK 1.4 " N SIDE OF H-A3-1F (Bushing) TIGHTEN CONNECTOR 3064 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 3941 500 2 500 1/22/2021 STORK 0.4 " S SIDE OF H-A3-F (Union) TIGHTEN CONNECTOR 3064 0083 Rules: HUNTSMAN, FF Size: 1 Service Type: GAS / VAPOR 899 500 19 500 1/22/2021 STORK 1.4' S SIDE OF H-A3-F (Plug) TIGHTEN CONNECTOR 0589 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 637 500 10 500 1/22/2021 STORK 0.4' S SIDE OF H-A3-1E (90) TIGHTEN CONNECTOR Page 1 of 2 on 4/20/2021 7:01:28 AM NEICVP1446E01 Appendix G Page 1 of 12 Indorama Ventures Oxides LLC Port Neches, Texas Leak Detail Report Indorama OO From: 1/1/2021 To: 3/31/2021 Include Leaks found while on DOR and IRO Leaks PNO.061 002 Tag Monitor Date Inspector Unit: OO-A3-W/W-SYS A3-3256-004 Comp Type: CONNECTOR Leak Source: connector 1/20/21 8:40 AM NRetherford 1/22/21 9:27 AM CMcGee A3-3267-001 Comp Type: CONNECTOR Leak Source: vent valve 1/20/21 8:45 AM NRetherford 1/22/21 9:26 AM CMcGee A3-3639-003 Comp Type: CONNECTOR Leak Source: connector 1/21/21 9:25 AM NRetherford 1/22/21 9:25 AM CMcGee A3-3642-003 Comp Type: CONNECTOR Leak Source: connector 1/21/21 9:27 AM NRetherford 1/22/21 9:24 AM CMcGee A3-3800-003 Comp Type: CONNECTOR Leak Source: connector 1/25/21 7:54 AM NRetherford 1/26/21 8:12 AM CMcGee A3-3801-003 Comp Type: CONNECTOR Leak Source: connector 1/25/21 9:16 AM NRetherford 1/26/21 8:15 AM CMcGee A3-3828-003 Comp Type: CONNECTOR Leak Source: connector 1/25/21 9:18 AM NRetherford 1/26/21 8:17 AM CMcGee A3-3948-000 Comp Type: CONNECTOR Leak Source: flange 1/21/21 10:04 AM BMartindale 1/22/21 9:39 AM CMcGee Instrument PPM Thresh. Rep. Date Repaired By: Area: SUBPART-FF - A3 W/W SYS Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 3943 6436 500 0083 5 500 1/22/2021 STORK Repair Type 0.4' N SIDE OF H-A3-D (90) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.5 Service Type: GAS / VAPOR 2858 500 173 500 1/22/2021 STORK 0.1' N SIDE OF H-A3-1D (Tee) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 757 500 7 500 1/22/2021 STORK 1.2' N SIDE OF H-A3-1B (90) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1719 500 21 500 1/22/2021 STORK 1.2' N SIDE OF H-A3-1B (90) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1114 500 202 500 1/26/2021 STORK 1.2 S SIDE OF H-A3-1B (90) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 15222 500 73 500 1/26/2021 STORK 1.2 S SIDE OF H-A3-1B (90) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 28281 500 10 500 1/26/2021 STORK 1.4 S SIDE OF H-A3-1B (90) TIGHTEN CONNECTOR 0587 0083 Rules: HUNTSMAN, FF Size: 4 Service Type: GAS / VAPOR 7299 500 305 500 1/22/2021 STORK 0.1 N SIDE OF H-A3-1A (Flange) TIGHTEN FLANGE This report was generated using a filter: Rule Name is equal to NESHAPS-FF Page 2 of 2 on 4/20/2021 7:01:28 AM NEICVP1446E01 Appendix G Page 2 of 12 Indorama Ventures Oxides LLC Port Neches, Texas Tag Monitor Date Inspector Unit: OO-A3-W/W-SYS A3-2103-003 A3-2213-002 A3-2415-002 A3-2420-000 A3-2548-000 A3-2549-000 A3-2913-000 A3-2996-003 A3-3054-002 Comp Type: CONNECTOR Leak Source: connector 4/12/21 9:50 AM NRetherford 4/13/21 1:28 PM CMcGee Comp Type: CONNECTOR Leak Source: union 4/12/21 8:07 AM GRowland 4/13/21 1:29 PM CMcGee Comp Type: CONNECTOR Leak Source: union 4/12/21 7:55 AM BMartindale 4/13/21 1:31 PM CMcGee Comp Type: VALVE Leak Source: packing 4/12/21 8:08 AM BMartindale 4/13/21 1:32 PM CMcGee Comp Type: VALVE Leak Source: VALVE PACKING 4/12/21 8:24 AM CCollins 4/13/21 1:26 PM CMcGee Comp Type: VALVE Leak Source: VALVE PACKING 4/12/21 8:00 AM CCollins 4/13/21 1:27 PM CMcGee Comp Type: VALVE Leak Source: valve packing 4/13/21 8:48 AM GRowland 4/15/21 7:41 AM CMcGee Comp Type: CONNECTOR Leak Source: connector 4/13/21 12:57 PM GRowland 4/15/21 7:42 AM CMcGee Comp Type: CONNECTOR Leak Source: union 4/13/21 7:40 AM NRetherford 4/15/21 7:43 AM CMcGee Leak Detail Report Indorama OO From: 4/1/2021 To: 6/30/2021 Include IRO Leaks PNO.061 003 Instrument PPM Thresh. Rep. Date Repaired By: Repair Type Area: SUBPART-FF - A3 W/W SYS Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.5' N SIDE OF H-A3-1J OH (90) 3943 37249 500 0083 357 500 4/13/2021 TURNER TIGHTEN CONNECTOR 0589 0083 Rules: HUNTSMAN, FF Size: 0.5 Service Type: GAS / VAPOR 844 500 115 500 4/13/2021 TURNER 1.2' S SIDE OF H-A3-1J (Union) TIGHTEN CONNECTOR 3931 0083 Rules: HUNTSMAN, FF Size: 0.5 Service Type: GAS / VAPOR 35157 500 4 500 4/13/2021 TURNER 1.1 " S SIDE OF H-A3-H (Union) TIGHTEN CONNECTOR 3931 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.1 " S SIDE OF H-A3-H (V-Uncategorized) 1449 500 281 500 4/13/2021 TURNER TIGHTEN PACKING 3064 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.2 " N SIDE OF H-A3-1G (V-Uncategorized) 1020 500 24 500 4/13/2021 TURNER TIGHTEN PACKING 3064 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.2 " N SIDE OF H-A3-1G (V-Uncategorized) 769 500 90 500 4/13/2021 TURNER TIGHTEN PACKING 0589 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.4' S SIDE OF H-A3-F (V-Uncategorized) 1134 500 108 500 4/15/2021 TURNER TIGHTEN PACKING 0589 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 4978 500 204 500 4/15/2021 TURNER 0.2' N SIDE OF H-A3-E (90) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1411 500 221 500 4/15/2021 TURNER 0.2' S SIDE OF H-A3-E (Union) TIGHTEN CONNECTOR Page 1 of 2 on 7/8/2021 3:53:15 PM NEICVP1446E01 Appendix G Page 3 of 12 Printed By: Ruby Indorama Ventures Oxides LLC Port Neches, Texas Tag Monitor Date Inspector Unit: OO-A3-W/W-SYS A3-3078-003 A3-3085-002 A3-3090-000 A3-3251-002 A3-3678-002 A3-3828-003 Comp Type: CONNECTOR Leak Source: 99 4/13/21 8:13 AM NRetherford 4/15/21 7:44 AM CMcGee Comp Type: CONNECTOR Leak Source: union 4/13/21 8:16 AM NRetherford 4/15/21 7:45 AM CMcGee Comp Type: CONNECTOR Leak Source: plug 4/13/21 8:18 AM NRetherford 4/15/21 7:46 AM CMcGee Comp Type: CONNECTOR Leak Source: UNION 4/13/21 8:05 AM CCollins 4/15/21 7:48 AM CMcGee Comp Type: CONNECTOR Leak Source: UNION 4/13/21 2:41 PM NHardy 4/15/21 7:49 AM CMcGee Comp Type: CONNECTOR Leak Source: connector 4/14/21 9:12 AM NRetherford 4/15/21 7:50 AM CMcGee Leak Detail Report Indorama OO From: 4/1/2021 To: 6/30/2021 Include IRO Leaks PNO.061 004 Instrument PPM Thresh. Rep. Date Repaired By: Area: SUBPART-FF - A3 W/W SYS Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 3943 19011 500 0083 91 500 4/15/2021 TURNER Repair Type 0.4' S SIDE OF H-A3-E (90) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 35488 500 67 500 4/15/2021 TURNER 0.4' S SIDE OF H-A3-1E (Union) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 26536 500 24 500 4/15/2021 TURNER 0.4' S SIDE OF H-A3-1E (Plug) TIGHTEN CONNECTOR 3064 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 8506 500 306 500 4/15/2021 TURNER 0.4' N SIDE OF H-A3-D (Union) TIGHTEN CONNECTOR 3062 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 9330 500 115 500 4/15/2021 TURNER 0.2' N SIDE OF H-A3-1B (Union) TIGHTEN CONNECTOR 3943 0083 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 16797 500 273 500 4/15/2021 TURNER 1.4 S SIDE OF H-A3-1B (90) TIGHTEN CONNECTOR This report was generated using a filter: Rule Name is equal to NESHAPS-FF Page 2 of 2 on 7/8/2021 3:53:15 PM NEICVP1446E01 Appendix G Page 4 of 12 Printed By: Ruby Indorama Ventures Oxides LLC Port Neches, Texas Leak Detail Report Indorama OO From: 7/1/2021 To: 9/30/2021 Include Leaks found while on DOR and IRO Leaks PNO.061 005 Tag Monitor Date Inspector Unit: OO-A3-W/W-SYS A3-2078-001 A3-2079-001 A3-2303-000 A3-2304-000 A3-2488-002 A3-2489-S2000 A3-2494-002 A3-2535-002 A3-2545-002 Comp Type: CONNECTOR Leak Source: 90 7/17/21 9:52 AM BMartindale 7/19/21 8:59 AM CMcGee Comp Type: CONNECTOR Leak Source: 90 7/17/21 9:55 AM BMartindale 7/19/21 8:58 AM CMcGee Comp Type: VALVE Leak Source: VALVE PACKING 7/17/21 2:09 PM NHardy 7/19/21 8:57 AM CMcGee Comp Type: CONNECTOR Leak Source: TEE 7/17/21 2:11 PM NHardy 7/19/21 8:56 AM CMcGee Comp Type: CONNECTOR Leak Source: Union 7/17/21 8:50 AM JCollins 7/19/21 8:54 AM CMcGee Comp Type: CONNECTOR Leak Source: Hose 7/17/21 8:57 AM JCollins 7/19/21 8:53 AM CMcGee Comp Type: CONNECTOR Leak Source: Union 7/17/21 10:14 AM JCollins 7/19/21 8:51 AM CMcGee Comp Type: CONNECTOR Leak Source: Union 7/17/21 1:18 PM JCollins 7/19/21 8:52 AM CMcGee Comp Type: CONNECTOR Leak Source: Union 7/17/21 1:35 PM JCollins 7/19/21 8:50 AM CMcGee Instrument PPM Thresh. Rep. Date Repaired By: Repair Type Area: SUBPART-FF - A3 W/W SYS Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.2' N SIDE OF H-A3-1J OH (90) 3931 2525 500 0096 16 500 7/19/2021 TURNER TIGHTEN CONNECTOR 3931 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 5816 500 28 500 7/19/2021 TURNER 1.2' N SIDE OF H-A3-1J OH (90) TIGHTEN CONNECTOR 0587 0096 Rules: HUNTSMAN, FF Size: 0.5 Service Type: GAS / VAPOR .3" N SIDE OF H-A3-H (V-Uncategorized) 3120 500 101 500 7/19/2021 TURNER TIGHTEN PACKING 0587 0096 Rules: HUNTSMAN, FF Size: 0.5 Service Type: GAS / VAPOR 9816 500 76 500 7/19/2021 TURNER .2" N SIDE OF H-A3-H (Tee) TIGHTEN CONNECTOR 0083 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 2814 500 91 500 7/19/2021 TURNER 1.1 " N SIDE OF H-A3-1G (Union) TIGHTEN CONNECTOR 0083 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 5506 500 22 500 7/19/2021 TURNER 1.1 " N SIDE OF H-A3-1G (Flexhose) TIGHTEN CONNECTOR 0083 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 3630 500 58 500 7/19/2021 TURNER 1.1 " N SIDE OF H-A3-1G (Union) TIGHTEN CONNECTOR 0083 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 11443 500 99 500 7/19/2021 TURNER 1.4 " N SIDE OF H-A3-1G (Union) TIGHTEN CONNECTOR 0083 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 793 500 103 500 7/19/2021 TURNER 0.2 " N SIDE OF H-A3-1G (Union) TIGHTEN CONNECTOR Page 1 of 3 on 10/8/2021 9:44:56 AM NEICVP1446E01 Appendix G Page 5 of 12 Printed By: dcorbello Indorama Ventures Oxides LLC Port Neches, Texas Leak Detail Report Indorama OO From: 7/1/2021 To: 9/30/2021 Include Leaks found while on DOR and IRO Leaks PNO.061 006 Tag Monitor Date Inspector Unit: OO-A3-W/W-SYS A3-2552-002 A3-2556-S1000 A3-2569-003 A3-2630-002 A3-2705-S1000 A3-2720-002 A3-2834-003 A3-2913-002 A3-2997-003 Comp Type: CONNECTOR Leak Source: union 7/23/21 9:42 AM NRetherford 7/26/21 8:39 AM CMcGee Comp Type: CONNECTOR Leak Source: tub con 7/23/21 9:43 AM NRetherford 7/26/21 8:40 AM CMcGee Comp Type: CONNECTOR Leak Source: connector 7/23/21 9:46 AM NRetherford 7/26/21 8:41 AM CMcGee Comp Type: CONNECTOR Leak Source: union 7/23/21 12:40 PM NRetherford 7/26/21 8:42 AM CMcGee Comp Type: CONNECTOR Leak Source: VENT HOLE 7/23/21 9:23 AM CCollins 7/26/21 8:44 AM CMcGee Comp Type: CONNECTOR Leak Source: UNION 7/23/21 9:42 AM CCollins 7/26/21 8:45 AM CMcGee Comp Type: CONNECTOR Leak Source: union 7/23/21 9:08 AM GRowland 7/26/21 8:47 AM CMcGee Comp Type: CONNECTOR Leak Source: union 7/23/21 12:37 PM GRowland 7/26/21 8:48 AM CMcGee Comp Type: CONNECTOR Leak Source: connector 7/26/21 8:02 AM NRetherford 7/27/21 8:07 AM CMcGee Instrument PPM Thresh. Rep. Date Repaired By: Repair Type Area: SUBPART-FF - A3 W/W SYS Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.2 " N SIDE OF H-A3-1G (Union) 3943 1020 500 0096 123 500 7/26/2021 TURNER TIGHTEN CONNECTOR 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1294 500 86 500 7/26/2021 TURNER 0.2 " N SIDE OF H-A3-1G (Plug) TIGHTEN CONNECTOR 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1425 500 0 500 7/26/2021 TURNER 0.4 " N SIDE OF H-A3-1G (90) TIGHTEN CONNECTOR 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1174 500 16 500 7/26/2021 TURNER 0.2 " S SIDE OF H-A3-1G (Union) TIGHTEN CONNECTOR 3064 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 558 500 217 500 7/26/2021 TURNER 1.1 " N SIDE OF H-A3-1F (Plug) TIGHTEN CONNECTOR 3064 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 2469 500 386 500 7/26/2021 TURNER 1.1 " N SIDE OF H-A3-1F (Union) TIGHTEN CONNECTOR 0589 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 2203 500 109 500 7/26/2021 TURNER 0.2 " S SIDE OF H-A3-1F (90) TIGHTEN CONNECTOR 0589 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.4' S SIDE OF H-A3-F (screw connector) 7673 500 77 500 7/26/2021 TURNER TIGHTEN CONNECTOR 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 2117 500 58 500 7/27/2021 TURNER 0.2' N SIDE OF H-A3-E (90) TIGHTEN CONNECTOR Page 2 of 3 on 10/8/2021 9:44:56 AM NEICVP1446E01 Appendix G Page 6 of 12 Printed By: dcorbello Indorama Ventures Oxides LLC Port Neches, Texas Tag A3-2999-003 A3-3000-001 A3-3002-003 A3-3089-002 A3-3120-003 A3-3399-002 A3-5274-000 Leak Detail Report Indorama OO From: 7/1/2021 To: 9/30/2021 Include Leaks found while on DOR and IRO Leaks PNO.061 007 Monitor Date Inspector Unit: OO-A3-W/W-SYS Comp Type: CONNECTOR Leak Source: connector 7/26/21 8:04 AM NRetherford 7/27/21 8:09 AM CMcGee Comp Type: CONNECTOR Leak Source: connector 7/26/21 8:06 AM NRetherford 7/27/21 8:10 AM CMcGee Comp Type: CONNECTOR Leak Source: connector 7/26/21 8:08 AM NRetherford 7/27/21 8:12 AM CMcGee Comp Type: CONNECTOR Leak Source: union 7/26/21 1:01 PM NRetherford 7/27/21 8:13 AM CMcGee Comp Type: CONNECTOR Leak Source: conector 7/26/21 1:10 PM NRetherford 7/27/21 8:15 AM CMcGee Comp Type: CONNECTOR Leak Source: union 7/26/21 9:16 AM GRowland 7/27/21 8:18 AM CMcGee Comp Type: CONNECTOR Leak Source: FLANGE 7/27/21 3:20 PM NHardy 7/28/21 7:19 AM CMcGee Instrument PPM Thresh. Rep. Date Repaired By: Area: SUBPART-FF - A3 W/W SYS Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 3943 3367 500 0096 23 500 7/27/2021 TURNER Repair Type 0.2' N SIDE OF H-A3-E (90) TIGHTEN CONNECTOR 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 18479 500 0 500 7/27/2021 TURNER 0.2' N SIDE OF H-A3-E (90) TIGHTEN CONNECTOR 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 6223 500 187 500 7/27/2021 TURNER 0.2' N SIDE OF H-A3-E (90) TIGHTEN CONNECTOR 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 7411 500 74 500 7/27/2021 TURNER 0.4' S SIDE OF H-A3-1E (Union) TIGHTEN CONNECTOR 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 2208 500 39 500 7/27/2021 TURNER 1.0' S SIDE OF H-A3-1E (90) TIGHTEN CONNECTOR 0589 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1121 500 161 500 7/27/2021 TURNER 1.0' N SIDE OF H-A3-1C (Union) TIGHTEN CONNECTOR 0587 0096 Rules: HUNTSMAN, FF Size: 3 Service Type: LIGHT LIQUID 45808 500 235 500 7/28/2021 TURNER C-O-14B N OF F-0-114A (Flange) TIGHTEN FLANGE This report was generated using a filter: Rule Name is equal to NESHAPS-FF Page 3 of 3 on 10/8/2021 9:44:56 AM NEICVP1446E01 Appendix G Page 7 of 12 Printed By: dcorbello Indorama Ventures Oxides LLC Port Neches, Texas Leak Detail Report Indorama OO From: 10/1/2021 To: 12/31/2021 Include Leaks found while on DOR and IRO Leaks PNO.061 008 Tag Monitor Date Inspector Unit: OO-A3-W/W-SYS A3-2003-000 A3-2015-000 A3-2046-000 A3-2148-S1000 A3-2248-002 A3-2252-001 A3-2304-000 A3-2507-000 A3-2508-000 Comp Type: VALVE Leak Source: tub con 10/14/21 7:38 AM NRetherford 10/15/21 8:02 AM CMcGee Comp Type: VALVE Leak Source: valve 10/14/21 8:01 AM NRetherford 10/15/21 8:03 AM CMcGee Comp Type: VALVE Leak Source: tub con 10/14/21 8:22 AM NRetherford 10/15/21 8:01 AM CMcGee Comp Type: CONNECTOR Leak Source: plug 10/14/21 2:21 PM NRetherford 10/15/21 8:13 AM CMcGee Comp Type: CONNECTOR Leak Source: UNION 10/14/21 2:57 PM NHardy 10/15/21 8:08 AM CMcGee Comp Type: CONNECTOR Leak Source: UNION 10/14/21 2:55 PM NHardy 10/15/21 8:07 AM CMcGee Comp Type: CONNECTOR Leak Source: SCREWED FITTING 10/9/21 10:16 AM GRowland 10/11/21 10:30 AM CMcGee Comp Type: VALVE Leak Source: valve 10/14/21 9:15 AM BMartindale 10/15/21 8:13 AM CMcGee Comp Type: VALVE Leak Source: valve 10/14/21 9:12 AM BMartindale 10/15/21 8:14 AM CMcGee Instrument PPM Thresh. Rep. Date Repaired By: Repair Type Area: SUBPART-FF - A3 W/W SYS Rules: HUNTSMAN, FF Size: 1 Service Type: GAS / VAPOR 0.2' N SIDE OF H-A3-1J (V-Uncategorized) 3943 9179 500 0096 31 500 10/15/2021 TURNER TIGHTEN PACKING 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.2' N SIDE OF H-A3-1J (V-Uncategorized) 23779 500 61 500 10/15/2021 TURNER TIGHTEN PACKING 3943 0096 Rules: HUNTSMAN, FF Size: 1 Service Type: GAS / VAPOR 0.4' N SIDE OF H-A3-1J (V-Uncategorized) 1888 500 361 500 10/15/2021 TURNER TIGHTEN PACKING 3943 0096 Rules: HUNTSMAN, FF Size: 1 Service Type: GAS / VAPOR 15615 500 110 500 10/15/2021 TURNER 0.2 S SIDE OF H-A3-1J (Plug) TIGHTEN CONNECTOR 3071 0096 Rules: HUNTSMAN, FF Size: 0.5 Service Type: GAS / VAPOR 3170 500 6 500 10/15/2021 TURNER 1.1' N SIDE OF H-A3-H (Union) TIGHTEN CONNECTOR 3071 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 8354 500 23 500 10/15/2021 TURNER 1.1' N SIDE OF H-A3-H (90) TIGHTEN CONNECTOR 3071 0096 Rules: HUNTSMAN, FF Size: 0.5 Service Type: GAS / VAPOR 20400 500 9 500 10/11/2021 TURNER .2" N SIDE OF H-A3-H (Tee) TIGHTEN CONNECTOR 3931 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.2 " N SIDE OF H-A3-1G (V-Uncategorized) 2135 500 16 500 10/15/2021 TURNER TIGHTEN PACKING 3931 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.2 " N SIDE OF H-A3-1G (V-Uncategorized) 971 500 33 500 10/15/2021 TURNER TIGHTEN PACKING Page 1 of 5 on 1/5/2022 1:47:46 PM NEICVP1446E01 Appendix G Page 8 of 12 Printed By: dcorbello Indorama Ventures Oxides LLC Port Neches, Texas Leak Detail Report Indorama OO From: 10/1/2021 To: 12/31/2021 Include Leaks found while on DOR and IRO Leaks PNO.061 009 Tag Monitor Date Inspector Unit: OO-A3-W/W-SYS A3-2509-S2000 A3-2627-000 A3-2634-000 A3-2669-000 A3-2673-000 A3-2695-000 A3-2803-000 A3-2862-000 A3-2979-003 Comp Type: CONNECTOR Leak Source: threads 10/14/21 9:04 AM BMartindale 10/15/21 8:15 AM CMcGee Comp Type: VALVE Leak Source: VALVE PACKING 10/14/21 9:08 AM CCollins 10/15/21 8:11 AM CMcGee Comp Type: VALVE Leak Source: VALVE PACKING 10/14/21 9:22 AM CCollins 10/15/21 8:10 AM CMcGee Comp Type: VALVE Leak Source: VALVE PACKING 10/14/21 10:20 AM CCollins 10/15/21 8:18 AM CMcGee Comp Type: VALVE Leak Source: VALVE PACKING 10/14/21 10:29 AM CCollins 10/15/21 8:17 AM CMcGee Comp Type: VALVE Leak Source: VALVE PACKING 10/14/21 12:47 PM CCollins 10/15/21 8:19 AM CMcGee Comp Type: VALVE Leak Source: VALVE PACKING 10/15/21 9:07 AM CCollins 10/18/21 1:07 PM CMcGee Comp Type: VALVE Leak Source: VALVE PACKING 10/15/21 10:50 AM CCollins 10/18/21 1:08 PM CMcGee Comp Type: CONNECTOR Leak Source: connector 10/15/21 8:08 AM NRetherford 10/18/21 1:10 PM CMcGee Instrument PPM Thresh. Rep. Date Repaired By: Repair Type Area: SUBPART-FF - A3 W/W SYS Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.2 " N SIDE OF H-A3-1G (Flexhose) 3931 1685 500 0096 19 500 10/15/2021 TURNER TIGHTEN CONNECTOR 3064 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.2 " S SIDE OF H-A3-1G (V-Uncategorized) 902 500 8 500 10/15/2021 TURNER TIGHTEN PACKING 3064 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.2 " S SIDE OF H-A3-1G (V-Uncategorized) 2377 500 46 500 10/15/2021 TURNER TIGHTEN PACKING 3064 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.3 " S SIDE OF H-A3-1G (V-Uncategorized) 101909 500 32 500 10/15/2021 TURNER TIGHTEN PACKING 3064 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.3 " S SIDE OF H-A3-1G (V-Uncategorized) 535 500 21 500 10/15/2021 TURNER TIGHTEN PACKING 3064 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.4 " S SIDE OF H-A3-1G (V-Uncategorized) 1912 500 10 500 10/15/2021 TURNER TIGHTEN PACKING 3064 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.4 " N SIDE OF H-A3-1F (V-Uncategorized) 821 500 312 500 10/18/2021 TURNER TIGHTEN PACKING 3064 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.4 " S SIDE OF H-A3-1F (V-Uncategorized) 11099 500 28 500 10/18/2021 TURNER TIGHTEN PACKING 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 21331 500 210 500 10/18/2021 TURNER 1.3' N SIDE OF H-A3-E (90) TIGHTEN CONNECTOR Page 2 of 5 on 1/5/2022 1:47:46 PM NEICVP1446E01 Appendix G Page 9 of 12 Printed By: dcorbello Indorama Ventures Oxides LLC Port Neches, Texas Leak Detail Report Indorama OO From: 10/1/2021 To: 12/31/2021 Include Leaks found while on DOR and IRO Leaks PNO.061 010 Tag Monitor Date Inspector Unit: OO-A3-W/W-SYS A3-2988-003 A3-2999-003 A3-3030-000 A3-3056-000 A3-3258-000 A3-3268-S2000 A3-3396-000 A3-3399-002 A3-3400-000 Comp Type: CONNECTOR Leak Source: connector 10/15/21 8:16 AM NRetherford 10/18/21 1:15 PM CMcGee Comp Type: CONNECTOR Leak Source: connector 10/15/21 8:31 AM NRetherford 10/18/21 1:18 PM CMcGee Comp Type: VALVE Leak Source: valve 10/15/21 1:47 PM NRetherford 10/18/21 1:19 PM CMcGee Comp Type: VALVE Leak Source: valve 10/15/21 9:44 AM NRetherford 10/18/21 1:22 PM CMcGee Comp Type: VALVE Leak Source: valve 10/15/21 7:52 AM BMartindale 10/18/21 1:27 PM CMcGee Comp Type: CONNECTOR Leak Source: vent 10/15/21 8:05 AM BMartindale 10/18/21 1:25 PM CMcGee Comp Type: VALVE Leak Source: packing 10/15/21 1:09 PM JWilson 10/18/21 1:32 PM CMcGee Comp Type: CONNECTOR Leak Source: union 10/15/21 1:16 PM JWilson 10/18/21 1:34 PM CMcGee Comp Type: VALVE Leak Source: packing 10/15/21 1:19 PM JWilson 10/18/21 1:37 PM CMcGee Instrument PPM Thresh. Rep. Date Repaired By: Area: SUBPART-FF - A3 W/W SYS Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 3943 5653 500 0096 32 500 10/18/2021 TURNER Repair Type 1.3' N SIDE OF H-A3-E (90) TIGHTEN CONNECTOR 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 4847 500 77 500 10/18/2021 TURNER 0.2' N SIDE OF H-A3-E (90) TIGHTEN CONNECTOR 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.4' N SIDE OF H-A3-E (V-Uncategorized) 1687 500 14 500 10/18/2021 TURNER TIGHTEN PACKING 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.2' S SIDE OF H-A3-E (V-Uncategorized) 984 500 28 500 10/18/2021 TURNER TIGHTEN PACKING 3931 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.4' N SIDE OF H-A3-D (V-Uncategorized) 1820 500 101 500 10/18/2021 TURNER TIGHTEN PACKING 3931 0096 Rules: HUNTSMAN, FF Size: 0.5 Service Type: GAS / VAPOR 899 500 67 500 10/18/2021 TURNER 0.1' N SIDE OF H-A3-1D (Plug) TIGHTEN CONNECTOR 0589 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.0' N SIDE OF H-A3-1C (V-Uncategorized) 1517 500 25 500 10/18/2021 TURNER TIGHTEN PACKING 0589 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1435 500 19 500 10/18/2021 TURNER 1.0' N SIDE OF H-A3-1C (Union) TIGHTEN CONNECTOR 0589 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1.0' N SIDE OF H-A3-1C (V-Uncategorized) 13870 500 31 500 10/18/2021 TURNER TIGHTEN PACKING Page 3 of 5 on 1/5/2022 1:47:46 PM NEICVP1446E01 Appendix G Page 10 of 12 Printed By: dcorbello Indorama Ventures Oxides LLC Port Neches, Texas Leak Detail Report Indorama OO From: 10/1/2021 To: 12/31/2021 Include Leaks found while on DOR and IRO Leaks PNO.061 011 Tag Monitor Date Inspector Unit: OO-A3-W/W-SYS A3-3454-000 A3-3458-000 A3-3678-002 A3-3704-002 A3-3830-000 A3-3830-S1000 A3-3954-S1000 A3-4274-S1000 A3-4381-000 Comp Type: VALVE Leak Source: valve 10/22/21 8:50 AM NRetherford 10/25/21 8:19 AM CMcGee Comp Type: VALVE Leak Source: valve 10/22/21 9:48 AM NRetherford 10/25/21 8:20 AM CMcGee Comp Type: CONNECTOR Leak Source: UNION 10/22/21 10:04 AM CCollins 10/25/21 8:22 AM CMcGee Comp Type: CONNECTOR Leak Source: UNION 10/22/21 10:48 AM CCollins 10/25/21 8:23 AM CMcGee Comp Type: VALVE Leak Source: valve 10/22/21 8:07 AM BMartindale 10/25/21 8:27 AM CMcGee Comp Type: CONNECTOR Leak Source: plug 10/22/21 8:07 AM BMartindale 10/25/21 8:28 AM CMcGee Comp Type: CONNECTOR Leak Source: fitting 10/22/21 12:27 PM BMartindale 10/25/21 8:25 AM CMcGee Comp Type: CONNECTOR Leak Source: SCREWED FITTING 10/26/21 4:56 PM NHardy 10/28/21 8:42 AM CMcGee Comp Type: VALVE Leak Source: VALVE PACKING 10/26/21 1:00 PM NHardy 10/28/21 8:45 AM CMcGee Instrument PPM Thresh. Rep. Date Repaired By: Repair Type Area: SUBPART-FF - A3 W/W SYS Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.2' N SIDE OF H-A3-1C (V-Uncategorized) 3943 4033 500 0096 24 500 10/25/2021 TURNER TIGHTEN PACKING 3943 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.2' N SIDE OF H-A3-1C (V-Uncategorized) 896 500 16 500 10/25/2021 TURNER TIGHTEN PACKING 3064 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 2999 500 73 500 10/25/2021 TURNER 0.2' N SIDE OF H-A3-1B (Union) TIGHTEN CONNECTOR 3064 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 1252 500 64 500 10/25/2021 TURNER 0.4' N SIDE OF H-A3-1B (Union) TIGHTEN CONNECTOR 3931 0096 Rules: HUNTSMAN, FF Size: 1 Service Type: GAS / VAPOR 1.4 S SIDE OF H-A3-1B (V-Uncategorized) 1853 500 310 500 10/25/2021 TURNER TIGHTEN PACKING 3931 0096 Rules: HUNTSMAN, FF Size: 1 Service Type: GAS / VAPOR 1305 500 421 500 10/25/2021 TURNER 1.4 S SIDE OF H-A3-1B (Plug) TIGHTEN CONNECTOR 3931 0096 Rules: HUNTSMAN, FF Size: 0.75 Service Type: GAS / VAPOR 0.1 N SIDE OF H-A3-1A FCV-80A (Nipple) 1159 500 19 500 10/25/2021 TURNER TIGHTEN CONNECTOR 3071 0096 Rules: HUNTSMAN, FF Size: 0.5 Service Type: GAS / VAPOR 0.8 S/G W SIDE OF F-A3-120B (POEL) (Plug) 7035 500 22 500 10/28/2021 TURNER TIGHTEN CONNECTOR 3071 0096 Rules: HUNTSMAN, FF Size: 4 Service Type: LIGHT LIQUID 1267 500 27 500 10/28/2021 TURNER 0.2 FILTERS W OF P-A3-237 A&B (V-Uncategorized) TIGHTEN PACKING Page 4 of 5 on 1/5/2022 1:47:46 PM NEICVP1446E01 Appendix G Page 11 of 12 Printed By: dcorbello Indorama Ventures Oxides LLC Port Neches, Texas Leak Detail Report Indorama OO From: 10/1/2021 To: 12/31/2021 Include Leaks found while on DOR and IRO Leaks PNO.061 012 Tag Monitor Date Inspector Instrument PPM Thresh. Rep. Date Repaired By: Repair Type This report was generated using a filter: Rule Name is equal to NESHAPS-FF Page 5 of 5 on 1/5/2022 1:47:46 PM NEICVP1446E01 Appendix G Page 12 of 12 Printed By: dcorbello Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 001 NEICVP1446E01 Appendix H Page 1 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 002 NEICVP1446E01 Appendix H Page 2 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 003 NEICVP1446E01 Appendix H Page 3 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 004 NEICVP1446E01 Appendix H Page 4 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 005 NEICVP1446E01 Appendix H Page 5 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 006 NEICVP1446E01 Appendix H Page 6 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 007 NEICVP1446E01 Appendix H Page 7 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 008 NEICVP1446E01 Appendix H Page 8 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 009 NEICVP1446E01 Appendix H Page 9 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 010 NEICVP1446E01 Appendix H Page 10 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 011 NEICVP1446E01 Appendix H Page 11 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 012 NEICVP1446E01 Appendix H Page 12 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 013 NEICVP1446E01 Appendix H Page 13 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.072 014 NEICVP1446E01 Appendix H Page 14 of 14 Indorama Ventures Oxides LLC Port Neches, Texas PNO.073001 NEICVP1446E01 Appendix I Page 1 of 2 Indorama Ventures Oxides LLC Port Neches, Texas PNO.073002 NEICVP1446E01 Appendix I Page 2 of 2 Indorama Ventures Oxides LLC Member of the SGS Group ( Socit Gnrale de Surveillance ) Port Neches, Texas From: To: Subject: Date: Attachments: Schafer, Cynthia Bustamante, Armando; Buenning, Hans; Nabiyar, Zel; Leiker, Brianna; Schneider, Matthew FW: Follow-up records request - NEIC CAA inspection Friday, November 4, 2022 8:02:17 AM image001.png image003.png Downloading the files now to a folder called "Received 11-4-22". See explanations below from Mike. Thanks, Cindy Cindy Schafer, P.E. Environmental Engineer U.S. Environmental Protection Agency National Enforcement Investigations Center Denver Federal Center, Building 25 | Denver, CO 80225 303-462-9310 From: Michael Dubois <Michael.Dubois@us.indorama.net> Sent: Thursday, November 3, 2022 4:54 PM To: Schafer, Cynthia <Schafer.Cynthia@epa.gov> Cc: Leslie Stuart <Leslie.Stuart@us.indorama.net> Subject: RE: Follow-up records request - NEIC CAA inspection Hi Cindy, We have uploaded the documents requested. I've combined each of the recent requests into a list below with comments for clarification. Let me know if we missed something. Thanks. "The LDAR database we received seems to only have information for the F5 area. I was expecting to get LDAR data for the ethylene and ethylene oxide processes at a minimum (during the inspection I think someone stated that the LDAR database covered the entire facility). I'd like to get the LDAR database (.bak file) for the ethylene and ethylene oxide process units, including the associated tanks and loading racks." Uploaded to FTP 11/02/2022 Records showing how much AD was offloaded onto trucks/sold from January 2018 - October 2022 Uploaded to FTP 11/03/2022 Analysis/test results of the AD showing the benzene content Uploaded to FTP 11/03/2022 The underlying analytical data that supports the TAB reports including information about exactly where samples were collected. We have the reported benzene quantities and the flow rates; we are asking for the test NEICVP1446E01 Appendix J Page 1 of 8 Indorama Ventures Oxides LLC Port Neches, Texas results and explanations of where the samples were taken This data appears to have been in use since 2004. We are unable to locate this information. In the files titled "YEAR BWON LDAR" there are records of leaks found and repaired that were identified as subject to BWON LDAR requirements. We aren't able to tell what pieces of equipment the leaks were found on. For each leak identified in the 2018-2021 BWON LDAR report, could you provide a narrative description of where each leak was found and what type of BWON waste management unit it is associated with? For example, the first leak in the 2020 BWON LDAR report is at unit OO-A3-W/W-SYS and at A3-2162-002 and is a connector. What type of unit is this? (e.g., vessel 2162 and it is a waste water separator). Uploaded to FTP 11/03/2022 40 CFR Part 63, YY NOCS [ethylene MACT NOCS] Uploaded to FTP 11/03/2022 Follow-Up Questions: What material is in the AD loading sump that is associated with the AD loading rack/AD washoil sump? - the "AD Loading Sump" tab in the "2020 Calcs.xls" states that this waste stream is not straight aromatic distillate and that it is controlled (a vacuum truck is used to remove material on the filter). How much of the material in the AD loading sump is aromatic distillate and how much is something else? Does the non-aromatic distillate material contain no benzene? Is this waste stream the only waste steam that is generated from the filter? Uploaded to FTP 11/03/2022 40 CFR Part 63, Subparts F and G NOCS that includes info for EtO tanks and loading racks The NOCs cannot be located. The R and S HON Study for storage vessels was previously provided. The R and S HON Study for loading racks was uploaded to FTP 11/03/2022. Original HON audit report [the report provided was an update covering the status of corrective actions being taken as a result of the audit] Uploaded to FTP 11/03/2022 Title V reports where HON violations found in audit were disclosed and any other disclosures to EPA of HON violations Already provided for Indorama reports. We do not have a signed copy of the original Huntsman submission. Flare date (excel format - same info/format as previously received) covering October 17-21, 2022 Uploaded to FTP on 11/03/2022. This includes the additional data Zel requested. BWON reports containing quarterly visual and annual Method 21 inspections for the waste management units Quarterly visuals included in previously provided weekly AVO inspections. Method 21 inspections uploaded to FTP site on 11/03/2022. Michael DuBois Environmental Manager Indorama Ventures-Port Neches Operations O: 409-723-3670 C: 360-389-1516 NEICVP1446E01 Appendix J Page 2 of 8 Indorama Ventures Oxides LLC Port Neches, Texas From: Schafer, Cynthia <Schafer.Cynthia@epa.gov> Sent: Tuesday, November 1, 2022 4:37 PM To: Michael Dubois <Michael.Dubois@us.indorama.net>; Leslie Stuart <Leslie.Stuart@us.indorama.net> Subject: RE: Follow-up records request - NEIC CAA inspection [External Email] Hi Mike and Leslie - I forgot, the LDAR database we received seems to only have information for the F5 area. I was expecting to get LDAR data for the ethylene and ethylene oxide processes at a minimum (during the inspection I think someone stated that the LDAR database covered the entire facility). I'd like to get the LDAR database (.bak file) for the ethylene and ethylene oxide process units, including the associated tanks and loading racks. Thanks, Cindy Cindy Schafer, P.E. Environmental Engineer U.S. Environmental Protection Agency National Enforcement Investigations Center Denver Federal Center, Building 25 | Denver, CO 80225 303-462-9310 From: Schafer, Cynthia Sent: Tuesday, November 1, 2022 3:14 PM To: Michael Dubois <Michael.Dubois@us.indorama.net>; Leslie Stuart <Leslie.Stuart@us.indorama.net> Subject: RE: Follow-up records request - NEIC CAA inspection Hi Mike and Leslie, I'm not sure if there was more to your recent message, but below is the message that I received (just says "Dor"). I believe Zel contacted you yesterday with additional flare related requests and questions. You can work with him to provide the requested info or use the GoAnywhere link I sent out during the inspection and I can get the info to him. I have a few requests to add: Records showing how much AD was offloaded onto trucks/sold from January 2018 - October 2022 NEICVP1446E01 Appendix J Page 3 of 8 Indorama Ventures Oxides LLC Port Neches, Texas Analysis/test results of the AD showing the benzene content The underlying analytical data that supports the TAB reports including information about exactly where samples were collected. We have the reported benzene quantities and the flow rates; we are asking for the test results and explanations of where the samples were taken In the files titled "YEAR BWON LDAR" there are records of leaks found and repaired that were identified as subject to BWON LDAR requirements. We aren't able to tell what pieces of equipment the leaks were found on. For each leak identified in the 2018-2021 BWON LDAR report, could you provide a narrative description of where each leak was found and what type of BWON waste management unit it is associated with? For example, the first leak in the 2020 BWON LDAR report is at unit OO-A3-W/W-SYS and at A3-2162-002 and is a connector. What type of unit is this? (e.g., vessel 2162 and it is a waste water separator). Let me know if you have any questions about what we are asking for or if you'd like to discuss any of the requests. Thanks, Cindy Cindy Schafer, P.E. Environmental Engineer U.S. Environmental Protection Agency National Enforcement Investigations Center Denver Federal Center, Building 25 | Denver, CO 80225 303-462-9310 From: Michael Dubois <Michael.Dubois@us.indorama.net> Sent: Tuesday, November 1, 2022 2:13 PM To: Schafer, Cynthia <Schafer.Cynthia@epa.gov>; Leslie Stuart <Leslie.Stuart@us.indorama.net> Subject: Re: Follow-up records request - NEIC CAA inspection Dor From: Schafer, Cynthia <Schafer.Cynthia@epa.gov> Sent: Friday, October 28, 2022 2:36:46 PM To: Leslie Stuart <Leslie.Stuart@us.indorama.net>; Michael Dubois <Michael.Dubois@us.indorama.net> Subject: Follow-up records request - NEIC CAA inspection [External Email] Good afternoon Leslie and Mike NEICVP1446E01 Appendix J Page 4 of 8 Indorama Ventures Oxides LLC Port Neches, Texas The NEIC inspection team has had a chance to start reviewing the records that were submitted by Indorama - Port Neches and would like to request the below records or answers to the below questions. We have requested some of these previously; if they aren't available please state that so we can note that the particular record isn't available and stop asking for it. 40 CFR Part 63, YY NOCS [ethylene MACT NOCS] Follow-Up Questions: What material is in the AD loading sump that is associated with the AD loading rack/AD washoil sump? - the "AD Loading Sump" tab in the "2020 Calcs.xls" states that this waste stream is not straight aromatic distillate and that it is controlled (a vacuum truck is used to remove material on the filter). How much of the material in the AD loading sump is aromatic distillate and how much is something else? Does the non-aromatic distillate material contain no benzene? Is this waste stream the only waste steam that is generated from the filter? 40 CFR Part 63, Subparts F and G NOCS that includes info for EtO tanks and loading racks Original HON audit report [the report provided was an update covering the status of corrective actions being taken as a result of the audit] Title V reports where HON violations found in audit were disclosed and any other disclosures to EPA of HON violations Flare date (excel format - same info/format as previously received) covering October 17-21, 2022 BWON reports containing quarterly visual and annual Method 21 inspections for the waste management units Also want to mention that there may be another request early next week for additional records regarding the flares. The team needs more time to go through what we've received before deciding if additional information is needed. I think the GoAnywhere link should still work, but let me know if you'd like me to send out a new link for any reason. Thanks, Cindy Cindy Schafer, P.E. Environmental Engineer U.S. Environmental Protection Agency National Enforcement Investigations Center Denver Federal Center, Building 25 | Denver, CO 80225 303-462-9310 From: Schafer, Cynthia Sent: Wednesday, October 26, 2022 4:50 PM NEICVP1446E01 Appendix J Page 5 of 8 Indorama Ventures Oxides LLC Port Neches, Texas To: Leslie Stuart <Leslie.Stuart@us.indorama.net> Cc: Michael Dubois <Michael.Dubois@us.indorama.net> Subject: RE: Files Uploaded Hi Leslie - I received the 23 files listed below. I will work with the team to get back to you quickly on any additional records requests. Thanks, Cindy Cindy Schafer, P.E. Environmental Engineer U.S. Environmental Protection Agency National Enforcement Investigations Center Denver Federal Center, Building 25 | Denver, CO 80225 303-462-9310 From: Leslie Stuart <Leslie.Stuart@us.indorama.net> Sent: Wednesday, October 26, 2022 4:01 PM To: Schafer, Cynthia <Schafer.Cynthia@epa.gov> Cc: Michael Dubois <Michael.Dubois@us.indorama.net> Subject: RE: Files Uploaded Cindy, I just uploaded 23 more files. 12 PDF files and 11 excel spreadsheets. Please let me know if you do not receive them. This should satisfy the records that have been requested. If you see a gap, please let us know. Thank you! NEICVP1446E01 Appendix J Page 6 of 8 Indorama Ventures Oxides LLC Port Neches, Texas Leslie Stuart Senior Environmental Manager Indorama Ventures Oxides, LLC. 346-380-6544 From: Schafer, Cynthia <Schafer.Cynthia@epa.gov> Sent: Wednesday, October 26, 2022 9:18 AM To: Leslie Stuart <Leslie.Stuart@us.indorama.net> Cc: Michael Dubois <Michael.Dubois@us.indorama.net> Subject: RE: Files Uploaded [External Email] Thank you Leslie - I have received the 4 documents listed below as well as the flare data in Excel. Thanks, Cindy Cindy Schafer, P.E. Environmental Engineer U.S. Environmental Protection Agency National Enforcement Investigations Center Denver Federal Center, Building 25 | Denver, CO 80225 NEICVP1446E01 Appendix J Page 7 of 8 Indorama Ventures Oxides LLC Port Neches, Texas 303-462-9310 From: Leslie Stuart <Leslie.Stuart@us.indorama.net> Sent: Tuesday, October 25, 2022 7:49 PM To: Schafer, Cynthia <Schafer.Cynthia@epa.gov> Cc: Michael Dubois <Michael.Dubois@us.indorama.net> Subject: Files Uploaded Cindy, Earlier this afternoon I uploaded the flare excel file. Just now I uploaded four more files: Please let me know if you do not get these files. Leslie Stuart Senior Environmental Manager Indorama Ventures Oxides, LLC. 346-380-6544 Important: This email and any files transmitted with it are confidential and may be privileged or otherwise protected from disclosure; they are intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient or have received this email or attachment in error, you must not read, copy, store, use, forward or disclose the email or attachment to any other person. Please return the message to the sender and delete it from your system immediately thereafter. NEICVP1446E01 Appendix J Page 8 of 8 Indorama Ventures Oxides LLC Port Neches, Texas PNO.048 001 NEICVP1446E01 Appendix L Page 1 of 13 Indorama Ventures Oxides LLC Port Neches, Texas ATTACHMENT 1 COMPLIANCE AUDIT PORT NECHES FINDINGS TABLE Revision Date: March 30, 2022 Finding Numbe r Regulatio n Reference Finding or Observation Date Discovere d Date/Length of Existence Corrective Measures Taken Status of Corrective Measures 03/30/2021 Work Remaining Quarterly Update 03/31/2021 Requested Extension Date Status of Corrective Measures 06/30/2021 Extension Requested 09/30/2021 1 40 CFR Updated HON 18-Nov-19 Unknown Indorama will All applicability Application to See Items 5, 7, 8. 63.10(b), applicability review and update determinations have update the Title V 63.151(j) documentatio 40 CFR 63, Subparts been reviewed and Permit to n could not be F and G applicability updated for F4, F5, incorporate all located for F4, and/or non- F6, with the newly identified and F6 or F5 applicability exception of the revised operating determinations for following: determinations for units. emissions sources F4, F5, and F6 will within the F-4, F-6, be submitted by and F-5 CMPUs to 4/30/2021 ensure accurate representation of current equipment and operations. Documentation will be developed and/or updated based on this review. Complete NA PNO.048 002 Status of Corrective Measures 12/21/2021 NA Status of Corrective Measures 03/30/2022 NA Status of Corrective Measures 06/30/2022 NA NEICVP1446E01 The revised NOCS will be submitted as required (Finding 2). The Title V Operating Permit will be updated as required and as necessary, pending the outcome of this review. Group Status Determinations for four (4) Wastewater Potential Points of Determination in F4 and F6 that could not be sampled due to safety concerns (See Item 7). Update of HON determinations in the form of an updated NOCS to be attached to the next HON semiannual reports for the EO and PO/MTBE CMPUs, respectively for F4, F6 and F5 by 4/30/2021. See Items 5, 7, 8. Update of HON semiannual report template for the EO and PO/MTBE See Items 5, 7, 8. Appendix L Page 2 of 13 Complete NA Complete NA NA NA NA NA NA NA Indorama Ventures Oxides LLC Port Neches, Texas ATTACHMENT 1 COMPLIANCE AUDIT PORT NECHES FINDINGS TABLE Revision Date: March 30, 2022 CMPUs, respectively, for F4, F6 and F5 to incorporate reporting requirements associated with revised determinations by 4/30/2021. Update of Title V Permit, as necessary pending the testing of the remaining wastewater potential points of determination. See Items 7, 8. See Items 5, 7, 8. Complete NA Update of Title V Permit, as necessary, pending the retest of the F4 CO2 Vent. See Item 5. See Items 5, 7, 8. Complete NA 2 40 CFR Notifications of 18-Nov-19 Unknown NOCS will be See Item 1, above. See Item 1, above. See Item 1, above. Complete NA 63.100, Compliance updated, as 63.151(j) Status were necessary, based on not updated to other action items reflect revised completed by applicability Indorama. Revised for F4, F6, or NOCS will be F5 operating submitted. units 3 40 CFR Detailed 18-Nov-19 March 2016 Indorama will All applicability Application to See Items 5, 7, 8. 63.10(b), applicability - TBD perform and determinations have update the Title V 63.151(j) documentatio document detailed been completed for Permit to n could not be 40 CFR 63, Subparts F8, with the incorporate all located for F and G applicability exception of the newly identified and group status and/or non- following: revised determination applicability determinations for s of the F8 determinations for F8 will be submitted operating unit. the F8 HON CMPU. by 4/30/2021. Complete NA NEICVP1446E01 Appendix L Page 3 of 13 PNO.048 003 NA NA NA NA NA NA NA NA NA NA NA NA Indorama Ventures Oxides LLC Port Neches, Texas ATTACHMENT 1 COMPLIANCE AUDIT PORT NECHES FINDINGS TABLE Revision Date: March 30, 2022 The NOCS will be submitted as required (Finding 4). The Title V Operating Permit will be updated as required and as necessary, pending the outcome of this review. Group Status Determination for one (1) Wastewater Potential Point of Determination in F8 that could not be sampled due to safety concerns (See Item 8) Incorporation of F8 HON determinations in the form of an updated NOCS to be attached to the next HON semiannual reports for the EO CMPU by 4/30/2021. See Items 5, 7, 8. Group Status Determination for one (1) Wastewater Potential Point of Determination that could not be sampled due to low water flow (See Item 8). Update of HON semiannual report template for the EO CMPU incorporate reporting requirements associated with F8 determinations. See Items 5, 7, 8. Complete NA Complete NA Complete NA See Items 5, 7, 8. 4 40 CFR NOCS 18-Nov-19 March 2016 The NOCS will be See Item 2, above. See Item 2, above. See Item 2, above. Complete NA 63.152(b) documentatio - TBD submitted as n was not required. updated and submitted for the F8 operating unit. NEICVP1446E01 Appendix L Page 4 of 13 PNO.048 004 NA NA NA NA NA NA NA NA NA NA NA NA Indorama Ventures Oxides LLC Port Neches, Texas ATTACHMENT 1 COMPLIANCE AUDIT PORT NECHES FINDINGS TABLE Revision Date: March 30, 2022 5 40 CFR Documentatio 18-Nov-19 Unknown Indorama will Engineering An application will F4 CO2 Vent engineering re- Complete - no NA 63.115 n for CO2 perform new TRE assessments have be submitted by test report to properly updates required. Vents determinations and been conducted for 4/30/2021 to document TRE > 4.0: associated establish F4, F6 and F8, with update the Title V 6/30/2021 to allow for with F4, F6, F8 operational successful Operating Permit to return of test results. operating units limitations for the demonstrations of reflect the is inconsistent CO2 Recovery Group 2 Status for determination that and does not System to ensure F4 CO2 Vent (TRE all three (3) of these adequately compliance, in between 1 and 4) vents are Group 2 demonstrate accordance with the and F6 and F8 CO2 with a TRE > 4.0. In Group 2 status methods and Vents (TRE above 4). the event that the as required. procedures outlined Method 18 retest in 40 CFR 63.115 for shows other results, the CO2 Vents in F4, Indorama will F6 and F8. update the Title V The NOCS will be accordingly. updated/submitted as required (Finding 2, Finding 4). The Title V The engineering For F4, the Method Title V Update (if necessary Complete - no NA Operating Permit assessment of the 18 retest is pending F4 Retest): updates required. will also be updated F4 CO2 Vent is scheduled to be 6/30/2021 as required and as believed to be completed in April necessary, pending inappropriately 2021 to properly the outcome of this biased high due to document the TRE review. performance issues as required by 40 with the testing CFR 63.115. contractor and data collected. Method 18 results were sampled, but not received for F4, therefore the only data available from testing was FTIR based data. The FTIR data is biased high due to cross- interferences between stream constituents as demonstrated by Method 18 results on other trains. As NEICVP1446E01 Appendix L Page 5 of 13 PNO.048 005 NA NA NA NA NA NA Indorama Ventures Oxides LLC Port Neches, Texas ATTACHMENT 1 COMPLIANCE AUDIT PORT NECHES FINDINGS TABLE Revision Date: March 30, 2022 such, Indorama is retesting the F4 CO2 Vent using Method 18 with a new testing contractor to properly document the TRE as above 4. In the event that the NOCS Update: (if necessary Complete - no NA retest does not pending F4 Retest) updates required. show a TRE > 4.0, 6/30/2021 Indorama will update the Title V accordingly. 6 40 CFR 71, Permitted 18-Nov-19 Unknown Pending the As discussed in Pending the retest NSR Update, as necessary: Complete - all units NA NSR maximum outcome of Finding Finding 5, above, of the CO2 Vents 6/30/2021. in compliance with Permit emissions 5, Indorama will performance test utilizing Method NSR permit limits. 5972A, rates for CO2 review permitted issues with the 25A, the NSR permit F8 permit 5952A, vents and emission rates and testing contractor will be updated, as amendment 10169 wastewater the NSR Permit for and data collected necessary. application fugitives are F-4, F-6 and F-8 to have provided test submitted to modify higher than ensure maximum results that are representation to actual emission rates align believed to biased more accurately emissions and with the proper high. As such, reflect emissions do not align Group Status for the retesting of all three characterization with existing CO2 Vents and (3) vents is 6/30/2021. HON wastewater fugitive scheduled in April applicability emissions in each 2021 utilizing 40 CFR determination unit, as needed. 60, Appendix A - s. Method 25A. Port access to enable compliant Method 4 flows has been resolved. NEICVP1446E01 For wastewater fugitive emissions, no updates to the NSR are necessary at this time. Appendix L Page 6 of 13 PNO.048 006 NA NA NA NA NA NA Indorama Ventures Oxides LLC Port Neches, Texas ATTACHMENT 1 COMPLIANCE AUDIT PORT NECHES FINDINGS TABLE Revision Date: March 30, 2022 PNO.048 007 7 40 CFR Detailed 18-Nov-19 Unknown Indorama will Wastewater A Title V application Sampling of one (1) potential Complete- Title V 12/31/21 for F4 and the low Operational The F8 and two F6 63.132(a)( applicability perform a review of Potential Points of will be submitted by POD in F8 that could not be application sampling, Group water F8 POD conditions PODs were 1)/ (c), documentatio F-4, F-6, F-8, and F-5 Determination 4/30/2021 to sampled due to lack of water submitted Status sampling are allowed for the designated as 63.144(b)/ n could not be CMPUs to identify (PODs) have been update the Group and finalization of Group 04/30/21. Determination, and complete. Group early installation Group 2 based on (c) located for and properly reviewed and Status Status Determination: Title V update if 2 status was of the F8 and the sample several HON document all updated for F4, F5, Determinations for 6/30/2021. necessary. confirmed. (two) F6 POD results. wastewater Points of Determination (PODs). applicability and non-applicability determinations to ensure all potential HON wastewater points of determination (PODs) are addressed. This effort will include the development and implementation of a HON Wastewater Sampling Plan to properly perform applicability and group status determinations for all wastewater potential PODs. F6 and F8. all completed determinations in F4, F5, F6 and F8. Sufficient water for F8 potential POD was determined present on June 30, 2021 to safely sample and the sampling contractor has been scheduled. The low water F8 POD was inadvertently drained by Operations prior to sampling. F6 and remaining F8 PODs on track for Q1/Q2 2022 turnaround sample port installation, collection, analysis, and updates. sample points. Sampling has been completed for these; however, sample results have not been received to make a Group determination yet. Remaining F6 PODs on track for Q2 2022 turnaround sample part installation and collection. The remaining F6 sample points were installed during the 2nd quarter turnaround. The POD determination samples were obtained on 6/30/2022. Results are forthcoming. NEICVP1446E01 The NOCS for the F- 4, F-6 and F-5 HON CMPUs will be updated and resubmitted and the NOCS for the F-8 HON CMPU will be submitted (See Findings 2 and 4) as required and as necessary, pending the outcome of this review. Wastewater PODs and Group Status Determinations have been reviewed and updated for F5, with all HAP containing PODs routed to the Wastewater Stripper System, the Process Liquid Fuels (PLF) system, and managed offsite as a RCRA Hazardous Waste being designated and managed as Group 1 NOCS update must be submitted (see Items 1, 3, above) by 4/30/2021. Six (6) potential POD Sample Port Installations: Indorama will install sampling ports no later than the next multi-day outage, with sampling within one calendar quarter of returning equipment to service after the outage. Currently, the next scheduled outage is 4th quarter 2021 for F4 and 1st /2nd quarter 2022 for F6/F8. Note: Previous updates inadvertently stated the sample port installation Complete- NOCS submitted 04/30/2021. Sample port installation per outage schedule. Note: The outage dates for F4 (1st qtr 2022) and F8 (1st/2nd qtr 2023) were inadvertently switched in prior quarterly updates. Process unit outage required: Revised schedule - 4th qtr 2021 for F4 (unplanned) and 1st/2nd qtr 2022 for F6/F8 for sample port installation, collection, analysis, and updates. Update: F4 and the low water F8 POD sampling are complete. Group 2 status was confirmed. F6 and remaining F8 PODs on track for Q1/Q2 2022 turnaround sample port installation, collection, analysis, and updates. Appendix L Page 7 of 13 Operational conditions allowed for the early installation of the F8 and (two) F6 POD sample points. Sampling has been completed for these; however, sample results have not been received to make a Group determination yet. The F8 and two F6 PODs were designated as Group 2 based on the sample results. The remaining F6 sample points were installed during the 2nd quarter Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 ATTACHMENT 1 COMPLIANCE AUDIT PORT NECHES FINDINGS TABLE Revision Date: March 30, 2022 PNO.048 008 Process Wastewaters. count was five rather than six. The low water F8 POD was inadvertently drained by Operations prior to sampling. Operational conditions allowed for the early installation of the F4 POD sample point. Sampling arrangements are being made and expected to be complete for both PODs by 12/31/21. Remaining F6 PODs on track for Q2 2022 turnaround sample part installation and collection. turnaround. The POD determination samples were obtained on 6/30/2022. Results are forthcoming. The Title V Operating Permit will be updated as required and as necessary, pending the outcome of this review. The HON Wastewater Sampling Plan was implemented in October/November 2020 for all potential PODs in F4, F6 and F8, with the exception of five (5) potential PODs that could not be sampled due to safety concerns (pressure), and one (1) potential POD that could not be sampled in F8 due to a lack of liquids Sampling of one (1) potential POD in F8 that could not be sampled due to a lack of liquids. Group Status Determinations, and Title V Update for remaining potential PODs (as necessary pending determinations): One (1) calendar quarter after sample port installation. Note: Previous updates inadvertently stated the sample port installation count was five rather than six. Appendix L Page 8 of 13 Sample port installation per outage schedule. Note: The outage dates for F4 (1st qtr 2022) and F8 (1st/2nd qtr 2023) were inadvertently switched in prior quarterly updates. Sufficient water for F8 potential POD was determined present on June 30, 2021 to safely sample and the Process unit outage required: Revised schedule - 4th qtr 2021 for F4 (unplanned) and 1st/2nd qtr 2022 for F6/F8 for sample port installation, collection, analysis, and updates. Update: The low water F8 POD was inadvertently drained by Operations prior to sampling. Operational conditions allowed for the early installation of the F4 POD sample F4 and the low water F8 POD sampling are complete. Group 2 status was confirmed. F6 and remaining F8 PODs on track for Q1/Q2 2022 turnaround sample port installation, collection, analysis, and updates. Operational conditions allowed for the early installation of the F8 and (two) F6 POD sample points. Sampling has been completed for these; however, sample results have not been received to make a Group determination yet. Remaining F6 PODs on track for Q2 2022 turnaround sample part installation and collection. The F8 and two F6 PODs were designated as Group 2 based on the sample results. The remaining F6 sample points were installed during the 2nd quarter turnaround. The POD determination samples were obtained on 6/30/2022. Results are forthcoming. Indorama Ventures Oxides LLC Port Neches, Texas 8 40 CFR Potential 63.132(a)( failure to 2)(i) identify all HON waste NEICVP1446E01 18-Nov-19 Unknown ATTACHMENT 1 COMPLIANCE AUDIT PORT NECHES FINDINGS TABLE Revision Date: March 30, 2022 PNO.048 009 sampling contractor has been scheduled. point. Sampling arrangements are being made and expected to be complete for both PODs by 12/31/21. For the potential PODs sampled in F4, F6 and F8 - wastewater analytical results indicate Group 2 Status at this time. Six (6) potential PODs associated with F4, F6 and F8 were not able to be sampled to determine Group Status for Process Wastewaters due to safety concerns (pressure). To safely sample these points, the equipment must be taken out of service and depressurized to allow for sampling port installation during the next scheduled outage. These potential PODs will then be sampled, with group status determinations finalized. NOCS and Title V Update for remaining potential PODs (as necessary pending determinations): To be submitted with the next HON Semiannual Compliance Report following finalization of Group Status Determinations. Pending sample port installation. Note: Previous updates inadvertently stated the sample port installation count was five rather than six. Sufficient water for F8 potential POD was determined present on June 30, 2021 to safely sample and the sampling contractor has been scheduled. Process unit outage required: Revised schedule - 4th qtr 2021 for F4 (unplanned) and 1st/2nd qtr 2022 for F6/F8 for sample port installation, collection, analysis, and updates. Update: The low water F8 POD was inadvertently drained by Operations prior to sampling. Operational conditions allowed for the early installation of the F4 POD sample point. Sampling arrangements are being made and expected to be complete for both PODs by 12/31/21. F4 and the low water F8 POD sampling are complete. Group 2 status was confirmed. F6 and remaining F8 PODs on track for Q1/Q2 2022 turnaround sample port installation, collection, analysis, and updates. Operational conditions allowed for the early installation of the F8 and (two) F6 POD sample points. Sampling has been completed for these; however, sample results have not been received to make a Group determination yet. Remaining F6 PODs on track for Q2 2022 turnaround sample part installation and collection. The F8 and two F6 PODs were designated as Group 2 based on the sample results. The remaining F6 sample points were installed during the 2nd quarter turnaround. The POD determination samples were obtained on 6/30/2022. Results are forthcoming. Indorama will conduct a review to ensure all waste management units Waste Management Units (WMUs) have been updated for F4, F5, F6 and F8 for An application will be submitted by 4/30/2021 to update the Title V Identification of WMUs managing any Group 1 process wastewaters identified from the Complete - Title V Updates for F4 and F6 submitted 04/30/21. Title V Process unit outage required: F4 and the low water F8 POD sampling are complete. Group Operational conditions allowed for the early installation The F8 and two F6 PODs were designated as Group 2 based on Appendix L Page 9 of 13 Indorama Ventures Oxides LLC Port Neches, Texas ATTACHMENT 1 COMPLIANCE AUDIT PORT NECHES FINDINGS TABLE Revision Date: March 30, 2022 PNO.048 010 management units managing HON Group 1 Wastewater Streams. managing HON Group 1 Wastewater Streams are identified and operating in compliance with the applicable requirements of 40 CFR 63.133 - 63.137. all completed determinations. The NOCS will be updated and resubmitted (See Finding 2) as required and as necessary, pending the outcome of this review. The Title V Operating Permit will also be updated as required and as necessary. Permit for to reflect all revised and newly identified WMU determinations. For updated WMUs in F5 and F4, F6, F8 (as warranted pending receipt of wastewater sampling results) NOCS update will be submitted by 4/30/2021. (see Items 1, 3, above). Upon completion of group status determinations for remaining potential PODs in Item 8, above, WMUs will be identified, as necessary, if any Group 1 Process Wastewaters are identified and an application will be submitted to update the Title V Permit. remaining potential PODs in Item 8, above and Title V Update (as necessary pending determinations): One (1) calendar quarter after sampling, see Item 8, above. NOCS Update for remaining potential PODs (as necessary pending determinations): To be submitted with the next HON Semiannual Compliance Report following finalization of Group Status Determinations, See Item 7, above. updates for F5 submitted 06/30/2021 Complete - NOCS for F4, F5, F6, F8 submitted 04/30/21. Sample port installation required for remaining PODs. Note: Previous updates inadvertently stated the sample port installation count was five rather than six. Revised schedule - 4th qtr 2021 for F4 (unplanned) and 1st/2nd qtr 2022 for F6/F8 for sample port installation, collection, analysis, and updates. Update: The low water F8 POD was inadvertently drained by Operations prior to sampling. Operational conditions allowed for the early installation of the F4 POD sample point. Sampling arrangements are being made and expected to be complete for both PODs by 12/31/21. 2 status was confirmed. F6 and remaining F8 PODs on track for Q1/Q2 2022 turnaround sample port installation, collection, analysis, and updates. of the F8 and (two) F6 POD sample points. Sampling has been completed for these; however, sample results have not been received to make a Group determination yet. Remaining F6 PODs on track for Q2 2022 turnaround sample part installation and collection. the sample results. The remaining F6 sample points were installed during the 2nd quarter turnaround. The POD determination samples were obtained on 6/30/2022. Results are forthcoming. 9 40 CFR Table 11 18-Nov-19 Unknown If deemed Waste management Upon completion of Update of F4, F6, F8 WMU Inspection template Process unit F4 and the low Operational The F8 and two F6 63.143(a) semiannual necessary, unit (WMU) group status Inspection Template, NOCS updates complete. outage required: water F8 POD conditions PODs were inspections for Indorama will inspections were determinations for and Title V Permit, as sampling are allowed for the designated as HON waste modify its existing not occurring in F5. remaining potential necessary pending complete. Group early installation Group 2 based on management units may require program of conducting and documenting inspections in accordance with the WMU inspection procedure has been developed and inspection template has been developed PODs in Item 8, above, WMUs will be identified, as necessary, if any Group 1 Process determinations for remaining potential PODs in Item 8, above: One (1) calendar quarter after Further Inspection Template, NOCS, and Title V Permit modification Revised schedule - 4th qtr 2021 for F4 (unplanned) and 2 status was confirmed. F6 and remaining F8 PODs on track of the F8 and (two) F6 POD sample points. Sampling has been completed the sample results. NEICVP1446E01 Appendix L Page 10 of 13 Indorama Ventures Oxides LLC Port Neches, Texas documentatio n updates. 10 40 CFR Annual visual 18-Nov-19 Unknown 63.148(i) inspections for HON closed vent systems may require documentatio n updates. NEICVP1446E01 ATTACHMENT 1 COMPLIANCE AUDIT PORT NECHES FINDINGS TABLE Revision Date: March 30, 2022 PNO.048 011 requirements outlined in Table 11 of 40 CFR 63, Subpart G. and finalized for F5, with first round of inspections utilizing new template completed in 4th quarter 2020. As a part of the final project quality control review, modifications were made to the initial inspection template that added additional inspection points and these additional points were inspected in 1st quarter 2021. Wastewaters are identified. Waste management unit inspection templates to be developed, as necessary, upon completion of group status determinations for F4, F6 and F8 potential PODs upon receipt of wastewater analytical for all potential PODs remaining to be sampled. The NOCS, Title V Permit and WMU inspection templates will be updated, as necessary, if additional Group 1 Process Wastewaters are identified. sample port installation in Item 7, above. pending remaining outage dependent POD determinations as needed. Sample port installation required for remaining PODs. Note: Previous updates inadvertently stated the sample port installation count was five rather than six. 1st/2nd qtr 2022 for F6/F8 for sample port installation, collection, analysis, and updates. Update: The low water F8 POD was inadvertently drained by Operations prior to sampling. Operational conditions allowed for the early installation of the F4 POD sample point. Sampling arrangements are being made and expected to be complete for both PODs by 12/31/21. for Q1/Q2 2022 turnaround sample port installation, collection, analysis, and updates. for these; however, sample results have not been received to make a Group determination yet. Remaining F6 PODs on track for Q2 2022 turnaround sample part installation and collection. The remaining F6 sample points were installed during the 2nd quarter turnaround. The POD determination samples were obtained on 6/30/2022. Results are forthcoming. If deemed necessary, Indorama will modify its existing program of conducting and documenting inspections of HON CVS systems. All HON CVS have been inspected, as required for F4, F5, F6 and F8. All HON Bypass Valves have been identified and secured with appropriate None currently. If additional waste management units are identified in Item 9, above, for the remaining Update of F4, F6, F8 CVS and Bypass Valve inspection and recordkeeping programs as necessary pending determinations for remaining potential PODs in Item 8, above: One (1) calendar quarter after Appendix L Page 11 of 13 Complete with the exception of outage dependent sample port installation previously identified. Process unit outage required: Revised schedule - 4th qtr 2021 for F4 (unplanned) and F4 and the low water F8 POD sampling are complete. Group 2 status was confirmed. F6 and remaining F8 PODs on track for Q1/Q2 2022 Operational conditions allowed for the early installation of the F8 and (two) F6 POD sample points. Sampling has been completed The F8 and two F6 PODs were designated as Group 2 based on the sample results. Indorama Ventures Oxides LLC Port Neches, Texas 11 40 CFR An incorrect 18-Nov-19 Unknown 63.110(d) application of overlap for process vents may exist between 40 CFR 60, NSPS NNN/RRR and 40 CFR 63 Subparts F and G. NEICVP1446E01 ATTACHMENT 1 COMPLIANCE AUDIT PORT NECHES FINDINGS TABLE Revision Date: March 30, 2022 inspections and records being maintained to document and identify diversions, as required. Manual bypass valves have been secured in the field using either a lock-and-key or car- seal configuration with monthly inspections conducted. For valves with position available in the DCS, records of valve position are being maintained to identify diversions. potential PODs to be sampled, the CVS and Bypass Valve inspection and recordkeeping programs will be reviewed and updated as necessary. sample port installation in Item 7, above. Review NSPS NNN/RRR applicability determinations for F-4, F-5, F-6, and F-8 Implement NSPS requirements for any NSPS NNN/RRR vents requiring control and routed to fuel gas systems, if necessary. NSPS NNN/RRR applicability determinations completed. NSPS requirements (CVS inspections and bypass valve monitoring) for fuel gas systems and process vents completed. Title V application will be submitted by 4/30/2021 to properly reflect revised determinations and to properly apply overlap provisions. None. Amend Title V Operating Permit as necessary to incorporate NSPS NNN/RRR applicability and Appendix L Page 12 of 13 Sample port installation required for remaining PODs. Note: Previous updates inadvertently stated the sample port installation count was five rather than six. 1st/2nd qtr 2022 for F6/F8 for sample port installation, collection, analysis, and updates. Update: The low water F8 POD was inadvertently drained by Operations prior to sampling. Operational conditions allowed for the early installation of the F4 POD sample point. Sampling arrangements are being made and expected to be complete for both PODs by 12/31/21. turnaround sample port installation, collection, analysis, and updates. Complete NA NA PNO.048 012 for these; however, sample results have not been received to make a Group determination yet. Remaining F6 PODs on track for Q2 2022 turnaround sample part installation and collection. The remaining F6 sample points were installed during the 2nd quarter turnaround. The POD determination samples were obtained on 6/30/2022. Results are forthcoming. NA NA Indorama Ventures Oxides LLC Port Neches, Texas correctly apply NSPS/HON overlap for affected vents. ATTACHMENT 1 COMPLIANCE AUDIT PORT NECHES FINDINGS TABLE Revision Date: March 30, 2022 PNO.048 013 NEICVP1446E01 Appendix L Page 13 of 13 Indorama Ventures Oxides LLC Port Neches, Texas 805 Las Cimas Pkwy Suite 300 Austin, TX 78746-6179 Telephone (512) 327-9840 Fax (512) 327-6163 PNO.067 001 Ethylene MACT Notification of Compliance Status Report Huntsman Petrochemical Corporation A3 Olefins Unit Port Neches, Texas March 2006 NEICVP1446E01 RMT, Inc. | Huntsman Petrochemical Corporation Final I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC Appendix M Page 1 of 60 2006 RMT, Inc. All Rights Reserved Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 002 Table of Contents 1. General Information.....................................................................................................................1-1 2. Specific Information by Source Type .........................................................................................2-1 2.1 Storage Vessels ...................................................................................................................2-1 2.2 Process Vents ......................................................................................................................2-4 2.3 Transfer Racks ....................................................................................................................2-4 2.4 Equipment...........................................................................................................................2-4 2.5 Waste Streams.....................................................................................................................2-4 2.6 Heat Exchange Systems.....................................................................................................2-5 2.7 Ethylene Cracking Furnaces / Associated Decoking Operations ................................2-5 List of Tables Table 1 Table 2 Summary of Affected Sources .............................................................................1-3 Storage Vessels ......................................................................................................2-2 List of Appendices Appendix A Appendix B Appendix C Appendix D T-O-126 Carbon Adsorber Design Evaluation T-O-126 Carbon Adsorber Monitoring Plan Waste Stream Documentation Heat Exchange System Alternative Monitoring Request RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC 3/2/06 NEICVP1446E01 i Appendix M Page 2 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 003 Section 1 General Information Huntsman Petrochemical Corporation (Huntsman) operates an ethylene manufacturing facility in Port Neches, Jefferson County, Texas. The facility is referred to as the A3 Olefins Unit and it is subject to requirements in the Ethylene MACT. The Ethylene MACT rule was promulgated as part of the Generic MACT (40 CFR 63, Subpart YY) and applies to chemical manufacturing process units in which ethylene and/or propylene are produced. A notification of compliance status report is required per 63.1110(d). 40 CFR 63.1110(d): Notification of Compliance Status (1) Contents. The owner or operator shall submit a Notification of Compliance Status for each affected source subject to this subpart containing the information specified in paragraphs (d)(1)(i) and (d)(1)(ii) of this section. (i) The Notification of Compliance Status shall include the information specified in this subpart and the subparts referenced by this subpart. Alternatively, this information can be submitted as part of a title V permit application or amendment. All required information is included in this Notification of Compliance Status Report. Huntsman is not electing to submit this report as a part of the Title V permit application or amendment as an alternative to meet this requirement. (ii) The Notification of Compliance Status shall include a statement from the owner or operator identifying which subpart he or she has elected to comply with, where given a choice, as provided for in 63.1100(g). Huntsman is in compliance with the requirements of 40 CFR 63 Subpart YY. All overlap in regulations applicable to Huntsman require compliance with 40 CFR 63 Subpart YY. (2) Due date. The owner or operator shall submit the Notification of Compliance Status for each affected source 240 days after the compliance date specified for the affected source under this subpart, or 60 days after completion of the initial performance test or initial compliance assessment, whichever is earlier. Notification of Compliance Status reports may be combined for multiple affected sources as long as the due date requirements for all sources covered in the combined report are met. RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC 3/2/06 NEICVP1446E01 1-1 Appendix M Page 3 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 004 The compliance date specified in 63.1102 for ethylene production is July 12, 2005. Therefore; the Notification of Compliance Status Report is due 240 days after July 12, 2005 or March 9, 2006. 40 CFR 63.1110(f): General report content All reports and notifications submitted pursuant to this subpart, including reports that combine information required under this subpart and a subpart referenced by this subpart, shall include the information specified in paragraphs (f)(1) through (4) of this section. (1) The name, address and telephone number (fax number may also be provided) of the owner or operator. Owner/Operator: Physical Address: Huntsman Petrochemical Corporation 6001 Highway 366, Port Neches, Texas 77651 Phone Number: 409-724-4460 (2) The name, address and telephone number of the person to whom inquiries should be addressed, if different than the owner or operator. David Gorsich, Environmental Unit Representative Huntsman Petrochemical Corporation P.O. Box 847 Port Neches, Texas 77651 409-724-4469 (3) The address (physical location) of the reporting facility. 6001 Highway 366 Port Neches, Texas 77651 (4) Identification of each affected source covered in the submission and identification of the subparts (this subpart and the subparts referenced in this subpart) that are applicable to that affected source. Summaries and groupings of this information are permitted. RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC 3/2/06 NEICVP1446E01 1-2 Appendix M Page 4 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 005 Table 1 Summary of Affected Sources Affected Source Group Storage Vessels Heat Exchange System Equipment Waste Applicable Subparts 40 CFR 63 Subpart YY 40 CFR 63 Subpart WW 40 CFR 63 Subpart SS 40 CFR 63 Subpart YY 40 CFR 63 Subpart XX 40 CFR 63 Subpart YY 40 CFR 63 Subpart UU 40 CFR 63 Subpart YY 40 CFR 63 Subpart XX 40 CFR 61 Subpart FF RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC 3/2/06 NEICVP1446E01 1-3 Appendix M Page 5 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 006 Section 2 Specific Information by Source Type According to 63.1103(e)(1), the Ethylene MACT regulates hazardous air pollutant (HAP) emissions from: Storage vessels that store liquids containing organic HAPs, Ethylene process vents from continuous unit operations, Transfer racks that load HAP-containing material, Leaks from equipment (as defined under 63,1101) that contains organic HAPs, Waste streams associated with the ethylene production unit, Heat exchange systems associated with an ethylene production unit, and Ethylene cracking furnaces and associated decoking operations Heat exchange system and waste requirements for ethylene production sources are found in 40 CFR 63, Subpart XX. Definitions found in 63.1101 of Subpart YY do not apply to ethylene process unit waste. Control requirements for affected sources are found in Table 7 of 63.1103(e), and a detailed compliance status for each affected source is provided below. 2.1 Storage Vessels Table 2 identifies storage vessels subject to Subpart YY along with the specified control requirement. RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC 3/2/06 NEICVP1446E01 2-1 Appendix M Page 6 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 007 Tank ID T-A3-29 T-A3-46 T-O-43 T-A3-39 T-O-126 T-O-127 T-O-87 T-O-88 Material Stored Wash Oil Tar Wash Oil Methanol Aromatic Distillate Aromatic Distillate Aromatic Distillate Aromatic Distillate Table 2 Storage Vessels 63.1103(e) Table 7 Control Requirement N/A - Organic HAP true vapor pressure < 3.4 kPa (0.5 psia) N/A - Organic HAP true vapor pressure < 3.4 kPa (0.5 psia) N/A - Organic HAP true vapor pressure < 3.4 kPa (0.5 psia) Submerged Fill Pipe Carbon Adsorber complying with 40 CFR 63 Subpart SS. Flare complying with 40 CFR 63 Subpart SS. Internal floating roof complying with 40 CFR 63 Subpart WW. Internal floating roof complying with 40 CFR 63 Subpart WW. Tanks T-O-126, 127, 87 and 88 can also store wastewater. Requirements associated with these waste streams are identified in Section 2.5 (waste streams). Tanks with submerged fill pipes, internal floating roofs, or without control requirements are not required to submit a notification of compliance status. A notification of compliance status is only required for tanks subject to Subpart SS which only affects Tanks T-O-126 and T-O-127. Tank T-O-126 Subpart SS NCS requirements 63.999(b)(2) - Routing storage vessel or low throughput transfer rack emissions to a nonflare control device. An owner or operator who elects to comply with 63.982 by routing emissions from a storage vessel or low throughput transfer rack to a nonflare control device, as specified in 63.985, shall submit, with the Notification of Compliance Status required by a referencing subpart, the applicable information specified in paragraphs (b)(2)(i) through (vi) of this section. Owners and operators who elect to comply with 63.985(b)(1)(i) by submitting a design evaluation shall submit the information specified in paragraphs (b)(2)(i) through (iv) of this section. Owners and operators who elect to comply with 63.985(b)(1)(ii) by submitting performance test results from a control device for a storage vessel or low throughput transfer rack shall submit the information specified in paragraphs (b)(2)(i), (ii), (iv), and (v) of this section. Owners and operators who elect to comply with 63.985(b)(1)(ii) by submitting performance test results from a shared control device shall submit the information specified in paragraph (b)(2)(vi) of this section. RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC 3/2/06 NEICVP1446E01 2-2 Appendix M Page 7 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 008 Huntsman elects to comply with 63.985(b)(1)(i) by submitting a design evaluation. The design evaluation for the carbon adsorption system associated with tank T-O-126 is included in appendix A of this report. 63.999(b)(2)(i) -A description of the parameter or parameters to be monitored to ensure that the control device is being properly operated and maintained, an explanation of the criteria used for selection of that parameter (or parameters), and the frequency with which monitoring will be performed (e.g., when the liquid level in the storage vessel is being raised). If continuous records are specified, indicate whether the provisions of 63.999(c)(6) apply. As required by the A3 Olefins Unit Federal Operating Permit Number O2288, the control device exhaust stream will be monitored daily to determine VOC breakthrough. Breakthrough occurs when the VOC concentration in the exhaust stream measures 100 ppmv or more. Provisions of 63.999(c)(6) are not applicable to storage vessels and continuous records are not specified. Monitoring records are maintained at the plant site. 63.999(b)(2)(ii) -The operating range for each monitoring parameter identified in the monitoring plan required by 63.985(c)(1). The specified operating range shall represent the conditions for which the control device is being properly operated and maintained. The operating range for the carbon adsorption system shall be during exhaust stream VOC concentrations of less than 100 ppmv. 63.999(b)(2)(iii) -The documentation specified in 63.985(b)(1)(i), if the owner or operator elects to prepare a design evaluation. The design evaluation for this carbon adsorption system is included as Appendix A of this report. 63.999(b)(2)(iv) -The provisions of paragraph (c)(6) of this section do not apply to any low throughput transfer rack for which the owner or operator has elected to comply with 63.985 or to any storage vessel for which the owner or operator is not required, by the applicable monitoring plan established under 63.985(c)(1), to keep continuous records. If continuous records are required, the owner or operator shall specify in the monitoring plan whether the provisions of paragraph (c)(6) of this section apply. Continuous records are not required and 63.999(c)(6) is not applicable to storage vessels. The Federal Operating Permit Number O2288 Periodic Monitoring Summary for the carbon adsorber associated with Tank T-O-126 is included in Appendix B and will suffice as the monitoring plan required by 63.985(c)(1). RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC 3/2/06 NEICVP1446E01 2-3 Appendix M Page 8 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 009 Tank T-O-127 Subpart SS NCS requirements Tank T-O-127 will not be operational until later this year. Once this tank is operational, a flare compliance assessment will be performed and the report will be submitted within 60 days of completing the assessment as required by 63.999(a)(1)(ii). 2.2 Process Vents The A3 Olefins Unit does not contain any continuously discharged process vents. 2.3 Transfer Racks There are no transfer racks associated with the A3 Olefins Unit. All products are piped to other production units or to off-site facilities. 2.4 Equipment As required by Table 7 of 63.1103(e), equipment must comply with requirements in 40 CFR 63 Subpart UU. Subpart UU only requires an initial notification of compliance status which was submitted on July 9, 2003. 2.5 Waste Streams Waste streams must comply with requirements in 40 CFR 63 Subpart XX as identified in Table 7 of 63.1103(e). Table 2 of Subpart XX requires that information in 40 CFR 61.357(d)(1) and (2) be submitted as part of the notification of compliance status required by 63.1110(d). 61.357(d)(As revised by 40 CFR 63 Subpart XX) - If the total annual benzene quantity from facility waste is equal to or greater than 10 Mg/yr (11 ton/yr), then the owner or operator shall submit to the Administrator the following reports: Submit the information in 40 CFR 61.357(d)(1) & (d)(2) as part of the Notification of Compliance Status required in 40 CFR 63.1110(d): 61.357(d)(1)(As revised by 40 CFR 63 Subpart XX): Submit as part of the Notification of Compliance Status required in 40 CFR 63.1110(d), or by the date of initial startup for a new source with an initial startup after the effective date, a certification that the equipment necessary to comply with these standards has been installed and that the required initial inspections or tests have been carried out in accordance with this subpart. A compliance certification is provided in Appendix C. RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC 3/2/06 NEICVP1446E01 2-4 Appendix M Page 9 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 010 61.357(d)(2) - Beginning on the date that the equipment necessary to comply with these standards has been certified in accordance with paragraph (d)(1) of this section, the owner or operator shall submit annually to the Administrator a report that updates the information listed in paragraphs (a)(1) through (a)(3) of this section. If the information in the annual report required by paragraphs (a)(1) through (a)(3) of this section is not changed in the following year, the owner or operator may submit a statement to that effect. The annual TAB report required by 61.357(d)(2)that was submitted to the Texas Commission on Environmental Quality (TCEQ) on April 7, 2005, is also provided in Appendix C. 2.6 Heat Exchange Systems A notification of compliance status is not required for heat exchange systems. Two heat exchange systems are operated at the A3 Olefins Unit. One system only includes exchanger EA3-205 from the A3 Olefins Unit and routes water to cooling tower CT-1. A delta pressure indicator monitors to ensure the pressure differential is greater than 5 psig. Heat Exchanger EA3-205 and CT-1 are exempt per 63.1084(a). All other exchangers at the A3 Olefins Unit send water to cooling tower CT-4. Samples are taken at two inlets and the exit of the cooling tower (East, West, and Supply). The concentration of the monitored cooling substance in the heat exchange system is required to be monitored by any method listed in 40 CFR Part 136. However, Part 136 does not have a monitoring method for all chemicals sampled. Alternative monitoring is allowed if approved by the administrator per 63.1086(a)(3). Huntsman submitted a request for alternative monitoring on August 12, 2005 and a copy of the request is included in Appendix D. Furthermore, Texas NSR Permit Number 19823 as referenced by Federal Operating Permit Number O2288 requires that the cooling tower return line be monitored using a leak detection limit of 0.05 ppmw VOC which corresponds to an emission rate of 0.43 kg/hr based on the maximum cooling tower recirculation rate. This leak definition satisfies the requirement and is much more conservative than the 3.06 kg/hr limit specified by 63.1086(a)(1). 2.7 Ethylene Cracking Furnaces / Associated Decoking Operations There are no control requirements or notification of compliance status requirements identified for ethylene cracking furnaces and associated decoking operations. RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC 3/2/06 NEICVP1446E01 2-5 Appendix M Page 10 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 011 Appendix A T-O-126 Carbon Adsorber Design Evaluation RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC NEICVP1446E01 Appendix M Page 11 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 012 HUNTSMAN PETROCHEMICAL CORPORATION PORT NECHES, TX T-O-126 CAS 40 CFR 63 Subpart SS Design Evaluation I. Gas Stream Description Displaced vapor as a result of loading aromatic distillate (AD) into Tank T-O-126 is routed to a carbon adsorption system (CAS) before venting to the atmosphere. The CAS consists of two carbon beds in series and the first bed is monitored for breakthrough. Breakthrough occurs when a VOC concentration of 100 ppmv is measured. Once the breakthrough concentration is measured, the carbon bed is replaced within 4 hours of detection. Number of Carbon Beds: Amount of Carbon per Bed: Breakthrough Concentration : Vessel Fill Rate: Vent stream Temp = 2 2,000 lb 100 ppmv 24,000 gph = 120 F 3,209 scf/hr II. Vapor Pollutant Concentrations Pollutant mw wt% 1,3-Butadiene 54 1.38% 1-Butene 56 0.59% 1-Pentene 70 1.58% 2-Butanone 72 0.08% 2-Methylbutene-1 70 1.58% 2-Methylbutene-2 70 1.58% 2-Methylnaphthalene 142 2.37% 3-Methylbutene-1 70 7.90% Acenaphthene 154 0.08% Acenaphthylene 152 0.08% Acetylene 26 0.00% Anthracene 178 0.08% Benzene 78 47.42% Cis-1,3-Pentadiene 68 0.79% Cis-2-Butene 56 0.59% Cis-2-Pentene 70 1.58% Ethane 30 0.00% Ethylbenzene 106 3.95% Ethylene 28 0.00% Fluoranthene 202 0.08% Fluorene 166 0.08% IC4 58 0.08% Isobutlyene 56 0.24% Isopentane 72 1.19% Isoprene 68 3.95% Methylene Chloride 85 0.08% Naphthalene 128 1.58% NC4 58 0.59% N-Pentane 72 1.19% N-Propylbenzene 120 0.08% Phenanthrene 178 0.08% Phenol 94 0.08% Propane 44 0.08% Propylene 42 0.08% Pyrene 202 0.08% Styrene 104 3.95% Sulfur Compounds 34 0.04% Toluene 92 7.90% Trans-1,3-Pentadiene 68 0.79% Trans-2-Butene 56 0.59% Trans-Pentene-2 70 1.58% Vinylacetylene 52 0.01% Xylenes 106 3.95% Total Vent Stream 79.3 100.0% 3/2/2006 50-09009.87 NEICVP1446E01 Page 1 of 2 Appendix M Page 12 of 60 I:\WPAUS\PJT\50-09101\20\AppA-TO126DesignEvaluation.xls 3/2/2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 013 II. Emissions at CAS Breakthrough Maximum emissions from the CAS are based on the maximum tank fill rate and breakthrough concentration. 3,209 cf 100 lbmol VOC 79.3 lb VOC 1 lb-mole = hr ####### lbmol gas lb-mole 423 cf 0.060 lb/hr III. Emissions entering CAS from Tank Maximum hourly tank emissions result from working losses. The working loss equation for tanks can be found AP-42 Section 7.1. Lw = 0.001MvPvaQ Lw = Working loss, lb/hr Mv = vapor molecular weight = 79.3 Pva = Vapor pressure, psia = 10 Q = hourly pump rate, bbl/hr = 571 Kn and Kp are assumed to equal 1. Lw = 453.21 lb/hr IV. CAS Control Efficiency % control = (453.21 - 0.06) lb/hr / (453.21) lb/hr x 100% = 99.99% 3/2/2006 50-09009.87 NEICVP1446E01 Page 2 of 2 Appendix M Page 13 of 60 I:\WPAUS\PJT\50-09101\20\AppA-TO126DesignEvaluation.xls 3/2/2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 014 Appendix B T-O-126 Carbon Adsorber Monitoring Plan RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC NEICVP1446E01 Appendix M Page 14 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 015 NEICVP1446E01 Appendix M Page 15 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 016 Appendix C Waste Stream Documentation RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC NEICVP1446E01 Appendix M Page 16 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 017 Waste Stream Compliance Certification Based on information and belief formed after a reasonable inquiry, I, as a responsible official of Huntsman Petrochemical Corporation, certify the information identified below is accurate and true to the best of my knowledge. The A3 Olefins Unit has: 1. 1. Installed the equipment for waste streams necessary to comply with 40 CFR 63 Subpart YY and the Subparts referenced by YY. 2. 2. Conducted the required initial inspections or tests for the wastes streams and associated required equipment in accordance with 40 CFR 63 Subpart XX and YY. Name and Title of the Owner/Operator: Signature of Owner/Operator: Date: NEICVP1446E01 Appendix M Page 17 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 018 BENZENE WASTE STREAM REVIEW This review meets the reporting requirements of the Environmental Protection Agency's Chapter 40 Code of Federal Regulations (CFR) Part 61, Subpart FF, 61.357 and summarizes the status of each waste stream in benzene operation. The Huntsman Petrochemical Corporation (Huntsman) C-4 and Oxides and Olefins (O&O) Plants are located at the Jefferson County Operations complex in Port Neches, Texas. During previous years, the C-4 and O&O Plants have generated more than 10 Megagrams per year of total annual benzene waste. This quantity has decreased due to process changes at the C-4 Plant during 2001 and the continued shutdown of the O&O Plant's A-3 Unit until the unit was restarted on September 11, 2004. Table 1: 2004 Benzene Quantities for C-4 and O&O Plants addresses each benzene waste stream for compliance with either the individual stream exemption or the control standards requirement as described in 40 CFR 61.342, Subpart FF. For 2004, Huntsman C-4 and O&O Plants' total annual benzene reporting consists of facility waste that is sent off-site for treatment and disposal, as well as, facility wastes that are managed on-site. For the O&O Plant, the A-3 Unit has historically contained the majority of Huntsman's benzene waste streams, however, discontinued operation of the A-3 Unit occurred on May 31, 2001. The A-3 Unit was restarted on September 11, 2004. A benzene waste stream with a flow-weighted annual average benzene concentration of less than 10 ppmw as determined by the procedures specified in 61.355(c)(2) or 61.355(c)(3) may be exempted from the control requirements of 61.342(c)(1). Benzene waste streams identified as meeting the exemption requirements of 40 CFR 61.342(c)(2) during 2004 include the following: A3 Exchanger Cleaning Solids C4 Sponge Oil Exchanger Residue O&O Soap Solution C4 Process Filters C-4 Hydroblast Pit Residue O&O Oily Trash Naphtha Soaked C-4 Solvent Tower and Stripper Residue C-4 Popcorn Polymer Wastewater System Tank Bottoms C-4 Vent Compressor Residue O&O/C-4 Contaminated Soil O&O/C-4 Contaminated Soil A benzene waste stream may be exempted from the control requirements of 61.342(c)(1) provided that the owner meets all of the conditions of 61.342(c)(3)(ii). The condition of 61.342(c)(3)(ii)(A) states that the owner or operator chooses not to exempt process wastewater under the conditions specified in 40 CFR 61.342(c)(3)(i). 61.342(c)(3)(ii)(B) states that the total annual benzene quantity in all benzene waste NEICVP1446E01 Appendix M Page 18 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 019 streams chosen for exemption must not exceed 2.0 Mg/yr. 61.342(c)(3)(ii)(C) declares that the total annual benzene quantity in all benzene waste streams chosen for exemption, including process unit turnaround waste, is determined for the year in which the waste is generated. 2004 benzene waste streams identified as meeting the exemption requirements of 40 CFR 61.342(c)(ii) include the following: A-3 Quench Water System Sludge O&O A-3 Gas Header O/W Residue A-3 Pall Filters C-4 Sponge Oil Exchanger Residue O&O Soap Solution A3 Hazardous Wastewater C4 Process Filters O&O Naphtha Pads and PPE O&O Naphtha Contaminated Soil C-4 Popcorn Polymer Wastewater System C-4 Popcorn Polymer C-4 Polyblend (Off-Site Disposal) C4 Polyblend Residue Benzene waste streams identified as not meeting the requirements for exemption are subject to the requirements of 40 CFR 61 Subpart FF 61.342(c)(1) for control of benzene emissions to the ambient air from waste operations. The C-4 Polyblend (Bz combusted in BIF), the O&O A-3 Quench Tower Tar and teh O&O A-3 Quench Drum Tar have been identified having an average annual water content less than 10%, therefore it meets the requirements of 61.342 (a)(1) and are not included in the 2004 TAB. Table 2: Excluded Waste Streams identifies all year 2001/2002/2003 benzene waste streams that were not in benzene operation at any time during 2004. These former benzene waste streams are not included in the 2004 TAB Report determination. The following waste streams are not applicable to 40 CFR 61.342, Subpart FF since each was not in benzene operation during 2003: O&O A-3 Sump to TO-88 O&O R&S TO-43 O&O Quench Area Sump to TO-88 O&O Wash Oil Sump to TO-88 C-4 Polyblend Residue A-3 Molecular Sieve A-3 Pyronaphtha Tank Bottoms Sludge A-3 Coke Fines From Furnace C-4 Raschig Rings C-4 Process Filters O&O Wastewater C-4 Crude Butadiene Tank Bottoms NEICVP1446E01 Appendix M Page 19 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 020 C-4 Spent Catalyst C-4 Oil Soaked Absorbent C-4 MTBE Catalyst Residue C-4 Boiler Rust and Scale C-4 Sump Cleanings For reporting year 2004, C-4 and O&O Plants' TAB waste summation of applicable benzene waste streams was 32.769 Mg/yr. Benzene waste streams excluded from the TAB calculations according to 61.342(a)(1) equalled 41.2924 Mg/yr. NEICVP1446E01 Appendix M Page 20 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 021 TABLE 1: 2004 BENZENE QUANTITIES FOR C-4 AND O&O PLANTS NEICVP1446E01 Appendix M Page 21 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 022 TABLE 1 2004 BENZENE QUANTITIES FOR C-4 AND O&O PLANTS STREAM DESCRIPTION SUBPART FF CONTROLS (Ref. 4) STREAM TYPE 61.357(a)(2) A-3 Quench Water System Sludge O&O A-3 Gas Header O/W Residue A-3 Exchanger Cleaning Solids A-3 Pall Filters C-4 Sponge Oil Exchanger Residue O&O Soap Solution A3 Hazardous Wastewater C4 Process Filters C-4 Hydroblast Pit Residue O&O Naphtha Pads and PPE O&O Oily Trash Naphtha Soaked O&O Naphtha Contaminated Soil C-4/O&O Lab Pack C-4 Solvent Tower and Stripper Residue C-4 Popcorn Polymer Wastewater System C-4 Popcorn Polymer Tank Bottoms C-4 Vent Compressor Residue O&O/C-4 Contaminated Soil O&O/C-4 Contaminated Soil C-4 Polyblend (Off-Site Disposal) C4 Polyblend Residue O&O R&S TO-87 O&O A-3 Sump / Wash Oil / Quench to T-O-88 O&O A-3 Sump / Wash Oil / Quench to T-O-126 O&O Quench Drum to WW Stripper O&O Spent Caustic to WW Stripper O&O Gasoline with Water 61.357(a)(2) exempt exempt exempt exempt exempt exempt yes exempt exempt exempt exempt exempt exempt exempt exempt exempt exempt exempt exempt exempt exempt exempt yes exempt exempt yes yes exempt Ref # 2, 3 2, 3 1, 3 2, 3 2,3 1, 5 2,3 1,3 2, 3 1, 3 2,3 1,3 1,3,5 2, 3 2,3,5 1, 3 1,5 1,5 1,5 2,3 2, 3 2 2, 5 2, 3 PTD PWW PWW PWW PWW - WASTE QUANTITY RANGE OF CONC. (lbs/yr) 5,180.00 150 1,100.00 16,940.00 4,650.00 399,880.00 770,420.00 6,424.00 22,640.00 3,500.00 121,140.00 2,400.00 147.00 12,248.00 8,332.00 4,600.00 2,940.00 3,440.00 195,150.00 2,599,500.00 211,950.00 200.00 6,921,822.00 14,839,337.00 4,990,861.00 106,535,636.00 57,837,787.00 259,073.00 (Mg/yr) (ppm) 61.357(a)(3)(i-v) 2.352 36.1 0.068 10 0.499 0.2 7.691 469 2.111 5.4 - 28.7 181.546 0.0 - 0.14 349.771 21.0 - 4788 2.916 0.0 - 5.8 10.279 0.2 - 2.3 1.589 10 54.998 0.0 - 5. 1.090 10.0 - 10.0 0.067 0 - 10 5.561 0 - 1.08 3.783 0 - 0.24 2.088 10.0 - 10.0 1.335 0.9 1.562 0.7 - 0.7 88.598 0 1,180.173 0 - 1.53 96.225 2750 - 5380 0.091 457 3,142.507 6500 6,737.059 1.0 - 24.0 2,265.851 1.0 - 24.0 48,367.179 42 - 91 26,258.355 31 - 370 117.619 10 FLOWWEIGHTED BENZENE CONC. (ppm) 36.10 10.00 0.20 469.00 6.61 0.06 5046.00 0.25 2.10 10.00 0.05 10.00 10.00 0.04 0.08 10.00 0.09 0.00 0.00 0.07 3048.00 457.00 6500.00 19.67 19.67 84.00 230.00 10.00 BENZENE QUANTITY (Mg/yr) 8.490E-05 6.810E-07 9.988E-08 3.607E-03 1.395E-05 1.089E-05 1.765E+00 7.291E-07 2.158E-05 1.589E-05 2.750E-06 1.090E-05 6.674E-07 2.108E-07 3.026E-07 2.088E-05 1.201E-07 0.000E+00 0.000E+00 8.261E-05 2.933E-01 4.150E-05 2.043E+01 1.325E-01 4.457E-02 4.063E+00 6.039E+00 1.176E-03 Streams Excluded from TAB Calculation (H2O <10%) (61.342(a)(1)) Polyblend (bz combusted in BIF) Yes - - O&O A-3 Quench Tower Tar exempt 2 - O&O A-3 Quench Drum Tar exempt 2 - 14,730,000.00 1,666.00 1,666.00 6,687.420 0.756 0.756 TAB 2,884-14,252 589 589 6174.51 589.00 589.00 32.7690 4.129E+01 4.455E-04 4.455E-04 REFERENCES: 1. Exempt from control requirements (<10 ppm benzene) (61.342(c)(2)) 2. Exempt from control requirements (benzene quantity sum <2 Mg/yr) (61.342(c)(3)(ii)) ==> 3. Waste taken offsite for treatment 4. Process Wastewater (PWW); Product Tank Draw-down (PTD); Landfill Leachate (LL) 5. Newly exempted stream for the year 2003 6. Waste stream not generated/disposed during 2003 Excluded from TAB 0.4753 Mg 41.2924 NEICVP1446E01 Appendix M Page 22 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 023 TABLE 2: EXCLUDED WASTE STREAMS NEICVP1446E01 Appendix M Page 23 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 024 TABLE 2 EXCLUDED WASTE STREAMS STREAM DESCRIPTION SUBPART FF CONTROLS STREAM TYPE 61.357(a)(2) 61.357(a)(2) Ref # O&O A-3 Sump to TO-88 exempt 1 O&O R&S TO-43 Yes 1 O&O Quench Area Sump to TO-88 exempt 1 O&O Wash Oil Sump to TO-88 exempt 1 C-4 Polyblend Residue exempt 1 A-3 Molecular Sieve exempt 1 A-3 Pyronaphtha Tank Bottoms Sludge exempt 1 A-3 Coke Fines From Furnace exempt 1 C-4 Raschig Rings exempt 1 C-4 Process Filters exempt 1 O&O Wastewater exempt 1 C-4 Crude Butadiene Tank Bottoms exempt 1 C-4 Spent Catalyst exempt 2,5 C-4 Oil Soaked Absorbent exempt 1,5 C-4 MTBE Catalyst Residue exempt 1,5 C-4 Boiler Rust and Scale exempt 1,5 C-4 Sump Cleanings exempt 1,5 PWW PTD PWW PWW - - WASTE QUANTITY RANGE OF CONC. (lbs/yr) 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 (Mg/yr) (ppm) 61.357(a)(3)(i-v) 0.000 14.3-29.4 0.000 62-830 0.000 7.93-33.80 0.000 1.7-120 0.000 1000 0.000 0.6 - 4.09 0.000 500 - 1039 0.000 1.2 - 1.2 0.000 0 - 0.4 0.000 0 - 0.6 0.000 0 - 0.5 0.000 1.5 - 4.3 0.000 0 - 11.1 0.000 0.8 - 0.8 0.000 0 - 3.47 0.000 1.2 - 1.2 0.000 0 - 1.5 FLOWWEIGHTED BENZENE CONC. (ppm) 20.50 490.5 17.98 42.925 1000 10 949 1.2 0.2 0.2 0.1 0.00 0.00 0.04 0.00 0.00 0.10 BENZENE QUANTITY (Mg/yr) 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 0.000E+00 Streams Excluded from TAB Calculation (H2O <10%) (61.342(a)(1)) C-4 Waste Oil exempt 1 - C-4 Hydrocarbon Slop Tank Residue exempt 1 - TAB 0.000 0.00 0.000 1,700 1,700 0.000E+00 0.00 0.000 124 -124 124 0.000E+00 REFERENCE: Excluded from TAB 0.00 1. These waste streams were included in the 2001, 2002, and/or 2003 TAB Reports, but were not in benzene operation during 2004. Due to process changes or a lack of facil generation, these waste streams are not included in the 2004 TAB Report for the C-4, O&O, and PO/MTBE facilities. NEICVP1446E01 Appendix M Page 24 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 025 TABLE 3: C-4 AND O&O PLANTS TOTAL BENZENE QUANTITY DATA NEICVP1446E01 Appendix M Page 25 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 026 Waste Description 11033191 A-3 Molecular Sieve 1104519H A-3 Quench Water System Sludge 1126219H O&O A-3 Gas Header O/W Residue 11303192 A-3 Exchanger Cleaning Solids 1114695H A-3 Pyronaphtha Tank Bottoms Sludge 11244041 A-3 Coke Fines From Furnaces 1134310H A-3 Pall Filters 1135119H A3 Hazardous Wastewater TABLE 3 C-4 AND O&O TOTAL BENZENE QUANTITY DATA Pounds (lbs) Date None Generated in CY 2004 Conc. (ppmw) Basis Total Weight (lbs) Total Benzene (lbs) Minimum (ppm) 5,180 9/23/2004 36.10 Measured 5,180 1.87E-01 36.10 150 10.00 8/27/2004 10.00 Estimate 150 1.50E-03 1,100 9/23/2004 0.24 Measured 1,100 0.00E+00 0.24 None Generated in CY 2004 None Generated in CY 2004 16,940 10/15/2004 12/1/2004 12/1/2004 469.00 469.00 469.00 469.00 Estimated Estimated Estimated 4,640 8,400 3,900 16,940 2.18E+00 3.94E+00 1.83E+00 7.94E+00 469.00 770,420 8/27/2004 8/31/2004 9/1/2004 9/1/2004 9/2/2004 9/7/2004 9/7/2004 9/2/2004 9/2/2004 9/3/2004 9/3/2004 9/8/2004 9/8/2004 9/9/2004 9/9/2004 1/4/2005 1/5/2005 1/4/2005 251.00 251.00 251.00 21.90 21.90 666.00 21.90 21.90 666.00 666.00 666.00 251.00 36.10 243.80 36.10 47,880.00 29,160.00 7,650.00 Measured Measured Measured Measured Measured Measured Measured Measured Measured Measured Measured Measured Measured Measured Measured Measured Measured Measured 43,780 42,280 35,120 39,440 42,640 22,760 31,580 40,380 43,980 41,800 25,380 42,500 40,960 41,580 37,520 37,940 41,740 42,820 1.10E+01 1.06E+01 8.82E+00 8.64E-01 9.34E-01 1.52E+01 6.92E-01 8.84E-01 2.93E+01 2.78E+01 1.69E+01 1.07E+01 1.48E+00 1.01E+01 1.35E+00 1.82E+03 1.22E+03 3.28E+02 21.90 Maximum (ppm) 36.10 10.00 0.24 469.00 47,880.00 Average Benzene (ppm) % Water Mg 36.10 10.00 0.24 >10 8.49E-05 >10 6.81E-07 >10 1.20E-07 469.00 >10 3.61E-03 5,046.00 >10 1.76E+00 NEICVP1446E01 Appendix M Page 26 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 027 Waste Description 3100606H C-4 Sponge Oil Exchanger Residue 31031191 Soap Solution 34043192 C-4 Raschig Rings 36023101 C-4 Process Filters 41433891 C-4 Hydroblast Pit Residue TABLE 3 C-4 AND O&O TOTAL BENZENE QUANTITY DATA Pounds (lbs) Date 1/5/2005 1/6/2005 Conc. (ppmw) 7,650.00 1,378.00 5,046.13 Basis Measured Measured Total Weight (lbs) 43,800 32,420 770,420 Total Benzene (lbs) 3.35E+02 4.47E+01 3.89E+03 Minimum (ppm) 4,650 7/7/2004 5/10/2004 28.70 5.35 6.61 Measured Measured 250 4,400 4,650 5.35 7.18E-03 2.35E-02 3.07E-02 399,880 0.10 4/30/2004 0.01 Measured 37,040 3.70E-04 4/30/2004 0.10 Measured 28,120 2.87E-03 4/30/2004 0.01 Measured 22,420 2.24E-04 5/4/2004 0.02 Measured 14,200 2.70E-04 5/4/2004 0.02 Measured 41,920 7.96E-04 11/4/2004 0.02 Measured 32,300 4.85E-04 11/4/2004 0.05 Measured 46,160 2.26E-03 11/4/2004 0.01 Measured 42,860 5.14E-04 10/29/2004 0.10 Measured 25,900 2.59E-03 11/1/2004 0.10 Measured 37,100 3.71E-03 10/29/2004 0.10 Measured 30,380 3.04E-03 11/23/2004 0.14 Measured 41,480 5.77E-03 0.06 399,880 2.29E-02 Maximum (ppm) 28.70 0.14 Average Benzene (ppm) % Water Mg 6.61 >10 1.39E-05 0.06 >10 1.09E-05 None Generated in CY 2004 6,424 22,640 1/1/2004 0.00 1/1/2004 1.50 1/1/2004 5.82 9/23/2004 0.00 0.25 Measured 3/24/2004 0.24 (TCLP) Measured 3/24/2004 0.42 (TCLP) Measured 7/22/2004 0.42 (TCLP) 7/22/2004 0.44 Measured 5,000 300 200 924 6,424 1,290 860 1,892 946 0.00 0.00E+00 4.50E-04 1.16E-03 0.00E+00 1.61E-03 0.20 3.10E-04 3.61E-04 7.95E-04 4.16E-04 5.80 0.25 >10 7.33E-07 5.70 2.10 >10 2.16E-05 NEICVP1446E01 Appendix M Page 27 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 028 Waste Description 41544891 Oily Trash Naphtha Soaked TABLE 3 C-4 AND O&O TOTAL BENZENE QUANTITY DATA Pounds (lbs) Conc. Date (ppmw) 7/22/2004 5.68 9/23/2004 0.46 12/29/2004 0.66 12/31/2004 0.48 9/24/2004 1.04 2.10 Basis Measured (TCLP) Measured (TCLP) Measured (TCLP) Measured (TCLP) Measured (TCLP) Total Weight (lbs) 6,622 462 3,872 3,000 3,696 22,640 Total Benzene (lbs) 3.76E-02 2.13E-04 2.56E-03 1.44E-03 3.84E-03 4.75E-02 Minimum (ppm) 121,140 2/19/2004 6/4/2004 8/27/2004 6/10/2004 11/10/2004 10/28/2004 4/28/2004 2/23/2004 10.70 0.20 1.52 0.05 0.00 8,380 0.00E+00 11,120 0.00E+00 4,420 0.00E+00 5,440 0.00E+00 22,100 0.00E+00 100 1.07E-03 500 0.00E+00 100 2.00E-05 5,700 0.00E+00 3,040 4.62E-03 11,220 0.00E+00 2,440 0.00E+00 46,580 0.00E+00 121,140 5.71E-03 Maximum (ppm) 5.70 Average Benzene (ppm) % Water Mg 0.05 >10 2.59E-06 4309319H O&O Naphtha Pads and PPE 4310301H O&O Naphtha Contaminated Soil 4317119H O&O Wastewater 4406609H C-4 Hydrocarbon Slop Tank Residue 44093191 C-4 Crude Butadiene Tank Bottoms 4703009H C-4/O&O Lab Pack 3,500 2,400 None Generated in CY 2004 None Generated in CY 2004 None Generated in CY 2004 174 10/21/2004 11/1/2004 10.00 10.00 estimated Estimate 3,500 2,400 3.50E-02 2.40E-02 10.00 10.00 10.00 10.00 10.00 10.00 >10 1.59E-05 >10 1.09E-05 10.00 10.00 10.00 >10 7.90E-07 NEICVP1446E01 Appendix M Page 28 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 029 Waste Description 51084031 C-4 Solvent Tower and Stripper Residue 51104031 C4 Popcorn Polymer Wastewater System 5106403H C-4 Popcorn Polymer 5119119H Soap Solution Wastewater 51203191 Tank Bottoms 34016091 C-4 Vent Compressor Residue TABLE 3 C-4 AND O&O TOTAL BENZENE QUANTITY DATA Pounds (lbs) Conc. Total Weight Total Benzene Minimum Date (ppmw) Basis (lbs) (lbs) (ppm) 10.00 Estimate 174 1.74E-03 12,248 0.00 Measured 3/24/2004 1.08 (TCLP) 430 4.64E-04 12/13/2004 0.00 ND 2,060 12/29/2004 0.00 ND 9,758 0.00E+00 0.04 12,248 4.64E-04 8,332 3/24/2004 0.00 ND Measured 9/23/2004 0.24 (TCLP) 12/29/2004 0.00 ND 0.08 5,160 2,772 400 8,332 0.00 0.00E+00 6.65E-04 0.00E+00 6.65E-04 4,600 2/26/2004 5/10/2004 7/6/2004 6/9/2004 8/27/2004 10.00 10.00 10.00 10.00 10.00 10.00 Estimate Estimate Estimate Estimate Estimate 1,200 1,600 800 600 400 4,600 1.20E-02 1.60E-02 8.00E-03 6.00E-03 4.00E-03 4.60E-02 10.00 305,000 0.05 11/13/2004 5.52 Measured 30,220 1.67E-01 11/13/2004 5.99 Measured 37,500 2.25E-01 11/14/2004 14.40 Measured 34,940 5.03E-01 11/14/2004 0.94 Measured 42,160 3.98E-02 11/17/2004 2.05 Measured 35,500 7.28E-02 11/17/2004 4.91 Measured 29,560 1.45E-01 11/18/2004 0.48 Measured 25,880 1.24E-02 11/17/2004 468.00 Measured 33,120 1.55E+01 11/18/2004 488.00 Measured 36,120 1.76E+01 112.43 305,000 3.43E+01 2,940 Measured 0.90 (TCLP) 2,940 2.65E-03 0.09 Measured 3,440 9/23/2004 ND (TCLP) 3,440 ND Maximum (ppm) 1.08 0.24 10.00 488.00 0.09 ND Average Benzene (ppm) % Water Mg 0.04 >10 2.11E-07 0.08 >10 3.02E-07 10.00 >10 2.09E-05 112.43 >10 1.56E-02 0.09 >10 1.20E-07 0.00 >10 0.00E+00 NEICVP1446E01 Appendix M Page 29 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 030 Waste Description 34033931 C-4 Spent Catalyst 41083011 O&O/C-4 Contaminated Soil 41263012 O&O/C-4 Contaminated Soil 41364091 C-4 Oil Soaked Absorbent 44183191 C-4 MTBE Catalyst Residue TABLE 3 C-4 AND O&O TOTAL BENZENE QUANTITY DATA Pounds (lbs) Date None Generated in CY 2004 Conc. (ppmw) Basis Total Weight (lbs) Total Benzene (lbs) Minimum (ppm) Maximum (ppm) Average Benzene (ppm) % Water Mg 195,150 0.00 5/15/2004 0.00 ND 24,000 0.00E+00 5/21/2004 0.00 ND 26,980 0.00E+00 9/20/2004 0.00 ND 28,280 0.00E+00 9/21/2004 0.00 ND 21,140 0.00E+00 10/15/2004 0.00 ND 13,579 0.00E+00 10/15/2004 0.00 ND 37,880 0.00E+00 9/23/2004 0.00 ND 27,380 0.00E+00 9/15/2004 0.00 ND 924 0.00E+00 9/10/2004 0.00 ND 8,360 0.00E+00 0.00 ND 6,627 0.00E+00 0.00 195,150 0.00E+00 2,599,500 0.00 4/8/2004 0.54 Measured 1,500 8.10E-04 7/6/2004 1.53 Measured 78,000 1.19E-01 5/5/2004 60,000 0.00E+00 5/5/2004 210,000 0.00E+00 5/5/2004 120,000 0.00E+00 5/18/2004 90,000 0.00E+00 5/24/2004 0.35 Measured 180,000 6.30E-02 9/3/2004 210,000 0.00E+00 9/20/2004 30,000 0.00E+00 9/16/2004 30,000 0.00E+00 9/15/2004 0.00 ND 1,140,000 0.00E+00 11/24/2004 0.00 ND 300,000 0.00E+00 5/24/2004 0.00 ND 90,000 0.00E+00 3/31/2004 60,000 0.00E+00 0.07 2,599,500 1.83E-01 None Generated in CY 2004 None Generated in CY 2004 0.00 0.00 >10 0.00E+00 1.53 0.07 >10 8.32E-05 NEICVP1446E01 Appendix M Page 30 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 031 Waste Description 46003012 C-4 Boiler Rust and Scale TABLE 3 C-4 AND O&O TOTAL BENZENE QUANTITY DATA Pounds (lbs) Date None Generated in CY 2004 Conc. (ppmw) Basis Total Weight (lbs) Total Benzene (lbs) Minimum (ppm) 51133191 C-4 Sump Cleanings None Generated in CY 2004 4400219 C-4 Polyblend (Off-Site Disposal) 211,950 8/10/2004 9/22/2003 3,048.00 3,048.00 3,048.00 Measured Measured 168,300 43,650 211,950 5.13E+02 1.33E+02 6.46E+02 3,048.00 4401403H C4 Polyblend Residue 200 2/26/2004 457.00 Measured 200 9.14E-02 4,578.00 C-4 Polyblend (bz combusted in BIF) 17,479,001 1/1/2004 2/1/2004 3/1/2004 4/1/2004 5/1/2004 6/1/2004 7/1/2004 8/1/2004 9/1/2004 10/1/2004 11/1/2004 12/1/2004 743.42 743.42 743.42 743.42 743.42 309.53 309.53 304.80 304.80 304.80 304.80 304.80 496.88 Measured Measured Measured Measured Measured Measured Measured Measured Measured Measured Measured Measured 1,472,124.90 1,001,208.10 1,781,817.60 1,773,155.90 1,583,730.70 2,222,231.20 1,686,790.40 2,301,770.10 214,634.30 1,220,743.60 1,415,624.00 805,170.30 17,479,001 1.09E+03 7.44E+02 1.32E+03 1.32E+03 1.18E+03 6.88E+02 5.22E+02 7.02E+02 6.54E+01 3.72E+02 4.31E+02 2.45E+02 8.68E+03 743.42 O&O A-3 Sump/Wash Oil/Quench to T-O88 14,839,337 Estimated 14,839,337 0.00E+00 1.00 O&O A-3 Sump/Wash Oil/Quench to T-O126 4,990,861 Estimated 4,990,861 0.00E+00 1.00 Maximum (ppm) 3,048.00 457.00 304.80 24.00 24.00 Average Benzene (ppm) % Water Mg 3,048.00 >10 2.93E-01 457.00 496.88 >10 4.15E-05 >10 3.94E+00 19.67 19.67 >10 1.33E-01 >10 4.46E-02 NEICVP1446E01 Appendix M Page 31 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 032 TABLE 4: C-4 AND O&O PLANTS OFF-SITE WASTE NEICVP1446E01 Appendix M Page 32 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 033 TABLE 4 C-4 AND O&O PLANTS OFF-SITE WASTE Waste 11033191 1126219H 11303192 1104519H 1114695H 11244041 1134310H 1135119H 3100606H 31031191 34043192 36023101 41433891 41544891 4309319H 4310301H 4317119H 4406609H 44093191 4703009H 51084031 5106403H 34016091 34033931 41083011 41263012 41364091 44183191 46003012 51133191 4400219 Description Pounds (lbs) Minimum (ppm) Maximum (ppm) Average (ppm) None Generated in A-3 Molecular Sieve CY 2004 O&O A-3 Gas Header O/W Residu 150 10 10 10 A-3 Exchanger Cleaning Solids 1,100 0.2 0.2 0.2 A-3 Quench Water System Sludge 5,180 36.10 36.10 36.10 None Generated in A-3 Pyronaphtha Tank Bottoms Sludge CY 2004 None Generated in A-3 Coke Fines From Furnaces CY 2004 A-3 Pall Filters 16,940 469.00 469.00 469.00 a-3 Hazardous Wastewater 770,420 21.90 47,880.00 5,046.00 C-4 Sponge Oil Exchanger Residue 4,650 5.40 28.70 6.60 Soap Solution 399,880 0.00 0.14 0.03 None Generated in C-4 Raschig Rings CY 2004 C-4 Process Filters 6,424 0.00 5.80 0.30 C-4 Hydroblast Pit Residue 22,640 0.20 5.70 2.10 Oily Trash Naphtha Soaked 11,810 0.00 10.70 0.00 O&O Naphtha Pads and PPE 3,500 10.00 10.00 10.00 O&O Naphtha Contaminated Soil 2,400 10.00 10.00 10.00 None Generated in O&O Wastewater CY 2004 None Generated in C-4 Hydrocarbon Slop Tank Residue CY 2004 C-4 Crude Butadiene Tank Bottoms 16,372 1.50 4.30 0.00 C-4/O&O Lab Pack 2,747 0.00 10.00 10.00 C-4 Solvent Tower and Stripper Residue 23,468 0.00 0.70 0.04 C-4 Popcorn Polymer 11,150 10.00 10.00 10.00 C-4 Vent Compressor Residue 946 0.70 0.70 0.00 C-4 Spent Catalyst 5,880 0.00 11.10 0.00 Contaminated Soil 450,880 0.00 3.47 0.00 Contaminated Soil 2,599,500 0.00 1.80 0.10 Oil Soaked Absorbent 1,419 0.80 0.80 0.00 MTBE Catalyst Residue 80,110 0.00 3.47 0.00 Boiler Rust and Scale 946 1.20 1.20 0.00 C-4 Sump Cleanings 25,680 0.00 1.50 0.00 C-4 Polyblend (Off-Site Disposal) 211,950 2,750.00 5,380.00 4,017.81 % Water >10 >10 >10 >10 >10 >10 >10 >10 >10 >10 >10 >10 >10 >10 >10 >10 >10 <10 >10 >10 >10 >10 >10 >10 >10 >10 >10 >10 >10 >10 >10 Benzene Mg 6.81E-07 9.99E-08 8.49E-05 3.61E-03 1.76E+00 1.39E-05 5.45E-06 8.75E-07 2.16E-05 0.00E+00 1.59E-05 1.09E-05 0.00E+00 1.25E-05 4.04E-07 5.06E-05 0.00E+00 0.00E+00 0.00E+00 1.18E-04 0.00E+00 0.00E+00 0.00E+00 0.00E+00 3.87E-01 NEICVP1446E01 Appendix M Page 33 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 034 Appendix D Heat Exchange System Alternative Monitoring Request RMT, Inc. | Huntsman Petrochemical Corporation I:\WPAUS\PJT\50-09101\20\R500910120-001.DOC NEICVP1446E01 Appendix M Page 34 of 60 Final March 2006 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 035 NEICVP1446E01 Appendix M Page 35 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 036 NEICVP1446E01 Appendix M Page 36 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 037 NEICVP1446E01 Appendix M Page 37 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 038 NEICVP1446E01 Appendix M Page 38 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 039 NEICVP1446E01 Appendix M Page 39 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 040 NEICVP1446E01 Appendix M Page 40 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 041 NEICVP1446E01 Appendix M Page 41 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 042 NEICVP1446E01 Appendix M Page 42 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 043 NEICVP1446E01 Appendix M Page 43 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 044 NEICVP1446E01 Appendix M Page 44 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 045 NEICVP1446E01 Appendix M Page 45 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 046 NEICVP1446E01 Appendix M Page 46 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 047 NEICVP1446E01 Appendix M Page 47 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 048 NEICVP1446E01 Appendix M Page 48 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 049 NEICVP1446E01 Appendix M Page 49 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 050 NEICVP1446E01 Appendix M Page 50 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 051 NEICVP1446E01 Appendix M Page 51 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 052 NEICVP1446E01 Appendix M Page 52 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 053 NEICVP1446E01 Appendix M Page 53 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 054 NEICVP1446E01 Appendix M Page 54 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 055 NEICVP1446E01 Appendix M Page 55 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 056 NEICVP1446E01 Appendix M Page 56 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 057 NEICVP1446E01 Appendix M Page 57 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 058 NEICVP1446E01 Appendix M Page 58 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 059 NEICVP1446E01 Appendix M Page 59 of 60 Indorama Ventures Oxides LLC Port Neches, Texas PNO.067 060 NEICVP1446E01 Appendix M Page 60 of 60 Indorama Ventures Oxides LLC Port Neches, Texas FEDERAL OPERATING PERMIT A FEDERAL OPERATING PERMIT IS HEREBY ISSUED TO Indorama Ventures Oxides LLC AUTHORIZING THE OPERATION OF Port Neches Operations A3 Unit / R&S Area / Utilities Area Petrochemical Manufacturing LOCATED AT Jefferson County, Texas Latitude 29 58 15 Longitude 93 56 26 Regulated Entity Number: RN100219252 This permit is issued in accordance with and subject to the Texas Clean Air Act (TCAA), Chapter 382 of the Texas Health and Safety Code and Title 30 Texas Administrative Code Chapter 122 (30 TAC Chapter 122), Federal Operating Permits. Under 30 TAC Chapter 122, this permit constitutes the permit holder's authority to operate the site and emission units listed in this permit. Operations of the site and emission units listed in this permit are subject to all additional rules or amended rules and orders of the Commission pursuant to the TCAA. This permit does not relieve the permit holder from the responsibility of obtaining New Source Review authorization for new, modified, or existing facilities in accordance with 30 TAC Chapter 116, Control of Air Pollution by Permits for New Construction or Modification. The site and emission units authorized by this permit shall be operated in accordance with 30 TAC Chapter 122, the general terms and conditions, special terms and conditions, and attachments contained herein. This permit shall expire five years from the date of issuance. The renewal requirements specified in 30 TAC 122.241 must be satisfied in order to renew the authorization to operate the site and emission units. Permit No: O2288 Issuance Date: June 10, 2021 For the Commission NEICVP1446E01 Appendix N Page 1 of 148 Renewal- Effective Page i Indorama Ventures Oxides LLC Port Neches, Texas Table of Contents Section Page General Terms and Conditions ..................................................................................................................... 1 Special Terms and Conditions: ..................................................................................................................... 1 Emission Limitations and Standards, Monitoring and Testing, and Recordkeeping and Reporting...................................................................................................................... 1 Additional Monitoring Requirements .............................................................................................. 12 New Source Review Authorization Requirements ......................................................................... 12 Compliance Requirements............................................................................................................. 13 Risk Management Plan .................................................................................................................. 14 Protection of Stratospheric Ozone ................................................................................................. 15 Permit Location .............................................................................................................................. 15 Permit Shield (30 TAC 122.148) ................................................................................................. 15 Attachments ................................................................................................................................................ 16 Applicable Requirements Summary............................................................................................... 17 Additional Monitoring Requirements .............................................................................................. 92 Permit Shield ................................................................................................................................ 110 New Source Review Authorization References ........................................................................... 118 Appendix A ................................................................................................................................................ 125 Acronym List ................................................................................................................................ 126 Appendix B ................................................................................................................................................ 127 NEICVP1446E01 Appendix N Page 2 of 148 Renewal- Effective Page ii Indorama Ventures Oxides LLC Port Neches, Texas General Terms and Conditions The permit holder shall comply with all terms and conditions contained in 30 TAC 122.143 (General Terms and Conditions), 30 TAC 122.144 (Recordkeeping Terms and Conditions), 30 TAC 122.145 (Reporting Terms and Conditions), and 30 TAC 122.146 (Compliance Certification Terms and Conditions). In accordance with 30 TAC 122.144(1), records of required monitoring data and support information required by this permit, or any applicable requirement codified in this permit, are required to be maintained for a period of five years from the date of the monitoring report, sample, or application unless a longer data retention period is specified in an applicable requirement. The five year record retention period supersedes any less stringent retention requirement that may be specified in a condition of a permit identified in the New Source Review Authorization attachment. If the permit holder chooses to demonstrate that this permit is no longer required, a written request to void this permit shall be submitted to the Texas Commission on Environmental Quality (TCEQ) by the Responsible Official in accordance with 30 TAC 122.161(e). The permit holder shall comply with the permit's requirements, including compliance certification and deviation reporting, until notified by the TCEQ that this permit is voided. The permit holder shall comply with 30 TAC Chapter 116 by obtaining a New Source Review authorization prior to new construction or modification of emission units located in the area covered by this permit. All reports required by this permit must include in the submittal a cover letter which identifies the following information: company name, TCEQ regulated entity number, air account number (if assigned), site name, area name (if applicable), and Air Permits Division permit number(s). Special Terms and Conditions: Emission Limitations and Standards, Monitoring and Testing, and Recordkeeping and Reporting 1. Permit holder shall comply with the following requirements: A. Emission units (including groups and processes) in the Applicable Requirements Summary attachment shall meet the limitations, standards, equipment specifications, monitoring, recordkeeping, reporting, testing, and other requirements listed in the Applicable Requirements Summary attachment to assure compliance with the permit. B. The textual description in the column titled "Textual Description" in the Applicable Requirements Summary attachment is not enforceable and is not deemed as a substitute for the actual regulatory language. The Textual Description is provided for information purposes only. C. A citation listed on the Applicable Requirements Summary attachment, which has a notation [G] listed before it, shall include the referenced section and subsection for all commission rules, or paragraphs for all federal and state regulations and all subordinate paragraphs, subparagraphs and clauses, subclauses, and items contained within the referenced citation as applicable requirements. D. When a grouped citation, notated with a [G] in the Applicable Requirements Summary, contains multiple compliance options, the permit holder must keep records of when each compliance option was used. E. Emission units subject to 40 CFR Part 63, Subpart F, G, H, YY, DDDDD and ZZZZ as identified in the attached Applicable Requirements Summary table are subject to NEICVP1446E01 Appendix N Page 3 of 148 Renewal- Effective Page 1 Indorama Ventures Oxides LLC Port Neches, Texas 30 TAC Chapter 113, Subchapter C, 113.110, 113.120, 113.130, 113.560, 113.1130 and 113.1090 respectively, which incorporates the 40 CFR Part 63 Subpart by reference. 2. The permit holder shall comply with the following sections of 30 TAC Chapter 101 (General Air Quality Rules): A. Title 30 TAC 101.1 (relating to Definitions), insofar as the terms defined in this section are used to define the terms used in other applicable requirements B. Title 30 TAC 101.3 (relating to Circumvention) C. Title 30 TAC 101.8 (relating to Sampling), if such action has been requested by the TCEQ D. Title 30 TAC 101.9 (relating to Sampling Ports), if such action has been requested by the TCEQ E. Title 30 TAC 101.10 (relating to Emissions Inventory Requirements) F. Title 30 TAC 101.201 (relating to Emission Event Reporting and Recordkeeping Requirements) G. Title 30 TAC 101.211 (relating to Scheduled Maintenance, Start-up, and Shutdown Reporting and Recordkeeping Requirements) H. Title 30 TAC 101.221 (relating to Operational Requirements) I. Title 30 TAC 101.222 (relating to Demonstrations) J. Title 30 TAC 101.223 (relating to Actions to Reduce Excessive Emissions) 3. Permit holder shall comply with the following requirements of 30 TAC Chapter 111: A. Visible emissions from stationary vents with a flow rate of less than 100,000 actual cubic feet per minute that are not listed in the Applicable Requirements Summary attachment for 30 TAC Chapter 111, Subchapter A, Division 1, shall not exceed 20% opacity averaged over a six minute period. The permit holder shall comply with the following requirements for stationary vents at the site subject to this standard: (i) Title 30 TAC 111.111(a)(1)(B) (relating to Requirements for Specified Sources) (ii) Title 30 TAC 111.111(a)(1)(E) (iii) Title 30 TAC 111.111(a)(1)(F)(i), (ii), (iii), or (iv) (iv) For emission units with vent emissions subject to 30 TAC 111.111(a)(1)(B), complying with 30 TAC 111.111(a)(1)(F)(ii), (iii), or (iv), and capable of producing visible emissions from, but not limited to, particulate matter, acid gases and NOx, the permit holder shall also comply with the following periodic monitoring requirements for the purpose of annual compliance certification under 30 TAC 122.146. These periodic monitoring requirements do not apply to vents that are not capable of producing visible emissions such as vents that emit only colorless VOCs; vents from non-fuming liquids; vents that provide passive ventilation, such as plumbing vents; or vent emissions from any other source that NEICVP1446E01 Appendix N Page 4 of 148 Renewal- Effective Page 2 Indorama Ventures Oxides LLC Port Neches, Texas NEICVP1446E01 does not obstruct the transmission of light. Vents, as specified in the "Applicable Requirements Summary" attachment, that are subject to the emission limitation of 30 TAC 111.111(a)(1)(B) are not subject to the following periodic monitoring requirements: (1) An observation of stationary vents from emission units in operation shall be conducted at least once during each calendar quarter unless the emission unit is not operating for the entire quarter. (2) For stationary vents from a combustion source, if an alternative to the normally fired fuel is fired for a period greater than or equal to 24 consecutive hours, the permit holder shall conduct an observation of the stationary vent for each such period to determine if visible emissions are present. If such period is greater than 3 months, observations shall be conducted once during each quarter. Supplementing the normally fired fuel with natural gas or fuel gas to increase the net heating value to the minimum required value does not constitute creation of an alternative fuel. (3) Records of all observations shall be maintained. (4) Visible emissions observations of emission units operated during daylight hours shall be conducted no earlier than one hour after sunrise and no later than one hour before sunset. Visible emissions observations of emission units operated only at night must be made with additional lighting and the temporary installation of contrasting backgrounds. Visible emissions observations shall be made during times when the activities described in 30 TAC 111.111(a)(1)(E) are not taking place. Visible emissions shall be determined with each stationary vent in clear view of the observer. The observer shall be at least 15 feet, but not more than 0.25 mile, away from each stationary vent during the observation. For outdoor locations, the observer shall select a position where the sun is not directly in the observer's eyes. When condensed water vapor is present within the plume, as it emerges from the emissions outlet, observations must be made beyond the point in the plume at which condensed water vapor is no longer visible. When water vapor within the plume condenses and becomes visible at a distance from the emissions outlet, the observation shall be evaluated at the outlet prior to condensation of water vapor. A certified opacity reader is not required for visible emissions observations. (5) Compliance Certification: (a) If visible emissions are not present during the observation, the RO may certify that the source is in compliance with the applicable opacity requirement in 30 TAC 111.111(a)(1) and (a)(1)(B). (b) However, if visible emissions are present during the observation, the permit holder shall either list this occurrence as a deviation on the next deviation report as required under 30 TAC 122.145(2) or conduct the appropriate opacity test specified in 30 TAC 111.111(a)(1)(F) as soon as practicable, but no later than 24 hours after observing visible emissions to determine if the source is in compliance with the opacity requirements. If an opacity test is performed and the source is Appendix N Page 5 of 148 Renewal- Effective Page 3 Indorama Ventures Oxides LLC Port Neches, Texas determined to be in compliance, the RO may certify that the source is in compliance with the applicable opacity requirement. However, if an opacity test is performed and the source is determined to be out of compliance, the permit holder shall list this occurrence as a deviation on the next deviation report as required under 30 TAC 122.145(2). The opacity test must be performed by a certified opacity reader. (c) Some vents may be subject to multiple visible emission or monitoring requirements. All credible data must be considered when certifying compliance with this requirement even if the observation or monitoring was performed to demonstrate compliance with a different requirement. B. For visible emissions from a building, enclosed facility, or other structure; the permit holder shall comply with the following requirements: (i) Title 30 TAC 111.111(a)(7)(A) (relating to Requirements for Specified Sources) (ii) Title 30 TAC 111.111(a)(7)(B)(i) or (ii) (iii) For a building containing an air emission source, enclosed facility, or other structure containing or associated with an air emission source subject to 30 TAC 111.111(a)(7)(A), complying with 30 TAC 111.111(a)(7)(B)(i) or (ii), and capable of producing visible emissions from, but not limited to, particulate matter, acid gases and NOx, the permit holder shall also comply with the following periodic monitoring requirements for the purpose of annual compliance certification under 30 TAC 122.146: (1) An observation of visible emissions from a building containing an air emission source, enclosed facility, or other structure containing or associated with an air emission source which is required to comply with 30 TAC 111.111(a)(7)(A) shall be conducted at least once during each calendar quarter unless the air emission source or enclosed facility is not operating for the entire quarter. (2) Records of all observations shall be maintained. (3) Visible emissions observations of air emission sources or enclosed facilities operated during daylight hours shall be conducted no earlier than one hour after sunrise and no later than one hour before sunset. Visible emissions observations of air emission sources or enclosed facilities operated only at night must be made with additional lighting and the temporary installation of contrasting backgrounds. Visible emissions shall be determined with each emissions outlet in clear view of the observer. The observer shall be at least 15 feet, but not more than 0.25 mile, away from each emissions outlet during the observation. For outdoor locations, the observer shall select a position where the sun is not directly in the observer's eyes. When condensed water vapor is present within the plume, as it emerges from the emissions outlet, observations must be made beyond the point in the plume at which condensed water vapor is no longer visible. When water vapor within the plume condenses and becomes visible at a distance from the emissions outlet, the observation shall be evaluated at the outlet prior to condensation of water vapor. A certified opacity reader is not required for visible emissions observations. NEICVP1446E01 Appendix N Page 6 of 148 Renewal- Effective Page 4 Indorama Ventures Oxides LLC Port Neches, Texas (4) Compliance Certification: (a) If visible emissions are not present during the observation, the RO may certify that the source is in compliance with the applicable opacity requirement in 30 TAC 111.111(a)(7) and (a)(7)(A) (b) However, if visible emissions are present during the observation, the permit holder shall either list this occurrence as a deviation on the next deviation report as required under 30 TAC 122.145(2) or conduct the appropriate opacity test specified in 30 TAC 111.111(a)(7)(B) as soon as practicable, but no later than 24 hours after observing visible emissions to determine if the source is in compliance with the opacity requirements. If an opacity test is performed and the source is determined to be in compliance, the RO may certify that the source is in compliance with the applicable opacity requirement. However, if an opacity test is performed and the source is determined to be out of compliance, the permit holder shall list this occurrence as a deviation on the next deviation report as required under 30 TAC 122.145(2). The opacity test must be performed by a certified opacity reader C. Certification of opacity readers determining opacities under Method 9 (as outlined in 40 CFR Part 60, Appendix A) to comply with opacity monitoring requirements shall be accomplished by completing the Visible Emissions Evaluators Course, or approved agency equivalent, no more than 180 days before the opacity reading. D. Emission limits on nonagricultural processes, except for the steam generators specified in 30 TAC 111.153, shall comply with the following requirements: (i) Emissions of PM from any source may not exceed the allowable rates as required in 30 TAC 111.151(a) (relating to Allowable Emissions Limits) (ii) Sources with an effective stack height (he) less than the standard effective stack height (He), must reduce the allowable emission level by multiplying it by [he/He]2 as required in 30 TAC 111.151(b) (iii) Effective stack height shall be calculated by the equation specified in 30 TAC 111.151(c) E. Outdoor burning, as stated in 30 TAC 111.201, shall not be authorized unless the following requirements are satisfied: (i) Title 30 TAC 111.205 (relating to Exception for Fire Training) (ii) Title 30 TAC 111.207 (relating to Exception for Recreation, Ceremony, Cooking, and Warmth) (iii) Title 30 TAC 111.219 (relating to General Requirements for Allowable Outdoor Burning) (iv) Title 30 TAC 111.221 (relating to Responsibility for Consequences of Outdoor Burning) NEICVP1446E01 Appendix N Page 7 of 148 Renewal- Effective Page 5 Indorama Ventures Oxides LLC Port Neches, Texas 4. For storage vessels maintaining working pressure as specified in 30 TAC Chapter 115, Subchapter B, Division 1: "Storage of Volatile Organic Compounds," the permit holder shall comply with the requirements of 30 TAC 115.112(a)(1). 5. For industrial wastewater specified in 30 TAC Chapter 115, Subchapter B, the permit holder shall comply with the following requirements for wastewater drains, junction boxes, lift stations and weirs: A. Title 30 TAC 115.142 (relating to Control Requirements) B. Title 30 TAC 115.142(1)(A) - (D) (relating to Control Requirements) C. Title 30 TAC 115.142(1)(E) and (F) (relating to Control Requirements) D. Title 30 TAC 115.145 (relating to Approved Test Methods) E. Title 30 TAC 115.146 (relating to Recordkeeping Requirements) F. Title 30 TAC 115.148 (relating to Determination of Wastewater Characteristics) 6. Permit holder shall comply with the following 30 TAC Chapter 115, Subchapter C requirements: A. When filling stationary gasoline storage vessels (Stage I) for motor vehicle fuel dispensing facilities, constructed prior to November 15, 1992, with transfers to stationary storage tanks located at a facility which has dispensed no more than 10,000 gallons of gasoline in any calendar month after January 1, 1991, the permit holder shall comply with the following requirements specified in 30 TAC Chapter 115, Subchapter C: (i) Title 30 TAC 115.222(3) (relating to Control Requirements), as it applies to liquid gasoline leaks, visible vapors, or significant odors (ii) Title 30 TAC 115.222(6) (relating to Control Requirements) (iii) Title 30 TAC 115.224(1) (relating to Inspection Requirements), as it applies to liquid gasoline leaks, visible vapors, or significant odors (iv) Title 30 TAC 115.226(2)(B) (relating to Recordkeeping Requirements) 7. The permit holder shall comply with the following requirements of 30 TAC Chapter 115, Subchapter F, Division 3, Degassing of Storage Tanks, Transport Vessels and Marine Vessels: A. For degassing of stationary VOC storage tanks, the permit holder shall comply with the following requirements: (i) Title 30 TAC 115.541(a) - (c) (relating to Emission Specifications) (ii) Title 30 TAC 115.541(f) (relating to Emission Specifications), for floating roof storage tanks (iii) Title 30 TAC 115.542(a) and (a)(1), (a)(2), (a)(3) or (a)(4) (relating to Control Requirements). Where the requirements of 30 TAC Chapter 115, Subchapter F contain multiple compliance options, the permit holder shall keep records of when each compliance option was used. (iv) Title 30 TAC 115.542(b) - (d), (relating to Control Requirements) NEICVP1446E01 Appendix N Page 8 of 148 Renewal- Effective Page 6 Indorama Ventures Oxides LLC Port Neches, Texas (v) Title 30 TAC 115.543 (relating to Alternate Control Requirements) (vi) Title 30 TAC 115.544(a)(1) and (a)(2) (relating to Inspection, Monitoring, and Testing Requirements), for inspections (vii) Title 30 TAC 115.544(b) (relating to Inspection, Monitoring, and Testing Requirements), for monitoring (viii) Title 30 TAC 115.544(b)(1) and (b)(2) (relating to Inspection, Monitoring, and Testing Requirements), for monitoring of control devices (ix) Title 30 TAC 115.544(b)(2)(A) - (J) (relating to Inspection, Monitoring, and Testing Requirements), for monitoring (as appropriate to the control device) (x) Title 30 TAC 115.544(b)(3), (b)(4) and (b)(6) (relating to Inspection, Monitoring, and Testing Requirements), for VOC concentration or lower explosive limit threshold monitoring (xi) Title 30 TAC 115.544(c), and (c)(1) - (c)(3) (relating to Inspection, Monitoring, and Testing Requirements), for testing of control devices used to comply with 30 TAC 115.542(a)(1) (xii) Title 30 TAC 115.545(1) - (7), (9) - (11) and (13) (relating to Approved Test Methods) (xiii) Title 30 TAC 115.546(a), (a)(1) and (a)(3) (relating to Recordkeeping and Notification Requirements), for recordkeeping (xiv) Title 30 TAC 115.546(a)(2) and (a)(2)(A) - (J) (relating to Recordkeeping and Notification Requirements), for recordkeeping (as appropriate to the control device) (xv) Title 30 TAC 115.546(a)(4) (relating to Recordkeeping and Notification Requirements), for recordkeeping of testing of control devices used to comply with 30 TAC 115.542(a)(1) (xvi) Title 30 TAC 115.547(4) (relating to Exemptions) B. For the degassing of all transport vessels with a nominal capacity of 8,000 gallons or more, the permit holder shall comply with the following requirements: (i) Title 30 TAC 115.541(a) - (c) and (d) (relating to Emission Specifications) (ii) Title 30 TAC 115.542(a) and (a)(1), (a)(2), (a)(3) or (a)(4) (relating to Control Requirements). Where the requirements of 30 TAC Chapter 115, Subchapter F contain multiple compliance options, the permit holder shall keep records of when each compliance option was used. (iii) Title 30 TAC 115.542(b), (c) and (e) (relating to Control Requirements) (iv) Title 30 TAC 115.543 (relating to Alternate Control Requirements) (v) Title 30 TAC 115.544(a)(1) and (a)(2) (relating to Inspection, Monitoring, and Testing Requirements), for inspections NEICVP1446E01 Appendix N Page 9 of 148 Renewal- Effective Page 7 Indorama Ventures Oxides LLC Port Neches, Texas (vi) Title 30 TAC 115.544(b) (relating to Inspection, Monitoring, and Testing Requirements), for monitoring (vii) Title 30 TAC 115.544(b)(1) and (b)(2) (relating to Inspection, Monitoring, and Testing Requirements), for monitoring of control devices (viii) Title 30 TAC 115.544(b)(2)(A) - (J) (relating to Inspection, Monitoring, and Testing Requirements), for monitoring (as appropriate to the control device) (ix) Title 30 TAC 115.544(b)(3), (b)(4) and (b)(6) (relating to Inspection, Monitoring, and Testing Requirements), for VOC concentration or lower explosive limit threshold monitoring (x) Title 30 TAC 115.544(c), and (c)(1) - (c)(3) (relating to Inspection, Monitoring, and Testing Requirements), for testing of control devices used to comply with 30 TAC 115.542(a)(1) (xi) Title 30 TAC 115.545(1) - (11) and (13) (relating to Approved Test Methods) (xii) Title 30 TAC 115.546(a), (a)(1) and (a)(3) (relating to Recordkeeping and Notification Requirements), for recordkeeping (xiii) Title 30 TAC 115.546(a)(2) and (a)(2)(A) - (J) (relating to Recordkeeping and Notification Requirements), for recordkeeping (as appropriate to the control device) (xiv) Title 30 TAC 115.546(a)(4) (relating to Recordkeeping and Notification Requirements), for recordkeeping of testing of control devices used to comply with 30 TAC 115.542(a)(1) 8. The permit holder shall comply with the following requirements for units subject to any subpart of 40 CFR Part 60, unless otherwise stated in the applicable subpart: A. Title 40 CFR 60.7 (relating to Notification and Recordkeeping) B. Title 40 CFR 60.8 (relating to Performance Tests) C. Title 40 CFR 60.11 (relating to Compliance with Standards and Maintenance Requirements) D. Title 40 CFR 60.12 (relating to Circumvention) E. Title 40 CFR 60.13 (relating to Monitoring Requirements) F. Title 40 CFR 60.14 (relating to Modification) G. Title 40 CFR 60.15 (relating to Reconstruction) H. Title 40 CFR 60.19 (relating to General Notification and Reporting Requirements) 9. The permit holder shall comply with the following requirements for units subject to any subpart of 40 CFR Part 61, unless otherwise stated in the applicable subpart: A. Title 40 CFR 61.05 (relating to Prohibited Activities) NEICVP1446E01 Appendix N Page 10 of 148 Renewal- Effective Page 8 Indorama Ventures Oxides LLC Port Neches, Texas B. Title 40 CFR 61.07 (relating to Application for Approval of Construction or Modification) C. Title 40 CFR 61.09 (relating to Notification of Start-up) D. Title 40 CFR 61.10 (relating to Source Reporting and Request Waiver) E. Title 40 CFR 61.12 (relating to Compliance with Standards and Maintenance Requirements) F. Title 40 CFR 61.13 (relating to Emissions Tests and Waiver of Emission Tests) G. Title 40 CFR 61.14 (relating to Monitoring Requirements) H. Title 40 CFR 61.15 (relating to Modification) I. Title 40 CFR 61.19 (relating to Circumvention) 10. For facilities where total annual benzene quantity from waste is greater than or equal to 10 megagrams per year and subject to emission standards in 40 CFR Part 61, Subpart FF, the permit holder shall comply with the following requirements: A. Title 40 CFR 61.342(c)(1)(i) - (iii) (relating to Standards: General) B. Title 40 CFR 61.342(c)(2) (relating to Standards: General) C. For exempting waste streams: (i) Title 40 CFR 61.342(c)(3)(i) (relating to Standards: General) (ii) Title 40 CFR 61.342(c)(3)(ii)(A) - (C) (relating to Standards: General) D. Title 40 CFR 61.342(f)(1), and (2) (relating to Standards: General) E. Title 40 CFR 61.342(g) (relating to Standards: General) F. Title 40 CFR 61.350(a) and (b) (relating to Standards: Delay of Repair) G. Title 40 CFR 61.355(a)(1)(iii), (a)(2), (a)(6), (b), and (c)(1) - (3) (relating to Test Methods, Procedures, and Compliance Provisions) H. Title 40 CFR 61.355(j) (relating to Test Methods, Procedures, and Compliance Provisions), for calculation procedures I. Title 40 CFR 61.356(a) (relating to Recordkeeping Requirements) J. Title 40 CFR 61.356(b), and (b)(1) (relating to Recordkeeping Requirements) K. Title 40 CFR 61.356(b)(2)(i) - (ii) (relating to Recordkeeping Requirements) L. Title 40 CFR 61.356(b)(5) (relating to Recordkeeping Requirements) M. Title 40 CFR 61.356(c) (relating to Recordkeeping Requirements) N. Title 40 CFR 61.357(a), (d)(1), (d)(2) (d)(6) and (d)(8) (relating to Reporting Requirements) NEICVP1446E01 Appendix N Page 11 of 148 Renewal- Effective Page 9 Indorama Ventures Oxides LLC Port Neches, Texas O. Title 40 CFR 61.357(d)(3) (relating to Reporting Requirements) P. Waste generated by remediation activities at these facilities are subject to the requirements identified under 40 CFR 61.342 for treatment and management of waste 11. For facilities with containers subject to emission standards in 40 CFR Part 61, Subpart FF, the permit holder shall comply with the following requirements: A. Title 40 CFR 61.345(a)(1) - (3), (b), and (c) (relating to Standards: Containers) B. Title 40 CFR 61.355(h) (relating to Test Methods, Procedures and Compliance Provisions) C. Title 40 CFR 61.356(g) (relating to Recordkeeping Requirements) D. Title 40 CFR 61.356(h) (relating to Recordkeeping Requirements) 12. For facilities with individual drain systems subject to emission standards in 40 CFR Part 61, Subpart FF, the permit holder shall comply with the following requirements: A. Title 40 CFR 61.346(a)(1)(i)(A), (B), (ii), (2), and (3) (relating to Standards: Individual Drain Systems) B. Title 40 CFR 61.346(b)(1), (2), (2)(i), (3), (4)(i) - (iv), and (5) (relating to Standards: Individual Drain Systems) C. Title 40 CFR 61.346(b)(2)(ii)(A) (relating to Standards: Individual Drain Systems), for junction boxes D. Title 40 CFR 61.346(b)(2)(ii)(B) (relating to Standards: Individual Drain Systems), for junction boxes E. Title 40 CFR 61.355(h) (relating to Test Methods, Procedures and Compliance Provisions) F. Title 40 CFR 61.356(g) (relating to Recordkeeping Requirements) G. Title 40 CFR 61.356(h) (relating to Recordkeeping Requirements) 13. The permit holder shall comply with the requirements of 30 TAC Chapter 113, Subchapter C, 113.100 for units subject to any subpart of 40 CFR Part 63, unless otherwise stated in the applicable subpart. 14. For the chemical manufacturing facilities with a 40 CFR Part 63, Subpart G Group 1 or Group 2 wastewater streams that are also subject to 40 CFR Part 61, Subpart FF, the permit holder shall comply with the following requirements (Title 30 TAC Chapter 113, Subchapter C, 113.120 incorporated by reference): A. Title 40 CFR 63.110(e)(1) (relating to Applicability), for 40 CFR Part 63, Subpart G applicability to Group 1 or 2 Wastewater Streams 15. For the chemical manufacturing facilities with a 40 CFR Part 63, Subpart G Group 2 wastewater stream, the permit holder shall comply with (Title 30 TAC Chapter 113, Subchapter C, 113.120 incorporated by reference): NEICVP1446E01 Appendix N Page 12 of 148 Renewal- Effective Page 10 Indorama Ventures Oxides LLC Port Neches, Texas A. Title 40 CFR 63.132(a), (a)(1), and (a)(1)(i) (relating to Process Wastewater Provisions - General) B. Title 40 CFR 63.146(b)(1) (relating to Process Wastewater Provisions - Reporting) C. Title 40 CFR 63.147(b)(8) (relating to Process Wastewater Provisions - Recordkeeping) 16. For the chemical manufacturing facilities subject to leak detection requirements in 40 CFR Part 63, Subpart G, the permit holder shall comply with the following requirements (Title 30 TAC Chapter 113, Subchapter C, 113.120 incorporated by reference): A. General Leak Detection Requirements: (i) Title 40 CFR 63.148(d)(1) - (3), and (e) (relating to Leak Inspection Provisions) (ii) Title 40 CFR 63.148(c), (g), (g)(2), (h), and (h)(2) (relating to Leak Inspection Provisions), for monitoring and testing requirements (iii) Title 40 CFR 63.148(g)(2), (h)(2), (i)(1) - (2), (i)(4)(i) - (viii), (i)(5), and 63.152(a)(1) - (5), for recordkeeping requirements (iv) Title 40 CFR 63.148(j), 63.151(a)(6)(i) - (iii), (b)(1) - (2), (j)(1) - (3), 63.152(a)(1) - (5), (b), (b)(1)(i) - (ii), and (b)(4), for reporting requirements B. For closed vent system or vapor collection systems constructed of hard piping: (i) Title 40 CFR 63.148(b)(1)(ii) (relating to Leak Inspection Provisions), for monitoring and testing requirements (ii) Title 40 CFR 63.148(i)(6) (relating to Leak Inspection Provisions), for recordkeeping requirements C. For facilities not operating flow indicators: (i) Title 40 CFR 63.148(f)(2) (relating to Leak Inspection Provisions), for monitoring and testing requirements (ii) Title 40 CFR 63.148(i)(3)(ii) (relating to Leak Inspection Provisions), for recordkeeping requirements (iii) Title 40 CFR 63.148(j)(3) (relating to Leak Inspection Provisions), for reporting requirements 17. For ethylene process facilities subject to 40 CFR Part 63, Subpart YY with benzene laden waste streams and total annual benzene quantity from the facility of less than 10 megagrams per year the permit holder shall comply with the following requirements for control of spent caustic and dilution stream blowdown waste streams as specified in 40 CFR 63.1095(b)(1) (Title 30 TAC Chapter 113, Subchapter C, 113.560 incorporated by reference): A. For facilities with waste managed in containers the permit holder shall comply with the following requirements: (i) Title 40 CFR 61.345(a)(1) - (3), (b), and (c) (relating to Standards: Containers) NEICVP1446E01 Appendix N Page 13 of 148 Renewal- Effective Page 11 Indorama Ventures Oxides LLC Port Neches, Texas (ii) Title 40 CFR 61.355(h) (relating to Test Methods, Procedures and Compliance Provisions) (iii) Title 40 CFR 61.356(g) (relating to Recordkeeping Requirements) (iv) Title 40 CFR 61.356(h) (relating to Recordkeeping Requirements) B. For facilities with waste managed in individual drain systems the permit holder shall comply with the following requirements: (i) Title 40 CFR 61.346(a)(1)(i)(A), (B), (ii), (2), and (3) (relating to Standards: Individual Drain Systems) (ii) Title 40 CFR 61.346(b)(1), (2), (2)(i), (3), (4)(i) - (iv), and (5) (relating to Standards: Individual Drain Systems) (iii) Title 40 CFR 61.346(b)(2)(ii)(A) (relating to Standards: Individual Drain Systems), for junction boxes (iv) Title 40 CFR 61.346(b)(2)(ii)(B) (relating to Standards: Individual Drain Systems), for junction boxes (v) Title 40 CFR 61.355(h) (relating to Test Methods, Procedures and Compliance Provisions) (vi) Title 40 CFR 61.356(g) (relating to Recordkeeping Requirements) (vii) Title 40 CFR 61.356(h) (relating to Recordkeeping Requirements) Additional Monitoring Requirements 18. The permit holder shall comply with the periodic monitoring requirements as specified in the attached "Periodic Monitoring Summary" upon issuance of the permit. Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the permit holder shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant-specific emissions unit is operating. The permit holder may elect to collect monitoring data on a more frequent basis and average the data, consistent with the averaging time specified in the "Periodic Monitoring Summary," for purposes of determining whether a deviation has occurred. However, the additional data points must be collected on a regular basis. In no event shall data be collected and used in particular instances to avoid reporting deviations. Deviations shall be reported according to 30 TAC 122.145 (Reporting Terms and Conditions). New Source Review Authorization Requirements 19. Permit holder shall comply with the requirements of New Source Review authorizations issued or claimed by the permit holder for the permitted area, including permits, permits by rule, standard permits, flexible permits, special permits, permits for existing facilities including Voluntary Emissions Reduction Permits and Electric Generating Facility Permits issued under 30 TAC Chapter 116, Subchapter I, or special exemptions referenced in the New Source Review Authorization References attachment. These requirements: A. Are incorporated by reference into this permit as applicable requirements NEICVP1446E01 Appendix N Page 14 of 148 Renewal- Effective Page 12 Indorama Ventures Oxides LLC Port Neches, Texas B. Shall be located with this operating permit C. Are not eligible for a permit shield 20. The permit holder shall comply with the general requirements of 30 TAC Chapter 106, Subchapter A or the general requirements, if any, in effect at the time of the claim of any PBR. 21. The permit holder shall maintain records to demonstrate compliance with any emission limitation or standard that is specified in a permit by rule (PBR) or Standard Permit listed in the New Source Review Authorizations attachment. The records shall yield reliable data from the relevant time period that are representative of the emission unit's compliance with the PBR or Standard Permit. These records may include, but are not limited to, production capacity and throughput, hours of operation, safety data sheets (SDS), chemical composition of raw materials, speciation of air contaminant data, engineering calculations, maintenance records, fugitive data, performance tests, capture/control device efficiencies, direct pollutant monitoring (CEMS, COMS, or PEMS), or control device parametric monitoring. These records shall be made readily accessible and available as required by 30 TAC 122.144. Any monitoring or recordkeeping data indicating noncompliance with the PBR or Standard Permit shall be considered and reported as a deviation according to 30 TAC 122.145 (Reporting Terms and Conditions). Compliance Requirements 22. The permit holder shall certify compliance in accordance with 30 TAC 122.146. The permit holder shall comply with 30 TAC 122.146 using at a minimum, but not limited to, the continuous or intermittent compliance method data from monitoring, recordkeeping, reporting, or testing required by the permit and any other credible evidence or information. The certification period may not exceed 12 months and the certification must be submitted within 30 days after the end of the period being certified. 23. Permit holder shall comply with the following 30 TAC Chapter 117 requirements: A. The permit holder shall comply with the compliance schedules and submit written notification to the TCEQ Executive Director as required in 30 TAC Chapter 117, Subchapter H, Division 1: (i) For sources in the Beaumont-Port Arthur Nonattainment area, 30 TAC 117.9000 B. The permit holder shall comply with the Initial Control Plan unit listing requirement in 30 TAC 117.150(c) and (c)(1). 24. Use of Emission Credits to comply with applicable requirements: A. Unless otherwise prohibited, the permit holder may use emission credits to comply with the following applicable requirements listed elsewhere in this permit: (i) Title 30 TAC Chapter 115 (ii) Title 30 TAC Chapter 117 (iii) Offsets for Title 30 TAC Chapter 116 B. The permit holder shall comply with the following requirements in order to use the emission credits to comply with the applicable requirements: NEICVP1446E01 Appendix N Page 15 of 148 Renewal- Effective Page 13 Indorama Ventures Oxides LLC Port Neches, Texas (i) The permit holder must notify the TCEQ according to 30 TAC 101.306(c)(2) (ii) The emission credits to be used must meet all the geographic, timeliness, applicable pollutant type, and availability requirements listed in 30 TAC Chapter 101, Subchapter H, Division 1 (iii) The executive director has approved the use of the credit according to 30 TAC 101.306(c)(2) (iv) The permit holder keeps records of the use of credits towards compliance with the applicable requirements in accordance with 30 TAC 101.302(g) and 30 TAC Chapter 122 (v) Title 30 TAC 101.305 (relating to Emission Reductions Achieved Outside the United States) 25. Use of Discrete Emission Credits to comply with the applicable requirements: A. Unless otherwise prohibited, the permit holder may use discrete emission credits to comply with the following applicable requirements listed elsewhere in this permit: (i) Title 30 TAC Chapter 115 (ii) Title 30 TAC Chapter 117 (iii) If applicable, offsets for Title 30 TAC Chapter 116 (iv) Temporarily exceed state NSR permit allowables B. The permit holder shall comply with the following requirements in order to use the credit to comply with the applicable requirements: (i) The permit holder must notify the TCEQ according to 30 TAC 101.376(d) (ii) The discrete emission credits to be used must meet all the geographic, timeliness, applicable pollutant type, and availability requirements listed in 30 TAC Chapter 101, Subchapter H, Division 4 (iii) The executive director has approved the use of the discrete emission credits according to 30 TAC 101.376(d)(1)(A) (iv) The permit holder keeps records of the use of credits towards compliance with the applicable requirements in accordance with 30 TAC 101.372(h) and 30 TAC Chapter 122 (v) Title 30 TAC 101.375 (relating to Emission Reductions Achieved Outside the United States) Risk Management Plan 26. For processes subject to 40 CFR Part 68 and specified in 40 CFR 68.10, the permit holder shall comply with the requirements of the Accidental Release Prevention Provisions in 40 CFR Part 68. The permit holder shall submit to the appropriate agency either a compliance schedule for meeting the requirements of 40 CFR Part 68 by the date provided in 40 CFR 68.10(a), or as part of the compliance certification submitted under this permit, a certification statement that the NEICVP1446E01 Appendix N Page 16 of 148 Renewal- Effective Page 14 Indorama Ventures Oxides LLC Port Neches, Texas source is in compliance with all requirements of 40 CFR Part 68, including the registration and submission of a risk management plan. Protection of Stratospheric Ozone 27. Permit holders at a site subject to Title VI of the FCAA Amendments shall meet the following requirements for protection of stratospheric ozone: A. Any on site servicing, maintenance, and repair on refrigeration and nonmotor vehicle air- conditioning appliances using ozone-depleting refrigerants or non-exempt substitutes shall be conducted in accordance with 40 CFR Part 82, Subpart F. Permit holders shall ensure that repairs on or refrigerant removal from refrigeration and nonmotor vehicle air- conditioning appliances using ozone-depleting refrigerants are performed only by properly certified technicians using certified equipment. Records shall be maintained as required by 40 CFR Part 82, Subpart F. B. The permit holder shall comply with 40 CFR Part 82, Subpart H related to Halon Emissions Reduction requirements as specified in 40 CFR 82.250 - 82.270 and the applicable Part 82 Appendices. Permit Location 28. The permit holder shall maintain a copy of this permit and records related to requirements listed in this permit on site. Permit Shield (30 TAC 122.148) 29. A permit shield is granted for the emission units, groups, or processes specified in the attached "Permit Shield." Compliance with the conditions of the permit shall be deemed compliance with the specified potentially applicable requirements or specified potentially applicable state-only requirements listed in the attachment "Permit Shield." Permit shield provisions shall not be modified by the executive director until notification is provided to the permit holder. No later than 90 days after notification of a change in a determination made by the executive director, the permit holder shall apply for the appropriate permit revision to reflect the new determination. Provisional terms are not eligible for this permit shield. Any term or condition, under a permit shield, shall not be protected by the permit shield if it is replaced by a provisional term or condition or the basis of the term and condition changes. NEICVP1446E01 Appendix N Page 17 of 148 Renewal- Effective Page 15 Indorama Ventures Oxides LLC Port Neches, Texas Attachments Applicable Requirements Summary Additional Monitoring Requirements Permit Shield New Source Review Authorization References NEICVP1446E01 Appendix N Page 18 of 148 Renewal- Effective Page 16 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Summary ............................................................................................................................................ 18 Applicable Requirements Summary ...................................................................................................... 31 Note: A "none" entry may be noted for some emission sources in this permit's "Applicable Requirements Summary" under the heading of "Monitoring and Testing Requirements" and/or "Recordkeeping Requirements" and/or "Reporting Requirements." Such a notation indicates that there are no requirements for the indicated emission source as identified under the respective column heading(s) for the stated portion of the regulation when the emission source is operating under the conditions of the specified SOP Index Number. However, other relevant requirements pursuant to 30 TAC Chapter 122 including Recordkeeping Terms and Conditions (30 TAC 122.144), Reporting Terms and Conditions (30 TAC 122.145), and Compliance Certification Terms and Conditions (30 TAC 122.146) continue to apply. NEICVP1446E01 Appendix N Page 19 of 148 Renewal- Effective Page 17 Indorama Ventures Oxides LLC Port Neches, Texas Unit Summary Unit/Group/ Process ID No. A3CA31A A3CA31A A3FA3103 A3FA3103 A3FA3103 A3FA3205A A3FA3205B A3FA357 A3FO11 A3FUG A3FUG Unit Type STATIONARY TURBINES Group/Inclusive Units N/A STATIONARY TURBINES N/A EMISSION N/A POINTS/STATIONARY VENTS/PROCESS VENTS DISTILLATION N/A OPERATIONS DISTILLATION N/A OPERATIONS EMISSION N/A POINTS/STATIONARY VENTS/PROCESS VENTS EMISSION N/A POINTS/STATIONARY VENTS/PROCESS VENTS EMISSION N/A POINTS/STATIONARY VENTS/PROCESS VENTS EMISSION N/A POINTS/STATIONARY VENTS/PROCESS VENTS FUGITIVE EMISSION N/A UNITS FUGITIVE EMISSION N/A SOP Index No. R7ICI1101X 60GG-005Y R5121-3 60NNN-047 60NNN-048 R5121-6 R5121-6 R5121-6 R5121-6 R5352-ALL 61V-ALL Regulation Requirement Driver 30 TAC Chapter 117, Subchapter B No changing attributes. 40 CFR Part 60, Subpart GG No changing attributes. 30 TAC Chapter 115, Vent Gas Controls No changing attributes. 40 CFR Part 60, Subpart NNN 40 CFR Part 60, Subpart NNN 30 TAC Chapter 115, Vent Gas Controls Subpart NNN Control Device = Boiler or process heater design heat input capacity less than 44 MW (150 MMBtu/hr). Subpart NNN Control Device = Boiler or process heater design heat input capacity greater than or equal to 44 MW (150 MMBtu/hr). No changing attributes. 30 TAC Chapter 115, Vent Gas Controls No changing attributes. 30 TAC Chapter 115, Vent Gas Controls No changing attributes. 30 TAC Chapter 115, Vent Gas Controls No changing attributes. 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 40 CFR Part 61, Subpart V No changing attributes. No changing attributes. NEICVP1446E01 Appendix N Page 20 of 148 Renewal- Effective Page 18 Indorama Ventures Oxides LLC Port Neches, Texas Unit Summary Unit/Group/ Process ID No. A3FUG A3FUG A3HA35 A3TA329 A3TA339 A3TA346 A3WASTE CG1 CG1 CG2 CG2 CT-1 CT-4 FDU-1 Unit Type UNITS FUGITIVE EMISSION UNITS FUGITIVE EMISSION UNITS BOILERS/STEAM GENERATORS/STEAM GENERATING UNITS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS CLOSED VENT SYSTEM AND CONTROL DEVICE STATIONARY TURBINES STATIONARY TURBINES STATIONARY TURBINES STATIONARY TURBINES INDUSTRIAL PROCESS COOLING TOWERS INDUSTRIAL PROCESS COOLING TOWERS STORAGE Group/Inclusive Units N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A SOP Index No. Regulation Requirement Driver 60VV-63YY 63YY-F R7ICI-606 R5112-020 R5112-005 R5112-027 63YY-W R7ICI1102X 60GG-006 R7ICI1102X 60GG-006 63YY-H 63YY-H R5112-00a 40 CFR Part 63, Subpart YY No changing attributes. 40 CFR Part 63, Subpart YY No changing attributes. 30 TAC Chapter 117, Subchapter B No changing attributes. 30 TAC Chapter 115, Storage of VOCs 30 TAC Chapter 115, Storage of VOCs 30 TAC Chapter 115, Storage of VOCs 40 CFR Part 63, Subpart YY No changing attributes. No changing attributes. No changing attributes. No changing attributes. 30 TAC Chapter 117, Subchapter B No changing attributes. 40 CFR Part 60, Subpart GG No changing attributes. 30 TAC Chapter 117, Subchapter B No changing attributes. 40 CFR Part 60, Subpart GG No changing attributes. 40 CFR Part 63, Subpart YY No changing attributes. 40 CFR Part 63, Subpart YY No changing attributes. 30 TAC Chapter 115, No changing attributes. NEICVP1446E01 Appendix N Page 21 of 148 Renewal- Effective Page 19 Indorama Ventures Oxides LLC Port Neches, Texas Unit Summary Unit/Group/ Process ID No. GRPA3PH1 Unit Type TANKS/VESSELS PROCESS HEATERS/FURNACES GRPA3PH1 PROCESS HEATERS/FURNACES GRPA3PH1 CLOSED VENT SYSTEM AND CONTROL DEVICE GRPUTIC1 GRPUTTK1 SRIC ENGINES STORAGE TANKS/VESSELS P-Q-108 SRIC ENGINES NEICVP1446E01 Group/Inclusive Units SOP Index No. A3HA31A, A3HA31B, A3HA31C, A3HA31D, A3HA31F, A3HA31G, A3HA31H, A3HA31J R7ICI-503 A3HA31A, A3HA31B, A3HA31C, A3HA31D, A3HA31F, A3HA31G, A3HA31H, A3HA31J 63DDDDD-63YY A3HA31A, A3HA31B, A3HA31C, A3HA31D, A3HA31E, A3HA31F, A3HA31G, A3HA31H, A3HA31J 63YY PU-10, PU-14A, PU- 63ZZZZ 14B 880789, 961010, A3FA3215, MCST-3, R-CC-4T, R-S-42T, R-S-53T, T-L797455 R5112-00a N/A 117-EMERG Regulation Storage of VOCs 30 TAC Chapter 117, Subchapter B Requirement Driver No changing attributes. 40 CFR Part 63, Subpart DDDDD No changing attributes. 40 CFR Part 63, Subpart YY No changing attributes. 40 CFR Part 63, Subpart ZZZZ 30 TAC Chapter 115, Storage of VOCs No changing attributes. No changing attributes. 30 TAC Chapter 117, Subchapter B No changing attributes. Appendix N Page 22 of 148 Renewal- Effective Page 20 Indorama Ventures Oxides LLC Port Neches, Texas Unit Summary Unit/Group/ Process ID No. P-Q-108 Unit Type SRIC ENGINES PROA3WW TREATMENT PROCESS PROA3WW TREATMENT PROCESS Group/Inclusive Units N/A N/A N/A SOP Index No. 63ZZZZ 61FFTP-WW1a 61FFTP-WW1b Regulation Requirement Driver 40 CFR Part 63, Subpart ZZZZ 40 CFR Part 61, Subpart FF 40 CFR Part 61, Subpart FF No changing attributes. Fuel Gas System = All gaseous vent streams from the treatment process or wastewater treatment system are routed to a fuel gas system. Less Than Atmospheric = A cover and closed-vent system are operated such that the treatment process or wastewater system unit is maintained at ambient atmospheric pressure., Closed-Vent System and Control Device = A closed-vent system and control device is used., AMOC = No alternate means of compliance (AMOC) to meet the requirements of 40 CFR 61.349 for a closed-vent system and control device is used., By-Pass Line = The closed-vent system contains a by-pass line that could divert the vent stream away from the control device., By-Pass Line Valve = A car-seal or lock and key configuration is used to secure the by-pass line valve in the closed position., Control Device Type/Operation = Flare., Fuel Gas System = Not all gaseous vent streams from the treatment process or wastewater treatment system are routed to a fuel gas system. NEICVP1446E01 Appendix N Page 23 of 148 Renewal- Effective Page 21 Indorama Ventures Oxides LLC Port Neches, Texas Unit/Group/ Process ID No. PRORSHON PU-11 Unit Type CHEMICAL MANUFACTURING PROCESS SRIC ENGINES PU-11 SRIC ENGINES R-CC-4 SRIC ENGINES R-CC-4 SRIC ENGINES R-S-42 SRIC ENGINES R-S-42 SRIC ENGINES R-S-53 SRIC ENGINES RRFUG LOADING/UNLOADING OPERATIONS RSELRTRKW LOADING/UNLOADING OPERATIONS NEICVP1446E01 Unit Summary Group/Inclusive Units N/A SOP Index No. Regulation 63F-002 40 CFR Part 63, Subpart F Requirement Driver No changing attributes. N/A 117-EMERG 30 TAC Chapter 117, No changing attributes. Subchapter B N/A 63ZZZZ 40 CFR Part 63, Subpart No changing attributes. ZZZZ N/A 117-EMERG 30 TAC Chapter 117, No changing attributes. Subchapter B N/A 63ZZZZ 40 CFR Part 63, Subpart No changing attributes. ZZZZ N/A 117-EMERG 30 TAC Chapter 117, No changing attributes. Subchapter B N/A 63ZZZZ 40 CFR Part 63, Subpart No changing attributes. ZZZZ N/A 117-EMERG 30 TAC Chapter 117, No changing attributes. Subchapter B N/A R5211-018 30 TAC Chapter 115, No changing attributes. Loading and Unloading of VOC N/A R5211-00c 30 TAC Chapter 115, True Vapor Pressure = True vapor Loading and Unloading of pressure greater than or equal to VOC 0.5 psia., Daily Throughput = Loading greater than or equal to 20,000 gallons per day., Chapter 115 Control Device Type = No control device., Control Options = Vapor balance system., Vapor Tight = Not all liquid and vapor lines are equipped with fittings which make Appendix N Page 24 of 148 Renewal- Effective Page 22 Indorama Ventures Oxides LLC Port Neches, Texas Unit/Group/ Process ID No. Unit Type RSELRTRKW RSELRTRKW RSELRTRKW RSELRVNTTW RSET010 RSET010 RSET0126 RSET0126 LOADING/UNLOADING OPERATIONS LOADING/UNLOADING OPERATIONS LOADING/UNLOADING OPERATIONS LOADING/UNLOADING OPERATIONS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS RSET0126 STORAGE TANKS/VESSELS RSET0126 STORAGE TANKS/VESSELS NEICVP1446E01 Unit Summary Group/Inclusive Units N/A N/A SOP Index No. R5211-018 63GL-0g2a Regulation 30 TAC Chapter 115, Loading and Unloading of VOC 40 CFR Part 63, Subpart G Requirement Driver vapor-tight connections that close automatically when disconnected. True Vapor Pressure = True vapor pressure less than 0.5 psia. No changing attributes. N/A 63YY-L 40 CFR Part 63, Subpart YY No changing attributes. N/A R5211-018 30 TAC Chapter 115, No changing attributes. Loading and Unloading of VOC N/A R5112-062 30 TAC Chapter 115, No changing attributes. Storage of VOCs N/A 63GT-036 40 CFR Part 63, Subpart G No changing attributes. N/A R5112-050 30 TAC Chapter 115, True Vapor Pressure = True vapor Storage of VOCs pressure is less than 1.0 psia N/A R5112-052 30 TAC Chapter 115, True Vapor Pressure = True vapor Storage of VOCs pressure is greater than or equal to 1.5 psia, Control Device Type = Flare N/A R5112-055 30 TAC Chapter 115, True Vapor Pressure = True vapor Storage of VOCs pressure is greater than or equal to 1.5 psia, Control Device Type = Other vapor recovery unit N/A 61FF-T02a 40 CFR Part 61, Subpart FF Bypass Line = The closed vent system contains any by-pass line that could divert the vent stream Appendix N Page 25 of 148 Renewal- Effective Page 23 Indorama Ventures Oxides LLC Port Neches, Texas Unit/Group/ Process ID No. Unit Type RSET0126 STORAGE TANKS/VESSELS RSET0126 RSET0127 RSET0127 STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS NEICVP1446E01 Unit Summary Group/Inclusive Units N/A N/A SOP Index No. 61FF-T03a 63YY-T Regulation Requirement Driver 40 CFR Part 61, Subpart FF 40 CFR Part 63, Subpart YY away from the control device., Bypass Line Valve = A car-seal or lock and key configuration are used to secure the by-pass line valve in the closed position., Control Device Type/Operation = Flare Bypass Line = The closed vent system does not contain any bypass line that could divert the vent stream away from the control device., Engineering Calculations = Engineering calculations show that the control device is proven to achieve its emission limitation., Control Device Type/Operation = Carbon adsorption system that does not regenerate the carbon bed directly in the control device, Alternate Monitoring Parameters = Alternate monitoring parameters not requested, Carbon Replacement Interval = The carbon in the carbon adsorption system is replaced when monitoring indicates breakthrough. No changing attributes. N/A R5112-050 30 TAC Chapter 115, True Vapor Pressure = True vapor Storage of VOCs pressure is less than 1.0 psia N/A R5112-052 30 TAC Chapter 115, True Vapor Pressure = True vapor Storage of VOCs pressure is greater than or equal to 1.5 psia, Control Device Type = Flare Appendix N Page 26 of 148 Renewal- Effective Page 24 Indorama Ventures Oxides LLC Port Neches, Texas Unit/Group/ Process ID No. RSET0127 RSET0127 RSET0180 RSET0180 RSET0204 RSET0204 RSET030 RSET030 RSET039 RSET040 RSET087 Unit Type STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS RSET087 RSET087 STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS NEICVP1446E01 Unit Summary Group/Inclusive Units N/A SOP Index No. 61FF-T02a Regulation Requirement Driver 40 CFR Part 61, Subpart FF No changing attributes. N/A 63YY-T 40 CFR Part 63, Subpart YY No changing attributes. N/A R5112-062 30 TAC Chapter 115, No changing attributes. Storage of VOCs N/A 63GT-036 40 CFR Part 63, Subpart G No changing attributes. N/A R5112-062 30 TAC Chapter 115, No changing attributes. Storage of VOCs N/A 63GT-036 40 CFR Part 63, Subpart G No changing attributes. N/A R5112-062 30 TAC Chapter 115, No changing attributes. Storage of VOCs N/A 63GT-036 40 CFR Part 63, Subpart G No changing attributes. N/A R5112-067 30 TAC Chapter 115, No changing attributes. Storage of VOCs N/A R5112-067 30 TAC Chapter 115, No changing attributes. Storage of VOCs N/A R5112-052 30 TAC Chapter 115, Tank Description = Tank using a Storage of VOCs vapor recovery system (VRS), Control Device Type = Flare N/A R5112-069 30 TAC Chapter 115, Tank Description = Tank using an Storage of VOCs internal floating roof (IFR) N/A 60Kb-33 40 CFR Part 60, Subpart Kb Storage Vessel Description = Fixed roof with an internal floating roof using a mechanical shoe seal Appendix N Page 27 of 148 Renewal- Effective Page 25 Indorama Ventures Oxides LLC Port Neches, Texas Unit/Group/ Process ID No. RSET087 Unit Type STORAGE TANKS/VESSELS RSET087 STORAGE TANKS/VESSELS NEICVP1446E01 Unit Summary Group/Inclusive Units N/A N/A SOP Index No. 60Kb-36 61FF-T02a Appendix N Page 28 of 148 Regulation Requirement Driver 40 CFR Part 60, Subpart Kb 40 CFR Part 61, Subpart FF Storage Vessel Description = Closed vent system (CVS) with a flare used as the control device (fixed roof) Alternative Standard for Tanks = The tank is not complying with the alternative standards in 40 CFR 61.351., Alternative Means of Compliance = Not using an alternate means of compliance to meet the requirements of 40 CFR 61.343 for tanks., Cover and Closed Vent = The cover and closed vent system are not operated such that the tank is maintained at a pressure less than atmospheric pressure and meets the conditions of 40 CFR 61.343(a)(1)(i)(C)(1)(3)., Bypass Line = The closed vent system contains any by-pass line that could divert the vent stream away from the control device., Bypass Line Valve = A car-seal or lock and key configuration are used to secure the by-pass line valve in the closed position., Control Device Type/Operation = Flare, Tank Control Requirements = The tank has a fixed roof and closed vent system routing vapors to either a fuel gas system or control device., Fuel Gas System = Gaseous emissions from the tank or enclosure are not routed to a fuel gas system. Renewal- Effective Page 26 Indorama Ventures Oxides LLC Port Neches, Texas Unit/Group/ Process ID No. RSET087 Unit Type STORAGE TANKS/VESSELS RSET087 RSET088 RSET088 RSET088 RSET088 RSET088 STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS STORAGE TANKS/VESSELS NEICVP1446E01 Unit Summary Group/Inclusive Units N/A N/A SOP Index No. 61FF-T04a 63YY-T Regulation Requirement Driver 40 CFR Part 61, Subpart FF 40 CFR Part 63, Subpart YY Alternative Standard for Tanks = The tank is complying with the alternative standards in 40 CFR 61.351., Kb Tank Type = Using a fixed roof and internal floating roof, that meets the requirements of 40 CFR 60.112b(a)(1), Seal Type = Mechanical shoe seal No changing attributes. N/A R5112-052 30 TAC Chapter 115, Tank Description = Tank using a Storage of VOCs vapor recovery system (VRS), Control Device Type = Flare N/A R5112-069 30 TAC Chapter 115, Tank Description = Tank using an Storage of VOCs internal floating roof (IFR) N/A 60Kb-33 40 CFR Part 60, Subpart Kb Storage Vessel Description = Fixed roof with an internal floating roof using a mechanical shoe seal N/A 60Kb-36 40 CFR Part 60, Subpart Kb Storage Vessel Description = Closed vent system (CVS) with a flare used as the control device (fixed roof) N/A 61FF-T02a 40 CFR Part 61, Subpart FF Alternative Standard for Tanks = The tank is not complying with the alternative standards in 40 CFR 61.351., Alternative Means of Compliance = Not using an alternate means of compliance to meet the requirements of 40 CFR 61.343 for tanks., Cover and Closed Vent = The cover and Appendix N Page 29 of 148 Renewal- Effective Page 27 Indorama Ventures Oxides LLC Port Neches, Texas Unit/Group/ Process ID No. Unit Type RSET088 STORAGE TANKS/VESSELS RSET088 STORAGE TANKS/VESSELS NEICVP1446E01 Unit Summary Group/Inclusive Units N/A N/A SOP Index No. 61FF-T04a 63YY-T Regulation Requirement Driver 40 CFR Part 61, Subpart FF 40 CFR Part 63, Subpart YY closed vent system are not operated such that the tank is maintained at a pressure less than atmospheric pressure and meets the conditions of 40 CFR 61.343(a)(1)(i)(C)(1)(3)., Bypass Line = The closed vent system contains any by-pass line that could divert the vent stream away from the control device., Bypass Line Valve = A car-seal or lock and key configuration are used to secure the by-pass line valve in the closed position., Control Device Type/Operation = Flare, Tank Control Requirements = The tank has a fixed roof and closed vent system routing vapors to either a fuel gas system or control device., Fuel Gas System = Gaseous emissions from the tank or enclosure are not routed to a fuel gas system. Alternative Standard for Tanks = The tank is complying with the alternative standards in 40 CFR 61.351., Kb Tank Type = Using a fixed roof and internal floating roof, that meets the requirements of 40 CFR 60.112b(a)(1), Seal Type = Mechanical shoe seal No changing attributes. Appendix N Page 30 of 148 Renewal- Effective Page 28 Indorama Ventures Oxides LLC Port Neches, Texas Unit/Group/ Process ID No. RSETFUG RSETFUG RSETFUG RSETQ142 UEHK10 UEHK10 UEHK11 UEHK11 UEHK9 UEHK9 UER037 Unit Type FUGITIVE EMISSION UNITS FUGITIVE EMISSION UNITS FUGITIVE EMISSION UNITS STORAGE TANKS/VESSELS BOILERS/STEAM GENERATORS/STEAM GENERATING UNITS BOILERS/STEAM GENERATORS/STEAM GENERATING UNITS BOILERS/STEAM GENERATORS/STEAM GENERATING UNITS BOILERS/STEAM GENERATORS/STEAM GENERATING UNITS BOILERS/STEAM GENERATORS/STEAM GENERATING UNITS BOILERS/STEAM GENERATORS/STEAM GENERATING UNITS FLARES UER037 FLARES NEICVP1446E01 Unit Summary Group/Inclusive Units N/A N/A SOP Index No. Regulation R5352-ALL 61V-ALL 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 40 CFR Part 61, Subpart V Requirement Driver No changing attributes. No changing attributes. N/A 63H-ALL 40 CFR Part 63, Subpart H No changing attributes. N/A R5112-003 30 TAC Chapter 115, No changing attributes. Storage of VOCs N/A R7ICI-607 30 TAC Chapter 117, No changing attributes. Subchapter B N/A 60Db-005 40 CFR Part 60, Subpart Db No changing attributes. N/A 60Db-002x 40 CFR Part 60, Subpart Db No changing attributes. N/A 63DDDDD 40 CFR Part 63, Subpart No changing attributes. DDDDD N/A R7ICI-607 30 TAC Chapter 117, No changing attributes. Subchapter B N/A 60Db-005 40 CFR Part 60, Subpart Db No changing attributes. N/A R1111-002 30 TAC Chapter 111, Visible No changing attributes. Emissions N/A 60A-003 40 CFR Part 60, Subpart A No changing attributes. Appendix N Page 31 of 148 Renewal- Effective Page 29 Indorama Ventures Oxides LLC Port Neches, Texas Unit/Group/ Process ID No. UER044 Unit Type FLARES UER044 UER046 FLARES FLARES UER046 FLARES Unit Summary Group/Inclusive Units N/A N/A N/A N/A SOP Index No. R1111-002 60A-003 R1111-002 60A-003 Regulation Requirement Driver 30 TAC Chapter 111, Visible Emissions 40 CFR Part 60, Subpart A 30 TAC Chapter 111, Visible Emissions 40 CFR Part 60, Subpart A No changing attributes. No changing attributes. No changing attributes. No changing attributes. NEICVP1446E01 Appendix N Page 32 of 148 Renewal- Effective Page 30 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. A3CA31A Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name EU R7ICI110 CO 1X 30 TAC Chapter 117, Subchapter B Emission Limitation, Standard or Equipment Specification Citation 117.105(c) 117.105(a) 117.130(a) 117.140(k) A3CA31A EU R7ICI110 NOX 1X 30 TAC Chapter 117, Subchapter B 117.105(c) 117.105(a) 117.130(a) 117.130(d) 117.130(d)(4) 117.140(k) 117.140(l) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements No person shall allow the discharge into the atmosphere from any stationary gas turbine with a megawatt (MW) rating greater than or equal to 10.0 MW, emissions in excess of a block one-hour average concentration of 132 ppmv carbon monoxide (CO) at 15% oxygen, dry basis. For stationary gas turbines equipped with CEMS or PEMS for CO, the owner or operator may elect to comply with the CO specification of this subsection using a 24-hour rolling average. [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(d) 117.135(e) 117.135(g) 117.140(a) [G] 117.140(h)(2) 117.8000(b) 117.8000(c) 117.8000(c)(2) 117.8000(c)(3) 117.8000(c)(5) 117.8000(c)(6) [G] 117.8000(d) No person shall allow the discharge into the atmosphere from any stationary gas turbine with a MW rating greater than or equal to 10.0 MW, emissions in excess of a block one-hour average concentration of 42 ppmv NOx at 15% oxygen, dry basis. [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(d) 117.135(e) 117.135(g) 117.140(a) 117.140(c)(1) [G] 117.140(c)(3) 117.8000(b) 117.8000(c) 117.8000(c)(1) 117.8000(c)(3) 117.8000(c)(5) 117.8000(c)(6) [G] 117.8000(d) Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 117.145(a) 117.145(f) 117.145(f)(1) [G] 117.145(f)(4) 117.145(f)(8) 117.145(f)(9) 117.145(a) 117.145(f) 117.145(f)(1) 117.145(f)(8) 117.145(f)(9) 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.145(d) 117.145(d)(1) 117.145(d)(1)(A) 117.145(d)(2) 117.145(d)(3) 117.145(d)(4) 117.145(d)(5) 117.8010 [G] 117.8010(1) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) [G] 117.8010(3) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.145(d) 117.145(d)(1) 117.145(d)(2) 117.145(d)(3) 117.145(d)(4) 117.145(d)(5) 117.8010 [G] 117.8010(1) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) 117.8010(2)(C) 117.8010(2)(D) [G] 117.8010(3) NEICVP1446E01 Appendix N Page 33 of 148 Renewal- Effective Page 31 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation A3CA31A EU A3FA3103 EP 60GG- SO2 005Y R5121-3 VOC 40 CFR Part 60, 60.333(b) Subpart GG 30 TAC Chapter 115, Vent Gas Controls 115.122(a)(2) 115.121(a)(2) 115.122(a)(2)(B) A3FA3103 EP 60NNN047 VOC/TOC 40 CFR Part 60, Subpart NNN 60.662(a) A3FA3103 EP 60NNN048 VOC/TOC 40 CFR Part 60, Subpart NNN 60.662(a) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) No stationary gas turbine shall burn any fuel which contains sulfur in excess of 0.8% by weight. Any vent gas streams affected by 115.121(a)(2) of this title must be controlled properly with a control efficiency of at least 98% or to a VOC concentration of no more than 20 ppmv (on a dry basis corrected to 3.0% oxygen for combustion devices). Affected facilities shall reduce TOC emissions by 98 weight-percent or to a concentration of 20ppmv, whichever is less stringent. Introduce the stream into the flame zone of a boiler/process heater. Affected facilities shall reduce TOC emissions by 98 weight-percent or to a concentration of 20ppmv, whichever is less stringent. Introduce the stream into the flame zone of a 60.334(h) [G] 60.334(h)(3) [G] 115.125 115.126(1) 115.126(1)(C) 115.126(2) ** See Periodic Monitoring Summary 60.663(c) 60.664(a) 60.664(b) 60.664(b)(1) 60.664(b)(2) 60.664(b)(3) [G] 60.664(b)(4) 60.703(c)(1) 60.703(c)(1)(i) 60.703(c)(1)(ii) 60.703(c)(2) 60.663(c) 60.663(c)(2) 60.664(c) 60.703(c)(1) 60.703(c)(1)(i) 60.703(c)(1)(ii) None 115.126 115.126(1) 115.126(1)(C) 115.126(2) 60.665(b) 60.665(b)(2) 60.665(b)(2)(i) 60.665(c) 60.665(c)(4) 60.703(c)(1) 60.703(c)(1)(i) 60.703(c)(1)(ii) 60.703(c)(2) 60.705(d)(1) 60.705(d)(2) 60.663(c)(2) 60.665(b) 60.665(b)(2) 60.665(b)(2)(i) 60.665(c) 60.665(c)(4) 60.703(c)(1) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) None None 60.665(a) 60.665(b) 60.665(b)(2) 60.665(b)(2)(i) 60.665(c) 60.665(c)(4) 60.665(k) 60.665(l) 60.665(l)(1) 60.705(l)(2) 60.705(l)(7) 60.665(a) 60.665(b) 60.665(b)(2) 60.665(b)(2)(i) 60.665(c) 60.665(c)(4) 60.665(k) NEICVP1446E01 Appendix N Page 34 of 148 Renewal- Effective Page 32 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation A3FA3205A EP R5121-6 VOC 30 TAC Chapter 115, Vent Gas Controls 115.122(a)(1) 115.121(a)(1) 115.122(a)(1)(C) A3FA3205B EP R5121-6 VOC 30 TAC Chapter 115, Vent Gas Controls 115.122(a)(1) 115.121(a)(1) 115.122(a)(1)(C) A3FA357 EP R5121-6 VOC 30 TAC Chapter 115, Vent Gas Controls 115.122(a)(1) 115.121(a)(1) 115.122(a)(1)(C) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) boiler/process heater. Vent gas streams affected by 115.121(a)(1) must be controlled properly with a control efficiency of at least 90% or to a volatile organic compound (VOC) concentration of no more than 20 parts per million (ppmv) (on a dry basis corrected to 3.0% oxygen for combustion devices). Vent gas streams affected by 115.121(a)(1) must be controlled properly with a control efficiency of at least 90% or to a volatile organic compound (VOC) concentration of no more than 20 parts per million (ppmv) (on a dry basis corrected to 3.0% oxygen for combustion devices). Vent gas streams affected by 115.121(a)(1) must be controlled properly with a control efficiency of at least 90% or to a volatile organic compound (VOC) concentration of no more than 20 parts per million (ppmv) (on a dry basis corrected to 3.0% oxygen for combustion devices). [G] 115.125 115.126(1) 115.126(1)(C) 115.126(2) ** See Periodic Monitoring Summary [G] 115.125 115.126(1) 115.126(1)(C) 115.126(2) ** See Periodic Monitoring Summary [G] 115.125 115.126(1) 115.126(1)(C) 115.126(2) ** See Periodic Monitoring Summary 60.703(c)(1)(i) 60.703(c)(1)(ii) 60.705(d)(1) 60.705(d)(2) 115.126 115.126(1) 115.126(1)(C) 115.126(2) 115.126 115.126(1) 115.126(1)(C) 115.126(2) 115.126 115.126(1) 115.126(1)(C) 115.126(2) 60.665(l) 60.665(l)(1) 60.705(l)(2) 60.705(l)(7) None None None NEICVP1446E01 Appendix N Page 35 of 148 Renewal- Effective Page 33 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. A3FO11 Unit Group Process Type SOP Index No. EP R5121-6 Pollutant State Rule or Federal Regulation Name VOC 30 TAC Chapter 115, Vent Gas Controls Emission Limitation, Standard or Equipment Specification Citation 115.122(a)(1) 115.121(a)(1) 115.122(a)(1)(C) A3FUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(3) 115.352(7) 115.357(1) A3FUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(3) 115.352(7) A3FUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & 115.352(1)(A) 115.352(1) 115.352(10) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Vent gas streams affected by 115.121(a)(1) must be controlled properly with a control efficiency of at least 90% or to a volatile organic compound (VOC) concentration of no more than 20 parts per million (ppmv) (on a dry basis corrected to 3.0% oxygen for combustion devices). No process drains shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. No process drains shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. No pressure relief valves shall be allowed to have a VOC leak, for more than 15 [G] 115.125 115.126(1) 115.126(1)(C) 115.126(2) ** See Periodic Monitoring Summary 115.354(1) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) 115.354(1) 115.354(10) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.354(1) 115.354(2) 115.354(4) NEICVP1446E01 Appendix N Page 36 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.126 115.126(1) 115.126(1)(C) 115.126(2) None 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) 115.356(5) None 115.352(7) 115.356 [G] 115.356(1) [G] 115.354(7) Renewal- Effective Page 34 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. A3FUG A3FUG A3FUG Unit Group Process Type SOP Index No. EU R5352- ALL EU R5352- ALL EU R5352- Pollutant State Rule or Federal Regulation Name Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter Emission Limitation, Standard or Equipment Specification Citation 115.352(2) 115.352(2)(A) 115.352(2)(B) 115.352(3) 115.352(5) 115.352(7) 115.352(9) 115.357(1) 115.357(8) 115.357(9) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(B) 115.352(3) 115.352(5) 115.352(7) 115.352(9) 115.357(12) 115.357(8) 115.357(9) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(B) 115.352(3) 115.352(4) 115.352(5) 115.352(6) 115.352(7) 115.357(1) 115.357(8) 115.357(9) 115.352(1)(A) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(5) 115.354(6) [G] 115.354(7) 115.354(9) [G] 115.355 115.357(1) No pressure relief valves shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(10) 115.354(2) 115.354(4) 115.354(5) 115.354(6) [G] 115.354(7) 115.354(9) [G] 115.355 No open-ended valves or lines shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(2) 115.354(5) 115.354(6) [G] 115.354(7) 115.354(9) [G] 115.355 115.357(1) No open-ended valves or 115.354(1) NEICVP1446E01 Appendix N Page 37 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) [G] 115.354(7) 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) [G] 115.354(7) 115.352(7) [G] 115.354(7) Renewal- Effective Page 35 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. A3FUG A3FUG Unit Group Process Type SOP Index No. ALL EU R5352- ALL EU R5352- ALL Pollutant State Rule or Federal Regulation Name 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(B) 115.352(3) 115.352(4) 115.352(5) 115.352(6) 115.352(7) 115.357(12) 115.357(8) 115.357(9) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(B) 115.352(3) 115.352(4) 115.352(5) 115.352(6) 115.352(7) 115.357(1) 115.357(8) 115.357(9) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(B) 115.352(3) 115.352(4) 115.352(5) 115.352(6) 115.352(7) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements lines shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(10) 115.354(2) 115.354(5) 115.354(6) [G] 115.354(7) 115.354(9) [G] 115.355 No valves shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(2) 115.354(5) 115.354(6) [G] 115.354(7) 115.354(9) [G] 115.355 115.357(1) No valves shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(10) 115.354(2) 115.354(5) 115.354(6) [G] 115.354(7) 115.354(9) [G] 115.355 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) [G] 115.354(7) 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) [G] 115.354(7) NEICVP1446E01 Appendix N Page 38 of 148 Renewal- Effective Page 36 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. A3FUG A3FUG Unit Group Process Type SOP Index No. EU R5352- ALL EU R5352- ALL Pollutant State Rule or Federal Regulation Name VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.357(12) 115.357(8) 115.357(9) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(3) 115.352(5) 115.352(7) 115.352(8) 115.357(1) 115.357(12) 115.357(8) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(3) 115.352(5) 115.352(7) 115.352(8) 115.357(12) 115.357(8) A3FUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(7) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements No flanges or other connectors shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. No flanges or other connectors shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. No agitators shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or 115.354(1) 115.354(11) 115.354(3) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) 115.354(1) 115.354(10) 115.354(11) 115.354(3) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) 115.354(1) 115.354(10) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) NEICVP1446E01 Appendix N Page 39 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) None Renewal- Effective Page 37 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. A3FUG A3FUG A3FUG Unit Group Process Type SOP Index No. EU R5352- ALL EU R5352- ALL EU R5352- ALL Pollutant State Rule or Federal Regulation Name VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.357(1) 115.357(12) 115.357(8) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(7) 115.357(1) 115.357(12) 115.357(8) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(7) 115.357(12) 115.357(8) 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements sound. No agitators shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) No agitators shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(10) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) No compressor seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background [G] 115.355 NEICVP1446E01 Appendix N Page 40 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) None Renewal- Effective Page 38 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. A3FUG A3FUG A3FUG Unit Group Process Type SOP Index No. EU R5352- ALL EU R5352- ALL EU R5352- ALL Pollutant State Rule or Federal Regulation Name VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(3) 115.357(8) 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(4) 115.357(8) 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(1) 115.357(8) 115.352(1)(C) 115.352(1) 115.352(10) 115.352(2) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. No compressor seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. [G] 115.355 No compressor seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(2) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) No component shall be allowed to have a VOC leak, for more than 15 days, after discovery. If the owner 115.354(1) 115.354(11) 115.354(13)(A) 115.354(13)(B) NEICVP1446E01 Appendix N Page 41 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.354(13)(D) 115.354(13)(E) 115.356 [G] 115.358(g) Renewal- Effective Page 39 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. A3FUG A3FUG Unit Group Process Type SOP Index No. EU R5352- ALL EU R5352- ALL Pollutant State Rule or Federal Regulation Name VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.352(2)(A) 115.352(2)(B) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(4) 115.352(5) 115.352(6) 115.352(7) 115.352(8) 115.357(8) 115.358(c)(1) [G] 115.358(h) 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(12) 115.357(8) 115.357(13) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements or operator elects to use the alternative work practice in 115.358 of this title, any leak detected as defined in 115.358 of this title, including any leak detected using the alternative work practice on a component that is subject to the requirements of this division but not specifically selected for alternative work practice monitoring. 115.354(13)(C) 115.354(13)(D) 115.354(13)(E) 115.354(13)(F) 115.354(4) 115.354(5) 115.354(9) [G] 115.355 115.358(c)(2) 115.358(d) [G] 115.358(e) 115.358(f) No compressor seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(10) 115.354(2) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 Components/systems that contact a process fluid containing VOC having a true vapor pressure equal to or less than 0.002 psia at 68 degrees Fahrenheit are exempt from the requirements of this division except 115.356(3)(C) of None Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) [G] 115.356(4) 115.356(5) 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) None 115.356 115.356(3) [G] 115.356(3)(C) None NEICVP1446E01 Appendix N Page 42 of 148 Renewal- Effective Page 40 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation A3FUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.357(11) A3FUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.357(10) A3FUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.357(5) A3FUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.357(6) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements this title. Sampling connection systems, as defined in 40 CFR 63.161 (January 17, 1997), that meet the requirements of 40 CFR 63.166(a) and (b) (June 20, 1996) are exempt from the requirements of this division except 115.356(3)(C) of this title. None Instrumentation systems, as defined in 40 CFR 63.161 (January 17, 1997), that meet 40 CFR 63.169 (June 20, 1996) are exempt from the requirements of this division except 115.356(3)(C) of this title. None Reciprocating compressors and positive displacement pumps used in natural gas/gasoline processing operations are exempt from the requirements of this division except 115.356(3)(C) of this title. None Components at a petroleum refinery or synthetic organic chemical, polymer, resin, or methyl-tert-butyl ether manufacturing process, that contact a process fluid that contains less than 10% VOC by weight and components at a natural gas/gasoline processing None NEICVP1446E01 Appendix N Page 43 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.356 115.356(3) [G] 115.356(3)(C) None 115.356 115.356(3) [G] 115.356(3)(C) None 115.356 115.356(3) [G] 115.356(3)(C) None 115.356 115.356(3) [G] 115.356(3)(C) None Renewal- Effective Page 41 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation A3FUG EU A3FUG EU A3FUG EU R5352ALL VOC R5352ALL VOC R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 30 TAC Chapter 115, Pet. Refinery & 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(4) 115.357(8) 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(1) 115.357(8) 115.352(1)(B) 115.352(1) 115.352(10) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements operation that contact a process fluid that contains less than 1.0% VOC by weight are exempt from the requirements of this division except 115.356(3)(C) of this title. No pump seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. [G] 115.355 No pump seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(2) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) No pump seals shall be allowed to have a VOC leak, for more than 15 days 115.354(1) 115.354(10) 115.354(2) NEICVP1446E01 Appendix N Page 44 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.354(10) 115.356 None Renewal- Effective Page 42 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. A3FUG Unit Group Process Type SOP Index No. EU R5352- ALL Pollutant State Rule or Federal Regulation Name Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(12) 115.357(8) 115.357(2) 115.352(9) A3FUG EU 61V-ALL VHAP 40 CFR Part 61, Subpart V [G] 61.242-8 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 A3FUG EU 61V-ALL VHAP 40 CFR Part 61, Subpart V 61.242-9 61.242-1(a) 61.242-1(b) 61.242-1(d) A3FUG EU 61V-ALL VHAP 40 CFR Part 61, Subpart V [G] 61.242-8 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(5) 115.354(6) 115.354(9) [G] 115.355 Each pressure relief valve equipped with a rupture disk must comply with 115.352(9) and 115.356(3)(C). None Comply with standards for flanges and other connectors. 61.242-8(a)(d) [G] 61.242-8 [G] 61.245(b) [G] 61.245(c) [G] 61.245(d) Each product accumulator vessel shall be equipped with a closed-vent system to capture and transport any leakage from the vessel to a control device as in 61.242-11, except in 61.242-1(c). [G] 61.245(d) Comply with standards for pressure relief devices in liquid service. 61.2428(a)-(d) [G] 61.242-8 [G] 61.245(b) [G] 61.245(c) [G] 61.245(d) Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) 115.356 115.356(3) [G] 115.356(3)(C) None [G] 61.246(a) [G] 61.246(b) [G] 61.246(c) [G] 61.246(e) [G] 61.246(i) 61.246(j) [G] 61.246(a) [G] 61.246(e) [G] 61.246(i) 61.246(j) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) [G] 61.246(a) [G] 61.246(b) [G] 61.246(c) [G] 61.246(e) [G] 61.246(i) 61.246(j) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) NEICVP1446E01 Appendix N Page 45 of 148 Renewal- Effective Page 43 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. A3FUG Unit Group Process Type SOP Index No. EU 61V-ALL Pollutant State Rule or Federal Regulation Name VHAP 40 CFR Part 61, Subpart V Emission Limitation, Standard or Equipment Specification Citation [G] 61.242-7 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 [G] 61.243-1 [G] 61.243-2 A3FUG EU A3FUG EU A3FUG EU A3FUG EU 61V-ALL VHAP 61V-ALL VHAP 61V-ALL VHAP 61V-ALL VHAP 40 CFR Part 61, Subpart V 40 CFR Part 61, Subpart V 40 CFR Part 61, Subpart V 40 CFR Part 61, Subpart V [G] 61.242-6 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 [G] 61.242-5 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 [G] 61.242-4 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 [G] 61.242-3 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 A3FUG EU 61V-ALL VHAP 40 CFR Part 61, Subpart V 61.242-1(e) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Comply with standards for valves. 61.242-7(a)-(h) [G] 61.242-7 [G] 61.243-1 [G] 61.245(b) [G] 61.245(c) [G] 61.245(d) Comply with standards for open-ended valves or lines. 61.242-6(a)-(c) [G] 61.245(d) Comply with standards for sampling connection systems. 61.242-5(a)-(c) [G] 61.245(d) Comply with standards for pressure relief devices in gas/vapor service. 61.242-4(a)-(c) [G] 61.242-4 [G] 61.245(b) [G] 61.245(c) [G] 61.245(d) Comply with standards for compressors. 61.2423(a)-(i) [G] 61.242-3 [G] 61.245(b) [G] 61.245(c) [G] 61.245(d) Equipment that is in vacuum service is excluded from the requirements of 61.242-2 to 61.242-11, if it is identified as required in 61.246(e)(5). None Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) [G] 61.246(a) [G] 61.246(b) [G] 61.246(c) [G] 61.246(e) [G] 61.246(f) [G] 61.246(g) [G] 61.246(i) 61.246(j) [G] 61.246(a) [G] 61.246(e) [G] 61.246(i) 61.246(j) [G] 61.246(a) [G] 61.246(e) [G] 61.246(i) 61.246(j) [G] 61.246(a) [G] 61.246(e) [G] 61.246(i) 61.246(j) [G] 61.246(a) [G] 61.246(b) [G] 61.246(c) [G] 61.246(e) [G] 61.246(h) [G] 61.246(i) 61.246(j) [G] 61.246(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) 61.247(d) [G] 61.247(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) None NEICVP1446E01 Appendix N Page 46 of 148 Renewal- Effective Page 44 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. A3FUG A3FUG A3FUG A3HA35 Unit Group Process Type SOP Index No. EU 61V-ALL EU 60VV- 63YY EU 63YY-F EU R7ICI- 606 Pollutant State Rule or Federal Regulation Name VHAP 40 CFR Part 61, Subpart V 112(B) HAPS 40 CFR Part 63, Subpart YY 112(B) HAPS 40 CFR Part 63, Subpart YY CO 30 TAC Chapter 117, Subchapter B Emission Limitation, Standard or Equipment Specification Citation [G] 61.242-2 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 Textual Description (See Special Term and Condition 1.B.) Comply with standards for pumps. 61.242-2(a)-(g) 63.1103 The permit holder shall comply with the applicable limitation, standard and/or equipment specification requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart YY 63.1103 The permit holder shall comply with the applicable limitation, standard and/or equipment specification requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart YY 117.110(c)(1) 117.110(c) 117.110(c)(1)(A) 117.110(c)(3) No person shall allow the discharge into the atmosphere from any boiler subject to NOx emission specifications in 117.110(a) CO in excess of 400 ppmv at 3.0% oxygen, dry basis, except as provided in 117.125 or 117.110(c)(3). Monitoring And Testing Requirements Recordkeeping Requirements (30 TAC 122.144) [G] 61.242-2 [G] 61.245(b) [G] 61.245(c) [G] 61.245(d) [G] 61.246(a) [G] 61.246(b) [G] 61.246(c) [G] 61.246(e) [G] 61.246(h) [G] 61.246(i) 61.246(j) The permit holder shall comply with the applicable monitoring and testing requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable recordkeeping requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable monitoring and testing requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable recordkeeping requirements of 40 CFR Part 63, Subpart YY [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(c) 117.135(d) 117.135(f) 117.135(f)(3) 117.135(g) 117.140(a) 117.140(b)(1) 117.140(b)(3) 117.145(a) 117.145(f) 117.145(f)(1) [G] 117.145(f)(2) 117.145(f)(8) 117.145(f)(9) 117.8100(a)(5)(C) Reporting Requirements (30 TAC 122.145) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart YY 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.145(d) 117.145(d)(1) 117.145(d)(2) 117.145(d)(3) 117.145(d)(4) 117.145(d)(5) 117.8010 NEICVP1446E01 Appendix N Page 47 of 148 Renewal- Effective Page 45 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation A3HA35 EU R7ICI- NOX 606 30 TAC Chapter 117, Subchapter B 117.110(a)(1) 117.110(a) 117.110(b) [G] 117.110(b)(1) 117.130(d) 117.130(d)(1) 117.140(k) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) No person shall allow the discharge into the atmosphere from any gasfired boilers with a maximum rated capacity equal to or greater than 40 MMBtu emissions of NOx in excess of 0.10 lb/MMBtu of heat input. 117.140(e) 117.8100(a) 117.8100(a)(1) 117.8100(a)(1)(A) 117.8100(a)(1)(B) 117.8100(a)(1)(B)(ii) 117.8100(a)(1)(B)(iii) 117.8100(a)(1)(C) 117.8100(a)(2) [G] 117.8100(a)(3) 117.8100(a)(4) 117.8100(a)(5) 117.8100(a)(5)(A) 117.8100(a)(5)(B) [G] 117.8100(a)(5)(D) [G] 117.8100(a)(5)(E) 117.8100(a)(6) [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(c) 117.135(d) 117.135(f) 117.135(f)(2) 117.135(g) 117.140(a) 117.140(b)(1) 117.140(b)(3) 117.140(c)(1) [G] 117.140(c)(3) 117.140(e) 117.8100(a) 117.8100(a)(1) 117.8100(a)(1)(A) 117.8100(a)(1)(B) 117.8100(a)(1)(B)(i) 117.8100(a)(1)(B)(ii) 117.8100(a)(1)(C) 117.8100(a)(2) 117.145(a) 117.145(f) 117.145(f)(1) [G] 117.145(f)(2) 117.145(f)(8) 117.145(f)(9) 117.8100(a)(5)(C) [G] 117.8010(1) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) [G] 117.8010(3) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) [G] 117.8010(8) 117.8100(c) 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.145(d) 117.145(d)(1) 117.145(d)(2) 117.145(d)(3) 117.145(d)(4) 117.145(d)(5) 117.8010 [G] 117.8010(1) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) 117.8010(2)(C) 117.8010(2)(D) [G] 117.8010(3) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) NEICVP1446E01 Appendix N Page 48 of 148 Renewal- Effective Page 46 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. A3TA329 A3TA339 A3TA346 A3WASTE Unit Group Process Type SOP Index No. EU R5112- 020 EU R5112- 005 EU R5112- 027 EU 63YY-W Pollutant State Rule or Federal Regulation Name VOC 30 TAC Chapter 115, Storage of VOCs VOC 30 TAC Chapter 115, Storage of VOCs VOC 30 TAC Chapter 115, Storage of VOCs 112(B) HAPS 40 CFR Part 63, Subpart YY Emission Limitation, Standard or Equipment Specification Citation 115.111(a)(1) 115.112(a)(1) 115.111(a)(1) 63.1103 The permit holder shall comply with the applicable limitation, standard and/or equipment specification requirements of 40 Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) Except as provided in 115.118, a storage tank storing VOC with a true vapor pressure less than 1.5 psia is exempt from the requirements of this division. Tanks shall not store VOC unless the required pressure is maintained, or they are equipped with the appropriate control device specified in Table I(a) or Table II(a). Except as provided in 115.118, a storage tank storing VOC with a true vapor pressure less than 1.5 psia is exempt from the requirements of this division. The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart YY [G] 117.8100(a)(3) 117.8100(a)(4) 117.8100(a)(5) 117.8100(a)(5)(A) 117.8100(a)(5)(B) [G] 117.8100(a)(5)(D) [G] 117.8100(a)(5)(E) 117.8100(a)(6) [G] 115.117 115.118(a)(1) 115.118(a)(5) 115.118(a)(7) [G] 117.8010(8) 117.8100(c) None [G] 115.117 ** See Periodic Monitoring Summary 115.118(a)(5) 115.118(a)(7) None [G] 115.117 115.118(a)(1) 115.118(a)(5) 115.118(a)(7) None The permit holder shall comply with the applicable monitoring and testing requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable recordkeeping requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart YY NEICVP1446E01 Appendix N Page 49 of 148 Renewal- Effective Page 47 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. CG1 CG1 Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name EU R7ICI110 CO 2X 30 TAC Chapter 117, Subchapter B EU R7ICI110 NOX 30 TAC Chapter 2X 117, Subchapter B Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements (30 TAC 122.144) CFR Part 63, Subpart YY 117.105(c) 117.105(a) 117.130(a) 117.140(k) No person shall allow the discharge into the atmosphere from any stationary gas turbine with a megawatt (MW) rating greater than or equal to 10.0 MW, emissions in excess of a block one-hour average concentration of 132 ppmv carbon monoxide (CO) at 15% oxygen, dry basis. For stationary gas turbines equipped with CEMS or PEMS for CO, the owner or operator may elect to comply with the CO specification of this subsection using a 24-hour rolling average. [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(c) 117.135(d) 117.135(f) 117.135(f)(3) 117.135(g) 117.140(a)(2)(A) 117.140(d) 117.140(e) 117.8100(a) 117.8100(a)(1) 117.8100(a)(1)(A) 117.8100(a)(1)(B) 117.8100(a)(1)(B)(ii) 117.8100(a)(1)(B)(iii) 117.8100(a)(1)(C) 117.8100(a)(2) [G] 117.8100(a)(3) 117.8100(a)(4) 117.8100(a)(5) 117.8100(a)(5)(A) 117.8100(a)(5)(B) [G] 117.8100(a)(5)(D) [G] 117.8100(a)(5)(E) 117.8100(a)(6) 117.8120 117.8120(1) 117.8120(1)(A) 117.145(a) 117.145(f) [G] 117.145(f)(2) 117.145(f)(7) 117.145(f)(8) 117.145(f)(9) 117.8100(a)(5)(C) 117.105(a)(1) 117.105(a) [G] 117.105(a)(2) 117.130(a) 117.130(d) 117.140(k) For purposes of this subchapter, the permit nitrogen oxides emission limit in effect on June 9, 1993, under a permit issued in accordance with Chapter [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(c) 117.135(d) 117.135(f) 117.145(a) 117.145(f) [G] 117.145(f)(2) 117.145(f)(9) 117.8100(a)(5)(C) Reporting Requirements (30 TAC 122.145) 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.145(d) 117.145(d)(1) 117.145(d)(2) 117.145(d)(3) 117.145(d)(4) 117.145(d)(5) 117.8010 [G] 117.8010(1) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) [G] 117.8010(3) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) [G] 117.8010(8) 117.8100(c) 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.8010 [G] 117.8010(1) NEICVP1446E01 Appendix N Page 50 of 148 Renewal- Effective Page 48 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation 117.140(l) CG1 CG2 EU 60GG- SO2 40 CFR Part 60, 60.333(b) 006 Subpart GG EU R7ICI110 CO 2X 30 TAC Chapter 117, Subchapter B 117.105(c) 117.105(a) 117.130(a) 117.140(k) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 116 of this title applies if lower than specifications of 117.150(b)-(d). 117.135(f)(2) 117.135(g) 117.140(a)(2)(A) 117.140(c)(1) [G] 117.140(c)(3) 117.140(e) 117.8100(a) 117.8100(a)(1) 117.8100(a)(1)(A) 117.8100(a)(1)(B) 117.8100(a)(1)(B)(i) 117.8100(a)(1)(B)(ii) 117.8100(a)(1)(C) 117.8100(a)(2) [G] 117.8100(a)(3) 117.8100(a)(4) 117.8100(a)(5) 117.8100(a)(5)(A) 117.8100(a)(5)(B) [G] 117.8100(a)(5)(D) [G] 117.8100(a)(5)(E) 117.8100(a)(6) No stationary gas turbine shall burn any fuel which contains sulfur in excess of 0.8% by weight. 60.334(h) [G] 60.334(h)(3) None No person shall allow the discharge into the atmosphere from any stationary gas turbine with a megawatt (MW) rating greater than or equal to 10.0 MW, emissions in excess of a block one-hour average concentration of 132 ppmv carbon monoxide (CO) at 15% oxygen, dry basis. For stationary gas [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(c) 117.135(d) 117.135(f) 117.135(f)(3) 117.135(g) 117.140(a)(2)(A) 117.140(d) 117.140(e) 117.8100(a) 117.145(a) 117.145(f) [G] 117.145(f)(2) 117.145(f)(7) 117.145(f)(8) 117.145(f)(9) 117.8100(a)(5)(C) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) 117.8010(2)(C) 117.8010(2)(D) [G] 117.8010(3) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) [G] 117.8010(8) 117.8100(c) None 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.145(d) 117.145(d)(1) 117.145(d)(2) 117.145(d)(3) 117.145(d)(4) 117.145(d)(5) 117.8010 [G] 117.8010(1) NEICVP1446E01 Appendix N Page 51 of 148 Renewal- Effective Page 49 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation CG2 EU R7ICI110 NOX 30 TAC Chapter 117.105(a)(1) 2X 117, Subchapter 117.105(a) B [G] 117.105(a)(2) 117.130(a) 117.130(d) 117.140(k) 117.140(l) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) turbines equipped with CEMS or PEMS for CO, the owner or operator may elect to comply with the CO specification of this subsection using a 24-hour rolling average. For purposes of this subchapter, the permit nitrogen oxides emission limit in effect on June 9, 1993, under a permit issued in accordance with Chapter 116 of this title applies if lower than specifications of 117.150(b)-(d). 117.8100(a)(1) 117.8100(a)(1)(A) 117.8100(a)(1)(B) 117.8100(a)(1)(B)(ii) 117.8100(a)(1)(B)(iii) 117.8100(a)(1)(C) 117.8100(a)(2) [G] 117.8100(a)(3) 117.8100(a)(4) 117.8100(a)(5) 117.8100(a)(5)(A) 117.8100(a)(5)(B) [G] 117.8100(a)(5)(D) [G] 117.8100(a)(5)(E) 117.8100(a)(6) 117.8120 117.8120(1) 117.8120(1)(A) [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(c) 117.135(d) 117.135(f) 117.135(f)(2) 117.135(g) 117.140(a)(2)(A) 117.140(c)(1) [G] 117.140(c)(3) 117.140(e) 117.8100(a) 117.8100(a)(1) 117.8100(a)(1)(A) 117.8100(a)(1)(B) 117.8100(a)(1)(B)(i) 117.8100(a)(1)(B)(ii) 117.8100(a)(1)(C) 117.8100(a)(2) [G] 117.8100(a)(3) 117.145(a) 117.145(f) [G] 117.145(f)(2) 117.145(f)(9) 117.8100(a)(5)(C) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) [G] 117.8010(3) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) [G] 117.8010(8) 117.8100(c) 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.8010 [G] 117.8010(1) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) 117.8010(2)(C) 117.8010(2)(D) [G] 117.8010(3) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) [G] 117.8010(8) 117.8100(c) NEICVP1446E01 Appendix N Page 52 of 148 Renewal- Effective Page 50 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. CG2 CT-1 CT-4 FDU-1 Unit Group Process Type SOP Index No. EU 60GG- 006 EU 63YY-H EU 63YY-H EU R5112- 00a Pollutant State Rule or Federal Regulation Name SO2 40 CFR Part 60, Subpart GG 112(B) HAPS 40 CFR Part 63, Subpart YY 112(B) HAPS 40 CFR Part 63, Subpart YY VOC 30 TAC Chapter 115, Storage of VOCs Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) 60.333(b) No stationary gas turbine shall burn any fuel which contains sulfur in excess of 0.8% by weight. 63.1103 The permit holder shall comply with the applicable limitation, standard and/or equipment specification requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart YY 63.1103 The permit holder shall comply with the applicable limitation, standard and/or equipment specification requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart YY 115.111(a)(1) Except as provided in 115.118, a storage tank storing VOC with a true vapor pressure less than 1.5 psia is exempt from the requirements of this Monitoring And Testing Requirements Recordkeeping Requirements (30 TAC 122.144) 117.8100(a)(4) 117.8100(a)(5) 117.8100(a)(5)(A) 117.8100(a)(5)(B) [G] 117.8100(a)(5)(D) [G] 117.8100(a)(5)(E) 117.8100(a)(6) 60.334(h) [G] 60.334(h)(3) None The permit holder shall comply with the applicable monitoring and testing requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable recordkeeping requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable monitoring and testing requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable recordkeeping requirements of 40 CFR Part 63, Subpart YY [G] 115.117 115.118(a)(1) 115.118(a)(5) 115.118(a)(7) Reporting Requirements (30 TAC 122.145) None The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart YY None NEICVP1446E01 Appendix N Page 53 of 148 Renewal- Effective Page 51 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. GRPA3PH1 GRPA3PH1 GRPA3PH1 Unit Group Process Type SOP Index No. EU R7ICI- 503 EU R7ICI- 503 EU 63DDDD D-63YY Pollutant State Rule or Federal Regulation Name CO 30 TAC Chapter 117, Subchapter B NOX 30 TAC Chapter 117, Subchapter B 112(B) HAPS 40 CFR Part 63, Subpart DDDDD Emission Limitation, Standard or Equipment Specification Citation 117.110(c)(1) 117.110(c) 117.110(c)(1)(B) 117.110(c)(3) 117.110(a)(2) 117.110(a) 117.110(b) 117.110(b)(2) 117.130(d) 117.140(k) 63.7505 The permit holder shall comply with the applicable limitation, standard and/or Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) division. No person shall allow the discharge into the atmosphere from any process heater subject to NOx emission specifications in 117.110(a) CO in excess of 400 ppmv at 3.0% oxygen, dry basis, except as provided in 117.125 or 117.110(c)(3). [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(d) 117.135(e) 117.135(g) 117.140(a) 117.8000(b) 117.8000(c) 117.8000(c)(2) 117.8000(c)(3) 117.8000(c)(5) 117.8000(c)(6) [G] 117.8000(d) ** See Periodic Monitoring Summary No person shall allow the discharge into the atmosphere from any gasfired process heaters with a maximum rated capacity equal to or greater than 40 MMBtu emissions of NOx in excess of 0.08 lb/MMBtu of heat input. [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(d) 117.135(e) 117.135(g) 117.140(a) 117.8000(b) 117.8000(c) 117.8000(c)(1) 117.8000(c)(3) 117.8000(c)(5) 117.8000(c)(6) [G] 117.8000(d) The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart DDDDD The permit holder shall comply with the applicable monitoring and testing requirements of 40 117.145(a) 117.145(f) 117.145(f)(1) 117.145(f)(9) 117.145(a) 117.145(f) 117.145(f)(1) 117.145(f)(9) The permit holder shall comply with the applicable recordkeeping requirements of 40 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.8010 [G] 117.8010(1) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) [G] 117.8010(3) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) [G] 117.8010(8) 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.8010 [G] 117.8010(1) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) 117.8010(2)(C) 117.8010(2)(D) [G] 117.8010(3) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart NEICVP1446E01 Appendix N Page 54 of 148 Renewal- Effective Page 52 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. GRPA3PH1 GRPUTIC1 GRPUTTK1 P-Q-108 Unit Group Process Type SOP Index No. EU 63YY EU 63ZZZZ EU R5112- 00a EU 117- EMERG Pollutant State Rule or Federal Regulation Name 112(B) HAPS 40 CFR Part 63, Subpart YY 112(B) HAPS 40 CFR Part 63, Subpart ZZZZ VOC 30 TAC Chapter 115, Storage of VOCs Exempt 30 TAC Chapter 117, Subchapter B Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) equipment specification requirements of 40 CFR Part 63, Subpart DDDDD CFR Part 63, Subpart DDDDD CFR Part 63, Subpart DDDDD DDDDD 63.1103 The permit holder shall comply with the applicable limitation, standard and/or equipment specification requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable monitoring and testing requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable recordkeeping requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart YY 63.6602-Table2c.1 63.6595(a)(1) 63.6605(a) 63.6605(b) 63.6625(e) 63.6625(h) 63.6625(i) 63.6640(f)(1) 63.6640(f)(2) 63.6640(f)(2)(i) 63.6640(f)(3) For each existing emergency stationary CI RICE and black start stationary CI RICE, located at a major source, you must comply with the requirements as specified in Table 2c.1.a-c. 63.6625(f) 63.6625(i) 63.6640(a) 63.6640(a)Table6.9.a.i 63.6640(a)Table6.9.a.ii 63.6625(i) 63.6655(e) 63.6655(f) 63.6660(a) 63.6660(b) 63.6660(c) 63.6640(e) 63.6650(f) 115.111(a)(1) Except as provided in 115.118, a storage tank storing VOC with a true vapor pressure less than 1.5 psia is exempt from the requirements of this division. [G] 115.117 115.118(a)(1) 115.118(a)(5) 115.118(a)(7) None 117.103(a)(6)(D) Units exempted from the provisions of this division, except as specified in 117.140(i), 117.145(f)(6), 117.8140(a) 117.8140(a)(3) 117.140(i) 117.145(f) 117.145(f)(6) 117.145(f)(6)(B) None NEICVP1446E01 Appendix N Page 55 of 148 Renewal- Effective Page 53 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. P-Q-108 PROA3WW PROA3WW Unit Group Process Type SOP Index No. EU 63ZZZZ PRO 61FFTPWW1a PRO 61FFTPWW1b Pollutant State Rule or Federal Regulation Name 112(B) HAPS 40 CFR Part 63, Subpart ZZZZ Benzene 40 CFR Part 61, Subpart FF Benzene 40 CFR Part 61, Subpart FF Emission Limitation, Standard or Equipment Specification Citation 63.6602-Table2c.1 63.6595(a)(1) 63.6605(a) 63.6605(b) 63.6625(e) 63.6625(h) 63.6625(i) 63.6640(f)(1) 63.6640(f)(2) 63.6640(f)(2)(i) 63.6640(f)(3) 61.348(a)(1) 61.340(d) 61.348(a)(1)(i) 61.348(a)(2) 61.348(a)(3) 61.348(a)(4) 61.348(e) 61.348(e)(1) 61.348(e)(2) 61.348(f) 61.348(a)(1) 60.18 61.348(a)(1)(i) 61.348(a)(2) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements 117.150(c)(1), and 117.154(a)(5), include stationary gas turbines and stationary internal combustion engines that are used exclusively in emergency situations, except that operation for testing or maintenance purposes is allowed for up to 52 hours per year, based on a rolling 12-month average. For each existing emergency stationary CI RICE and black start stationary CI RICE, located at a major source, you must comply with the requirements as specified in Table 2c.1.a-c. 63.6625(f) 63.6625(i) 63.6640(a) 63.6640(a)Table6.9.a.i 63.6640(a)Table6.9.a.ii The owner or operator shall design, install, operate and maintain a treatment process that removes or destroys benzene as specified. 61.348(e)(1) 61.348(f) 61.354(a)(2) The owner or operator shall design, install, operate and maintain a treatment process that removes or 60.18(f)(2) 61.348(e)(1) 61.348(f) 61.349(a)(1)(i) NEICVP1446E01 Appendix N Page 56 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 63.6625(i) 63.6655(e) 63.6655(f) 63.6660(a) 63.6660(b) 63.6660(c) 63.6640(e) 63.6650(f) 61.354(a)(2) 61.356(e) 61.356(e)(1) 61.356(e)(2) [G] 61.356(i) 61.357(d)(7) 61.357(d)(7)(ii) 61.354(a)(2) 61.354(c) 61.354(c)(3) 61.356(e) 61.357(d)(7) 61.357(d)(7)(ii) 61.357(d)(7)(iv) 61.357(d)(7)(iv)(F) Renewal- Effective Page 54 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. PRORSHON PU-11 Unit Group Process Type SOP Index No. PRO 63F-002 Pollutant State Rule or Federal Regulation Name 112(B) HAPS 40 CFR Part 63, Subpart F Emission Limitation, Standard or Equipment Specification Citation 61.348(a)(3) 61.348(a)(4) 61.348(e) 61.348(e)(1) 61.348(e)(2) 61.348(f) 61.349(a) 61.349(a)(1)(i) 61.349(a)(1)(ii) 61.349(a)(1)(ii)(B) 61.349(a)(1)(iii) 61.349(a)(1)(iv) 61.349(b) 61.349(e) 61.349(f) 61.349(g) 63.100(b) [G] 63.102(a) [G] 63.102(c) 63.105(d) EU 117- Exempt 30 TAC Chapter 117.103(a)(6)(D) EMERG 117, Subchapter B Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements destroys benzene as specified. 61.349(a)(1)(ii) 61.349(e) 61.349(f) 61.354(a)(2) 61.354(c) 61.354(c)(3) 61.354(f)(1) [G] 61.355(h) Except as provided in paragraphs (b)(4) and (c) of this section, the provisions of subparts F, G, and H apply to chemical manufacturing process units that meet the criteria. 63.103(b)(1) 63.103(b)(3) 63.103(b)(4) [G] 63.103(b)(5) 63.103(b)(6) Units exempted from the provisions of this division, except as specified in 117.140(i), 117.145(f)(6), 117.150(c)(1), and 117.154(a)(5), include stationary gas turbines and stationary internal combustion engines that are used exclusively in emergency situations, except that operation for testing or maintenance purposes is allowed for up to 52 hours per year, based 117.8140(a) 117.8140(a)(3) Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 61.356(e)(1) 61.356(e)(2) 61.356(f) 61.356(f)(1) 61.356(h) [G] 61.356(i) 61.356(j) 61.356(j)(1) 61.356(j)(2) 61.356(j)(3) 61.356(j)(3)(i) 61.356(j)(7) [G] 63.103(c) [G] 63.105(b) 63.105(c) 63.105(e) 63.103(b)(2) [G] 63.103(b)(5) [G] 63.103(d) 117.140(i) 117.145(f) 117.145(f)(6) 117.145(f)(6)(B) None NEICVP1446E01 Appendix N Page 57 of 148 Renewal- Effective Page 55 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. PU-11 R-CC-4 R-CC-4 Unit Group Process Type SOP Index No. EU 63ZZZZ EU 117- EMERG EU 63ZZZZ Pollutant State Rule or Federal Regulation Name 112(B) HAPS 40 CFR Part 63, Subpart ZZZZ Exempt 30 TAC Chapter 117, Subchapter B 112(B) HAPS 40 CFR Part 63, Subpart ZZZZ Emission Limitation, Standard or Equipment Specification Citation 63.6602-Table2c.1 63.6595(a)(1) 63.6605(a) 63.6605(b) 63.6625(e) 63.6625(h) 63.6625(i) 63.6640(f)(1) 63.6640(f)(2) 63.6640(f)(2)(i) 63.6640(f)(3) 117.103(a)(6)(D) 63.6602-Table2c.1 63.6595(a)(1) 63.6605(a) 63.6605(b) 63.6625(e) 63.6625(h) 63.6625(i) 63.6640(f)(1) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements on a rolling 12-month average. For each existing emergency stationary CI RICE and black start stationary CI RICE, located at a major source, you must comply with the requirements as specified in Table 2c.1.a-c. 63.6625(f) 63.6625(i) 63.6640(a) 63.6640(a)Table6.9.a.i 63.6640(a)Table6.9.a.ii Units exempted from the provisions of this division, except as specified in 117.140(i), 117.145(f)(6), 117.150(c)(1), and 117.154(a)(5), include stationary gas turbines and stationary internal combustion engines that are used exclusively in emergency situations, except that operation for testing or maintenance purposes is allowed for up to 52 hours per year, based on a rolling 12-month average. 117.8140(a) 117.8140(a)(3) For each existing emergency stationary CI RICE and black start stationary CI RICE, located at a major source, you must comply with the requirements as specified in Table 2c.1.a-c. 63.6625(f) 63.6625(i) 63.6640(a) 63.6640(a)Table6.9.a.i 63.6640(a)Table6.9.a.ii NEICVP1446E01 Appendix N Page 58 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 63.6625(i) 63.6655(e) 63.6655(f) 63.6660(a) 63.6660(b) 63.6660(c) 63.6640(e) 63.6650(f) 117.140(i) 117.145(f) 117.145(f)(6) 117.145(f)(6)(B) None 63.6625(i) 63.6655(e) 63.6655(f) 63.6660(a) 63.6660(b) 63.6660(c) 63.6640(e) 63.6650(f) Renewal- Effective Page 56 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. R-S-42 R-S-42 R-S-53 Unit Group Process Type SOP Index No. EU 117- EMERG EU 63ZZZZ EU 117- EMERG Pollutant State Rule or Federal Regulation Name Exempt 30 TAC Chapter 117, Subchapter B 112(B) HAPS 40 CFR Part 63, Subpart ZZZZ Exempt 30 TAC Chapter 117, Subchapter B Emission Limitation, Standard or Equipment Specification Citation 63.6640(f)(2) 63.6640(f)(2)(i) 63.6640(f)(3) 117.103(a)(6)(D) 63.6602-Table2c.1 63.6595(a)(1) 63.6605(a) 63.6605(b) 63.6625(e) 63.6625(h) 63.6625(i) 63.6640(f)(1) 63.6640(f)(2) 63.6640(f)(2)(i) 63.6640(f)(3) 117.103(a)(6)(D) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Units exempted from the provisions of this division, except as specified in 117.140(i), 117.145(f)(6), 117.150(c)(1), and 117.154(a)(5), include stationary gas turbines and stationary internal combustion engines that are used exclusively in emergency situations, except that operation for testing or maintenance purposes is allowed for up to 52 hours per year, based on a rolling 12-month average. 117.8140(a) 117.8140(a)(3) For each existing emergency stationary CI RICE and black start stationary CI RICE, located at a major source, you must comply with the requirements as specified in Table 2c.1.a-c. 63.6625(f) 63.6625(i) 63.6640(a) 63.6640(a)Table6.9.a.i 63.6640(a)Table6.9.a.ii Units exempted from the provisions of this division, except as specified in 117.140(i), 117.145(f)(6), 117.150(c)(1), and 117.154(a)(5), include stationary gas turbines and 117.8140(a) 117.8140(a)(3) NEICVP1446E01 Appendix N Page 59 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 117.140(i) 117.145(f) 117.145(f)(6) 117.145(f)(6)(B) None 63.6625(i) 63.6655(e) 63.6655(f) 63.6660(a) 63.6660(b) 63.6660(c) 63.6640(e) 63.6650(f) 117.140(i) 117.145(f) 117.145(f)(6) 117.145(f)(6)(B) None Renewal- Effective Page 57 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. RRFUG EU R5211018 RSELRTRKW EU R521100c RSELRTRKW EU R5211018 Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements stationary internal combustion engines that are used exclusively in emergency situations, except that operation for testing or maintenance purposes is allowed for up to 52 hours per year, based on a rolling 12-month average. VOC 30 TAC Chapter 115, Loading and Unloading of VOC 115.217(a)(1) 115.214(a)(1)(B) 115.214(a)(1)(D) 115.214(a)(1)(D)(i) Vapor pressure (at landbased operations). All landbased loading and unloading of VOC with a true vapor pressure less than 0.5 psia is exempt from the requirements of this division, except as specified. 115.214(a)(1)(A) 115.214(a)(1)(A)(i) 115.215 115.215(4) VOC 30 TAC Chapter 115, Loading and Unloading of VOC 115.212(a)(1) 115.212(a)(1)(B) 115.212(a)(3)(A) 115.212(a)(3)(A)(ii) 115.212(a)(3)(B) [G] 115.212(a)(3)(C) 115.212(a)(3)(E) 115.214(a)(1)(B) 115.214(a)(1)(C) At operations other than gasoline terminals, gasoline bulk plants, and marine terminals, vapors from loading VOC with a true vapor pressure of 0.5 psia or greater must be controlled by one of the methods specified in 115.212(a)(1)(A)-(C). 115.212(a)(3)(B) 115.214(a)(1)(A) 115.214(a)(1)(A)(i) 115.214(a)(1)(A)(ii) 115.214(a)(1)(A)(iii) 115.215 115.215(1) 115.215(10) [G] 115.215(2) 115.215(4) 115.215(9) VOC 30 TAC Chapter 115, Loading and Unloading of VOC 115.217(a)(1) 115.214(a)(1)(B) 115.214(a)(1)(D) 115.214(a)(1)(D)(i) Vapor pressure (at landbased operations). All landbased loading and unloading of VOC with a true vapor pressure less than 0.5 psia is exempt from the requirements of this division, except as 115.214(a)(1)(A) 115.214(a)(1)(A)(i) 115.215 115.215(4) Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.216 115.216(2) 115.216(3)(B) None 115.216 115.216(2) 115.216(3)(A) 115.216(3)(A)(i) 115.216(3)(A)(ii) 115.216(3)(A)(iii) 115.216(3)(B) None 115.216 115.216(2) 115.216(3)(B) None NEICVP1446E01 Appendix N Page 60 of 148 Renewal- Effective Page 58 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. RSELRTRKW EU 63GL0g2a RSELRTRKW EU 63YY-L RSELRVNTT EU W R5211018 RSET010 EU R5112062 RSET010 EU 63GT036 Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) specified. 112(B) HAPS 40 CFR Part 63, 63.126(c) Subpart G For each Group 2 transfer rack, maintain records as required in 63.130(f). No other provisions for transfer racks apply to the Group 2 transfer rack. None 63.130(f) 63.130(f)(1) 63.130(f)(2) 63.130(f)(3) 63.130(f)(3)(i) 63.130(f)(3)(ii) 63.152(c)(4)(iii) 112(B) HAPS 40 CFR Part 63, Subpart YY 63.1103 The permit holder shall comply with the applicable limitation, standard and/or equipment specification requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable monitoring and testing requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable recordkeeping requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart YY VOC 30 TAC Chapter 115, Loading and Unloading of VOC 115.217(a)(1) 115.214(a)(1)(B) 115.214(a)(1)(D) 115.214(a)(1)(D)(i) Vapor pressure (at landbased operations). All landbased loading and unloading of VOC with a true vapor pressure less than 0.5 psia is exempt from the requirements of this division, except as specified. 115.214(a)(1)(A) 115.214(a)(1)(A)(i) 115.215 115.215(4) 115.216 115.216(2) 115.216(3)(B) None VOC 30 TAC Chapter 115, Storage of VOCs 115.112(a)(1) 115.112(a)(3) Tanks shall not store VOC unless the required pressure is maintained, or they are equipped with the appropriate control device specified in Table I(a) or Table II(a). 115.115(a) 115.115(a)(6) [G] 115.117 115.118(a)(4) 115.118(a)(4)(F) 115.118(a)(5) 115.118(a)(7) None 112(B) HAPS 40 CFR Part 63, Subpart G 63.119(e) 63.119(a)(2) 63.119(e)(1) The owner or operator who elects to use a closed vent system and control device 63.120(d)(1) 63.120(d)(1)(ii) 63.120(d)(1)(ii)(A) 63.123(a) 63.123(f)(1) [G] 63.123(f)(2) 63.120(d)(1)(ii)(B) 63.120(d)(2) 63.120(d)(2)(i) NEICVP1446E01 Appendix N Page 61 of 148 Renewal- Effective Page 59 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation 63.119(e)(3) 63.119(e)(4) 63.119(e)(5) [G] 63.148(d) 63.148(e) RSET0126 EU R5112050 VOC 30 TAC Chapter 115, Storage of VOCs 115.111(a)(1) RSET0126 EU R5112052 VOC 30 TAC Chapter 115, Storage of VOCs 115.112(a)(1) 115.112(a)(3) 60.18 Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements (defined in 63.111) to comply with63.119(a)(1) or (a)(2) shall comply with 63.119(e)(1)-(5). 63.120(d)(5) 63.120(d)(6) 63.148(b)(2)(iii) [G] 63.148(c) 63.148(g) 63.148(g)(2) 63.148(h) 63.148(h)(2) Except as provided in 115.118, a storage tank storing VOC with a true vapor pressure less than 1.5 psia is exempt from the requirements of this division. Tanks shall not store VOC unless the required pressure is maintained, or they are equipped with the appropriate control device specified in Table I(a) or [G] 115.117 115.115(a) 115.115(a)(6) 115.116(a)(2) [G] 115.117 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 63.148(g)(2) 63.148(h)(2) 63.148(i)(1) 63.148(i)(2) [G] 63.148(i)(4) 63.148(i)(5) [G] 63.152(a) 115.118(a)(1) 115.118(a)(5) 115.118(a)(7) [G] 63.120(d)(2)(iii) 63.120(d)(3) 63.120(d)(3)(i) 63.120(d)(3)(ii) 63.120(d)(4) 63.122(b) 63.122(c)(1) [G] 63.122(g)(1) [G] 63.122(g)(2) 63.151(a)(7) [G] 63.151(b) [G] 63.151(j) [G] 63.152(a) 63.152(b) [G] 63.152(b)(1) 63.152(b)(4) 63.152(c)(1) 63.152(c)(2) 63.152(c)(2)(i) [G] 63.152(c)(2)(ii) 63.152(c)(2)(iii) 63.152(c)(3) 63.152(c)(3)(i) 63.152(c)(4)(ii) [G] 63.152(c)(6) None 115.118(a)(5) 115.118(a)(7) None NEICVP1446E01 Appendix N Page 62 of 148 Renewal- Effective Page 60 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSET0126 RSET0126 RSET0126 Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation EU R5112- VOC 30 TAC Chapter 115.112(a)(1) 055 115, Storage of 115.112(a)(3) VOCs EU 61FF- Benzene 40 CFR Part 61, 61.343(a)(1) T02a Subpart FF 60.18 61.343(a)(1)(i)(A) 61.343(a)(1)(i)(B) 61.343(c) 61.343(d) 61.349(a) 61.349(a)(1)(i) 61.349(a)(1)(ii) 61.349(a)(1)(ii)(B) 61.349(a)(1)(iii) 61.349(a)(1)(iv) 61.349(b) 61.349(e) 61.349(f) 61.349(g) EU 61FF- Benzene 40 CFR Part 61, 61.343(a)(1) T03a Subpart FF 61.343(a)(1)(i)(A) 61.343(a)(1)(i)(B) 61.343(c) 61.343(d) 61.349(a) 61.349(a)(1)(i) 61.349(a)(1)(iii) 61.349(a)(1)(iv) 61.349(a)(2)(ii) 61.349(b) 61.349(e) 61.349(f) 61.349(g) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Table II(a). Tanks shall not store VOC unless the required pressure is maintained, or they are equipped with the appropriate control device specified in Table I(a) or Table II(a). The owner or operator shall install, operate, and maintain a fixed-roof and closed-vent system that routes all organic vapors vented from the tank to a control device. 115.115(a) 115.115(a)(6) [G] 115.117 60.18(f)(2) 61.343(a)(1)(i)(A) 61.343(c) 61.349(a)(1)(i) 61.349(a)(1)(ii) 61.349(e) 61.349(f) 61.354(c) 61.354(c)(3) 61.354(f)(1) [G] 61.355(h) The owner or operator shall install, operate, and maintain a fixed-roof and closed-vent system that routes all organic vapors vented from the tank to a control device. 61.343(a)(1)(i)(A) 61.343(c) 61.349(a)(1)(i) 61.349(e) 61.349(f) 61.354(d) [G] 61.355(h) NEICVP1446E01 Appendix N Page 63 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.118(a)(4) 115.118(a)(4)(F) 115.118(a)(5) 115.118(a)(7) None 61.349(a)(1)(ii) 61.354(c) 61.354(c)(3) 61.356(d) 61.356(f) 61.356(f)(1) 61.356(g) 61.356(h) 61.356(j) 61.356(j)(1) 61.356(j)(2) 61.356(j)(3) 61.356(j)(3)(i) 61.356(j)(7) 61.357(d)(7) 61.357(d)(7)(iv) 61.357(d)(7)(iv)(F) 61.356(d) 61.356(f) 61.356(f)(1) 61.356(f)(2) 61.356(f)(2)(i) 61.356(f)(2)(i)(G) 61.356(g) 61.356(h) 61.356(j) 61.356(j)(1) 61.356(j)(10) 61.356(j)(2) 61.356(j)(3) None Renewal- Effective Page 61 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSET0126 RSET0127 RSET0127 RSET0127 Unit Group Process Type SOP Index No. EU 63YY-T EU R5112- 050 EU R5112- 052 EU 61FF- T02a Pollutant State Rule or Federal Regulation Name 112(B) HAPS 40 CFR Part 63, Subpart YY VOC 30 TAC Chapter 115, Storage of VOCs VOC 30 TAC Chapter 115, Storage of VOCs Benzene 40 CFR Part 61, Subpart FF Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) 63.1103 The permit holder shall comply with the applicable limitation, standard and/or equipment specification requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart YY 115.111(a)(1) Except as provided in 115.118, a storage tank storing VOC with a true vapor pressure less than 1.5 psia is exempt from the requirements of this division. 115.112(a)(1) 115.112(a)(3) 60.18 Tanks shall not store VOC unless the required pressure is maintained, or they are equipped with the appropriate control device specified in Table I(a) or Table II(a). 61.343(a)(1) 60.18 61.343(a)(1)(i)(A) 61.343(a)(1)(i)(B) 61.343(c) 61.343(d) 61.349(a) 61.349(a)(1)(i) 61.349(a)(1)(ii) 61.349(a)(1)(ii)(B) 61.349(a)(1)(iii) 61.349(a)(1)(iv) 61.349(b) 61.349(e) The owner or operator shall install, operate, and maintain a fixed-roof and closed-vent system that routes all organic vapors vented from the tank to a control device. Monitoring And Testing Requirements Recordkeeping Requirements (30 TAC 122.144) The permit holder shall comply with the applicable monitoring and testing requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable recordkeeping requirements of 40 CFR Part 63, Subpart YY [G] 115.117 115.118(a)(1) 115.118(a)(5) 115.118(a)(7) 115.115(a) 115.115(a)(6) 115.116(a)(2) [G] 115.117 115.118(a)(5) 115.118(a)(7) 60.18(f)(2) 61.343(a)(1)(i)(A) 61.343(c) 61.349(a)(1)(i) 61.349(a)(1)(ii) 61.349(e) 61.349(f) 61.354(c) 61.354(c)(3) 61.354(f)(1) [G] 61.355(h) 61.349(a)(1)(ii) 61.354(c) 61.354(c)(3) 61.356(d) 61.356(f) 61.356(f)(1) 61.356(g) 61.356(h) 61.356(j) 61.356(j)(1) 61.356(j)(2) 61.356(j)(3) 61.356(j)(3)(i) 61.356(j)(7) Reporting Requirements (30 TAC 122.145) The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart YY None None 61.357(d)(7) 61.357(d)(7)(iv) 61.357(d)(7)(iv)(F) NEICVP1446E01 Appendix N Page 64 of 148 Renewal- Effective Page 62 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSET0127 RSET0180 RSET0180 Unit Group Process Type SOP Index No. EU 63YY-T EU R5112- 062 EU 63GT- 036 Pollutant State Rule or Federal Regulation Name 112(B) HAPS 40 CFR Part 63, Subpart YY VOC 30 TAC Chapter 115, Storage of VOCs 112(B) HAPS 40 CFR Part 63, Subpart G Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements (30 TAC 122.144) 61.349(f) 61.349(g) 63.1103 The permit holder shall comply with the applicable limitation, standard and/or equipment specification requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable monitoring and testing requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable recordkeeping requirements of 40 CFR Part 63, Subpart YY 115.112(a)(1) 115.112(a)(3) Tanks shall not store VOC unless the required pressure is maintained, or they are equipped with the appropriate control device specified in Table I(a) or Table II(a). 115.115(a) 115.115(a)(6) [G] 115.117 115.118(a)(4) 115.118(a)(4)(F) 115.118(a)(5) 115.118(a)(7) 63.119(e) 63.119(a)(2) 63.119(e)(1) 63.119(e)(3) 63.119(e)(4) 63.119(e)(5) [G] 63.148(d) 63.148(e) The owner or operator who elects to use a closed vent system and control device (defined in 63.111) to comply with63.119(a)(1) or (a)(2) shall comply with 63.119(e)(1)-(5). 63.120(d)(1) 63.120(d)(1)(ii) 63.120(d)(1)(ii)(A) 63.120(d)(5) 63.120(d)(6) 63.148(b)(2)(iii) [G] 63.148(c) 63.148(g) 63.148(g)(2) 63.148(h) 63.148(h)(2) 63.123(a) 63.123(f)(1) [G] 63.123(f)(2) 63.148(g)(2) 63.148(h)(2) 63.148(i)(1) 63.148(i)(2) [G] 63.148(i)(4) 63.148(i)(5) [G] 63.152(a) Reporting Requirements (30 TAC 122.145) The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart YY None 63.120(d)(1)(ii)(B) 63.120(d)(2) 63.120(d)(2)(i) [G] 63.120(d)(2)(iii) 63.120(d)(3) 63.120(d)(3)(i) 63.120(d)(3)(ii) 63.120(d)(4) 63.122(b) 63.122(c)(1) [G] 63.122(g)(1) [G] 63.122(g)(2) 63.151(a)(7) [G] 63.151(b) [G] 63.151(j) [G] 63.152(a) 63.152(b) [G] 63.152(b)(1) 63.152(b)(4) NEICVP1446E01 Appendix N Page 65 of 148 Renewal- Effective Page 63 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation RSET0204 EU R5112062 VOC 30 TAC Chapter 115, Storage of VOCs 115.112(a)(1) 115.112(a)(3) RSET0204 EU 63GT036 112(B) HAPS 40 CFR Part 63, Subpart G 63.119(e) 63.119(a)(2) 63.119(e)(1) 63.119(e)(3) 63.119(e)(4) 63.119(e)(5) [G] 63.148(d) 63.148(e) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Tanks shall not store VOC unless the required pressure is maintained, or they are equipped with the appropriate control device specified in Table I(a) or Table II(a). 115.115(a) 115.115(a)(6) [G] 115.117 The owner or operator who elects to use a closed vent system and control device (defined in 63.111) to comply with63.119(a)(1) or (a)(2) shall comply with 63.119(e)(1)-(5). 63.120(d)(1) 63.120(d)(1)(ii) 63.120(d)(1)(ii)(A) 63.120(d)(5) 63.120(d)(6) 63.148(b)(2)(iii) [G] 63.148(c) 63.148(g) 63.148(g)(2) 63.148(h) 63.148(h)(2) Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.118(a)(4) 115.118(a)(4)(F) 115.118(a)(5) 115.118(a)(7) 63.152(c)(1) 63.152(c)(2) 63.152(c)(2)(i) [G] 63.152(c)(2)(ii) 63.152(c)(2)(iii) 63.152(c)(3) 63.152(c)(3)(i) 63.152(c)(4)(ii) [G] 63.152(c)(6) None 63.123(a) 63.123(f)(1) [G] 63.123(f)(2) 63.148(g)(2) 63.148(h)(2) 63.148(i)(1) 63.148(i)(2) [G] 63.148(i)(4) 63.148(i)(5) [G] 63.152(a) 63.120(d)(1)(ii)(B) 63.120(d)(2) 63.120(d)(2)(i) [G] 63.120(d)(2)(iii) 63.120(d)(3) 63.120(d)(3)(i) 63.120(d)(3)(ii) 63.120(d)(4) 63.122(b) 63.122(c)(1) [G] 63.122(g)(1) [G] 63.122(g)(2) 63.151(a)(7) [G] 63.151(b) [G] 63.151(j) [G] 63.152(a) 63.152(b) [G] 63.152(b)(1) 63.152(b)(4) 63.152(c)(1) 63.152(c)(2) 63.152(c)(2)(i) NEICVP1446E01 Appendix N Page 66 of 148 Renewal- Effective Page 64 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation RSET030 EU R5112062 VOC 30 TAC Chapter 115, Storage of VOCs 115.112(a)(1) 115.112(a)(3) RSET030 EU 63GT036 112(B) HAPS 40 CFR Part 63, Subpart G 63.119(e) 63.119(a)(2) 63.119(e)(1) 63.119(e)(3) 63.119(e)(4) 63.119(e)(5) [G] 63.148(d) 63.148(e) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Tanks shall not store VOC unless the required pressure is maintained, or they are equipped with the appropriate control device specified in Table I(a) or Table II(a). 115.115(a) 115.115(a)(6) [G] 115.117 The owner or operator who elects to use a closed vent system and control device (defined in 63.111) to comply with63.119(a)(1) or (a)(2) shall comply with 63.119(e)(1)-(5). 63.120(d)(1) 63.120(d)(1)(ii) 63.120(d)(1)(ii)(A) 63.120(d)(5) 63.120(d)(6) 63.148(b)(2)(iii) [G] 63.148(c) 63.148(g) 63.148(g)(2) 63.148(h) 63.148(h)(2) Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.118(a)(4) 115.118(a)(4)(F) 115.118(a)(5) 115.118(a)(7) [G] 63.152(c)(2)(ii) 63.152(c)(2)(iii) 63.152(c)(3) 63.152(c)(3)(i) 63.152(c)(4)(ii) [G] 63.152(c)(6) None 63.123(a) 63.123(f)(1) [G] 63.123(f)(2) 63.148(g)(2) 63.148(h)(2) 63.148(i)(1) 63.148(i)(2) [G] 63.148(i)(4) 63.148(i)(5) [G] 63.152(a) 63.120(d)(1)(ii)(B) 63.120(d)(2) 63.120(d)(2)(i) [G] 63.120(d)(2)(iii) 63.120(d)(3) 63.120(d)(3)(i) 63.120(d)(3)(ii) 63.120(d)(4) 63.122(b) 63.122(c)(1) [G] 63.122(g)(1) [G] 63.122(g)(2) 63.151(a)(7) [G] 63.151(b) [G] 63.151(j) [G] 63.152(a) 63.152(b) [G] 63.152(b)(1) 63.152(b)(4) 63.152(c)(1) 63.152(c)(2) 63.152(c)(2)(i) [G] 63.152(c)(2)(ii) 63.152(c)(2)(iii) 63.152(c)(3) NEICVP1446E01 Appendix N Page 67 of 148 Renewal- Effective Page 65 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements RSET039 EU RSET040 EU RSET087 EU RSET087 EU RSET087 EU R5112067 VOC R5112067 VOC R5112052 VOC R5112069 VOC 60Kb-33 VOC 30 TAC Chapter 115, Storage of VOCs 30 TAC Chapter 115, Storage of VOCs 30 TAC Chapter 115, Storage of VOCs 30 TAC Chapter 115, Storage of VOCs 40 CFR Part 60, Subpart Kb 115.111(a)(1) 115.111(a)(1) 115.112(a)(1) 115.112(a)(3) 60.18 115.112(a)(1) 115.112(a)(2) 115.112(a)(2)(A) 115.112(a)(2)(B) 115.112(a)(2)(C) 115.112(a)(2)(D) 115.112(a)(2)(E) 115.114(a)(1)(A) 60.112b(a)(1) 60.112b(a)(1)(i) 60.112b(a)(1)(ii)(C) 60.112b(a)(1)(iii) Except as provided in 115.118, a storage tank storing VOC with a true vapor pressure less than 1.5 psia is exempt from the requirements of this division. Except as provided in 115.118, a storage tank storing VOC with a true vapor pressure less than 1.5 psia is exempt from the requirements of this division. Tanks shall not store VOC unless the required pressure is maintained, or they are equipped with the appropriate control device specified in Table I(a) or Table II(a). Tanks shall not store VOC unless the required pressure is maintained, or they are equipped with the appropriate control device specified in Table I(a) or Table II(a). [G] 115.117 [G] 115.117 115.115(a) 115.115(a)(6) 115.116(a)(2) [G] 115.117 115.114(a)(1) 115.114(a)(1)(A) [G] 115.117 Storage vessels specified in 60.112b(a) and equipped with a fixed roof in combination with an internal 60.113b(a)(1) 60.113b(a)(2) 60.113b(a)(4) 60.113b(a)(5) Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.118(a)(1) 115.118(a)(5) 115.118(a)(7) 63.152(c)(3)(i) 63.152(c)(4)(ii) [G] 63.152(c)(6) None 115.118(a)(1) 115.118(a)(5) 115.118(a)(7) None 115.118(a)(5) 115.118(a)(7) None 115.118(a)(3) 115.118(a)(5) 115.118(a)(7) 115.114(a)(1)(B) 60.115b 60.115b(a)(2) 60.116b(a) 60.116b(b) 60.113b(a)(2) 60.113b(a)(5) 60.115b 60.115b(a)(1) NEICVP1446E01 Appendix N Page 68 of 148 Renewal- Effective Page 66 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSET087 RSET087 RSET087 Unit Group Process Type SOP Index No. EU 60Kb-36 EU 61FF- T02a EU 61FF- T04a Pollutant State Rule or Federal Regulation Name VOC 40 CFR Part 60, Subpart Kb Benzene 40 CFR Part 61, Subpart FF Benzene 40 CFR Part 61, Subpart FF Emission Limitation, Standard or Equipment Specification Citation 60.112b(a)(1)(iv) 60.112b(a)(1)(ix) 60.112b(a)(1)(v) 60.112b(a)(1)(vi) 60.112b(a)(1)(vii) 60.112b(a)(1)(viii) [G] 60.112b(a)(3) 60.18 61.343(a)(1) 60.18 61.343(a)(1)(i)(A) 61.343(a)(1)(i)(B) 61.343(c) 61.343(d) 61.349(a) 61.349(a)(1)(i) 61.349(a)(1)(ii) 61.349(a)(1)(ii)(B) 61.349(a)(1)(iii) 61.349(a)(1)(iv) 61.349(b) 61.349(e) 61.349(f) 61.349(g) 61.351(a) 60.112b(a)(1) 60.112b(a)(1)(i) 60.112b(a)(1)(ii)(C) 60.112b(a)(1)(iii) 60.112b(a)(1)(iv) 60.112b(a)(1)(ix) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements floating roof shall meet the specifications listed in 60.112b(a)(1)(i)-(ix). 60.116b(a) 60.116b(b) 60.116b(c) 60.116b(e) 60.116b(e)(1) [G] 60.116b(e)(3) Storage vessels specified in 60.112b(a) and equipped with a closed vent system/control device are to meet the specifications of 60.112b(a)(3)(i)-(ii). 60.113b(d) 60.116b(a) 60.116b(b) 60.116b(e) 60.116b(e)(1) [G] 60.116b(e)(3) [G] 60.485(b) ** See Periodic Monitoring Summary The owner or operator shall install, operate, and maintain a fixed-roof and closed-vent system that routes all organic vapors vented from the tank to a control device. 60.18(f)(2) 61.343(a)(1)(i)(A) 61.343(c) 61.349(a)(1)(i) 61.349(a)(1)(ii) 61.349(e) 61.349(f) 61.354(c) 61.354(c)(3) 61.354(f)(1) [G] 61.355(h) As an alternative to the standards for tanks specified in 61.343, an owner or operator may elect to comply with one of the following 61.351(a)(1)-(3): 60.113b(a)(1) 60.113b(a)(2) 60.113b(a)(4) 60.113b(a)(5) NEICVP1446E01 Appendix N Page 69 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 60.116b(c) 60.115b(a)(3) 60.115b 60.115b(d)(2) 60.116b(a) 60.116b(b) 60.115b 60.115b(d)(1) 60.115b(d)(3) 61.349(a)(1)(ii) 61.354(c) 61.354(c)(3) 61.356(d) 61.356(f) 61.356(f)(1) 61.356(f)(2)(i)(D) 61.356(g) 61.356(h) 61.356(j) 61.356(j)(1) 61.356(j)(2) 61.356(j)(3) 61.356(j)(3)(i) 61.356(j)(7) 61.357(d)(7) 61.357(d)(7)(iv) 61.357(d)(7)(iv)(F) 60.115b 60.115b(a)(2) 61.356(k) 60.113b(a)(2) 60.113b(a)(5) 60.115b 60.115b(a)(1) 60.115b(a)(3) 61.357(e) 61.357(f) Renewal- Effective Page 67 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSET087 RSET088 RSET088 RSET088 Unit Group Process Type SOP Index No. EU 63YY-T EU R5112- 052 EU R5112- 069 EU 60Kb-33 Pollutant State Rule or Federal Regulation Name 112(B) HAPS 40 CFR Part 63, Subpart YY VOC 30 TAC Chapter 115, Storage of VOCs VOC 30 TAC Chapter 115, Storage of VOCs VOC 40 CFR Part 60, Subpart Kb Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 60.112b(a)(1)(v) 60.112b(a)(1)(vi) 60.112b(a)(1)(vii) 60.112b(a)(1)(viii) 61.351(a)(1) 61.351(b) 63.1103 The permit holder shall comply with the applicable limitation, standard and/or equipment specification requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable monitoring and testing requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable recordkeeping requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart YY 115.112(a)(1) 115.112(a)(3) 60.18 Tanks shall not store VOC unless the required pressure is maintained, or they are equipped with the appropriate control device specified in Table I(a) or Table II(a). 115.115(a) 115.115(a)(6) 115.116(a)(2) [G] 115.117 115.118(a)(5) 115.118(a)(7) None 115.112(a)(1) 115.112(a)(2) 115.112(a)(2)(A) 115.112(a)(2)(B) 115.112(a)(2)(C) 115.112(a)(2)(D) 115.112(a)(2)(E) 115.114(a)(1)(A) Tanks shall not store VOC unless the required pressure is maintained, or they are equipped with the appropriate control device specified in Table I(a) or Table II(a). 115.114(a)(1) 115.114(a)(1)(A) [G] 115.117 115.118(a)(3) 115.118(a)(5) 115.118(a)(7) 115.114(a)(1)(B) 60.112b(a)(1) 60.112b(a)(1)(i) 60.112b(a)(1)(ii)(C) 60.112b(a)(1)(iii) 60.112b(a)(1)(iv) 60.112b(a)(1)(ix) Storage vessels specified in 60.112b(a) and equipped with a fixed roof in combination with an internal floating roof shall meet the specifications listed in 60.113b(a)(1) 60.113b(a)(2) 60.113b(a)(4) 60.113b(a)(5) 60.116b(a) 60.116b(b) 60.115b 60.115b(a)(2) 60.116b(a) 60.116b(b) 60.116b(c) 60.113b(a)(2) 60.113b(a)(5) 60.115b 60.115b(a)(1) 60.115b(a)(3) NEICVP1446E01 Appendix N Page 70 of 148 Renewal- Effective Page 68 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSET088 RSET088 RSET088 Unit Group Process Type SOP Index No. EU 60Kb-36 EU 61FF- T02a EU 61FF- T04a Pollutant State Rule or Federal Regulation Name VOC 40 CFR Part 60, Subpart Kb Benzene 40 CFR Part 61, Subpart FF Benzene 40 CFR Part 61, Subpart FF Emission Limitation, Standard or Equipment Specification Citation 60.112b(a)(1)(v) 60.112b(a)(1)(vi) 60.112b(a)(1)(vii) 60.112b(a)(1)(viii) [G] 60.112b(a)(3) 60.18 61.343(a)(1) 60.18 61.343(a)(1)(i)(A) 61.343(a)(1)(i)(B) 61.343(c) 61.343(d) 61.349(a) 61.349(a)(1)(i) 61.349(a)(1)(ii) 61.349(a)(1)(ii)(B) 61.349(a)(1)(iii) 61.349(a)(1)(iv) 61.349(b) 61.349(e) 61.349(f) 61.349(g) 61.351(a) 60.112b(a)(1) 60.112b(a)(1)(i) 60.112b(a)(1)(ii)(C) 60.112b(a)(1)(iii) 60.112b(a)(1)(iv) 60.112b(a)(1)(ix) 60.112b(a)(1)(v) 60.112b(a)(1)(vi) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements 60.112b(a)(1)(i)-(ix). 60.116b(c) 60.116b(e) 60.116b(e)(1) [G] 60.116b(e)(3) Storage vessels specified in 60.112b(a) and equipped with a closed vent system/control device are to meet the specifications of 60.112b(a)(3)(i)-(ii). 60.113b(d) 60.116b(a) 60.116b(b) 60.116b(e) 60.116b(e)(1) [G] 60.116b(e)(3) [G] 60.485(b) ** See Periodic Monitoring Summary The owner or operator shall install, operate, and maintain a fixed-roof and closed-vent system that routes all organic vapors vented from the tank to a control device. 60.18(f)(2) 61.343(a)(1)(i)(A) 61.343(c) 61.349(a)(1)(i) 61.349(a)(1)(ii) 61.349(e) 61.349(f) 61.354(c) 61.354(c)(3) 61.354(f)(1) [G] 61.355(h) As an alternative to the standards for tanks specified in 61.343, an owner or operator may elect to comply with one of the following 61.351(a)(1)-(3): 60.113b(a)(1) 60.113b(a)(2) 60.113b(a)(4) 60.113b(a)(5) NEICVP1446E01 Appendix N Page 71 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 60.115b 60.115b(d)(2) 60.116b(a) 60.116b(b) 60.115b 60.115b(d)(1) 60.115b(d)(3) 61.349(a)(1)(ii) 61.354(c) 61.354(c)(3) 61.356(d) 61.356(f) 61.356(f)(1) 61.356(f)(2)(i)(D) 61.356(g) 61.356(h) 61.356(j) 61.356(j)(1) 61.356(j)(2) 61.356(j)(3) 61.356(j)(3)(i) 61.356(j)(7) 60.115b 60.115b(a)(2) 61.356(k) 61.357(d)(7) 61.357(d)(7)(iv) 61.357(d)(7)(iv)(F) 60.113b(a)(2) 60.113b(a)(5) 60.115b 60.115b(a)(1) 60.115b(a)(3) 61.357(e) 61.357(f) Renewal- Effective Page 69 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSET088 RSETFUG RSETFUG Unit Group Process Type SOP Index No. EU 63YY-T EU R5352- ALL EU R5352- ALL Pollutant State Rule or Federal Regulation Name 112(B) HAPS 40 CFR Part 63, Subpart YY VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements (30 TAC 122.144) 60.112b(a)(1)(vii) 60.112b(a)(1)(viii) 61.351(a)(1) 61.351(b) 63.1103 The permit holder shall comply with the applicable limitation, standard and/or equipment specification requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable monitoring and testing requirements of 40 CFR Part 63, Subpart YY The permit holder shall comply with the applicable recordkeeping requirements of 40 CFR Part 63, Subpart YY 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(3) 115.352(7) 115.357(1) No process drains shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) 115.352(1)(C) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(B) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(4) No component shall be allowed to have a VOC leak, for more than 15 days, after discovery. If the owner or operator elects to use the alternative work practice in 115.358 of this title, any leak detected as defined in 115.358 of this title, including any leak detected using the alternative work practice on a component 115.354(1) 115.354(11) 115.354(13)(A) 115.354(13)(B) 115.354(13)(C) 115.354(13)(D) 115.354(13)(E) 115.354(13)(F) 115.354(4) 115.354(5) 115.354(9) [G] 115.355 115.352(7) 115.354(13)(D) 115.354(13)(E) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) [G] 115.356(4) 115.356(5) Reporting Requirements (30 TAC 122.145) The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart YY None [G] 115.358(g) NEICVP1446E01 Appendix N Page 72 of 148 Renewal- Effective Page 70 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSETFUG Unit Group Process Type SOP Index No. EU R5352- ALL Pollutant State Rule or Federal Regulation Name VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.352(5) 115.352(6) 115.352(7) 115.352(8) 115.357(8) 115.358(c)(1) [G] 115.358(h) 115.357(2) 115.352(9) RSETFUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.357(13) RSETFUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.357(11) RSETFUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.357(10) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements that is subject to the requirements of this division but not specifically selected for alternative work practice monitoring. 115.358(c)(2) 115.358(d) [G] 115.358(e) 115.358(f) Each pressure relief valve equipped with a rupture disk must comply with 115.352(9) and 115.356(3)(C). None Components/systems that contact a process fluid containing VOC having a true vapor pressure equal to or less than 0.002 psia at 68 degrees Fahrenheit are exempt from the requirements of this division except 115.356(3)(C) of this title. None Sampling connection systems, as defined in 40 CFR 63.161 (January 17, 1997), that meet the requirements of 40 CFR 63.166(a) and (b) (June 20, 1996) are exempt from the requirements of this division except 115.356(3)(C) of this title. None Instrumentation systems, as defined in 40 CFR 63.161 (January 17, 1997), that meet 40 CFR 63.169 (June 20, 1996) are exempt None NEICVP1446E01 Appendix N Page 73 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.356 115.356(3) [G] 115.356(3)(C) None 115.356 115.356(3) [G] 115.356(3)(C) None 115.356 115.356(3) [G] 115.356(3)(C) None 115.356 115.356(3) [G] 115.356(3)(C) None Renewal- Effective Page 71 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation RSETFUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.357(5) RSETFUG EU RSETFUG EU R5352ALL VOC R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(1) 115.357(8) 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(12) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements from the requirements of this division except 115.356(3)(C) of this title. Reciprocating compressors and positive displacement pumps used in natural gas/gasoline processing operations are exempt from the requirements of this division except 115.356(3)(C) of this title. No pump seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. None 115.354(1) 115.354(2) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) No compressor seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(10) 115.354(2) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 NEICVP1446E01 Appendix N Page 74 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.356 115.356(3) [G] 115.356(3)(C) None 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) None Renewal- Effective Page 72 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSETFUG RSETFUG RSETFUG Unit Group Process Type SOP Index No. EU R5352- ALL EU R5352- ALL EU R5352- ALL Pollutant State Rule or Federal Regulation Name VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.357(8) 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(12) 115.357(8) 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(1) 115.357(8) 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements No pump seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(10) 115.354(2) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 No compressor seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(2) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) No pump seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping [G] 115.355 NEICVP1446E01 Appendix N Page 75 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) None Renewal- Effective Page 73 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSETFUG RSETFUG RSETFUG Unit Group Process Type SOP Index No. EU R5352- ALL EU R5352- ALL EU R5352- ALL Pollutant State Rule or Federal Regulation Name VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.352(3) 115.352(5) 115.352(7) 115.357(4) 115.357(8) 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(4) 115.357(8) 115.352(1)(B) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(5) 115.352(7) 115.357(3) 115.357(8) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements or exuding of process fluid based on sight, smell, or sound. No compressor seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. [G] 115.355 No compressor seals shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 10,000 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. [G] 115.355 No agitators shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening 115.354(1) 115.354(10) 115.354(5) 115.354(6) 115.354(9) NEICVP1446E01 Appendix N Page 76 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) None Renewal- Effective Page 74 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSETFUG RSETFUG RSETFUG Unit Group Process Type SOP Index No. EU R5352- ALL EU R5352- ALL EU R5352- ALL Pollutant State Rule or Federal Regulation Name VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Emission Limitation, Standard or Equipment Specification Citation 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(7) 115.357(12) 115.357(8) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(7) 115.357(1) 115.357(12) 115.357(8) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(C) 115.352(2)(C)(i) 115.352(2)(C)(ii) 115.352(2)(C)(iii) 115.352(3) 115.352(7) 115.357(1) 115.357(12) 115.357(8) 115.352(1)(A) 115.352(1) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. [G] 115.355 115.357(1) No agitators shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) No agitators shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(10) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) No flanges or other 115.354(1) connectors shall be allowed 115.354(10) NEICVP1446E01 Appendix N Page 77 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.354(10) None Renewal- Effective Page 75 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.352(10) 115.352(2) 115.352(2)(A) 115.352(3) 115.352(5) 115.352(7) 115.352(8) 115.357(12) 115.357(8) RSETFUG EU RSETFUG EU RSETFUG EU R5352ALL VOC R5352ALL VOC R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 30 TAC Chapter 115, Pet. 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(3) 115.352(5) 115.352(7) 115.352(8) 115.357(1) 115.357(12) 115.357(8) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(B) 115.352(3) 115.352(4) 115.352(5) 115.352(6) 115.352(7) 115.357(12) 115.357(8) 115.357(9) 115.352(1)(A) 115.352(1) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. No flanges or other connectors shall be allowed to have a VOC leak, for more than 15 days after discovery which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. No valves shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(11) 115.354(3) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) 115.354(1) 115.354(11) 115.354(3) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 115.357(1) 115.354(1) 115.354(10) 115.354(2) 115.354(5) 115.354(6) [G] 115.354(7) 115.354(9) [G] 115.355 No valves shall be allowed to have a VOC leak, for 115.354(1) 115.354(2) NEICVP1446E01 Appendix N Page 78 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) None 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) [G] 115.354(7) 115.352(7) 115.356 [G] 115.354(7) Renewal- Effective Page 76 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSETFUG RSETFUG Unit Group Process Type SOP Index No. EU R5352- ALL EU R5352- ALL Pollutant State Rule or Federal Regulation Name Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(B) 115.352(3) 115.352(4) 115.352(5) 115.352(6) 115.352(7) 115.357(1) 115.357(8) 115.357(9) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(B) 115.352(3) 115.352(4) 115.352(5) 115.352(6) 115.352(7) 115.357(12) 115.357(8) 115.357(9) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(B) 115.352(3) 115.352(4) 115.352(5) 115.352(6) 115.352(7) 115.357(1) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(5) 115.354(6) [G] 115.354(7) 115.354(9) [G] 115.355 115.357(1) No open-ended valves or lines shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(10) 115.354(2) 115.354(5) 115.354(6) [G] 115.354(7) 115.354(9) [G] 115.355 No open-ended valves or lines shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(2) 115.354(5) 115.354(6) [G] 115.354(7) 115.354(9) [G] 115.355 115.357(1) Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) [G] 115.354(7) 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) 115.356(5) [G] 115.354(7) NEICVP1446E01 Appendix N Page 79 of 148 Renewal- Effective Page 77 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSETFUG RSETFUG Unit Group Process Type SOP Index No. EU R5352- ALL EU R5352- ALL Pollutant State Rule or Federal Regulation Name VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.357(8) 115.357(9) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(B) 115.352(3) 115.352(5) 115.352(7) 115.352(9) 115.357(12) 115.357(8) 115.357(9) 115.357(6) RSETFUG EU R5352ALL VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(2)(B) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements No pressure relief valves shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(1) 115.354(10) 115.354(2) 115.354(4) 115.354(5) 115.354(6) [G] 115.354(7) 115.354(9) [G] 115.355 Components at a petroleum refinery or synthetic organic chemical, polymer, resin, or methyl-tert-butyl ether manufacturing process, that contact a process fluid that contains less than 10% VOC by weight and components at a natural gas/gasoline processing operation that contact a process fluid that contains less than 1.0% VOC by weight are exempt from the requirements of this division except 115.356(3)(C) of this title. None No pressure relief valves shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 115.354(1) 115.354(2) 115.354(4) 115.354(5) 115.354(6) [G] 115.354(7) NEICVP1446E01 Appendix N Page 80 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) [G] 115.356(3)(C) 115.356(5) [G] 115.354(7) 115.356 115.356(3) [G] 115.356(3)(C) None 115.352(7) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) [G] 115.356(3)(C) [G] 115.354(7) Renewal- Effective Page 78 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSETFUG Unit Group Process Type SOP Index No. EU R5352- ALL Pollutant State Rule or Federal Regulation Name VOC 30 TAC Chapter 115, Pet. Refinery & Petrochemicals Emission Limitation, Standard or Equipment Specification Citation 115.352(3) 115.352(5) 115.352(7) 115.352(9) 115.357(1) 115.357(8) 115.357(9) 115.352(1)(A) 115.352(1) 115.352(10) 115.352(2) 115.352(2)(A) 115.352(3) 115.352(7) RSETFUG EU RSETFUG EU 61V-ALL VHAP 61V-ALL VHAP 40 CFR Part 61, Subpart V [G] 61.242-8 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 40 CFR Part 61, Subpart V 61.242-9 61.242-1(a) 61.242-1(b) 61.242-1(d) RSETFUG EU 61V-ALL VHAP 40 CFR Part 61, Subpart V [G] 61.242-8 61.242-1(a) 61.242-1(b) 61.242-1(d) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. 115.354(9) [G] 115.355 115.357(1) No process drains shall be allowed to have a VOC leak, for more than 15 days after discovery, which exceeds a screening concentration greater than 500 parts per million by volume above background as methane, or the dripping or exuding of process fluid based on sight, smell, or sound. Comply with standards for flanges and other connectors. 61.242-8(a)(d) 115.354(1) 115.354(10) 115.354(5) 115.354(6) 115.354(9) [G] 115.355 [G] 61.242-8 [G] 61.245(b) [G] 61.245(c) [G] 61.245(d) Each product accumulator vessel shall be equipped with a closed-vent system to capture and transport any leakage from the vessel to a control device as in 61.242-11, except in 61.242-1(c). [G] 61.245(d) Comply with standards for pressure relief devices in liquid service. 61.2428(a)-(d) [G] 61.242-8 [G] 61.245(b) [G] 61.245(c) [G] 61.245(d) NEICVP1446E01 Appendix N Page 81 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 115.356(5) 115.352(7) 115.354(10) 115.356 [G] 115.356(1) [G] 115.356(2) 115.356(3) 115.356(3)(A) 115.356(3)(B) 115.356(5) None [G] 61.246(a) [G] 61.246(b) [G] 61.246(c) [G] 61.246(e) [G] 61.246(i) 61.246(j) [G] 61.246(a) [G] 61.246(e) [G] 61.246(i) 61.246(j) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) [G] 61.246(a) [G] 61.246(b) [G] 61.246(c) [G] 61.246(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) Renewal- Effective Page 79 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation [G] 61.242-10 RSETFUG EU 61V-ALL VHAP 40 CFR Part 61, Subpart V [G] 61.242-7 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 [G] 61.243-1 [G] 61.243-2 RSETFUG EU RSETFUG EU RSETFUG EU RSETFUG EU 61V-ALL VHAP 61V-ALL VHAP 61V-ALL VHAP 61V-ALL VHAP 40 CFR Part 61, Subpart V 40 CFR Part 61, Subpart V 40 CFR Part 61, Subpart V 40 CFR Part 61, Subpart V [G] 61.242-6 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 [G] 61.242-5 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 [G] 61.242-4 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 [G] 61.242-3 61.242-1(a) 61.242-1(b) 61.242-1(d) [G] 61.242-10 RSETFUG EU 61V-ALL VHAP 40 CFR Part 61, Subpart V [G] 61.242-2 61.242-1(a) 61.242-1(b) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Comply with standards for valves. 61.242-7(a)-(h) [G] 61.242-7 [G] 61.243-1 [G] 61.245(b) [G] 61.245(c) [G] 61.245(d) Comply with standards for open-ended valves or lines. 61.242-6(a)-(c) [G] 61.245(d) Comply with standards for sampling connection systems. 61.242-5(a)-(c) [G] 61.245(d) Comply with standards for pressure relief devices in gas/vapor service. 61.242-4(a)-(c) [G] 61.242-4 [G] 61.245(b) [G] 61.245(c) [G] 61.245(d) Comply with standards for compressors. 61.2423(a)-(i) [G] 61.242-3 [G] 61.245(b) [G] 61.245(c) [G] 61.245(d) Comply with standards for pumps. 61.242-2(a)-(g) [G] 61.242-2 [G] 61.245(b) [G] 61.245(c) Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) [G] 61.246(i) 61.246(j) [G] 61.246(a) [G] 61.246(b) [G] 61.246(c) [G] 61.246(e) [G] 61.246(f) [G] 61.246(g) [G] 61.246(i) 61.246(j) [G] 61.246(a) [G] 61.246(e) [G] 61.246(i) 61.246(j) [G] 61.246(a) [G] 61.246(e) [G] 61.246(i) 61.246(j) [G] 61.246(a) [G] 61.246(e) [G] 61.246(i) 61.246(j) [G] 61.246(a) [G] 61.246(b) [G] 61.246(c) [G] 61.246(e) [G] 61.246(h) [G] 61.246(i) 61.246(j) [G] 61.246(a) [G] 61.246(b) [G] 61.246(c) [G] 61.247(a) [G] 61.247(b) 61.247(c) 61.247(d) [G] 61.247(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) [G] 61.247(e) [G] 61.247(a) [G] 61.247(b) 61.247(c) NEICVP1446E01 Appendix N Page 82 of 148 Renewal- Effective Page 80 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation 61.242-1(d) [G] 61.242-10 Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements [G] 61.245(d) RSETFUG EU RSETFUG EU 61V-ALL VHAP 40 CFR Part 61, 61.242-1(e) Subpart V 63H-ALL 112(B) HAPS 40 CFR Part 63, Subpart H [G] 63.167 63.162(a) 63.162(c) [G] 63.162(g) 63.162(h) [G] 63.171 [G] 63.175 Equipment that is in vacuum service is excluded from the requirements of 61.242-2 to 61.242-11, if it is identified as required in 61.246(e)(5). None Standards: Open-ended valves or lines. 63.167(a)(e). [G] 63.175 [G] 63.180(b) [G] 63.180(d) RSETFUG EU 63H-ALL 112(B) HAPS 40 CFR Part 63, Subpart H [G] 63.168 63.162(a) 63.162(c) [G] 63.162(f) [G] 63.162(g) 63.162(h) [G] 63.171 [G] 63.175 Standards: Valves in gas/vapor service and in light liquid service. 63.168(a)-(j) [G] 63.168 [G] 63.175 [G] 63.180(b) [G] 63.180(d) RSETFUG EU 63H-ALL 112(B) HAPS 40 CFR Part 63, Subpart H [G] 63.174 63.162(a) 63.162(c) [G] 63.162(f) [G] 63.162(g) Standards: Connectors in gas/vapor service and in light liquid service. 63.174(a)-(j) [G] 63.174 [G] 63.180(b) [G] 63.180(d) NEICVP1446E01 Appendix N Page 83 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) [G] 61.246(e) [G] 61.246(h) [G] 61.246(i) 61.246(j) [G] 61.246(e) [G] 61.247(e) None 63.181(a) [G] 63.181(b) 63.181(c) 63.181(h) [G] 63.181(h)(1) [G] 63.181(h)(2) 63.181(h)(4) [G] 63.181(h)(5) 63.181(h)(6) 63.181(h)(7) [G] 63.181(i) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(d) 63.181(h) [G] 63.181(h)(1) [G] 63.181(h)(2) 63.181(h)(4) [G] 63.181(h)(5) 63.181(h)(6) 63.181(h)(7) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) Renewal- Effective Page 81 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSETFUG RSETFUG RSETFUG RSETFUG RSETFUG Unit Group Process Type SOP Index No. EU 63H-ALL EU 63H-ALL EU 63H-ALL EU 63H-ALL EU 63H-ALL Pollutant State Rule or Federal Regulation Name 112(B) HAPS 40 CFR Part 63, Subpart H 112(B) HAPS 40 CFR Part 63, Subpart H 112(B) HAPS 40 CFR Part 63, Subpart H 112(B) HAPS 40 CFR Part 63, Subpart H 112(B) HAPS 40 CFR Part 63, Subpart H Emission Limitation, Standard or Equipment Specification Citation 63.162(h) [G] 63.171 [G] 63.173 63.162(a) 63.162(c) [G] 63.162(f) [G] 63.162(g) 63.162(h) [G] 63.171 63.170 63.162(a) 63.162(c) [G] 63.162(g) 63.162(h) [G] 63.171 [G] 63.169 63.162(a) 63.162(c) [G] 63.162(f) [G] 63.162(g) 63.162(h) [G] 63.171 [G] 63.169 63.162(a) 63.162(c) [G] 63.162(f) [G] 63.162(g) 63.162(h) [G] 63.171 [G] 63.169 63.162(a) 63.162(c) [G] 63.162(f) [G] 63.162(g) 63.162(h) [G] 63.171 Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Standards: Agitators gas/vapor service and in light liquid service. 63.173(a)-(j). [G] 63.173 [G] 63.180(b) [G] 63.180(d) Standards: Surge control vessels and bottom receivers. [G] 63.180(b) [G] 63.180(d) Standards: Pressure relief devices in liquid service. 63.169(a)-(d) [G] 63.169 [G] 63.180(b) [G] 63.180(d) Standards: Instrumentation systems. 63.169(a)-(d) [G] 63.169 [G] 63.180(b) [G] 63.180(d) Standards: Agitators in heavy liquid service. 63.169(a)-(d) [G] 63.169 [G] 63.180(b) [G] 63.180(d) Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(d) 63.181(a) [G] 63.181(b) 63.181(c) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(d) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(d) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(d) [G] 63.181(i) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) NEICVP1446E01 Appendix N Page 84 of 148 Renewal- Effective Page 82 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSETFUG RSETFUG RSETFUG RSETFUG RSETFUG RSETFUG Unit Group Process Type SOP Index No. EU 63H-ALL EU 63H-ALL EU 63H-ALL EU 63H-ALL EU 63H-ALL EU 63H-ALL Pollutant State Rule or Federal Regulation Name 112(B) HAPS 40 CFR Part 63, Subpart H 112(B) HAPS 40 CFR Part 63, Subpart H 112(B) HAPS 40 CFR Part 63, Subpart H 112(B) HAPS 40 CFR Part 63, Subpart H 112(B) HAPS 40 CFR Part 63, Subpart H 112(B) HAPS 40 CFR Part 63, Subpart H Emission Limitation, Standard or Equipment Specification Citation [G] 63.169 63.162(a) 63.162(c) [G] 63.162(f) [G] 63.162(g) 63.162(h) [G] 63.171 [G] 63.169 63.162(a) 63.162(c) [G] 63.162(f) [G] 63.162(g) 63.162(h) [G] 63.171 [G] 63.169 63.162(a) 63.162(c) [G] 63.162(f) [G] 63.162(g) 63.162(h) [G] 63.171 [G] 63.166 63.162(a) 63.162(c) [G] 63.162(g) 63.162(h) [G] 63.171 [G] 63.165 63.162(a) 63.162(c) [G] 63.162(g) 63.162(h) [G] 63.171 [G] 63.164 63.162(a) 63.162(c) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Standards: Connectors in heavy liquid service. 63.169(a)-(d) [G] 63.169 [G] 63.180(b) [G] 63.180(d) Standards: Valves in heavy liquid service. 63.169(a)(d) [G] 63.169 [G] 63.180(b) [G] 63.180(d) Standards: Pumps in heavy liquid service. 63.169(a)(d) [G] 63.169 [G] 63.180(b) [G] 63.180(d) Standards: Sampling connection systems. 63.166(a)-(c) [G] 63.180(b) [G] 63.180(d) Standards: Pressure relief device in gas/vapor service. 63.165(a)-(d) [G] 63.165 [G] 63.180(b) [G] 63.180(c) [G] 63.180(d) Standards: Compressors. 63.164(a)-(i) [G] 63.164 [G] 63.180(b) [G] 63.180(c) Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(d) [G] 63.181(i) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(d) [G] 63.181(i) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(d) [G] 63.181(i) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(i) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(f) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) 63.182(c) NEICVP1446E01 Appendix N Page 85 of 148 Renewal- Effective Page 83 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. RSETFUG Unit Group Process Type SOP Index No. EU 63H-ALL Pollutant State Rule or Federal Regulation Name 112(B) HAPS 40 CFR Part 63, Subpart H Emission Limitation, Standard or Equipment Specification Citation [G] 63.162(f) [G] 63.162(g) 63.162(h) [G] 63.171 63.162(e) 63.162(a) 63.162(c) [G] 63.162(g) 63.162(h) RSETFUG EU 63H-ALL 112(B) HAPS 40 CFR Part 63, Subpart H [G] 63.163 63.162(a) 63.162(c) [G] 63.162(f) [G] 63.162(g) 63.162(h) [G] 63.171 [G] 63.176 Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements [G] 63.180(d) Equipment that is in organic HAP service less than 300 hours per year is excluded from the requirements of 63.163 - 63.174 and 63.178 if it is identified as required in 63.181(j). [G] 63.180(d) Standards: Pumps in light liquid service. 63.163(a)-(j) [G] 63.163 [G] 63.176 [G] 63.180(b) [G] 63.180(d) RSETQ142 EU UEHK10 EU R5112003 VOC R7ICI- CO 607 30 TAC Chapter 115, Storage of VOCs 115.111(a)(1) 30 TAC Chapter 117, Subchapter B 117.110(c)(1) 117.110(c) 117.110(c)(1)(A) 117.110(c)(3) Except as provided in 115.118, a storage tank storing VOC with a true vapor pressure less than 1.5 psia is exempt from the requirements of this division. No person shall allow the discharge into the atmosphere from any boiler subject to NOx emission specifications in 117.110(a) CO in excess of 400 ppmv at 3.0% oxygen, dry basis, except [G] 115.117 [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(c) 117.135(d) 117.135(f) 117.135(f)(3) 117.135(g) NEICVP1446E01 Appendix N Page 86 of 148 Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) [G] 63.181(d) [G] 63.181(f) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(i) 63.181(j) 63.181(a) [G] 63.181(b) 63.181(c) [G] 63.181(d) 63.181(h) [G] 63.181(h)(3) 63.181(h)(4) [G] 63.181(h)(5) 63.181(h)(6) 63.181(h)(7) 63.181(h)(8) 115.118(a)(1) 115.118(a)(5) 115.118(a)(7) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) [G] 63.182(a) [G] 63.182(b) [G] 63.182(a) [G] 63.182(b) 63.182(c) [G] 63.182(c)(1) 63.182(c)(4) [G] 63.182(d) None 117.145(a) 117.145(f) [G] 117.145(f)(2) 117.145(f)(8) 117.145(f)(9) 117.8100(a)(5)(C) 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.145(d) 117.145(d)(1) 117.145(d)(2) 117.145(d)(3) Renewal- Effective Page 84 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation UEHK10 EU R7ICI- NOX 607 30 TAC Chapter 117, Subchapter B 117.110(a)(1) 117.110(a) 117.110(b) [G] 117.110(b)(1) 117.130(d) 117.130(d)(1) 117.140(k) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) as provided in 117.125 or 117.110(c)(3). No person shall allow the discharge into the atmosphere from any gasfired boilers with a maximum rated capacity equal to or greater than 40 MMBtu emissions of NOx in excess of 0.10 lb/MMBtu of heat input. 117.140(a)(2)(A) 117.140(b)(1) 117.140(b)(3) 117.140(e) 117.8100(a) 117.8100(a)(1) 117.8100(a)(1)(A) 117.8100(a)(1)(B) 117.8100(a)(1)(B)(ii) 117.8100(a)(1)(B)(iii) 117.8100(a)(1)(C) 117.8100(a)(2) [G] 117.8100(a)(3) 117.8100(a)(4) 117.8100(a)(5) 117.8100(a)(5)(A) 117.8100(a)(5)(B) [G] 117.8100(a)(5)(D) [G] 117.8100(a)(5)(E) 117.8100(a)(6) [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(c) 117.135(d) 117.135(f) 117.135(f)(2) 117.135(g) 117.140(a)(2)(A) 117.140(b)(1) 117.140(b)(3) 117.140(c)(1) [G] 117.140(c)(3) 117.140(e) 117.8100(a) 117.8100(a)(1) 117.8100(a)(1)(A) 117.8100(a)(1)(B) 117.8100(a)(1)(B)(i) 117.145(a) 117.145(f) [G] 117.145(f)(2) 117.145(f)(8) 117.145(f)(9) 117.8100(a)(5)(C) 117.145(d)(4) 117.145(d)(5) 117.8010 [G] 117.8010(1) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) [G] 117.8010(3) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) [G] 117.8010(8) 117.8100(c) 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.145(d) 117.145(d)(1) 117.145(d)(2) 117.145(d)(3) 117.145(d)(4) 117.145(d)(5) 117.8010 [G] 117.8010(1) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) 117.8010(2)(C) 117.8010(2)(D) [G] 117.8010(3) 117.8010(4) NEICVP1446E01 Appendix N Page 87 of 148 Renewal- Effective Page 85 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation UEHK10 EU 60Db- NOX 005 40 CFR Part 60, Subpart Db 60.44b(e) 60.44b(h) 60.44b(i) 60.46b(a) UEHK10 EU 60Db- PM 005 40 CFR Part 60, 60.40b(a) Subpart Db UEHK10 EU 60Db005 PM (Opacity) 40 CFR Part 60, Subpart Db 60.40b(a) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) 117.8100(a)(1)(B)(ii) 117.8100(a)(1)(C) 117.8100(a)(2) [G] 117.8100(a)(3) 117.8100(a)(4) 117.8100(a)(5) 117.8100(a)(5)(A) 117.8100(a)(5)(B) [G] 117.8100(a)(5)(D) [G] 117.8100(a)(5)(E) 117.8100(a)(6) Except in 60.44b(l), on/after 60.8 tests, no facility firing specified fuels shall discharge NOx in excess of the specified formula, unless subject to federal ACF of 10% or less. 60.46b(c) 60.46b(e) 60.46b(e)(1) [G] 60.48b(b) 60.48b(c) 60.48b(d) 60.48b(e) [G] 60.48b(e)(2) 60.48b(e)(3) 60.48b(f) [G] 60.48b(b) 60.48b(c) [G] 60.49b(d) [G] 60.49b(g) 60.49b(o) This subpart applies to each steam generating unit constructed, modified, or reconstructed after 6/19/84, and that has a heat input capacity from fuels combusted in the unit > 29 MW (100 MMBtu/hr). None [G] 60.49b(d) 60.49b(o) This subpart applies to each steam generating unit constructed, modified, or reconstructed after 6/19/84, and that has a heat input capacity from fuels combusted in the unit > 29 MW (100 MMBtu/hr). None [G] 60.49b(d) 60.49b(o) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) [G] 117.8010(8) 117.8100(c) 60.49b(a) 60.49b(a)(1) 60.49b(a)(2) 60.49b(a)(3) 60.49b(b) 60.49b(i) 60.49b(v) 60.49b(w) 60.49b(a) 60.49b(a)(1) 60.49b(a)(3) 60.49b(a) 60.49b(a)(1) 60.49b(a)(3) NEICVP1446E01 Appendix N Page 88 of 148 Renewal- Effective Page 86 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. UEHK10 UEHK11 UEHK11 UEHK11 UEHK11 Unit Group Process Type SOP Index No. EU 60Db- 005 EU 60Db- 002x EU 60Db- 002x EU 60Db- 002x EU 63DDDD D Pollutant State Rule or Federal Regulation Name SO2 40 CFR Part 60, Subpart Db PM 40 CFR Part 60, Subpart Db PM (Opacity) 40 CFR Part 60, Subpart Db SO2 40 CFR Part 60, Subpart Db 112(B) HAPS 40 CFR Part 63, Subpart DDDDD Emission Limitation, Standard or Equipment Specification Citation 60.40b(a) 60.40b(a) 60.40b(a) 60.40b(a) 63.7505 The permit holder shall comply with the applicable limitation, standard and/or Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) This subpart applies to each steam generating unit constructed, modified, or reconstructed after 6/19/84, and that has a heat input capacity from fuels combusted in the unit > 29 MW (100 MMBtu/hr). None This subpart applies to each steam generating unit constructed, modified, or reconstructed after 6/19/84, and that has a heat input capacity from fuels combusted in the unit > 29 MW (100 MMBtu/hr). None This subpart applies to each steam generating unit constructed, modified, or reconstructed after 6/19/84, and that has a heat input capacity from fuels combusted in the unit > 29 MW (100 MMBtu/hr). None This subpart applies to each steam generating unit constructed, modified, or reconstructed after 6/19/84, and that has a heat input capacity from fuels combusted in the unit > 29 MW (100 MMBtu/hr). None The permit holder shall comply with the applicable requirements of 40 CFR Part 63, Subpart DDDDD The permit holder shall comply with the applicable monitoring and testing requirements of 40 [G] 60.49b(d) 60.49b(o) [G] 60.49b(d) 60.49b(o) [G] 60.49b(d) 60.49b(o) [G] 60.49b(d) 60.49b(o) The permit holder shall comply with the applicable recordkeeping requirements of 40 60.49b(a) 60.49b(a)(1) 60.49b(a)(3) 60.49b(a) 60.49b(a)(1) 60.49b(a)(3) 60.49b(a) 60.49b(a)(1) 60.49b(a)(3) 60.49b(a) 60.49b(a)(1) 60.49b(a)(3) The permit holder shall comply with the applicable reporting requirements of 40 CFR Part 63, Subpart NEICVP1446E01 Appendix N Page 89 of 148 Renewal- Effective Page 87 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. UEHK9 UEHK9 Unit Group Process Type SOP Index No. EU R7ICI- 607 EU R7ICI- 607 Pollutant State Rule or Federal Regulation Name CO 30 TAC Chapter 117, Subchapter B NOX 30 TAC Chapter 117, Subchapter B Emission Limitation, Standard or Equipment Specification Citation Textual Description (See Special Term and Condition 1.B.) equipment specification requirements of 40 CFR Part 63, Subpart DDDDD 117.110(c)(1) 117.110(c) 117.110(c)(1)(A) 117.110(c)(3) No person shall allow the discharge into the atmosphere from any boiler subject to NOx emission specifications in 117.110(a) CO in excess of 400 ppmv at 3.0% oxygen, dry basis, except as provided in 117.125 or 117.110(c)(3). 117.110(a)(1) 117.110(a) 117.110(b) [G] 117.110(b)(1) 117.130(d) No person shall allow the discharge into the atmosphere from any gasfired boilers with a maximum rated capacity Monitoring And Testing Requirements Recordkeeping Requirements (30 TAC 122.144) CFR Part 63, Subpart DDDDD CFR Part 63, Subpart DDDDD [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(c) 117.135(d) 117.135(f) 117.135(f)(3) 117.135(g) 117.140(a)(2)(A) 117.140(b)(1) 117.140(b)(3) 117.140(e) 117.8100(a) 117.8100(a)(1) 117.8100(a)(1)(A) 117.8100(a)(1)(B) 117.8100(a)(1)(B)(ii) 117.8100(a)(1)(B)(iii) 117.8100(a)(1)(C) 117.8100(a)(2) [G] 117.8100(a)(3) 117.8100(a)(4) 117.8100(a)(5) 117.8100(a)(5)(A) 117.8100(a)(5)(B) [G] 117.8100(a)(5)(D) [G] 117.8100(a)(5)(E) 117.8100(a)(6) 117.145(a) 117.145(f) [G] 117.145(f)(2) 117.145(f)(8) 117.145(f)(9) 117.8100(a)(5)(C) [G] 117.135(a)(1) 117.135(a)(4) 117.135(b) 117.135(c) 117.135(d) 117.145(a) 117.145(f) [G] 117.145(f)(2) 117.145(f)(8) 117.145(f)(9) Reporting Requirements (30 TAC 122.145) DDDDD 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.145(d) 117.145(d)(1) 117.145(d)(2) 117.145(d)(3) 117.145(d)(4) 117.145(d)(5) 117.8010 [G] 117.8010(1) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) [G] 117.8010(3) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) [G] 117.8010(8) 117.8100(c) 117.135(b) 117.135(g) [G] 117.145(b) [G] 117.145(c) 117.145(d) NEICVP1446E01 Appendix N Page 90 of 148 Renewal- Effective Page 88 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation 117.130(d)(1) 117.140(k) UEHK9 EU 60Db- NOX 005 40 CFR Part 60, Subpart Db 60.44b(e) 60.44b(h) 60.44b(i) 60.46b(a) UEHK9 EU 60Db- PM 005 40 CFR Part 60, Subpart Db 60.40b(a) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) equal to or greater than 40 MMBtu emissions of NOx in excess of 0.10 lb/MMBtu of heat input. 117.135(f) 117.135(f)(2) 117.135(g) 117.140(a)(2)(A) 117.140(b)(1) 117.140(b)(3) 117.140(c)(1) [G] 117.140(c)(3) 117.140(e) 117.8100(a) 117.8100(a)(1) 117.8100(a)(1)(A) 117.8100(a)(1)(B) 117.8100(a)(1)(B)(i) 117.8100(a)(1)(B)(ii) 117.8100(a)(1)(C) 117.8100(a)(2) [G] 117.8100(a)(3) 117.8100(a)(4) 117.8100(a)(5) 117.8100(a)(5)(A) 117.8100(a)(5)(B) [G] 117.8100(a)(5)(D) [G] 117.8100(a)(5)(E) 117.8100(a)(6) 117.8100(a)(5)(C) Except in 60.44b(l), on/after 60.8 tests, no facility firing specified fuels shall discharge NOx in excess of the specified formula, unless subject to federal ACF of 10% or less. 60.46b(c) 60.46b(e) 60.46b(e)(1) [G] 60.48b(b) 60.48b(c) 60.48b(d) 60.48b(e) [G] 60.48b(e)(2) 60.48b(e)(3) 60.48b(f) [G] 60.48b(b) 60.48b(c) [G] 60.49b(d) [G] 60.49b(g) 60.49b(o) This subpart applies to each None steam generating unit constructed, modified, or [G] 60.49b(d) 60.49b(o) 117.145(d)(1) 117.145(d)(2) 117.145(d)(3) 117.145(d)(4) 117.145(d)(5) 117.8010 [G] 117.8010(1) 117.8010(2) 117.8010(2)(A) 117.8010(2)(B) 117.8010(2)(C) 117.8010(2)(D) [G] 117.8010(3) 117.8010(4) [G] 117.8010(5) 117.8010(6) [G] 117.8010(7) [G] 117.8010(8) 117.8100(c) 60.49b(a) 60.49b(a)(1) 60.49b(a)(2) 60.49b(a)(3) 60.49b(b) 60.49b(i) 60.49b(v) 60.49b(w) 60.49b(a) 60.49b(a)(1) 60.49b(a)(3) NEICVP1446E01 Appendix N Page 91 of 148 Renewal- Effective Page 89 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. Unit Group Process Type SOP Index No. Pollutant State Rule or Federal Regulation Name Emission Limitation, Standard or Equipment Specification Citation UEHK9 EU 60Db005 PM (Opacity) 40 CFR Part 60, Subpart Db 60.40b(a) UEHK9 EU 60Db- SO2 005 40 CFR Part 60, Subpart Db 60.40b(a) UER037 EU R1111002 Opacity 30 TAC Chapter 111, Visible Emissions 111.111(a)(4)(A) UER037 CD 60A-003 Opacity 40 CFR Part 60, Subpart A 60.18(b) 60.18(c)(1) 60.18(c)(2) 60.18(c)(3)(ii) 60.18(c)(4)(i) 60.18(c)(6) 60.18(e) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) reconstructed after 6/19/84, and that has a heat input capacity from fuels combusted in the unit > 29 MW (100 MMBtu/hr). This subpart applies to each steam generating unit constructed, modified, or reconstructed after 6/19/84, and that has a heat input capacity from fuels combusted in the unit > 29 MW (100 MMBtu/hr). None This subpart applies to each steam generating unit constructed, modified, or reconstructed after 6/19/84, and that has a heat input capacity from fuels combusted in the unit > 29 MW (100 MMBtu/hr). None Visible emissions from a process gas flare shall not be permitted for more than five minutes in any two-hour period. Non-excessive upset events are subject to the provisions under 101.222(b). 111.111(a)(4)(A)(i) 111.111(a)(4)(A)(ii) Flares shall comply with paragraphs (c)-(f) of 60.18. 60.18(d) 60.18(f)(1) 60.18(f)(2) 60.18(f)(3) 60.18(f)(4) [G] 60.49b(d) 60.49b(o) [G] 60.49b(d) 60.49b(o) 111.111(a)(4)(A)(ii) None 60.49b(a) 60.49b(a)(1) 60.49b(a)(3) 60.49b(a) 60.49b(a)(1) 60.49b(a)(3) None None NEICVP1446E01 Appendix N Page 92 of 148 Renewal- Effective Page 90 Indorama Ventures Oxides LLC Port Neches, Texas Applicable Requirements Summary Unit Group Process ID No. UER044 Unit Group Process Type SOP Index No. EU R1111- 002 Pollutant State Rule or Federal Regulation Name Opacity 30 TAC Chapter 111, Visible Emissions Emission Limitation, Standard or Equipment Specification Citation 111.111(a)(4)(A) UER044 CD UER046 EU 60A-003 Opacity R1111002 Opacity 40 CFR Part 60, Subpart A 30 TAC Chapter 111, Visible Emissions 60.18(b) 60.18(c)(1) 60.18(c)(2) 60.18(c)(3)(ii) 60.18(c)(4)(i) 60.18(c)(6) 60.18(e) 111.111(a)(4)(A) UER046 CD 60A-003 Opacity 40 CFR Part 60, Subpart A 60.18(b) 60.18(c)(1) 60.18(c)(2) 60.18(c)(3)(ii) 60.18(c)(4)(i) 60.18(c)(6) 60.18(e) Textual Description (See Special Term and Condition 1.B.) Monitoring And Testing Requirements Recordkeeping Requirements Reporting Requirements (30 TAC 122.144) (30 TAC 122.145) Visible emissions from a process gas flare shall not be permitted for more than five minutes in any two-hour period. Non-excessive upset events are subject to the provisions under 101.222(b). 111.111(a)(4)(A)(i) 111.111(a)(4)(A)(ii) Flares shall comply with paragraphs (c)-(f) of 60.18. 60.18(d) 60.18(f)(1) 60.18(f)(2) 60.18(f)(3) 60.18(f)(4) 111.111(a)(4)(A)(ii) None None None Visible emissions from a process gas flare shall not be permitted for more than five minutes in any two-hour period. Non-excessive upset events are subject to the provisions under 101.222(b). 111.111(a)(4)(A)(i) 111.111(a)(4)(A)(ii) Flares shall comply with paragraphs (c)-(f) of 60.18. 60.18(d) 60.18(f)(1) 60.18(f)(2) 60.18(f)(3) 60.18(f)(4) 111.111(a)(4)(A)(ii) None None None NEICVP1446E01 Appendix N Page 93 of 148 Renewal- Effective Page 91 Indorama Ventures Oxides LLC Port Neches, Texas Additional Monitoring Requirements Periodic Monitoring Summary ................................................................................................................. 93 NEICVP1446E01 Appendix N Page 94 of 148 Renewal- Effective Page 92 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: A3FA3103 Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 115, Vent Gas Controls SOP Index No.: R5121-3 Pollutant: VOC Main Standard: 115.122(a)(2) Monitoring Information Indicator: VOC Concentration Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to measure and record fugitive emissions. Periodic Monitoring Text: Measure and record fugitive emissions from the vapor collection system in accordance with part 60, appendix A, method 21. NEICVP1446E01 Appendix N Page 95 of 148 Renewal- Effective Page 93 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: A3FA3103 Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 115, Vent Gas Controls SOP Index No.: R5121-3 Pollutant: VOC Main Standard: 115.122(a)(2) Monitoring Information Indicator: Visual Inspection Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to conduct inspections or repair any defects in vapor collection system shall be considered and reported as a deviation. Periodic Monitoring Text: Visually inspect all components of the vapor collection system for defects, such as cracks, holes, gaps, loose connections, or broken or missing covers or other closure devices, that could result in air emissions. NEICVP1446E01 Appendix N Page 96 of 148 Renewal- Effective Page 94 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: A3FA3205A Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 115, Vent Gas Controls SOP Index No.: R5121-6 Pollutant: VOC Main Standard: 115.122(a)(1) Monitoring Information Indicator: VOC Concentration Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to measure and record fugitive emissions. Periodic Monitoring Text: Measure and record fugitive emissions from the vapor collection system in accordance with part 60, appendix A, method 21. NEICVP1446E01 Appendix N Page 97 of 148 Renewal- Effective Page 95 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: A3FA3205A Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 115, Vent Gas Controls SOP Index No.: R5121-6 Pollutant: VOC Main Standard: 115.122(a)(1) Monitoring Information Indicator: Visual Inspection Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to conduct inspections or repair any defects in vapor collection system shall be considered and reported as a deviation. Periodic Monitoring Text: Visually inspect all components of the vapor collection system for defects, such as cracks, holes, gaps, loose connections, or broken or missing covers or other closure devices, that could result in air emissions. NEICVP1446E01 Appendix N Page 98 of 148 Renewal- Effective Page 96 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: A3FA3205B Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 115, Vent Gas Controls SOP Index No.: R5121-6 Pollutant: VOC Main Standard: 115.122(a)(1) Monitoring Information Indicator: VOC Concentration Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to measure and record fugitive emissions. Periodic Monitoring Text: Measure and record fugitive emissions from the vapor collection system in accordance with part 60, appendix A, method 21. NEICVP1446E01 Appendix N Page 99 of 148 Renewal- Effective Page 97 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: A3FA3205B Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 115, Vent Gas Controls SOP Index No.: R5121-6 Pollutant: VOC Main Standard: 115.122(a)(1) Monitoring Information Indicator: Visual Inspection Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to conduct inspections or repair any defects in vapor collection system shall be considered and reported as a deviation. Periodic Monitoring Text: Visually inspect all components of the vapor collection system for defects, such as cracks, holes, gaps, loose connections, or broken or missing covers or other closure devices, that could result in air emissions. NEICVP1446E01 Appendix N Page 100 of 148 Renewal- Effective Page 98 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: A3FA357 Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 115, Vent Gas Controls SOP Index No.: R5121-6 Pollutant: VOC Main Standard: 115.122(a)(1) Monitoring Information Indicator: VOC Concentration Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to measure and record fugitive emissions. Periodic Monitoring Text: Measure and record fugitive emissions from the vapor collection system in accordance with part 60, appendix A, method 21. NEICVP1446E01 Appendix N Page 101 of 148 Renewal- Effective Page 99 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: A3FA357 Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 115, Vent Gas Controls SOP Index No.: R5121-6 Pollutant: VOC Main Standard: 115.122(a)(1) Monitoring Information Indicator: Visual Inspection Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to conduct inspections or repair any defects in vapor collection system shall be considered and reported as a deviation. Periodic Monitoring Text: Visually inspect all components of the vapor collection system for defects, such as cracks, holes, gaps, loose connections, or broken or missing covers or other closure devices, that could result in air emissions. NEICVP1446E01 Appendix N Page 102 of 148 Renewal- Effective Page 100 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: A3FO11 Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 115, Vent Gas Controls SOP Index No.: R5121-6 Pollutant: VOC Main Standard: 115.122(a)(1) Monitoring Information Indicator: VOC Concentration Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to measure and record fugitive emissions. Periodic Monitoring Text: Measure and record fugitive emissions from the vapor collection system in accordance with part 60, appendix A, method 21. NEICVP1446E01 Appendix N Page 103 of 148 Renewal- Effective Page 101 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: A3FO11 Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 115, Vent Gas Controls SOP Index No.: R5121-6 Pollutant: VOC Main Standard: 115.122(a)(1) Monitoring Information Indicator: Visual Inspection Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to conduct inspections or repair any defects in vapor collection system shall be considered and reported as a deviation. Periodic Monitoring Text: Visually inspect all components of the vapor collection system for defects, such as cracks, holes, gaps, loose connections, or broken or missing covers or other closure devices, that could result in air emissions. NEICVP1446E01 Appendix N Page 104 of 148 Renewal- Effective Page 102 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: A3TA339 Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 115, Storage of VOCs SOP Index No.: R5112-005 Pollutant: VOC Main Standard: 115.112(a)(1) Monitoring Information Indicator: Record of Tank Construction Specifications Minimum Frequency: N/A Averaging Period: N/A Deviation Limit: Records are not kept. Periodic Monitoring Text: Keep a record of tank construction specifications (e.g. engineering drawings) that show a fill pipe that extends from the top of a tank to have a maximum clearance of six inches (15.2 centimeters) from the bottom or, when the tank is loaded from the side, a discharge opening entirely submerged when the pipe used to withdraw liquid from the tank can no longer withdraw liquid in normal operation. NEICVP1446E01 Appendix N Page 105 of 148 Renewal- Effective Page 103 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: A3TA339 Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 115, Storage of VOCs SOP Index No.: R5112-005 Pollutant: VOC Main Standard: 115.112(a)(1) Monitoring Information Indicator: Structural Integrity of the Pipe Minimum Frequency: Emptied and degassed Averaging Period: N/A Deviation Limit: Fill pipe repairs not completed prior to refilling storage vessel. Periodic Monitoring Text: Inspect to determine the structural integrity of the fill pipe and record each time the storage vessel is emptied and degassed to ensure that it continues to meet the specifications in the above requirement. If the structural integrity of the fill pipe is in question, repairs shall be made before the storage vessel is refilled. It shall be considered and reported as a deviation if the repairs are not completed prior to refilling the storage vessel. NEICVP1446E01 Appendix N Page 106 of 148 Renewal- Effective Page 104 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: GRPA3PH1 Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 30 TAC Chapter 117, Subchapter B SOP Index No.: R7ICI-503 Pollutant: CO Main Standard: 117.110(c)(1) Monitoring Information Indicator: CO Concentration Minimum Frequency: Biennially (Every 2 years) Averaging Period: N/A Deviation Limit: Maximum CO concentration shall not exceed 400 ppmv at 3.0% O2. Periodic Monitoring Text: For boilers or process heaters with a heat input capacity of less than 10 MMBtu/hr. but greater than 5 MMBtu/hr., you must conduct a tune-up biennially (every 2 years) as specified in 40 CFR 63 Subpart DDDDD, 63.7540(a)(11) and 63.7540(a)(10)(i)-(vi) to demonstrate continuous compliance. Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer. NEICVP1446E01 Appendix N Page 107 of 148 Renewal- Effective Page 105 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: RSET087 Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 40 CFR Part 60, Subpart Kb SOP Index No.: 60Kb-36 Pollutant: VOC Main Standard: [G] 60.112b(a)(3) Monitoring Information Indicator: VOC Concentration Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to measure and record fugitive emissions. Periodic Monitoring Text: Measure and record fugitive emissions from the vapor collection system in accordance with part 60, appendix A, method 21. NEICVP1446E01 Appendix N Page 108 of 148 Renewal- Effective Page 106 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: RSET087 Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 40 CFR Part 60, Subpart Kb SOP Index No.: 60Kb-36 Pollutant: VOC Main Standard: [G] 60.112b(a)(3) Monitoring Information Indicator: Visual Inspection Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to conduct inspections or repair any defects in vapor collection system shall be considered and reported as a deviation. Periodic Monitoring Text: Visually inspect all components of the vapor collection system for defects, such as cracks, holes, gaps, loose connections, or broken or missing covers or other closure devices, that could result in air emissions. NEICVP1446E01 Appendix N Page 109 of 148 Renewal- Effective Page 107 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: RSET088 Control Device ID No.: UERO44 Control Device Type: Flare Applicable Regulatory Requirement Name: 40 CFR Part 60, Subpart Kb SOP Index No.: 60Kb-36 Pollutant: VOC Main Standard: [G] 60.112b(a)(3) Monitoring Information Indicator: VOC Concentration Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to measure and record fugitive emissions Periodic Monitoring Text: Measure and record fugitive emissions from the vapor collection system in accordance with part 60, appendix A, method 21. NEICVP1446E01 Appendix N Page 110 of 148 Renewal- Effective Page 108 Indorama Ventures Oxides LLC Port Neches, Texas Periodic Monitoring Summary Unit/Group/Process Information ID No.: RSET088 Control Device ID No.: N/A Control Device Type: N/A Applicable Regulatory Requirement Name: 40 CFR Part 60, Subpart Kb SOP Index No.: 60Kb-36 Pollutant: VOC Main Standard: [G] 60.112b(a)(3) Monitoring Information Indicator: Visual Inspection Minimum Frequency: Once per year Averaging Period: N/A Deviation Limit: Failure to conduct inspections or repair any defects in vapor collection system shall be considered and reported as a deviation. Periodic Monitoring Text: Visually inspect all components of the vapor collection system for defects, such as cracks, holes, gaps, loose connections, or broken or missing covers or other closure devices, that could result in air emissions. NEICVP1446E01 Appendix N Page 111 of 148 Renewal- Effective Page 109 Indorama Ventures Oxides LLC Port Neches, Texas Permit Shield Permit Shield .......................................................................................................................................... 111 NEICVP1446E01 Appendix N Page 112 of 148 Renewal- Effective Page 110 Indorama Ventures Oxides LLC Port Neches, Texas Permit Shield The Executive Director of the TCEQ has determined that the permit holder is not required to comply with the specific regulation(s) identified for each emission unit, group, or process in this table. Unit / Group / Process ID No. Group / Inclusive Units Regulation Basis of Determination 0674 N/A 0674 N/A 0674 N/A 961009 N/A 961009 N/A 961009 N/A 970183 N/A 970183 N/A 970183 N/A A3HA33 N/A A3HA34 N/A 30 TAC Chapter 115, Storage of VOCs 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 30 TAC Chapter 115, Storage of VOCs 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 30 TAC Chapter 115, Storage of VOCs 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 40 CFR Part 63, Subpart DDDDD 40 CFR Part 63, Subpart DDDDD Tank capacity is less than 1,000 gallons. Tank stores VOC (but not petroleum or petroleum liquids) and was constructed before 7/23/84 and has not been modified later than 7/23/84. Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Tank capacity is less than 1,000 gallons. Tank capacity is less than 40 cubic meters (10,567 gallons). Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Tank capacity is less than 1,000 gallons. Tank capacity is less than 40 cubic meters (10,567 gallons). Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Unit is a process heater that is used as a control device to comply with another standard. At least 50% of the average annual heat input is provided by regulated gas streams that are subject to another standard. Unit is a process heater that is used as a control device to comply with another standard. At least 50% of the average annual heat input is provided by regulated gas streams that are NEICVP1446E01 Appendix N Page 113 of 148 Renewal- Effective Page 111 Indorama Ventures Oxides LLC Port Neches, Texas Permit Shield The Executive Director of the TCEQ has determined that the permit holder is not required to comply with the specific regulation(s) identified for each emission unit, group, or process in this table. Unit / Group / Process ID No. Group / Inclusive Units Regulation Basis of Determination A3HA35 N/A A3HA35 N/A A3TA329 N/A A3TA329 N/A A3TA339 N/A A3TA339 N/A A3TA346 N/A A3TA346 N/A CT-1 N/A CT-10 N/A 40 CFR Part 60, Subpart Db 40 CFR Part 63, Subpart DDDDD 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 40 CFR Part 63, Subpart Q 40 CFR Part 63, Subpart Q subject to another standard. Boiler was constructed before 6/19/84 and has not been modified later than 6/19/84. Unit is a waste heat boiler which is excluded from applicability based on the definition of a boiler. Tank capacity is greater than 75 cubic meters (19,813 gal) but less than 151 cubic meters (39,890 gal) and maximum true vapor pressure of the liquid stored is less than 15.0 kPa (2.2 psia). Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Tank capacity is less than 40 cubic meters (10,567 gallons). Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Tank capacity is less than 40 cubic meters (10,567 gallons). Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Cooling tower is not operated with chromiumbased water treatment chemicals from September 8, 1994. Cooling tower is not operated with chromiumbased water treatment chemicals from NEICVP1446E01 Appendix N Page 114 of 148 Renewal- Effective Page 112 Indorama Ventures Oxides LLC Port Neches, Texas Permit Shield The Executive Director of the TCEQ has determined that the permit holder is not required to comply with the specific regulation(s) identified for each emission unit, group, or process in this table. Unit / Group / Process ID No. Group / Inclusive Units Regulation Basis of Determination CT-4 FDU-1 FDU-1 GRPA3PH1 GRPUTIC1 GRPUTIC1 GRPUTTK1 GRPUTTK1 MCST-1 MCST-1 N/A 40 CFR Part 63, Subpart Q N/A 40 CFR Part 60, Subpart Kb N/A A3HA31A, A3HA31B, A3HA31C, A3HA31D, A3HA31F, A3HA31G, A3HA31H, A3HA31J PU-10, PU-14A, PU-14B 40 CFR Part 63, Subpart G 40 CFR Part 60, Subpart RRR 30 TAC Chapter 117, Subchapter B PU-10, PU-14A, PU-14B 40 CFR Part 60, Subpart IIII 880789, 961010, A3FA3215, MCST-3, 40 CFR Part 60, Subpart Kb R-CC-4T, R-S-42T, R-S-53T, T-L797455 880789, 961010, A3FA3215, MCST-3, 40 CFR Part 63, Subpart G R-CC-4T, R-S-42T, R-S-53T, T-L797455 N/A 30 TAC Chapter 115, Storage of VOCs N/A 40 CFR Part 60, Subpart Kb September 8, 1994. Cooling tower is not operated with chromiumbased water treatment chemicals from September 8, 1994. Tank stores VOC (but not petroleum or petroleum liquids) and was constructed before 7/23/84 and has not been modified later than 7/23/84. Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Reactor process constructed before 6/29/90 and has not been modified later than 6/29/90. Unit was placed into service after November 15, 1992 and is not a functionally identical replacement. Unit did not commence construction/reconstruction after 07/11/2005. Tank capacity is less than 40 cubic meters (10,567 gallons). Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Tank capacity is less than 1,000 gallons. Tank capacity is less than 40 cubic meters NEICVP1446E01 Appendix N Page 115 of 148 Renewal- Effective Page 113 Indorama Ventures Oxides LLC Port Neches, Texas Permit Shield The Executive Director of the TCEQ has determined that the permit holder is not required to comply with the specific regulation(s) identified for each emission unit, group, or process in this table. Unit / Group / Process ID No. Group / Inclusive Units Regulation Basis of Determination MCST-1 N/A MCST-2 N/A MCST-2 N/A MCST-2 N/A P-Q-108 N/A P-T-39 N/A P-T-39 N/A P-T-39 N/A PU-11 N/A R-CC-4 N/A R-S-42 N/A R-S-53 N/A 40 CFR Part 63, Subpart G 30 TAC Chapter 115, Storage of VOCs 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 40 CFR Part 60, Subpart IIII 30 TAC Chapter 115, Storage of VOCs 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 40 CFR Part 60, Subpart IIII 40 CFR Part 60, Subpart IIII 40 CFR Part 60, Subpart IIII 40 CFR Part 60, Subpart IIII (10,567 gallons). Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Tank capacity is less than 1,000 gallons. Tank capacity is less than 40 cubic meters (10,567 gallons). Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Unit did not commence construction or modification/reconstruction after 07/11/2005. Storage vessel is located at a motor vehicle fuel dispensing facility and has capacity less than 25,000 gallons. Tank capacity is less than 40 cubic meters (10,567 gallons). Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Unit did not commence construction/reconstruction after 07/11/2005. Unit did not commence construction/reconstruction after 07/11/2005. Unit did not commence construction/reconstruction after 07/11/2005. Unit did not commence construction/reconstruction after 07/11/2005. NEICVP1446E01 Appendix N Page 116 of 148 Renewal- Effective Page 114 Indorama Ventures Oxides LLC Port Neches, Texas Permit Shield The Executive Director of the TCEQ has determined that the permit holder is not required to comply with the specific regulation(s) identified for each emission unit, group, or process in this table. Unit / Group / Process ID No. Group / Inclusive Units Regulation Basis of Determination R-S-53 N/A RSELRVNTTW N/A RSET010 N/A RSET0126 N/A RSET0126 N/A RSET0127 N/A RSET0127 N/A RSET0180 N/A RSET0204 N/A 40 CFR Part 63, Subpart ZZZZ 40 CFR Part 63, Subpart G 40 CFR Part 60, Subpart Kb 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 40 CFR Part 60, Subpart Kb 40 CFR Part 60, Subpart Kb Unit is an existing emergency stationary RICE with a site rating >500 BHP located at a major source of HAP emissions that does not operate or not contractually obligated to be available more than 15 hours per calendar year as in 63.6640(f)(2)(ii)-(i Not subject to 40 CFR Subpart F-transfer rack is not a HON Group 1 or Group 2 transfer rack. As HON Group 1 or Group 2 storage vessel, tank is required to comply only with the provisions of HON. Tank stores VOC (but not petroleum or petroleum liquids) and was constructed before 7/23/84 and has not been modified later than 7/23/84. Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Tank stores VOC (but not petroleum or petroleum liquids) and was constructed before 7/23/84 and has not been modified later than 7/23/84. Not subject to 40 CFR 63, Subpart F - tank is not a HON GROUP 1 or GROUP 2 storage vessel As HON Group 1 or Group 2 storage vessel, tank is required to comply only with the provisions of HON. As HON Group 1 or Group 2 storage vessel, NEICVP1446E01 Appendix N Page 117 of 148 Renewal- Effective Page 115 Indorama Ventures Oxides LLC Port Neches, Texas Permit Shield The Executive Director of the TCEQ has determined that the permit holder is not required to comply with the specific regulation(s) identified for each emission unit, group, or process in this table. Unit / Group / Process ID No. Group / Inclusive Units Regulation Basis of Determination RSET030 N/A RSET039 N/A RSET039 N/A RSET040 N/A RSET040 N/A RSET087 N/A RSET087 N/A RSET088 N/A RSETFUG N/A 40 CFR Part 60, Subpart Kb 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 30 TAC Chapter 115, Water Separation 40 CFR Part 63, Subpart G 40 CFR Part 63, Subpart G 40 CFR Part 60, Subpart VV tank is required to comply only with the provisions of HON. As HON Group 1 or Group 2 storage vessel, tank is required to comply only with the provisions of HON. Tank capacity is greater than 151 cubic meters (39,890 gallons) and maximum true vapor pressure of the liquid stored is less than 3.5kPa (0.5 psia). Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Tank capacity is greater than 151 cubic meters (39,890 gallons) and maximum true vapor pressure of the liquid stored is less than 3.5kPa (0.5 psia). Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Vessel is primarily a storage tank. As such, it complies with 30 TAC 115 storage vessel provisions and not 30 TAC 115 VOC water separator provisions. Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Not subject to 40 CFR 63 Subject F-tank is not a HON Group 1 or Group 2 storage vessel. For fugitive components, Huntsman has elected to comply with the requirements of 40 CFR 63, NEICVP1446E01 Appendix N Page 118 of 148 Renewal- Effective Page 116 Indorama Ventures Oxides LLC Port Neches, Texas Permit Shield The Executive Director of the TCEQ has determined that the permit holder is not required to comply with the specific regulation(s) identified for each emission unit, group, or process in this table. Unit / Group / Process ID No. Group / Inclusive Units Regulation Basis of Determination RSETQ142 N/A RSETQ142 N/A UEHK10 N/A UEHK9 N/A UER037 N/A UER044 N/A UER046 N/A 40 CFR Part 60, Subpart Kb 40 CFR Part 63, Subpart G 40 CFR Part 63, Subpart DDDDD 40 CFR Part 63, Subpart DDDDD 40 CFR Part 63, Subpart A 40 CFR Part 63, Subpart A 40 CFR Part 63, Subpart A Subpart H, and not the requirements of 40 CFR 60, Subpart VV. Tank capacity is less than 40 cubic meters (10,567 gallons). Not subject to 40 CFR 63 Subpart F-tank is not a HON Group 1 or Group 2 storage vessel. Unit is a waste heat boiler which is excluded from applicability based on the definition of a boiler. Unit is a waste heat boiler which is excluded from applicability based on the definition of a boiler. Flare is not used to comply with applicable subparts of part 63. Flare is not used to comply with applicable subparts of part 63. Flare is not used to comply with applicable subparts of part 63. NEICVP1446E01 Appendix N Page 119 of 148 Renewal- Effective Page 117 Indorama Ventures Oxides LLC Port Neches, Texas New Source Review Authorization References New Source Review Authorization References ................................................................................... 119 New Source Review Authorization References by Emission Unit ..................................................... 121 NEICVP1446E01 Appendix N Page 120 of 148 Renewal- Effective Page 118 Indorama Ventures Oxides LLC Port Neches, Texas New Source Review Authorization References The New Source Review authorizations listed in the table below are applicable requirements under 30 TAC Chapter 122 and enforceable under this operating permit. Prevention of Significant Deterioration (PSD) Permits PSD Permit No.: PSDTX780 Issuance Date: 01/15/2016 Title 30 TAC Chapter 116 Permits, Special Permits, and Other Authorizations (Other Than Permits By Rule, PSD Permits, or NA Permits) for the Application Area. Authorization No.: 16909 Issuance Date: 01/15/2016 Authorization No.: 19823 Issuance Date: 05/28/2019 Authorization No.: 29516 Issuance Date: 05/31/2018 Authorization No.: 49247 Issuance Date: 10/12/2020 Authorization No.: 56390 Issuance Date: 05/13/2014 Authorization No.: 83816 Issuance Date: 11/30/2020 Permits By Rule (30 TAC Chapter 106) for the Application Area Number: 5 Version No./Date: 09/23/1982 Number: 5 Version No./Date: 03/15/1985 Number: 5 Version No./Date: 11/05/1986 Number: 5 Version No./Date: 08/30/1988 Number: 5 Version No./Date: 07/20/1992 Number: 5 Version No./Date: 10/04/1995 Number: 14 Version No./Date: 01/08/1980 Number: 14 Version No./Date: 09/12/1989 Number: 51 Version No./Date: 11/05/1986 Number: 51 Version No./Date: 08/30/1988 Number: 51 Version No./Date: 07/20/1992 Number: 51 Version No./Date: 06/07/1996 Number: 58 Version No./Date: 01/08/1980 Number: 80 Version No./Date: 01/08/1980 Number: 86 Version No./Date: 07/20/1992 Number: 106.261 Version No./Date: 09/04/2000 Number: 106.262 Version No./Date: 09/04/2000 Number: 106.263 Version No./Date: 11/01/2001 Number: 106.264 Version No./Date: 09/04/2000 Number: 106.355 Version No./Date: 11/01/2001 Number: 106.371 Version No./Date: 09/04/2000 Number: 106.433 Version No./Date: 09/04/2000 NEICVP1446E01 Appendix N Page 121 of 148 Renewal- Effective Page 119 Indorama Ventures Oxides LLC Port Neches, Texas New Source Review Authorization References The New Source Review authorizations listed in the table below are applicable requirements under 30 TAC Chapter 122 and enforceable under this operating permit. Number: 106.452 Number: 106.454 Number: 106.472 Number: 106.473 Number: 106.478 Number: 106.511 Version No./Date: 09/04/2000 Version No./Date: 11/01/2001 Version No./Date: 09/04/2000 Version No./Date: 03/14/1997 Version No./Date: 03/14/1997 Version No./Date: 03/14/1997 NEICVP1446E01 Appendix N Page 122 of 148 Renewal- Effective Page 120 Indorama Ventures Oxides LLC Port Neches, Texas New Source Review Authorization References by Emissions Unit The following is a list of New Source Review (NSR) authorizations for emission units listed elsewhere in this operating permit. The NSR authorizations are applicable requirements under 30 TAC Chapter 122 and enforceable under this operating permit. Unit/Group/Process ID No. 0674 880789 961009 961010 970183 A3CA31A A3FA3103 A3FA3205A A3FA3205B A3FA3215 A3FA357 A3FO11 A3FUG A3HA31A A3HA31B A3HA31C A3HA31D A3HA31E A3HA31F A3HA31G A3HA31H Emission Unit Name/Description COOLING TOWER 4GREY METAL SLIMICIDE TANK YELLOW FIBERGLASS BALANCED POLYMER TANK BOILER HOUSE WHITE STEEL STEAMATE TANK BOILER HOUSE WHITE STEEL STEAMATE TANK COOLING TOWER 4 YELLOW FIBERGLASS DIANODIC TANK TURBINE C-A3-1 DEMETHANIZER WASTEWATER STRIPPER WASTEWATER STRIPPER DMDS TANK FUEL GAS MIXING DRUM F-O-11 COALESCER FUGITIVES CRACKING HEATER CRACKING HEATER CRACKING HEATER CRACKING HEATER CRACKING HEATER CRACKING HEATER CRACKING HEATER CRACKING HEATER NEICVP1446E01 Appendix N Page 123 of 148 New Source Review Authorization 106.478/03/14/1997 51/11/05/1986 86/07/20/1992 86/07/20/1992 51/11/05/1986 19823 19823 19823 19823 19823 19823 19823 19823 19823 19823 19823 19823 19823 19823 19823 19823 Renewal- Effective Page 121 Indorama Ventures Oxides LLC Port Neches, Texas New Source Review Authorization References by Emissions Unit The following is a list of New Source Review (NSR) authorizations for emission units listed elsewhere in this operating permit. The NSR authorizations are applicable requirements under 30 TAC Chapter 122 and enforceable under this operating permit. Unit/Group/Process ID No. A3HA31J A3HA33 A3HA34 A3HA35 A3TA329 A3TA339 A3TA346 A3WASTE CG1 CG2 CT-1 CT-10 CT-4 FDU-1 MCST-1 MCST-2 MCST-3 P-Q-108 P-T-39 PROA3WW PRORSHON Emission Unit Name/Description CRACKING HEATER HEATER H -A3-3 HEATER H-A3-4 WASTE HEAT BOILER TANK T-A3-29 TANK T-A3-39 TAR SETTLING TANK A3 WASTE STREAMS 37 MEGAWATT GE FRAME 6 GAS TURBINE 37 MEGAWATT GE FRAME 6 GAS TURBINE COOLING TOWER NO. 1 COOLING TOWER NO. 10 COOLING TOWER NO. 4 DISEL FUEL DISPENSING TANK (GREY) YELLOW FIBERGLASS TANK BY MAINTANCE SHOP GRAY STEEL KEROSENE TANK SOUTH OF FUEL AREA GRAY STEEL DEGREASER SOLVENT TANK FIREWATER PUMP GASOLINE UST FUEL DISPENSING TANK A3 WASTEWATER TREATMENT PROCESS R&S HON PROCESS NEICVP1446E01 Appendix N Page 124 of 148 New Source Review Authorization 19823 19823 19823 19823 19823 19823 19823 19823 16909, PSDTX780 16909, PSDTX780 19823 106.371/09/04/2000 19823 14/01/08/1980 106.473/03/14/1997 58/01/08/1980 80/01/08/1980 5/03/15/1985 14/09/12/1989 19823 29516 Renewal- Effective Page 122 Indorama Ventures Oxides LLC Port Neches, Texas New Source Review Authorization References by Emissions Unit The following is a list of New Source Review (NSR) authorizations for emission units listed elsewhere in this operating permit. The NSR authorizations are applicable requirements under 30 TAC Chapter 122 and enforceable under this operating permit. Unit/Group/Process ID No. PU-10 PU-11 PU-14A PU-14B R-CC-4 R-CC-4T R-S-42 R-S-42T R-S-53 R-S-53T RRFUG RSELRTRKW RSELRVNTTW RSET010 RSET0126 RSET0127 RSET0180 RSET0204 RSET030 RSET039 RSET040 Emission Unit Name/Description UTILITIES FIREWATER PUMP UTILITIES FIREWATER PUMP UTILITIES FIREWATER PUMP UTILITIES FIREWATER PUMP O&O CENTRAL EMERGENCY GENERATOR DIESEL TANK - O&O CENTRAL EMERGENCY GENERATOR UTILITIES BACKUP GENERATOR DIESEL TANK - UTILITIES BACKUP GENERATOR JCO ADMIN. BLDG. EMERGENCY GENERATOR DIESEL TANK - JCO ADMIN. BLDG. EMERGENCY GEN. RAILCAR HEEL EMISSIONS ABOVE GROUND LOADING RACK VENT CONDENSATE T/W LOADING TANK T-0-10 FUGITIVES AROMATIC DISTILLATE TANK AROMATIC DISTILLATE TANK TANK T-0-180 FUGITIVES TANK T-0-204 TANK T-0-30-FUGITIVES TANK T-O-39 TANK T-O-40 NEICVP1446E01 Appendix N Page 125 of 148 New Source Review Authorization 106.511/03/14/1997 5/09/23/1982 5/10/04/1995 5/10/04/1995 5/11/05/1986 51/11/05/1986 5/08/30/1988 51/08/30/1988 5/07/20/1992 51/07/20/1992 56390 106.261/09/04/2000, 106.262/09/04/2000 106.472/09/04/2000 29516 19823 19823 29516 29516 29516 19823 19823 Renewal- Effective Page 123 Indorama Ventures Oxides LLC Port Neches, Texas New Source Review Authorization References by Emissions Unit The following is a list of New Source Review (NSR) authorizations for emission units listed elsewhere in this operating permit. The NSR authorizations are applicable requirements under 30 TAC Chapter 122 and enforceable under this operating permit. Unit/Group/Process ID No. RSET087 RSET088 RSETFUG RSETQ142 T-L-797455 UEHK10 UEHK11 UEHK9 UER037 UER044 UER046 Emission Unit Name/Description TANK T-O-87 TANK T-O-88 R&S FUGITIVES FLUSH COLLECTION TANK YELLOW FIBERGLASS ANTIFOAM TANK HRSG HK10 BOILER HK-11 HRSG-HK9 FLARE NO. 3 FLARE NO. 1 FLARE NO. 2 New Source Review Authorization 19823 19823 29516 106.472/09/04/2000 106.473/03/14/1997 16909, PSDTX780 16909, PSDTX780 16909, PSDTX780 19823 19823 19823 NEICVP1446E01 Appendix N Page 126 of 148 Renewal- Effective Page 124 Indorama Ventures Oxides LLC Port Neches, Texas Appendix A Acronym List ........................................................................................................................................... 126 NEICVP1446E01 Appendix N Page 127 of 148 Renewal- Effective Page 125 Indorama Ventures Oxides LLC Port Neches, Texas Acronym List The following abbreviations or acronyms may be used in this permit: ACFM .................................................................................................................. actual cubic feet per minute AMOC.................................................................................................................... alternate means of control ARP ...................................................................................................................................Acid Rain Program ASTM .......................................................................................... American Society of Testing and Materials B/PA .......................................................................................... Beaumont/Port Arthur (nonattainment area) CAM ......................................................................................................... Compliance Assurance Monitoring CD ............................................................................................................................................. control device COMS..................................................................................................continuous opacity monitoring system CVS .................................................................................................................................. closed-vent system D/FW ................................................................................................ Dallas/Fort Worth (nonattainment area) DR ....................................................................................................................... Designated Representative ElP.................................................................................................................... El Paso (nonattainment area) EP............................................................................................................................................. emission point EPA ....................................................................................................U.S. Environmental Protection Agency EU .............................................................................................................................................. emission unit FCAA Amendments ............................................................................... Federal Clean Air Act Amendments FOP ........................................................................................................................... federal operating permit GF .............................................................................................................................................grandfathered gr/100 scf.................................................................................................. grains per 100 standard cubic feet HAP .............................................................................................................................hazardous air pollutant H/G/B............................................................................... Houston/Galveston/Brazoria (nonattainment area) H2S ........................................................................................................................................hydrogen sulfide ID No. .............................................................................................................................identification number lb/hr .................................................................................................................................... pound(s) per hour MMBtu/hr................................................................................................Million British thermal units per hour MRRT ................................................................................ monitoring, recordkeeping, reporting, and testing NA ............................................................................................................................................ nonattainment N/A ............................................................................................................................................ not applicable NADB ............................................................................................................. National Allowance Data Base NOx..........................................................................................................................................nitrogen oxides NSPS......................................................................... New Source Performance Standard (40 CFR Part 60) NSR.................................................................................................................................New Source Review ORIS.............................................................................................. Office of Regulatory Information Systems Pb ............................................................................................................................................................. lead PBR ......................................................................................................................................... Permit By Rule PM ....................................................................................................................................... particulate matter ppmv..................................................................................................................... parts per million by volume PSD ...................................................................................................... prevention of significant deterioration RO ................................................................................................................................... Responsible Official SO2 ............................................................................................................................................. sulfur dioxide TCEQ ...................................................................................... Texas Commission on Environmental Quality TSP ...................................................................................................................... total suspended particulate TVP ..................................................................................................................................true vapor pressure U.S.C................................................................................................................................United States Code VOC....................................................................................................................... volatile organic compound NEICVP1446E01 Appendix N Page 128 of 148 Renewal- Effective Page 126 Indorama Ventures Oxides LLC Port Neches, Texas Appendix B Major NSR Summary Table .................................................................................................................... 128 NEICVP1446E01 Appendix N Page 129 of 148 Renewal- Effective Page 127 Indorama Ventures Oxides LLC Port Neches, Texas Major NSR Summary Table Permit Number: 16909 / PSDTX780 Emission Point No. Source Name (2) Air Contaminant Name (3) (1) CG1 (4) CG2 (4) 37 Megawatt GE Frame 6 Gas Turbine and 212 MMBtu/hr Duct Burner 37 Megawatt GE Frame 6 Gas Turbine and 212 MMBtu/hr Duct Burner NOx CO VOC SO2 SO3 PM10 PM2.5 NOx CO VOC SO2 SO3 PM10 PM2.5 Emission Rates lbs/hour 66.70 31.50 2.50 8.20 0.30 4.00 4.00 66.70 31.50 2.50 8.20 0.30 4.00 4.00 TPY (5) ----------------------------- Issuance Date: 01/15/2016 Monitoring and Testing Requirements Recordkeeping Requirements Spec. Cond. Spec. Cond. Reporting Requirements Spec. Cond. 2, 8, 9, 10, 12, 14, 2, 3, 9, 10, 12, 14, 15 15, 17, 18 2, 10, 12, 18 2, 8, 9, 10, 12, 14, 2, 3, 9, 10, 12, 14, 15 15, 17, 18 2, 10, 12, 18 NEICVP1446E01 Appendix N Page 130 of 148 Renewal- Effective Page 128 Indorama Ventures Oxides LLC Port Neches, Texas Major NSR Summary Table Permit Number: 16909 / PSDTX780 Emission Point No. Source Name (2) Air Contaminant Name (3) (1) CG1 (4) CG2 (4) 37 Megawatt GE Frame 6 Gas Turbine and 250 MMBtu/hr Duct Burner 37 Megawatt GE Frame 6 Gas Turbine and 250 MMBtu/hr Duct Burner NOx CO VOC SO2 SO3 PM10 PM2.5 NOx CO VOC SO2 SO3 PM10 PM2.5 Emission Rates lbs/hour 70.41 34.10 2.76 8.68 0.32 4.26 4.26 70.41 34.10 2.76 8.68 0.32 4.26 4.26 TPY (5) ----------------------------- Issuance Date: 01/15/2016 Monitoring and Testing Requirements Recordkeeping Requirements Spec. Cond. Spec. Cond. 6 17 6 17 Reporting Requirements Spec. Cond. NEICVP1446E01 Appendix N Page 131 of 148 Renewal- Effective Page 129 Indorama Ventures Oxides LLC Port Neches, Texas Major NSR Summary Table Permit Number: 16909 / PSDTX780 Emission Point No. Source Name (2) Air Contaminant Name (3) (1) CG1 (4) CG2 (4) 37 Megawatt GE Frame 6 Gas Turbine and Duct Burner 37 Megawatt GE Frame 6 Gas Turbine and Duct Burner NOx CO VOC SO2 SO3 PM10 PM2.5 NOx CO VOC SO2 SO3 PM10 PM2.5 Issuance Date: 01/15/2016 Emission Rates Monitoring and Testing Requirements Recordkeeping Requirements Reporting Requirements lbs/hour TPY (5) Spec. Cond. Spec. Cond. Spec. Cond. --- 259.93 --- 123.35 --- 9.26 --- 31.92 2, 6, 8, 9, 10, 12, 2, 3, 9, 10, 12, 14, 14, 15 15, 17, 18 2, 10, 12, 18 --- 1.20 --- 16.66 --- 16.66 --- 259.93 --- 123.35 --- 9.26 --- 31.92 2, 6, 8, 9, 10, 12, 2, 3, 9, 10, 12, 14, 14, 15 15, 17, 18 2, 10, 12, 18 --- 1.20 --- 16.66 --- 16.66 NEICVP1446E01 Appendix N Page 132 of 148 Renewal- Effective Page 130 Indorama Ventures Oxides LLC Port Neches, Texas Major NSR Summary Table Permit Number: 16909 / PSDTX780 Emission Point No. Source Name (2) Air Contaminant Name (3) (1) UEHK11 Boiler No. 11 NOx CO VOC SO2 PM10 PM2.5 Emission Rates lbs/hour 14.3 20.8 0.9 3.2 2.9 2.9 TPY (5) 62.4 91.0 3.8 14.0 12.5 12.5 Issuance Date: 01/15/2016 Monitoring and Testing Requirements Recordkeeping Requirements Spec. Cond. Spec. Cond. Reporting Requirements Spec. Cond. 2, 8, 9, 11, 16 2, 3, 9, 11, 16, 17, 19 2, 11, 16, 19 (1) Emission point identification - either specific equipment designation or emission point number from plot plan. (2) Specific point source name. For fugitive sources, use area name or fugitive source name. (3) VOC - volatile organic compounds as defined in Title 30 Texas Administrative Code 101.1 NOx - total oxides of nitrogen SO2 - sulfur dioxide SO3 - sulfur trioxide PM10 - total particulate matter equal to or less than 10 microns in diameter, including PM2.5, as represented. Where PM is not listed, is shall be assumed that no PM greater than 10 microns is emitted. PM2.5 - particulate matter equal to or less than 2.5 microns in diameter CO - carbon monoxide (4) Turbine (CG1 and CG2) hourly emissions are based on 20F ambient temperature and annual emissions are based on 66.5F ambient temperature. (5) Compliance with annual emission limits (tons per year) is based on a 12-month rolling period. Annual emissions include those due to higher and lower duct burner firing rates. NEICVP1446E01 Appendix N Page 133 of 148 Renewal- Effective Page 131 Indorama Ventures Oxides LLC Port Neches, Texas Texas Commission on Environmental Quality Air Quality Permit A Permit Is Hereby Issued To Huntsman Petrochemical, LLC Authorizing the Construction and Operation of Huntsman Port Neches Facility Located at Port Neches, Jefferson County, Texas Latitude 29 57 36 Longitude -93 55 48 Permits: 16909 and PSDTX780 Amendment Date: January 15, 2016 Expiration Date: July 11, 2024 For the Commission 1. Facilities covered by this permit shall be constructed and operated as specified in the application for the permit. All representations regarding construction plans and operation procedures contained in the permit application shall be conditions upon which the permit is issued. Variations from these representations shall be unlawful unless the permit holder first makes application to the Texas Commission on Environmental Quality (commission) Executive Director to amend this permit in that regard and such amendment is approved. [Title 30 Texas Administrative Code (TAC) Section 116.116 (30 TAC 116.116)] 1 2. Voiding of Permit. A permit or permit amendment is automatically void if the holder fails to begin construction within 18 months of the date of issuance, discontinues construction for more than 18 months prior to completion, or fails to complete construction within a reasonable time. Upon request, the executive director may grant an 18-month extension. Before the extension is granted the permit may be subject to revision based on best available control technology, lowest achievable emission rate, and netting or offsets as applicable. One additional extension of up to 18 months may be granted if the permit holder demonstrates that emissions from the facility will comply with all rules and regulations of the commission, the intent of the Texas Clean Air Act (TCAA), including protection of the public's health and physical property; and (b)(1)the permit holder is a party to litigation not of the permit holder's initiation regarding the issuance of the permit; or (b)(2) the permit holder has spent, or committed to spend, at least 10 percent of the estimated total cost of the project up to a maximum of $5 million. A permit holder granted an extension under subsection (b)(1) of this section may receive one subsequent extension if the permit holder meets the conditions of subsection (b)(2) of this section. [30 TAC 116.120] 3. Construction Progress. Start of construction, construction interruptions exceeding 45 days, and completion of construction shall be reported to the appropriate regional office of the commission not later than 15 working days after occurrence of the event. [30 TAC 116.115(b)(2)(A)] 4. Start-up Notification. The appropriate air program regional office shall be notified prior to the commencement of operations of the facilities authorized by the permit in such a manner that a representative of the commission may be present. The permit holder shall provide a separate notification for the commencement of operations for each unit of phased construction, which may involve a series of units commencing operations at different times. Prior to operation of the facilities authorized by the permit, the permit holder shall identify the source or sources of allowances to be utilized for compliance with Chapter 101, Subchapter H, Division 3 of this title (relating to Mass Emissions Cap and Trade Program). [30 TAC 116.115(b)(2)(B)] 5. Sampling Requirements. If sampling is required, the permit holder shall contact the commission's Office of Compliance and Enforcement prior to sampling to obtain the proper data forms and procedures. All sampling and testing procedures must be approved by the executive director and coordinated with the regional representatives of the commission. The permit holder is also responsible for providing sampling Revised (10/12) NEICVP1446E01 Appendix N Page 134 of 148 1 Indorama Ventures Oxides LLC Port Neches, Texas facilities and conducting the sampling operations or contracting with an independent sampling consultant. [30 TAC 116.115(b)(2)(C)] 6. Equivalency of Methods. The permit holder must demonstrate or otherwise justify the equivalency of emission control methods, sampling or other emission testing methods, and monitoring methods proposed as alternatives to methods indicated in the conditions of the permit. Alternative methods shall be applied for in writing and must be reviewed and approved by the executive director prior to their use in fulfilling any requirements of the permit. [30 TAC 116.115(b)(2)(D)] 7. Recordkeeping. The permit holder shall maintain a copy of the permit along with records containing the information and data sufficient to demonstrate compliance with the permit, including production records and operating hours; keep all required records in a file at the plant site. If, however, the facility normally operates unattended, records shall be maintained at the nearest staffed location within Texas specified in the application; make the records available at the request of personnel from the commission or any air pollution control program having jurisdiction in a timely manner; comply with any additional recordkeeping requirements specified in special conditions in the permit; and retain information in the file for at least two years following the date that the information or data is obtained. [30 TAC 116.115(b)(2)(E)] 8. Maximum Allowable Emission Rates. The total emissions of air contaminants from any of the sources of emissions must not exceed the values stated on the table attached to the permit entitled "Emission Sources--Maximum Allowable Emission Rates." [30 TAC 116.115(b)(2)(F)] 1 9. Maintenance of Emission Control. The permitted facilities shall not be operated unless all air pollution emission capture and abatement equipment is maintained in good working order and operating properly during normal facility operations. The permit holder shall provide notification in accordance with 30 TAC 101.201, 101.211, and 101.221 of this title (relating to Emissions Event Reporting and Recordkeeping Requirements; Scheduled Maintenance, Startup, and Shutdown Reporting and Recordkeeping Requirements; and Operational Requirements). [30 TAC 116.115(b)(2)(G)] 10. Compliance with Rules. Acceptance of a permit by an applicant constitutes an acknowledgment and agreement that the permit holder will comply with all rules and orders of the commission issued in conformity with the TCAA and the conditions precedent to the granting of the permit. If more than one state or federal rule or regulation or permit condition is applicable, the most stringent limit or condition shall govern and be the standard by which compliance shall be demonstrated. Acceptance includes consent to the entrance of commission employees and agents into the permitted premises at reasonable times to investigate conditions relating to the emission or concentration of air contaminants, including compliance with the permit. [30 TAC 116.115(b)(2)(H)] 11. This permit may not be transferred, assigned, or conveyed by the holder except as provided by rule. [30 TAC 116.110(e)] 12. There may be additional special conditions attached to a permit upon issuance or modification of the permit. Such conditions in a permit may be more restrictive than the requirements of Title 30 of the Texas Administrative Code. [30 TAC 116.115(c)] 13. Emissions from this facility must not cause or contribute to "air pollution" as defined in Texas Health and Safety Code (THSC) 382.003(3) or violate THSC 382.085. If the executive director determines that such a condition or violation occurs, the holder shall implement additional abatement measures as necessary to control or prevent the condition or violation. 14. The permit holder shall comply with all the requirements of this permit. Emissions that exceed the limits of this permit are not authorized and are violations of this permit. 1 1 Please be advised that the requirements of this provision of the general conditions may not be applicable to greenhouse gas emissions. Revised (10/12) NEICVP1446E01 Appendix N Page 135 of 148 2 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Numbers 16909 and PSDTX780 1. This permit covers only those sources of emissions listed in the attached table entitled "Emissions Sources - Maximum Allowable Emission Rates" (MAERT), and those sources are limited to the emission limits and other conditions specified in the attached table. Planned maintenance, startup, and shutdown (MSS) activities for the facilities authorized by this permit are separately authorized under New Source Review Permit No. 83816. Federal Applicability 2. The sources identified in this condition are subject to and shall comply with the applicable requirements in Title 40 Code of Federal Regulations (40 CFR) Part 60, New Source Performance Standards (NSPS) as follows. If any condition of this permit is more stringent than the regulation so incorporated, then for the purposes of complying with this permit the permit condition shall govern and be the standard by which compliance shall be demonstrated. Source Gas Turbines/Heat Recovery Steam Generator (HRSG) Duct Burners Gas Turbines/HRSG Duct Burners Emission Point No. (EPN) CG1 and CG2 CG1 and CG2 Boiler No. 11 UEHK11 All of the above sources Subpart Db Standards of Performance for: Industrial Steam Generating Units GG Stationary Gas Turbines Db Industrial Steam Generating Units A General Conditions 3. The holder of this permit shall physically identify and mark in a conspicuous location all equipment that has the potential of emitting air contaminants as follows: A. The facility identification numbers as submitted to the Emissions Assessment Section of the Texas Commission on Environmental Quality (TCEQ). B. The EPNs as listed on the MAERT. Emission Standards and Operating Specifications 4. Emissions from the gas turbines and HRSG duct burners (EPNs CG1 and CG2) shall not exceed the following except during startup and shutdown3: NEICVP1446E01 Appendix N Page 136 of 148 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Numbers 16909 and PSDTX780 Page 2 Mode of Operation Turbine Only1 Duct Burner Only Nitrogen Oxides (NOx) 25 parts per million volume dry (ppmvd)2 0.10 pounds per million British thermal units (lb/MMBtu)4 Carbon Monoxide (CO) 25 ppmvd2 0.07 lb/MMBtu4 Turbine and Duct Burner5 26.0 ppmvd2 27.5 ppmvd2 1 Measured concentrations in the exhaust stack prior to the duct burners. 2 On a dry basis at 15 percent oxygen (O2). 3 Startup and shutdown shall not exceed four hours. 4 Based on the higher heating value of the fuel. 5 Measured concentrations in the exhaust stack after the duct burners. 5. The amount of electricity produced from each cogeneration unit is limited as follows: Product Short-Term Production Rate1 Annual Production Rate2 Electricity 43 Megawatt-hours (MW-hr) 3.153 x 105 MW-hr/yr 1 Based on 20F ambient temperature. 2 Based on 66.5F average annual temperature and a 12-month rolling average. 6. The higher firing rate of each HRSG duct burner of 250 million British thermal units per hour (MMBtu/hr) is limited to 500 hours per year. At all other times, the firing rate of each HRSG duct burner is limited to 212 MMBtu/hr. Both rates are to be based on the higher heating value of the fuel. (01/16) 7. Emissions from Boiler No. 11 (EPN UEHK11) shall not exceed the following: A. NOx: 0.05 lb/MMBtu, based upon the higher heating value of the fuel on an hourly basis corrected as specified in 40 CFR Part 60, Appendix A, Method 19. B. CO: 100 ppmvd at 3 percent (by volume) stack gas (O2), averaged over a onehour period. 8. Fuel fired at this facility is limited as follows. The use of any other fuels will require an authorization under 30 TAC Chapter 106 or 116. Upon request by the Executive Director of the TCEQ or any local air pollution control program having jurisdiction, the holder of this permit shall provide a sample and/or an analysis of the fuels fired in Boiler No. 11 (EPN UEHK11) or shall allow air pollution control agency representatives to obtain a sample for analysis. A. Fuel fired in the two Gas Turbines (EPNs CG1 and CG2) is limited to pipelinequality, sweet natural gas containing no more than 2.0 grains of hydrogen sulfide (H2S) and 4.0 grains of total sulfur per 100 dry standard cubic feet (dscf). B. Fuel fired in the two HRSG Duct Burners (EPNs CG1 and CG2) is limited to natural gas that meets the requirements of Special Condition No. 8A or plant fuel gas NEICVP1446E01 Appendix N Page 137 of 148 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Numbers 16909 and PSDTX780 Page 3 containing no more than 2.0 grains of H2S and 4.0 grains of total sulfur per 100 dscf. C. The holder of this permit shall monitor the sulfur content of the fuel gas-fired in the Gas Turbine (EPNs CG1 and CG2) in accordance with NSPS Subpart GG or on a custom sampling schedule approved by the TCEQ and EPA. D. Fuel used in Boiler No. 11 (EPN UEHK11) shall be limited to pipeline-quality, sweet natural gas and/or fuel mix gas containing no more than 4.0 grains of total sulfur per 100 dscf. 9. Opacity of emissions from any one stack authorized by this permit shall not exceed five percent averaged over a six-minute period from each stack. This determination shall be made by first observing for visible emissions while each facility is in operation. Observations shall be made at least 15 feet and no more than 0.25 miles from the emission point(s). Up to three emissions points may be read concurrently, provided that all three emissions points are within a 70 degree viewing sector or angle in front of the observer such that the proper sun position (at the observer's back) can be maintained for all three emission points. If visible emissions are observed from an emission point, then the opacity shall be determined and documented within 24 hours for that emission point using 40 CFR Part 60, Appendix A, Test Method 9. Observations shall be performed and recorded quarterly. If the opacity exceeds five percent, corrective action to eliminate the source of visible emissions shall be taken promptly and documented within one week of first observation. Initial Determination of Compliance for the Cogeneration Facility (EPNs CG1 and CG2) 10. The holder of this permit shall perform stack sampling and other testing as required to initially establish the actual pattern and quantities of air contaminants being emitted into the atmosphere from the gas turbine. Sampling must be conducted in accordance with appropriate procedures of the TCEQ Sampling Procedures Manual and in accordance with EPA Test Method No. 9 for opacity (consisting of 30 six-minute readings as provided in 40 CFR 60.11[b]), Test Method No. 10 for the concentration of CO, Test Method No. 5 for the concentration of particulate matter (PM), and Test Method No. 20 for the concentrations of NOx and O2. For gaseous fuel, sampling shall be conducted according to one of the appropriate test methods specified in 40 CFR 60.335(b) to demonstrate initial compliance with the sulfur dioxide (SO2) limits in the MAERT and the fuel sulfur limits of Special Conditions Nos. 8A and 8B. The holder of this permit is responsible for providing sampling and testing facilities and conducting the sampling and testing operation at his expense. A. The TCEQ Beaumont Regional Office shall be contacted as soon as testing is scheduled but not less than 45 days prior to sampling to schedule a pretest meeting. The notice shall include: 1) Date for pretest meeting. 2) Date sampling will occur. NEICVP1446E01 Appendix N Page 138 of 148 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Numbers 16909 and PSDTX780 Page 4 3) Name of firm conducting sampling. 4) Type of sampling equipment to be used. 5) Method or procedure to be used in sampling. The purpose of the pretest meeting is to review and formalize the necessary sampling and testing procedures, to provide the proper data forms for recording pertinent data, to identify each operating parameter which is significant to maintaining emission compliance, and to review the format procedures for submitting the test reports. A written proposed description of any deviation from sampling procedures specified in this permit condition or any TCEQ or the EPA sampling procedures shall be made available to the TCEQ at or prior to the pretest meeting. The TCEQ Regional Director shall approve or disapprove of any deviation from specified sampling procedures. Requests to waive testing for any pollutant specified in Special Condition No. 10B shall be submitted to the TCEQ Office of Air, Air Permits Division. Test waivers and alternate/equivalent procedure proposals for NSPS testing which must have the EPA approval shall be submitted to the TCEQ Regional Office. Any equivalent test procedures or any test waivers must be approved by the TCEQ prior to the date required in Special Condition No. 10E for conducting the tests. B. Air emissions from gas turbines to be tested for at full load include (but are not limited to) the following: NOx, O2, CO, PM, and opacity. This testing will be used to demonstrate compliance with the MAERT and Special Condition No. 4. C. The NOx, O2, CO, and PM from the gas turbines shall be sampled concurrently at four premix mode turbine loads, including the minimum and maximum load point in the premix mode. Maximum loads are the maximums achievable for the atmospheric conditions occurring during the test. The NOx and CO concentrations shall be corrected and reported according to Special Condition No. 4. This testing will be used to demonstrate initial compliance with the MAERT and Special Condition No. 4. D. The NOx, CO, and O2 shall be measured simultaneously upstream and downstream of the duct burner. The PM shall be measured downstream only while the turbines and duct burners are firing at the maximum combined rate for the ambient conditions occurring during the test. The duct burner NOx and CO emission rates shall be determined by Test Method No. 19. E. Sampling shall occur within 60 days after achieving the maximum production rate at which the turbines will be operated, but no later than 180 days after initial start-up of the turbines. Additional sampling shall occur as may be required by the TCEQ. F. Within 60 days after the completion of the testing and sampling required herein, copies of the sampling report shall be distributed as follows: One copy to the TCEQ Beaumont Regional Office. One copy to the TCEQ Austin Office of Air, Air Permits Division. One copy to the EPA Region 6 Office in Dallas. NEICVP1446E01 Appendix N Page 139 of 148 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Numbers 16909 and PSDTX780 Page 5 Initial Determination of Compliance for Boiler No. 11 (EPN UEHK11) 11. The holder of this permit shall perform stack sampling and other testing as required to establish the actual pattern and quantities of air contaminants being emitted into the atmosphere from Boiler No. 11 under two scenarios: (1) firing 100 percent natural gas and (2) firing 100 percent fuel mix gas. The holder of this permit is responsible for providing sampling and testing facilities and conducting the sampling and testing operations at his expense. Sampling shall be conducted in accordance with the appropriate procedures of the TCEQ Sampling Procedures Manual and in accordance with the appropriate EPA Test Methods. Fuel sampling using the methods and procedures of 40 CFR 60.335(d) may be conducted in lieu of stack sampling for SO2. If fuel sampling is used, compliance shall be based on 100 percent conversion of the sulfur in the fuel to SO2. Any deviations from those procedures must be approved by the Executive Director of the TCEQ prior to sampling. The TCEQ Executive Director or her designated representative shall be afforded the opportunity to observe all such sampling. The holder of this permit is responsible for providing sampling and testing facilities and conducting the sampling and testing operations at his expense. A. The TCEQ Beaumont Regional Office shall be contacted as soon as testing is scheduled, but not less than 45 days prior to sampling to schedule a pretest meeting. The notice shall include: 1) Date for pretest meeting. 2) Date sampling will occur. 3) Name of firm conducting sampling. 4) Type of sampling equipment to be used. 5) Method or procedure to be used in sampling. 6) Procedure used to determine Boiler No. 11 loads during and after the sampling period. The purpose of the pretest meeting is to review the necessary sampling and testing procedures, to provide the proper data forms for recording pertinent data, and to review the format procedures for submitting the test reports. A written proposed description of any deviation from sampling procedures specified in permit conditions, the TCEQ, or the EPA sampling procedures shall be made available to the TCEQ prior to the pretest meeting. The TCEQ Regional Director shall approve or disapprove of any deviation from specified sampling procedures. Requests to waive testing for any pollutant specified in this condition shall be submitted to the TCEQ Office of Air, Air Permits Division. Test waivers and alternate/equivalent procedure proposals for new source performance standards testing which must have the EPA approval shall be submitted to the TCEQ Regional Office. B. Air contaminants emitted from Boiler No. 11 to be tested for while firing under two scenarios (1) firing 100 percent natural gas and (2) firing 100 percent fuel mix gas including (but are not limited to) NOx, CO, SO2, O2, and opacity. NEICVP1446E01 Appendix N Page 140 of 148 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Numbers 16909 and PSDTX780 Page 6 C. Sampling while firing 100 percent fuel mix gas shall occur within 60 days after initial start-up of the facilities. Sampling while firing 100 percent natural gas shall occur no later than the next scheduled shutdown of the A-3 Olefins Unit. Sample may also occur at such other times as may be required by the Executive Director of the TCEQ. Requests for additional time to perform sampling shall be submitted to the TCEQ Regional Office. Additional time to comply with the applicable requirements of 40 CFR Part 60 and 40 CFR Part 61 requires EPA approval, and requests shall be submitted to the TCEQ Regional Office. D. The plant shall operate at maximum production rates during stack emission testing. Primary operating parameters that enable determination of production rate shall be monitored and recorded during the stack test. These parameters are to be determined at the pretest meeting. If the plant is unable to operate at maximum rates during testing, then future production rates are limited to the rates established during testing, and the permit holder will apply for a permit alteration to reduce the allowable mass emission rates according. Additional stack testing may be required when higher production rates are achieved. E. Three copies of the final sampling report shall be forwarded to the TCEQ within 60 days after sampling is completed. Sampling reports shall comply with the attached conditions of Chapter 14 of the TCEQ Sampling Procedures Manual. The reports shall be distributed as follows: One copy to the TCEQ Beaumont Regional Office. One copy to the TCEQ Austin Office of Air, Air Permits Division. One copy to the EPA Region 6 Office in Dallas. Continuous Demonstration of Compliance for the Cogeneration Facility (EPNs CG1 and CG2) 12. The holder of this permit shall install, calibrate, maintain, and operate a continuous emissions monitoring system (CEMS) to: A. Measure and record the concentrations of NOx and O2 at the exhaust stack. B. Measure and record the concentration of CO in the exhaust stack. C. Measure and record ambient temperature and fuel flow to the gas turbines and duct burners. D. The NOx and CO concentrations shall be corrected and reported according to Special Condition No. 4. E. The CEMS required in Special Condition Nos. 12A and 12B shall comply with the following requirements: 1) The CEMS shall meet the design and performance specifications, pass the field tests, and meet the installation requirements and data analysis and reporting requirements specified in the applicable performance specifications in 40 CFR Part 60, Appendix B. The performance specification tests shall be conducted during the sampling required by Special Condition No. 10 and NEICVP1446E01 Appendix N Page 141 of 148 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Numbers 16909 and PSDTX780 Page 7 written copies of the results shall be submitted within 60 days of completion of the tests to the TCEQ Beaumont Regional Office and the TCEQ Office of Air, Air Permits Division in Austin. 2) The system shall be zeroed and spanned daily and corrective action taken when the 24-hour span drift exceed two times the amounts specified in 40 CFR Part 60, Appendix B. Each gaseous monitor shall be quality-assured at least quarterly in accordance with 40 CFR Part 60, Appendix F, Procedure 1, 5.1.2. A cylinder gas audit (CGA) may be performed in lieu of the annual relative accuracy test audits. An equivalent method approved by the TCEQ and the EPA may be used. 3) Each NOx, CO, and O2 CEMS shall complete a minimum of one cycle of sampling, analyzing, and data recording for each successive 15-minute period. One-hour averages shall be computed from normally at least four and at a minimum of two data points equally-spaced over each one-hour period. Data recorded during periods of CEMS breakdowns, repairs, calibration checks, and zero and span adjustments shall not be included in the computed data averages. The gaseous monitoring data shall be reduced to hourly average concentrations at least once every day, using a minimum of four equallyspaced data points from each one-hour period. At least 23 hourly averages shall be generated per day. The gaseous monitoring data shall be reduced to units of the permit allowable emission rate at least once every day. 4) All CGA exceedances greater than 15 percent accuracy and any unscheduled CEMS downtime in excess of 48 hours shall be reported to the TCEQ Beaumont Regional Office, and necessary corrective action shall be taken. Unscheduled CEMS downtime is any CEMS downtime not required for daily zero and span checks and quarterly CGAs. Supplemental stack concentration measurements may be required at the discretion of the TCEQ Regional Director or the EPA. 13. The holder of this permit shall install, operate, and maintain a turbine control system that will maintain NOx and CO levels within the limits specified in Special Condition No. 4. 14. The holder of this permit shall install, calibrate, maintain, and operate a continuous monitoring system to: A. Measure and record the amount of steam produced from each HRSG in pounds per hour (lbs/hr). B. Measure and record the amount of electricity produced from each cogeneration unit in MW-hours. 15. After the demonstration of initial compliance required in Special Condition No. 10, the CEMS required in Special Condition No. 12 shall constitute the methods for demonstrating continuous compliance with the standards. The CEMS will be used to evaluate compliance with the emission limitations in the MAERT and Special Condition Nos. 2, and 4. The fuel sulfur monitoring required in Special Condition No. 8C shall constitute the NEICVP1446E01 Appendix N Page 142 of 148 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Numbers 16909 and PSDTX780 Page 8 method of demonstrating continuous compliance with the emission limitations in the MAERT and Special Condition Nos. 8A and 8B. Continuous Determination of Compliance for Boiler No. 11 (EPN UEHK11) 16. In order to demonstrate continuous compliance with the NOx and CO limits of Special Condition No. 7 and the MAERT for Boiler No. 11 (EPN UEHK11), the holder of this permit shall comply with the monitoring conditions of 40 CFR 60.48b. The CEMS used to measure and record the in-stack concentration of NOx, CO, and O2 from Boiler No. 11 shall be installed, calibrated, and maintained in accordance with the requirements of 40 CFR 60.13 and 60.48(b). In addition, the holder of this permit shall comply with the following: A. The CEMS shall meet the design and performance specifications, pass the field tests, and meet the installation requirements and data analysis and reporting requirements specified in the applicable Performance Specifications in 40 CFR Part 60, Appendix B. The Performance Specification tests shall be conducted prior to or during the sampling required by Special Condition No. 11, and written copies of the results shall be submitted within 60 days of completion of the tests to the TCEQ Beaumont Regional Office and the TCEQ Air Permits Division in Austin. B. The system shall be zeroed and spanned daily and corrective action taken when the 24-hour span drift exceeds two times the amounts specified in 40 CFR Part 60, Appendix B. Each gaseous monitor shall be quality-assured at least quarterly using CGA. The CGA method to be used is contained in 40 CFR Part 60, Appendix F, Procedure 1. C. The gaseous monitoring data shall be reduced to hourly average concentrations at least once every day, using a minimum of four equally-spaced data points from each one-hour period. At least 23 hourly averages shall be generated per day. D. All CGA exceedances greater than 15 percent accuracy and any unscheduled CEMS downtime in excess of 48 hours shall be reported to the TCEQ Beaumont Regional Office within 24 hours of detection, and necessary corrective action shall be taken. Supplemental stack concentration measurements may be required at the discretion of the TCEQ Regional Director. E. The CEMS shall demonstrate a system reliability of at least 90 percent based on an annual rolling period (downtime does not include daily zero and span measurement time or unit downtime), or options to increase system reliability to an acceptable value, including a redundant CEMS, may be required by the TCEQ Beaumont Regional Director. Recordkeeping Requirements 17. The following information shall be made and maintained by the holder of this permit for a period of five years rather than the two-year period specified in General Condition No. 7 NEICVP1446E01 Appendix N Page 143 of 148 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Numbers 16909 and PSDTX780 Page 9 and shall be made available on request to representatives of the TCEQ, the EPA, or any local air pollution control program having jurisdiction: A. A copy of this permit shall be kept at the plant site and made available at the request of personnel from the TCEQ or any air pollution control agency with jurisdiction. B. Recordkeeping requirements for EPNs CG1 and CG2 are as follows: 1) Block hourly average NOx, CO, and O2 concentrations which are monitored pursuant to Special Condition No. 12. 2) The results of all fuel sampling conducted pursuant to Special Condition No. 8C. 3) The results of all stack tests conducted pursuant to Special Condition No. 11. 4) The holder of this permit shall maintain a raw data file of all CEMS measurements, including CEMS performance testing measurements: all CEMS calibration checks and adjustments and maintenance performed on these systems in permanent form suitable for inspection. 5) The time and date of all turbine startups and shutdowns. 6) The hourly and annual electricity production rate which is monitored pursuant to Special Condition No. 12. 7) The hourly firing rate of each HRSG duct burner pursuant to Special Condition No. 6, including the total number of hours at the higher firing rate for each HRSG duct burner. (01/16) C. Recordkeeping requirements for EPN UEHK11: 1) The block one-hour average CO concentrations in ppmvd, the block one-hour average NOx emissions in lb/MMBtu of heat input, and the average emissions of NOx and CO reported in units of lbs/hr and TPY for Boiler No. 11. 2) Records of initial performance test shall be maintained for the life of Boiler No. 11, along with the permit application received by TCEQ on September 9, 1999, as revised in response to all requests for information. 3) The holder of this permit shall maintain a raw data file of all CEMS measurements for Boiler No. 11, including CEMS performance testing measurements, all CEMS calibration checks and adjustments and maintenance performed on these systems; or measurements of operating conditions monitored, including steam generating unit load, identified in the monitoring plan. These data shall be maintained in a permanent form, either hard copy or electronically, so long as it is suitable for inspection. 4) Copies of natural gas contract specifications and process vent gas specifications including (but not limited to) those for total sulfur shall be kept in an on-site file. Records of fuel purchased, including date delivered, amount delivered, and any sulfur analyses shall be kept in an on-site file. NEICVP1446E01 Appendix N Page 144 of 148 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Numbers 16909 and PSDTX780 Page 10 Reporting Requirements 18. For the Gas Turbines (EPNs CG1 and CG2), the holder of this permit shall submit to the TCEQ Beaumont Regional Office and the TCEQ Compliance Section in Austin semiannual reports as described in 40 CFR 60.7. Such reports are required for each emission unit which is required to be continuously monitored pursuant to Special Condition No. 12. In addition to the information specified in 40 CFR 60.7(c), each report shall contain the hours of operation of the facility and a report summary of the periods of noncomplying emissions and CEMS downtimes by cause. 19. For Boiler No. 11 (EPN UEHK11), all occurrences of noncomplying emissions/conditions must be logged and copies sent to the TCEQ Beaumont Regional Office on a semiannual basis. Maintenance Condition 20. The permit holder may conduct periodic water washings utilizing a soap solution on Gas Turbines CG1 and CG2 a maximum of 3 times per calendar week per turbine and no more than 156 times per year per turbine. Each water wash (with soap) period shall not exceed one hour. During these water wash periods, the NOx and CO emissions rates in the MAERT shall apply. However, the emissions concentrations required in Special Condition No. 4 and recorded by CEMS shall be temporarily suspended for the one block hourly average concentrations recorded during the one-hour water wash (with soap) period, not to exceed a total of two block hourly average concentrations per water wash (with soap) period. Additionally, the permit holder may conduct periodic water washings (without soap) on Gas Turbines CG1 and CG2 without restriction provided that the emissions limitations in the MAERT and Special Condition No. 4 are not exceeded as a result of these washings. Date: January 15, 2016 NEICVP1446E01 Appendix N Page 145 of 148 Indorama Ventures Oxides LLC Port Neches, Texas Emission Sources - Maximum Allowable Emission Rates Permit Numbers 16909 and PSDTX780 This table lists the maximum allowable emission rates and all sources of air contaminants on the applicant's property covered by this permit. The emission rates shown are those derived from information submitted as part of the application for permit and are the maximum rates allowed for these facilities, sources, and related activities. Any proposed increase in emission rates may require an application for a modification of the facilities covered by this permit. Emission Point No. (1) Air Contaminants Data Source Name (2) Air Contaminant Name (3) Emission Rates lbs/hour TPY (5) CG1 (4) 37 Megawatt GE Frame 6 Gas Turbine and 212 MMBtu/hr Duct Burner CG2 (4) 37 Megawatt GE Frame 6 Gas Turbine and 212 MMBtu/hr Duct Burner CG1 (4) 37 Megawatt GE Frame 6 Gas Turbine and 250 MMBtu/hr Duct Burner CG2 (4) Project Number: 234448 NEICVP1446E01 37 Megawatt GE Frame 6 Gas Turbine and 250 MMBtu/hr Duct NOx CO VOC SO2 SO3 PM10 PM2.5 NOx CO VOC SO2 SO3 PM10 PM2.5 NOx CO VOC SO2 SO3 PM10 PM2.5 NOx CO Appendix N Page 146 of 148 66.70 --- 31.50 --- 2.50 --- 8.20 --- 0.30 --- 4.00 --- 4.00 --- 66.70 --- 31.50 --- 2.50 --- 8.20 --- 0.30 --- 4.00 --- 4.00 --- 70.41 --- 34.10 --- 2.76 --- 8.68 --- 0.32 --- 4.26 --- 4.26 --- 70.41 --- 34.10 --- Indorama Ventures Oxides LLC Port Neches, Texas Permit Numbers 16909 and PSDTX780 Page Emission Sources - Maximum Allowable Emission Rates CG1 (4) CG2 (4) UEHK11 37 Megawatt GE Frame 6 Gas Turbine and Duct Burner 37 Megawatt GE Frame 6 Gas Turbine and Duct Burner Boiler No. 11 VOC SO2 SO3 PM10 PM2.5 NOx CO VOC SO2 SO3 PM10 PM2.5 NOx CO VOC SO2 SO3 PM10 PM2.5 NOx CO VOC SO2 PM10 PM2.5 2.76 8.68 0.32 4.26 4.26 ----------------------------14.3 20.8 0.9 3.2 2.9 2.9 ----------259.93 123.35 9.26 31.92 1.20 16.66 16.66 259.93 123.35 9.26 31.92 1.20 16.66 16.66 62.4 91.0 3.8 14.0 12.5 12.5 (1) Emission point identification - either specific equipment designation or emission point number from plot plan. (2) Specific point source name. For fugitive sources, use area name or fugitive source name. (3) VOC - volatile organic compounds as defined in Title 30 Texas Administrative Code 101.1 NOx - total oxides of nitrogen Project Number: 234448 NEICVP1446E01 Appendix N Indorama Ventures Oxides LLC Page 147 of 148 Port Neches, Texas Permit Numbers 16909 and PSDTX780 Page Emission Sources - Maximum Allowable Emission Rates SO2 - sulfur dioxide SO3 - sulfur trioxide PM10 - total particulate matter equal to or less than 10 microns in diameter, including PM2.5, as represented. Where PM is not listed, is shall be assumed that no PM greater than 10 microns is emitted. PM2.5 - particulate matter equal to or less than 2.5 microns in diameter CO - carbon monoxide (4) Turbine (CG1 and CG2) hourly emissions are based on 20F ambient temperature and annual emissions are based on 66.5F ambient temperature. (5) Compliance with annual emission limits (tons per year) is based on a 12 month rolling period. Annual emissions include those due to higher and lower duct burner firing rates. Date: January 15, 2016 Project Number: 234448 NEICVP1446E01 Appendix N Page 148 of 148 Indorama Ventures Oxides LLC Port Neches, Texas PNO.031 001 Storage Tank Data Tank Number T-O-87 T-O-88 T-O-126 T-O-127 T-A3-39 Product RAWPYROBK WATERAD WATERAD WATERAD Methanol Type of Construction Volume Control Date Capacity (gal) Device 7/22/1953 440,608 IFR 11/1/1953 440,608 IFR 4/8/1958 215,898 Flare 4/8/1958 132,183 Flare 9/1/1964 3,093 N/A Type of Floating Roof Internal Internal N/A N/A N/A Floating Roof Construciton Type Pan Type Pan Type N/A N/A N/A Deck Seam Type Welded Welded N/A N/A N/A Type of floating rim seals Liquid mounted primary Liquid mounted primary N/A N/A N/A Type of Floating Roof Support Removable Legs Removable Legs N/A N/A N/A Date last out of service or Date of top side Installation of floating roof Applicable floating roof inspection CAA Regs 1/9/2013 10/17/2022 Kb, FF, YY 9/13/2014 10/18/2022 Kb, FF, YY N/A 6/9/2016 FF & YY N/A 5/23/2016 FF & YY N/A 8/7/2008 N/A NEICVP1446E01 Appendix O Page 1 of 1 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 1. This permit covers only those sources of emissions listed in the attached table entitled "Emission Sources - Maximum Allowable Emission Rates" (MAERT), and those sources are limited to the emission limits and other conditions specified in that table. 2. Non-fugitive emissions from relief valves, safety valves, or rupture discs of gases containing volatile organic compounds (VOC) at a concentration of greater than 1 percent are not authorized by this permit unless authorized on the MAERT. Any releases directly to atmosphere from relief valves, safety valves, or rupture discs of gases containing VOC at a concentration greater than 1 weight percent are not consistent with good practice for minimizing emissions with the exception of the following: PV-A3-26 (Caustic Scrubber) PRV-A3-29 (Deethanizer Tower) PRV-A3-32/602S (No. 1 Depropanizer) PRV-A3-602/602B (No. 2 Depropanizer) PRV-A3-297 (Fuel to H-A3-5) PRV-A3-1720 (No. 2 Wastewater Degasser [R-A3-207]) PRV-A3-28/28A (Demethanizer Tower) PRV-A3-31/31A (Ethylene Tower) PRV-A3-36/36A (No. 1 Propylene Tower) PRV-O-246 (E-O-2 Propane Heater) PRV-A3-1719 (Caustic Coalescer) PRV-O-342 (Propane to Storage Tanks) Federal Applicability 3. These facilities shall comply with all applicable requirements of the U.S. Environmental Protection Agency (EPA) regulations on Standards of Performance for New Stationary Sources promulgated in Title 40 Code of Federal Regulations Part 60 (40 CFR Part 60): A. Subpart A, General Provisions. B. Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after July 23, 1984. C. Subpart GG, Standards of Performance for Stationary Gas Turbines. NEICVP1446E01 Appendix P Page 1 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 2 D. Subpart VV, Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry for which Construction, Reconstruction, or Modification Commenced After January 5, 1981, and on or Before November 7, 2006. E. Subpart NNN, Standards of Performance for Volatile Organic Compound (VOC) Emissions from Synthetic Organic Chemical Manufacturing Industry (SOCMI) Distillation Operations. F. Subpart RRR, Standards of Performance for Volatile Organic Compound Emissions from Synthetic Organic Chemical Manufacturing Industry (SOCMI) Reactor Processes. 4. These facilities shall comply with all applicable requirements of the EPA regulations on National Emission Standards for Hazardous Air Pollutants in 40 CFR Part 61: A. Subpart A, General Provisions. B. Subpart J, National Emission Standards for Equipment Leaks (Fugitive Emission Sources) of Benzene. C. Subpart FF, National Emission Standard for Benzene Waste Operations. 5. These facilities shall comply with all applicable requirements of the EPA regulations on National Emission Standards for Hazardous Air Pollutants for Source Categories in 40 CFR Part 63: A. Subpart A, General Provisions. B. Subpart XX, National Emission Standards for Ethylene Manufacturing Process Units: Heat Exchange Systems and Waste Operations. C. Subpart YY, National Emission Standards for Hazardous Air Pollutants for Source Categories: Generic Maximum Achievable Control Technology Standards. Emission Standards and Operational Specifications 6. The annual production of ethylene shall not exceed 693.6 million pounds per year (MMlb/yr) and annual production of propylene shall not exceed 671.1 MMlb/yr. Records of annual production of each product shall be maintained and updated monthly. 7. The cracking furnaces shall be limited to an annual total of 225 decoking cycles and shall be limited to a short-term total of three furnaces decoking simultaneously. The hydrogenation reactors shall be limited to ten regenerations per year. Furnace decoking and reactor regeneration may occur simultaneously. The decoking and regeneration limits are the equivalent of the spray drum emission limits as represented in the MAERT. 8. The following fired heating duty limits, on a higher heating value basis, shall apply: Source H-A3-1A-H, J H-A3-3 H-A3-4 C-A3-1-1 Annual Average Firing Rate (MMBtu/hr) 476.7 1.0 3.1 233.0 Maximum Firing Rate (MMBtu/hr) 842.0 10.0 10.0 266.0 NEICVP1446E01 Appendix P Page 2 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 3 H-A3-5 Source Annual Average Firing Rate (MMBtu/hr) 197.0 Maximum Firing Rate (MMBtu/hr) 250.0 A rolling 12-month average total firing rate shall be updated monthly to demonstrate compliance with the annual firing rates shown in this condition. Records of the monthly rolling firing rates and their corresponding maximum (short-term) firing rates shall be maintained at the plant site for a period of two years and made available to representatives of the TCEQ on request. 9. The burners in the waste heat boiler shall not exceed 0.08 lb NOx/MMBtu. 10. Flares shall be designed and operated in accordance with the following requirements: (05/19) A. The flare systems shall be designed such that the combined assist natural gas and waste stream to each flare meets the 40 CFR 60.18 specifications of minimum heating value and maximum tip velocity at all times when emissions may be vented to them. The heating value and velocity requirements shall be satisfied during operations authorized by this permit. Flare testing per 40 CFR 60.18(f) may be requested by the appropriate regional office to demonstrate compliance with these requirements. B. The flare shall be operated with a flame present at all times and/or have a constant pilot flame. The pilot flame shall be continuously monitored by a thermocouple, infrared monitor, or ultraviolet monitor. The time, date, and duration of any loss of pilot flame shall be recorded. Each monitoring device shall be accurate to, and shall be calibrated at a frequency in accordance with, the manufacturer's specifications C. The flare shall be operated with no visible emissions except periods not to exceed a total of five minutes during any two consecutive hours. This shall be ensured by the use of steam assist to the flare. D. The permit holder shall install a continuous flow monitor and calorimeter that provide a record of the vent stream flow and Btu content to the flare. The flow monitor sensor and analyzer sample points shall be installed in the vent stream as near as possible to the flare inlet such that the total vent stream to the flare is measured and analyzed. Readings shall be taken at least once every 15 minutes and the average hourly values of the flow and Btu content shall be recorded each hour. The monitors shall be calibrated or have a calibration check performed on an annual basis to meet the following accuracy specifications: the flow monitor shall be 5.0%, temperature monitor shall be 2.0% at absolute temperature, and pressure monitor shall be 5.0 mm Hg. The calorimeter shall be calibrated, installed, operated, and maintained, in accordance with manufacturer recommendations, to continuously measure and record the net heating value of the gas sent to the flare, in British thermal units/standard cubic foot of the gas. The monitors and analyzers shall operate as required by this section at least 95% of the time when the flare is operational, averaged over a rolling 12 month period. Flared gas net heating value and actual exit velocity determined in accordance with 40 CFR 60.18(f)(3) and 60.18(f)(4) shall be recorded at least once every hour. Hourly mass emission rates shall NEICVP1446E01 Appendix P Page 3 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 4 be determined and recorded using the above readings and the emission factors used in the permit amendment application, PI-1 dated October 05, 2015. E. The calorimeter required in this condition shall be installed no later than 12 months after the issuance date of this permit. F. The following flare heat inputs limits shall apply: EPN UER044 and UER046 UER037 Average Annual Heat Input to Flare (MMBtu/yr) 394,227 402,474 Maximum Heat Input to Flare (MMBtu/hr) 337 213 A rolling 12-month total heat input rate shall be updated monthly to demonstrate compliance with the annual heat input shown in this condition. Records of the monthly rolling heat input rates and their corresponding maximum (short-term) rates shall be maintained at the plant site for a period of two years and made available to representatives of the TCEQ on request. 11. Fuel for the combustion devices is limited to natural gas or fuel gas with a sulfur content of less than four grains total sulfur per 100 dry standard cubic feet. Use of any other fuel will require a permit modification and approval from the Executive Director of the Texas Commission on Environmental Quality (TCEQ). 12. Emissions from AD/WW Tanks: T-O-87, T-O-88, T-O-126, and T-O-127 shall be sent to Flares UER044 and UER046, or a carbon adsorption system as specified in Special Condition No. 16. Also, to minimize off-property impacts from the AD/wastewater tanks, the vents on Tanks T-O-87 and T-O-88 shall be sealed and emissions shall be routed to Flares UER044 and UER046, or a carbon adsorption system as specified in Special Condition No. 16. 13. Gas Turbines shall be operated in accordance with the following requirements: A. During operation of the gas turbine, when the gas turbine is exhausting through the Waste Heat Boiler (Emission Point No. [EPN] A3HA35), the average hourly concentration in parts per million by volume dry (ppmvd) corrected to 15 percent oxygen (O2) (ppmvd at 15 percent O2) in the waste heat boiler exhaust gases shall not exceed 37 ppmvd for NOx. Carbon monoxide (CO) concentration in the waste heat boiler stack shall not exceed 25 ppmvd corrected to 15 percent O2. B. During operation of the gas turbine, when the gas turbine is exhausting through the Bypass Stack (EPN A3CA31), the average concentration in ppmvd at 15 percent O2 in the bypass stack exhaust gases shall not exceed 42 ppmvd for NOx. Carbon monoxide concentration in the bypass stack shall not exceed 25 ppmvd corrected to 15 percent O2. C. The above limits shall apply except during periods of maintenance, start-up, or shutdown (MSS), not to exceed 3 hours. In addition, the above limits shall not apply when it is necessary, due to mechanical constraints, to operate the gas turbine at a partial load level at which emissions will rise above these values. These periods shall not exceed 12 hours per event. NEICVP1446E01 Appendix P Page 4 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 5 D. The gas turbine shall exhaust through the waste heat boiler at all times except as specified below: (1) During periods specified in Special Condition No. 13.C. (2) The gas turbine shall be allowed to exhaust through the Bypass Stack (EPN A3CA31) during maintenance and repairs which require the waste heat boiler to be taken out of service. Records of each maintenance and repair including the description and duration of the activity shall be kept at the plant site. Storage Tanks 14. Storage tank throughput and service shall be limited to the following: Tank Identifier T-A3-29 T-A3-39 T-A3-46 T-O-39 T-O-40 T-O-43 T-O-87 T-O-88 T-O-126 T-O-127 Service Wash Oil Methanol Tar Waste Oil Waste Oil Wash Oil Aromatic Distillate / Wastewater Aromatic Distillate / Wastewater Aromatic Distillate / Wastewater Aromatic Distillate / Wastewater Fill/Withdrawal Rate (gallons/hr) 19,200 4,500 4,519 6,006 6,006 19,200 24,000 (Note) (Note) (Note) Rolling 12 Month Throughput (gallons) 2,500,000 12,400 1,718,960 613,200 613,200 2,500,000 42,000,000 (Note) (Note) (Note) Note: The Aromatic Distillate (AD)/Wastewater Tanks (T-O-87, T-O-88, T-O-126, and T-O-127) are listed under a VOC emission cap. The combined AD fill rates and throughputs for all three tanks are listed under T-O-87. 15. Storage tanks are subject to the following requirements: The control requirements specified in parts A-E of this condition shall not apply (1) where the VOC has an aggregate partial pressure of less than 0.50 psia at the maximum feed temperature or 95F, whichever is greater, or (2) to storage tanks smaller than 25,000 gallons. A. An internal floating roof shall be installed on all tanks or the tank emissions shall be routed to a flare. Tanks T-O-43, T-O-87, T-O-88, T-O-126, and T-O-127 may also be routed a carbon adsorption system as specified in Special Condition No.16. An open-top tank containing a floating roof (external floating roof-tank), which uses double seal or secondary seal technology, shall be an approved control alternative to an internal floating roof tank provided the primary seal consists of either a mechanical shoe seal or a liquid-mounted seal, and the secondary seal is rim-mounted. A weather-shield is not approvable as a secondary seal NEICVP1446E01 Appendix P Page 5 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 6 unless specifically reviewed and determined to be vapor-tight. A pressure tank that does not normally vent to atmosphere during normal operations, including filling, is considered equivalent control. B. For any tank equipped with a floating roof, the permit holder shall perform the visual inspections and any seal gap measurements specified in Title 40 Code of Federal Regulations 60.113b (40 CFR 60.113b) Testing and Procedures (as amended at 54 FR 32973, Aug. 11, 1989) to verify fitting and seal integrity. Records shall be maintained of the dates inspection was performed, any measurements made, results of inspections and measurements made (including raw data), and actions taken to correct any deficiencies noted. Tanks T-O-43, T-O-87, and T-O-88 shall have gaskets on all sample hatches. C. The floating roof design shall incorporate sufficient flotation to conform to the requirements of API Code 650 dated November 1, 1998 except that an internal floating cover need not be designed to meet rainfall support requirements and the materials of construction may be steel or other materials. D. Except for labels, logos, etc. not to exceed 15 percent of the tank total surface area, uninsulated tank exterior surfaces exposed to the sun shall be white or unpainted aluminum. Storage tanks must be equipped with permanent submerged fill pipes. This requirement does not apply to geodesic domes. E. The permit holder shall maintain a record of tank throughput for the previous month and the past consecutive 12 month period for each tank. . 16. At all times when in service, the Fixed-Roof Storage Tanks, T-A3-46, T-A3-29, AD/WW Tanks (TO-87, T-O-88, T-O-126, and T-O-127) except for the period when AD/WW Tanks are vented to the LP Flares (EPN: UER044 and UER046), and Oxygen Analyzer Vent shall vent through a carbon adsorption system (CAS) consisting of at least two activated carbon canisters that are connected in series. A. The CAS shall be sampled daily or at intervals no greater than 20 percent of the design carbon replacement interval, whichever is the greater interval, to determine breakthrough of VOC. The sampling point shall be at the outlet of the initial canister but before the inlet to the second or final polishing canister. Sampling shall be done during tank filling which maximum emission is expected to occur. B. The VOC sampling and analysis shall be performed using an instrument with a flame ionization detector (FID), or a TCEQ-approved alternative detector. The instrument/FID must meet all requirements specified in Section 8.1 of EPA Method 21 (40 CFR 60, Appendix A). Sampling and analysis for VOC breakthrough shall be performed as follows: (1) Immediately prior to performing sampling, the instrument/FID shall be calibrated with zero and span calibration gas mixtures. Zero gas shall be certified to contain less than 0.1 ppmv total hydrocarbons. Span calibration gas shall be methane at a concentration within 10 percent of 100 ppmv and certified by the manufacturer to be 2 percent accurate. Calibration error for the zero and span calibration gas checks must be less than 5 percent of the span calibration gas value before sampling may be conducted. (2) The sampling point shall be at the outlet of the initial canister but before the inlet to the second or final polishing canister. Sample ports or connections must be designed such that air leakage into the sample port does not occur during sampling. NEICVP1446E01 Appendix P Page 6 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 7 (3) During sampling, data recording shall not begin until after two times the instrument response time. The VOC concentration shall be monitored for at least 5 minutes, recording 1-minute averages, during tank filling. C. Breakthrough shall be defined as the highest 1 minute average measured VOC concentration at or exceeding 100 ppmv ppmv. When the condition of breakthrough of VOC from the initial saturation canister occurs, the waste gas flow shall be switched to the second canister and a fresh canister shall be placed as the new final polishing canister within twenty-four hours . Sufficient new activated carbon canisters shall be maintained at the site to replace spent carbon canisters such that replacements can be done in the above specified time frame. D. Records of the CAS monitoring maintained at the plant site, shall include (but are not limited to) the following: (1) Sample time and date. (2) Monitoring results (ppmv). (3) Corrective action taken including the time and date of that action. (4) Process operations occurring at the time of sampling. E. Alternate monitoring or sampling requirements that are equivalent or better may be approved by the TCEQ Regional Manager or the TCEQ Regulatory Compliance Section Manager. Alternate requirements must be approved in writing before they can be used for compliance purposes. F. The holder of this permit may request a change in frequency of breakthrough sampling after completing at least three months of sampling as specified above. The request shall include a copy of the CAS monitoring records specified in paragraph D of this condition and shall be submitted to the TCEQ Office of Air, Air Permits Division, Air Permits Division in Austin for review and response. The permit holder may not change the sampling frequency until written approval is received from the Executive Director of the TCEQ. Cooling Tower and Heat Exchanger System 17. The holder of this permit shall perform sampling and make repairs as necessary to demonstrate ongoing compliance with the emission limits for the Cooling Tower (EPN CT-4). The results of all monitoring and maintenance efforts affecting the cooling tower and heat exchanger system shall be recorded and such records shall be maintained for a period of five years. The records shall be made available to TCEQ personnel upon request. This permit does not authorize any emission rates from the cooling tower(s) other than those listed on the attached MAERT. This permit does not authorize emissions not listed on the MAERT during repair or delay of repair, paragraphs C and D below. A. The VOC emissions associated with cooling tower water shall be monitored weekly with an approved method. The sampling method shall be the air stripping method known as the "El Paso" method which is described in the TCEQ Publication, "Air Quality Permit Technical Guidance for Chemical Sources: Cooling Towers," TCEQ Publication No. RG-108, May 1997 (Revised). The sample port shall be located on the top of the above ground horizontal section of the water line returning to the cooling tower. NEICVP1446E01 Appendix P Page 7 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 8 The minimum detection level of the overall testing system shall be 0.030 part per million by weight (ppmw) VOC (concentration VOC in water entering the cooling tower). The minimum detection limit for the air stripped VOC shall be 0.500 ppmv (concentration VOC in the stripping air). Calibration standards shall include at least zero ppmv and 10 ppmv VOC in air (as methane). The concentration of VOC in the stripped air may also be determined by the EPA Methods TO14 and TO15. The testing, analysis, and recordkeeping shall include the air contaminant speciation, physical characteristics, and instrumentation response factors used to convert from the air contaminant concentration in the stripping air (ppmv) to air contaminant concentration in the cooling water (ppmw). Alternate methods may be approved by the TCEQ Regional Office. B. If a heat exchanger leak greater than or equal to 0.050 ppmw VOC (net concentration of strippable air contaminant in the water) is detected, the permittee shall comply with the leak repair requirements of paragraph C below except as provided in paragraph D. C. Leaks associated with the cooling tower(s), as defined by paragraph B, shall be repaired as soon as practical but not later than 45 calendar days after the permittee receives results of the monitoring tests indicating a leak. The leak shall be repaired unless the permittee demonstrates that the results are due to a condition other than a leak. D. Documentation of a decision to delay repair shall state the reasons repair was delayed and shall specify a schedule for completing the repair as soon as practical. For the purpose of this permit condition, delay of repair means not performing the repairs within 45 calendar days after the owner or operator receives results of monitoring tests indicating a leak. Delay of repair beyond the limits specified in subparagraphs (1) through (5) requires approval of the TCEQ Beaumont Regional Office. All documentation of a decision to delay repair shall be submitted in writing to the TCEQ Beaumont Regional Office at least ten days prior to the deadline. If approval from the TCEQ is not received within ten days after a properly submitted notification, approval will automatically be granted unless notified otherwise. If ten days notice cannot be given due to some unscheduled occurrence, then a telephone notice shall be given immediately, followed by a written request including the reason a ten-day notice could not be given. In this case, extension of the deadline will be assumed until a response is received from the TCEQ or until automatic approval after ten days. (1) Delay of repair of heat exchange systems for which leaks have been detected is allowed if the leaking equipment is isolated from the cooling tower system. Notice to the TCEQ Beaumont Regional Office shall include a description of how the exchanger is blocked and a schedule for repair. (2) Delay of repair of heat exchange systems for which leaks have been detected is allowed if the pressure of the cooling water throughout the leaking exchanger is increased to a pressure greater than the process side of the exchanger, thus reversing the direction of the leak. Notice to the TCEQ Beaumont Regional Office shall include a description of how the water pressure was increased and a schedule for repair. (3) Delay of repair may be allowed if repair is technically infeasible without a total unit shutdown or a partial unit shutdown and a shutdown is expected within the next two months. Notice to the TCEQ Beaumont Regional Office shall include a description of why repair of the exchanger is technically infeasible prior to shutdown and a schedule for shutdown and repair. NEICVP1446E01 Appendix P Page 8 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 9 (4) Delay of repair may be allowed for up to 120 calendar days if necessary parts are not available. Notice to the TCEQ Beaumont Regional Office shall include the basis of the reason for delay, the expected emissions during the delay, and a schedule for repair. (5) Delay of repair may be allowed if repair is technically infeasible without a shutdown and the shutdown would cause greater emissions than the potential emissions from delaying repair. The permit holder may delay repair until the next shutdown of the process equipment associated with the leaking heat exchanger. Notice to the TCEQ Beaumont Regional Office shall include the basis for the determination that a shutdown for repair would cause greater emissions than the emissions likely to result from delaying repair. If the delay will exceed two years and the projected emissions due to this leak will exceed the rates as listed in the MAERT for this source, then the permit holder shall submit a permit amendment or permit by rule application to seek authorization for any increase in VOC and/or benzene emissions. 18. Except during periods when the A-3 Unit is processing refinery grade propylene (which does not contain benzene) only, the permit holder is required to monitor for leaks of benzene from the cooling tower and heat exchanger system in VOC service in addition to the requirements of Special Condition No. 17. The benzene emissions shall be monitored daily at a minimum detection limit of 0.003 ppmw (concentration of benzene in the water). Alternate methods may be approved by the Director of the TCEQ Regional Office. If a heat exchanger leak greater than or equal to 0.030 ppmw benzene is detected, the permittee shall comply with the leak repair requirements of Special Condition No. 17, paragraph C, except as provided in paragraph D. 19. The cooling tower (EPN CT-4) shall be operated and monitored in accordance with the following: A. Cooling towers shall each be equipped with drift eliminators having manufacturer's design assurance of 0.001% drift or less. Drift eliminators shall be maintained and inspected at least annually. The permit holder shall maintain records of all inspections and repairs. B. Total dissolved solids (TDS) shall not exceed 1700 parts per million by weight (ppmw). Dissolved solids in the cooling water drift are considered to be emitted as PM, PM10, and PM2.5 as represented in the permit application calculations. C. Cooling towers shall be analyzed for particulate emissions using one of the following methods: (1) Cooling water shall be sampled at least once per day for total dissolved solids (TDS); or (2) TDS monitoring may be reduced to weekly if conductivity is monitored daily and TDS is calculated using a ratio of TDS-to-conductivity (in ppmw per mho/cm or ppmw/siemens). The ratio of TDS-to-conductivity shall be determined by concurrently monitoring TDS and conductivity on a weekly basis. The permit holder may use the average of two consecutive TDS-to-conductivity ratios to calculate daily TDS; or (3) TDS monitoring may be reduced to quarterly if conductivity is monitored daily and TDS is calculated using a correlation factor established for each cooling tower. The correlation factor shall be the average of nine consecutive weekly TDS-to-conductivity ratios determined using C(2) above provided the highest ratio is not more than 10% larger than the smallest ratio. (4) The permit holder shall validate the TDS-to-conductivity correlation factor once each calendar quarter. If the ratio of concurrently sampled TDS and conductivity is more NEICVP1446E01 Appendix P Page 9 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 10 than 10% higher or lower than the established factor, the permit holder shall increase TDS monitoring to weekly until a new correlation factor can be established. D. Cooling water sampling shall be representative of the cooling tower feed water and shall be conducted using approved methods. (1) The analysis method for TDS shall be EPA Method 160.1, ASTM D5907, or SM 2540 C [SM - 19th edition of Standard Methods for Examination of Water]. Water samples should be capped upon collection, and transferred to a laboratory area for analysis. (2) The analysis method for conductivity shall be either ASTM D1125-95A (field or routine laboratory testing) or ASTM D1125-95B (continuous monitor). The analysis may be conducted at the sample site or with a calibrated process conductivity meter. If a conductivity meter is used, it shall be calibrated at least annually. Documentation of the method and any associated calibration records shall be maintained. (3) Alternate sampling and analysis methods may be used to comply with D(1) and D(2) with written approval from the TCEQ Regional Director. (4) Records of all instrument calibrations and test results and process measurements used for the emission calculations shall be retained. E. Emission rates of PM, PM10 and PM2.5 shall be calculated using the measured TDS and the ratio or correlation of TDS to conductivity measurements, the design drift rate and the daily maximum and average actual cooling water circulation rate for the short term and annual average rates. Alternately, the design maximum circulation rate may be used for all calculations. Emission records shall be updated monthly. Piping, Valves, Connectors, Pumps, Agitators and Compressors in contact with VOC - Intensive Directed Maintenance - 28MID 20. Except as may be provided for in the Special Conditions of this permit, the following requirements apply to the above-referenced equipment: A. The requirements of paragraphs F and G shall not apply (1) where the VOC has an aggregate partial pressure or vapor pressure of less than 0.044 pounds per square inch, absolute (psia) at 68F or (2) operating pressure is at least 5 kilopascals (0.725 psi) below ambient pressure. Equipment excluded from this condition shall be identified in a list or by one of the methods described below to be made available upon request. The exempted components may be identified by one or more of the following methods: (1) piping and instrumentation diagram (PID); (2) a written or electronic database or electronic file; (3) color coding; (4) a form of weatherproof identification; or (5) designation of exempted process unit boundaries. B. Construction of new and reworked piping, valves, pump systems, agitators, and compressor systems shall conform to applicable American National Standards Institute (ANSI), American NEICVP1446E01 Appendix P Page 10 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 11 Petroleum Institute (API), American Society of Mechanical Engineers (ASME), or equivalent codes. C. New and reworked underground process pipelines shall contain no buried valves such that fugitive emission monitoring is rendered impractical. New and reworked buried connectors shall be welded. D. To the extent that good engineering practice will permit, new and reworked valves and piping connections shall be so located to be reasonably accessible for leak-checking during plant operation. Difficult-to-monitor and unsafe-to-monitor valves, as defined by Title 30 Texas Administrative Code Chapter 115 (30 TAC Chapter 115), shall be identified in a list to be made available upon request. The difficult-to-monitor and unsafe-to-monitor valves may be identified by one or more of the methods described in subparagraph A above. E. New and reworked piping connections shall be welded or flanged. Screwed connections are permissible only on piping smaller than two-inch diameter. Gas or hydraulic testing of the new and reworked piping connections at no less than operating pressure shall be performed prior to returning the components to service or they shall be monitored for leaks using an approved gas analyzer within 15 days of the components being returned to service. Adjustments shall be made as necessary to obtain leak-free performance. Connectors shall be inspected by visual, audible, and/or olfactory means at least weekly by operating personnel walk-through. Each open-ended valve or line shall be equipped with an appropriately sized cap, blind flange, plug, or a second valve to seal the line. Except during sampling, both valves shall be closed. If the isolation of equipment for hot work or the removal of a component for repair or replacement results in an open ended line or valve, it is exempt from the requirement to install a cap, blind flange, plug, or second valve for 72 hours. If the repair or replacement is not completed within 72 hours, the permit holder must complete either of the following actions within that time period; (1) a cap, blind flange, plug, or second valve must be installed on the line or valve; or (2) the open-ended valve or line shall be monitored once for leaks above background for a plant or unit turnaround lasting up to 45 days with an approved gas analyzer and the results recorded. For all other situations, the open-ended valve or line shall be monitored once by the end of the 72 hours period following the creation of the open ended line and monthly thereafter with an approved gas analyzer and the results recorded. For turnarounds and all other situations, leaks are indicated by readings of 500 ppmv and must be repaired within 24 hours or a cap, blind flange, plug, or second valve must be installed on the line or valve. F. Accessible valves shall be monitored by leak checking for fugitive emissions at least quarterly using an approved gas analyzer with a directed maintenance program. Sealless/leakless valves (including, but not limited to, welded bonnet bellows and diaphragm valves) and relief valves equipped with a rupture disc upstream or venting to a control device are not required to be monitored. For valves equipped with rupture discs, a pressure-sensing device shall be installed between the relief valve and rupture disc to monitor disc integrity. All leaking discs shall be replaced at the earliest opportunity but no later than the next process shutdown. A check of the reading of the pressure-sensing device to verify disc integrity shall be performed at least quarterly and recorded in the unit log or equivalent. Pressure-sensing NEICVP1446E01 Appendix P Page 11 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 12 devices that are continuously monitored with alarms are exempt from recordkeeping requirements specified in this paragraph. An approved gas analyzer shall conform to requirements listed in Method 21 of 40 CFR part 60, appendix A. The gas analyzer shall be calibrated with methane. In addition, the response factor of the instrument for a specific VOC of interest shall be determined and meet the requirements of Section 8 of Method 21. If a mixture of VOCs is being monitored, the response factor shall be calculated for the average composition of the process fluid. A calculated average is not required when all of the compounds in the mixture have a response factor less than 10 using methane. If a response factor less than 10 cannot be achieved using methane, then the instrument may be calibrated with one of the VOC to be measured or any other VOC so long as the instrument has a response factor of less than 10 for each of the VOC to be measured. A directed maintenance program shall consist of the repair and maintenance of components assisted simultaneously by the use of an approved gas analyzer such that a minimum concentration of leaking VOC is obtained for each component being maintained. A first attempt to repair the leak must be made within 5 days. Records of the first attempt to repair shall be maintained. Replaced components shall be re-monitored within 15 days of being placed back into VOC service. G. All new and replacement pumps, compressors, and agitators shall be equipped with a shaft sealing system that prevents or detects emissions of VOC from the seal. These seal systems need not be monitored and may include (but are not limited to) dual pump seals with barrier fluid at higher pressure than process pressure, seals degassing to vent control systems kept in good working order, or seals equipped with an automatic seal failure detection and alarm system. Submerged pumps or sealless pumps (including, but not limited to, diaphragm, canned, or magnetic-driven pumps) may be used to satisfy the requirements of this condition and need not be monitored. All other pump, compressor, and agitator seals shall be monitored with an approved gas analyzer at least quarterly. H. Damaged or leaking valves, connectors, compressor seals, pump seals, and agitator seals found to be emitting VOC in excess of 500 parts per million by volume (ppmv) or found by visual inspection to be leaking (e.g., dripping process fluids) shall be tagged and replaced or repaired. A leaking component shall be repaired as soon as practicable, but no later than 15 days after the leak is found. If the repair of a component would require a unit shutdown that would create more emissions than the repair would eliminate, the repair may be delayed until the next scheduled shutdown. All leaking components which cannot be repaired until a scheduled shutdown shall be identified for such repair by tagging. A listing of all components that qualify for delay of repair shall be maintained on a delay of repair list. The cumulative daily emissions from all components on the delay of repair list shall be estimated by multiplying by 24 the mass emission rate for each component calculated in accordance with the instructions in 30 TAC 115.782 (c)(1)(B)(i)(II). The calculations of the cumulative daily emissions from all components on the delay of repair list shall be updated within ten days of when the latest leaking component is added to the delay of repair list. When the cumulative daily emission rate of all components on the delay of repair list times the number of days until the next scheduled unit shutdown is equal to or exceeds the total emissions from a unit shutdown as calculated in accordance with 30 TAC 115.782 (c)(1)(B)(i)(I), the TCEQ Regional Manager and any local programs shall be notified and may require early unit NEICVP1446E01 Appendix P Page 12 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 13 shutdown or other appropriate action based on the number and severity of tagged leaks awaiting shutdown. This notification shall be made within 15 days of making this determination. I. In lieu of the monitoring frequency specified in paragraph F, valves in gas and light liquid service may be monitored on a semiannual basis if the percent of valves leaking for two consecutive quarterly monitoring periods is less than 0.5 percent. Valves in gas and light liquid service may be monitored on an annual basis if the percent of valves leaking for two consecutive semiannual monitoring periods is less than 0.5 percent. If the percent of valves leaking for any semiannual or annual monitoring period is 0.5 percent or greater, the facility shall revert to quarterly monitoring until the facility again qualifies for the alternative monitoring schedules previously outlined in this paragraph. J. The percent of valves leaking used in paragraph I shall be determined using the following formula: ((V_l+V_s ))/V_t 100=V_p Where: Vl = the number of valves found leaking by the end of the monitoring period, either by Method 21 or sight, sound, and smell. Vs = the number of valves for which repair has been delayed and are listed on the facility shutdown log. Vt = the total number of valves in the facility subject to the monitoring requirements, as of the last day of the monitoring period, not including nonaccessible and unsafe to-monitor valves. Vp = the percentage of leaking valves for the monitoring period. K. Records of repairs shall include date of repairs, repair results, justification for delay of repairs, and corrective actions taken for all components. Records of instrument monitoring shall indicate dates and times, test methods, and instrument readings. The instrument monitoring record shall include the time that monitoring took place for no less than 95% of the instrument readings recorded. Records of physical inspections shall be noted in the operator's log or equivalent. L. Compliance with the requirements of this condition does not assure compliance with requirements of 30 TAC Chapter 115, an applicable New Source Performance Standard, or an applicable National Emission Standard for Hazardous Air Pollutants and does not constitute approval of alternative standards for these regulations. 28CNTQ (Connectors Inspected Quarterly) 21. In addition to the weekly physical inspection required by Item E of Special Condition No. 20, all accessible connectors in gas/vapor and light liquid service shall be monitored quarterly with an NEICVP1446E01 Appendix P Page 13 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 14 approved gas analyzer in accordance with Items F through J of Special Condition No. 20 (28CNTQ). A. Allowance for reduced monitoring frequencies. (1) The frequency of monitoring may be reduced from quarterly to semiannually if the percent of connectors leaking for two consecutive quarterly monitoring periods is less than 0.5 percent. (2) The frequency of monitoring may be reduced from semiannually to annually if the percent of connectors leaking for two consecutive semiannual monitoring periods is less than 0.5 percent. B. If the percent of connectors leaking for any semiannual or annual monitoring period is 0.5 percent or greater, the facility shall revert to quarterly monitoring until the facility again qualifies for the alternative monitoring schedules previously outlined in this paragraph. The percent of connectors leaking used in paragraph A shall be determined using the following formula: (C_l+C_s)/C_t 100=C_p Where: Cl = the number of connectors found leaking by the end of the monitoring period, either by Method 21 or sight, sound, and smell. Cs = the number of connectors for which repair has been delayed and are listed on the facility shutdown log. Ct = the total number of connectors in the facility subject to the monitoring requirements, as of the last day of the monitoring period, not including nonaccessible and unsafe-to-monitor connectors. Cp = the percentage of leaking connectors for the monitoring period. Initial Determination of Compliance 22. The permit holder shall perform stack sampling and other testing as required to establish the actual pattern and quantities of air contaminants being emitted into the atmosphere from the waste heat boiler exhaust, the cracking furnaces, and the Spray Drum (FA350). The permit holder is responsible for providing sampling and testing facilities and conducting the sampling and testing operations at his expense. Sampling shall be conducted in accordance with the appropriate procedures of the TCEQ Sampling Procedures Manual and with the EPA Reference Method 8 for sulfur dioxide (SO2), Reference Method 9 for opacity, Reference Method 10 for the concentration of CO, and Reference Method 20 for the concentrations of NOx and O2 or equivalent methods. Fuel sampling using the methods and procedures of 40 CFR 60.335(d) may be conducted in lieu of stack sampling for SO2. If fuel sampling is used, compliance with SO2 limits shall be based on 100 percent conversion of the sulfur in the fuel to SO2. Requests to waive testing for any pollutant specified in this condition shall be submitted to the TCEQ Office of Air, Air Permits Division. Test waivers and alternate/equivalent procedure NEICVP1446E01 Appendix P Page 14 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 15 proposals for Title 40 Code of Federal Regulation Part 60 (40 CFR Part 60) testing which must have EPA approval shall be submitted to the TCEQ Regional Director. A. The appropriate TCEQ Regional Office shall be notified not less than 45 days prior to sampling. The notice shall include: (1) Proposed date for pretest meeting. (2) Date sampling will occur. (3) Name of firm conducting sampling. (4) Type of sampling equipment to be used. (5) Method or procedure to be used in sampling. (6) Description of any proposed deviation from the sampling procedures specified in this permit or TCEQ/EPA sampling procedures. (7) Method for determining turbine load both before and after sampling. The purpose of the pretest meeting is to review the necessary sampling and testing procedures, to provide the proper data forms for recording pertinent data, and to review the format procedures for the test reports. The TCEQ Regional Director must approve any deviation from specified sampling procedures. B. Air contaminants emitted from the waste heat boiler exhaust to be tested for while the duct burner and turbine are being fired at full load include (but are not limited to) NOx, O2, CO, and opacity. C. The NOx and CO concentrations shall be corrected and reported according to Special Condition No. 13. This testing will be used to demonstrate initial compliance with Special Condition No. 13 and the MAERT. D. Sampling of the waste heat boiler shall occur as required by the TCEQ. E. Air contaminants emitted from the cracking furnaces to be tested for while the furnaces are fired at full load include (but are not limited to) NOx, O2, and CO. F. Sampling of the Cracking Furnaces (EPNs A3HA31, A-H, and J) to ensure compliance with the emission caps shall occur within 180 days of initial operation of the cracking furnace LowNOx burners. Additional sampling shall occur as may be required by the TCEQ. Sampling of one cracking furnace may be considered representative of each cracking furnace in the group HA31, A-H, and J, upon the approval of TCEQ Beaumont Regional Office, at the time of the pretest meeting. G. Air contaminants emitted from the Spray Drum (FA350) shall be tested at full load. Testing shall include nickel, chromium, and particulate matter less than 10 microns in diameter. Testing shall occur within 180 days after start-up following approval of the March 2001 amendment to this permit. H. Copies of the final sampling report shall be forwarded to the offices below within 60 days after sampling is completed. Sampling reports shall comply with the attached provisions entitled "Chapter 14, Contents of Sampling Reports" of the TCEQ Sampling Procedures Manual. The reports shall be distributed as follows: NEICVP1446E01 Appendix P Page 15 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 16 One copy to the appropriate TCEQ Regional Office. One copy to each local air pollution control program. Demonstration of Compliance 23. The holder of this permit shall install, calibrate, maintain, and operate a continuous emission monitoring system (CEMS) to measure and record the concentrations of NOx, CO, and O2 in the waste heat boiler exhaust. If the turbine is operated without the waste heat boiler, the CEMS shall measure and record the concentration of NOx, CO, and O2 in the turbine exhaust. The NOx and CO concentrations shall be corrected and reported according to Special Condition No. 13. A. The CEMS shall meet the design and performance specifications, pass the field tests, and meet the installation requirements and the data analysis and reporting requirements specified in the applicable Performance Specification Nos. 1 through 7, Title 40 Code of Federal Regulation Part 60 (40 CFR Part 60), Appendix B. If there are no applicable performance specifications in 40 CFR Part 60, Appendix B, contact the TCEQ Office of Air, Air Permits Division for requirements to be met. B. The system shall be zeroed and spanned daily and corrective action taken when the 24-hour span drift exceeds two times the amounts specified in 40 CFR Part 60, Appendix B or as specified by the TCEQ if not specified in Appendix B. Zero and span is not required on weekends and plant holidays if instrument technicians are not normally scheduled on those days. Each monitor shall be quality-assured at least quarterly using Cylinder Gas Audits (CGA) in accordance with 40 CFR Part 60, Appendix F, Procedure 1, Section 5.1.2, with the following exception: a relative accuracy test audit (RATA) is not required once every four quarters (i.e., four successive quarterly CGA may be conducted). An equivalent quality-assurance method approved by the TCEQ may also be used. Successive quarterly audits shall occur no closer than two months. All CGA exceedances of +15 percent accuracy indicate that the CEMS is out of control. C. The monitoring data shall be reduced to hourly average concentrations at least once each day, using a minimum of four equally-spaced data points from each one-hour period. The individual average concentrations shall be reduced to units of the permit allowable emission rates in pound per hour (lb/hr) at least once each day and cumulative tons per year on a 12month rolling average at least once every month. D. All monitoring data and quality-assurance data shall be maintained by the source for a period of two years and shall be made available to the TCEQ Executive Director or designated representative upon request. The data from the CEMS may, at the discretion of the TCEQ, be used to determine compliance with the conditions of this permit. E. All cylinder gas audit exceedances of 15 percent accuracy and any CEMS downtime shall be reported to the TCEQ Beaumont Regional Director within three days of any downtime, and necessary corrective action shall be taken. Supplemental stack concentration measurements may be required at the discretion of the TCEQ Beaumont Regional Director. NEICVP1446E01 Appendix P Page 16 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 17 24. The custom fuel monitoring schedule (CFMS) approved by the EPA in March 1997 is recognized as enforceable conditions of this permit. The sampling and analysis frequency for fuel nitrogen and sulfur in the current phase of the CFMS is semiannually. Wastewater Requirements 25. At all times when in service except as authorized under Special Condition No. 26, the wastewater shall be routed through a CAS consisting of at least two activated carbon beds (WWTP A-3 Carbon Beds) that are connected in series to remove organics from the wastewater stream. A. The CAS shall be sampled and the event recorded daily to determine breakthrough of benzene. The sampling point shall be after the outlet of the initial bed but before the inlet to the final bed. B. The method of benzene sampling and analysis shall be by collection using the approach of 40 CFR 61.355(c)(3)(i) Subpart FF, and water analysis by EPA SW-846, Method 8260 or another method approved by TCEQ Regional Office, at a minimum detection limit of 0.010 ppmw, with a turn-around-time sufficient to determine the benzene concentration in the water. The analytical system shall be calibrated each day that analyses are conducted. Facility owner or operator shall prepare and maintain on-site records of the monitoring and analysis plan. C. Breakthrough shall be defined as a measured benzene concentration of 20 ppmw. When the condition of breakthrough from the initial bed occurs, the wastewater flow shall be switched to the second bed or a standby series of beds immediately. Within 24 hours of detection of breakthrough, a fresh bed shall be placed as the new final polishing bed. Sufficient new activated carbon shall be maintained at the site to replace spent carbon beds such that replacements can be done in the above specified time frames. D. Records of the CAS monitoring and CAS operations shall be maintained at the plant site and include (but will not be limited to) the following: (1) Sample time and date. (2) Laboratory results (benzene, ppmw). (3) Corrective action taken including the time and date of that action. (4) Bed change out method, schedule, and frequency. These records shall be made available to representatives of the TCEQ and local programs upon request and shall be retained for at least two years following the date that the data are obtained. E. The holder of this permit may request a change in frequency of breakthrough sampling from the daily sampling only after completing at least three months of sampling as specified above. The request would then be to a frequency of either daily or at intervals no greater than 20 percent of the observed carbon replacement interval, whichever is the greater interval. The request or any other alternative frequency request shall include a copy of the CAS sampling/analysis records and CAS change out specified in paragraph D of this condition and shall be submitted to the TCEQ Office of Air, Air Permits Division, Air Permits Division in Austin for review and response. The permit holder may not change the sampling frequency until written approval is received from the Executive Director of the TCEQ. (9/03) NEICVP1446E01 Appendix P Page 17 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 18 F. The permit holder shall monitor and record the wastewater concentrations from the outlet of the second WWTP A-3 carbon bed for benzene, toluene, phenanthrene, and anthracene on a quarterly basis. The concentration of each of these air contaminants shall not exceed 0.02 ppmw, 0.03 ppmw, 1.76 ppmw, and 0.13 ppmw, respectively. The sampling and analytical method shall be in accordance with the requirements in 40 CFR Part 61, Subpart FF. Records of the sampling locations, sampling procedures, test methods, sample custody forms, analytical method, and analytical results shall be kept on-site. 26. During the period when the wastewater stripper is not operational, the wastewater shall be routed through a CAS consisting of at least two activated carbon beds (WWTP A-3 Carbon Beds) that are connected in series to remove organics from the wastewater stream. A. The CAS shall be sampled and the event recorded at least once every six hours to determine breakthrough of benzene. The sampling point shall be after the outlet of the initial bed but before the inlet to the final bed. B. The method of benzene sampling and analysis shall be by collection using the approach of 40 CFR 61.355(c)(3)(i) Subpart FF, and water analysis by EPA SW-846, Method 8260 or another method approved by TCEQ Regional Office, at a minimum detection limit of 0.010 ppmw, with a turn-around-time sufficient to determine the benzene concentration in the water. The analytical system shall be calibrated each day that analyses are conducted. Facility owner or operator shall prepare and maintain on-site records of the monitoring and analysis plan. C. Breakthrough shall be defined as a measured benzene concentration of 0.5 ppmw. When the condition of breakthrough from the initial bed occurs, the wastewater flow shall be switched to the second bed or a standby series of beds immediately. Within 24 hours of detection of breakthrough, a fresh bed shall be placed as the new final polishing bed. Sufficient new activated carbon shall be maintained at the site to replace spent carbon beds such that replacements can be done in the above specified time frames. D. Records of the CAS monitoring and CAS operations shall be maintained at the plant site and include (but will not be limited to) the following: (1) Sample time and date. (2) Laboratory results (benzene, ppmw). (3) Corrective action taken including the time and date of that action. (4) Bed change out method, schedule, and frequency. These records shall be made available to representatives of the TCEQ and local programs upon request and shall be retained for at least two years following the date that the data are obtained. E. The holder of this permit may request a change in frequency of breakthrough sampling from the daily sampling only after completing at least three months of sampling as specified above. The request would then be to a frequency of either daily or at intervals no greater than 20 percent of the observed carbon replacement interval, whichever is the greater interval. The request or any other alternative frequency request shall include a copy of the CAS sampling/analysis records and CAS change out specified in paragraph D of this condition and shall be submitted to the TCEQ Office of Air, Air Permits Division, Air Permits Division in NEICVP1446E01 Appendix P Page 18 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 19 Austin for review and response. The permit holder may not change the sampling frequency until written approval is received from the Executive Director of the TCEQ. F. The permit holder shall monitor and record the wastewater concentrations from the outlet of the second WWTP A-3 carbon bed for benzene, toluene, phenanthrene, and anthracene on a weekly basis. The concentration of each of these air contaminants shall not exceed 0.02 ppmw, 0.03 ppmw, 1.76 ppmw, and 0.13 ppmw, respectively. The sampling and analytical method shall be in accordance with the requirements in 40 CFR Part 61, Subpart FF. Records of the sampling locations, sampling procedures, test methods, sample custody forms, analytical method, and analytical results shall be kept on-site. Periodic Maintenance 27. The permit holder may conduct water washings utilizing a soap solution on Gas Turbine C-A3-1-1 a maximum of six times per calendar week. Each wash period shall not exceed 30 minutes. During these wash periods, the NOx and CO concentrations required in Special Condition No. 13 and recorded by the CEMS emission monitors shall be temporarily suspended for the wash period. The limits specified on the MAERT apply during these periods. Periods of turbine washings shall be logged and documented to show compliance on the semiannual excess emissions reports. Recordkeeping and Reporting Requirements 28. The records required by this special condition shall be maintained in hard copy or electronic format and shall be maintained for at least five years rather than the two-year period specified in General Condition No. 7. These records shall be made immediately available at the request of personnel from the TCEQ or any air pollution control agency with jurisdiction. 29. The holder of this permit shall submit to the EPA Region 6 Office in Dallas and the TCEQ Regional Office semiannual reports as described in 40 CFR 60.7. Such reports are required for each emission unit which is required to be continuously monitored pursuant to Special Condition Nos. 22 and 23. In addition to the information specified in 40 CFR 60.7(c), each report shall contain: A. Hours of operation of the facility, a summary of the periods of noncomplying emissions, monitoring system percent reliability, and monitoring system downtimes by cause. B. Times when span drift exceeds amounts established in 40 CFR Part 60, Appendices B and F, or as specified by the TCEQ. The reporting of excess emissions required by this condition does not relieve the holder of this permit from the notification requirements of upset conditions or maintenance as required by 30 TAC 101.201 and 101.211. 30. For the purposes of reporting pursuant to Special Condition No. 23, noncomplying emissions or conditions are defined as follows: A. Each 1-hour period of turbine operation, except during wash periods (as defined in Special Condition No. 27), start-up or shutdown, not to exceed three hours, or during part load 7 operation, not to exceed 12 hours, during which the average emissions of NOx or CO, as measured and recorded by the monitoring system, exceed the emission limitations of Special Condition No. 13 or the MAERT. NEICVP1446E01 Appendix P Page 19 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Special Conditions Permit Number 19823 Page 20 B. Noncomplying annual emissions of NOx and CO are defined as a rolling 12-month period during which the 12-month cumulative emissions of NOx and CO exceed the annual limits in the MAERT. C. Noncomplying emissions of SO2 are defined as any sample of fuel which is found to contain sulfur which indicated exceedance of the requirements of Special Condition No. 11, based on 100 percent conversion of the sulfur in the fuel to SO2. Emission Reductions 31. This permit is conditioned on the completion of all emission reduction projects represented on the netting calculations, Table 2N, performed for permit amendment application for Permit Number 19823, Form PI-1 received January 7, 2002. The reduction of emissions shall occur not later than any increase in production from these permitted facilities. The holder of this permit shall maintain records of these emission reductions and provide access and/or copies upon request to the TCEQ Executive Director, representatives, or any local air pollution control program having jurisdiction. Construction of these facilities must commence as defined in 40 CFR 52.21(b)(9) (prevention of significant deterioration) or 40 CFR 51.165(a)(1)(xvi) (nonattainment) no later than five years after the reductions are actually accomplished, or the above reductions are no longer creditable, and the permits are automatically void. Permit by Rule 32. The following sources and/or activities are authorized under a Permit by Rule (PBR) by Title 30 Texas Administrative Code Chapter 106 (30 TAC Chapter 106). These lists are not intended to be all inclusive and can be altered without modifications to this permit. Authorization PBR Registration No. 91994 PBR Registration No. 109215 PBR Registration No. 139463 Source or Activity Increase in cooling tower emissions Increase in fugitive emissions Increase in fugitive and flare emissions Date: May 28, 2019 NEICVP1446E01 Appendix P Page 20 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Permit Renewal & Amendment Source Analysis & Technical Review Company City County Project Types Project Reviewer Site Name Huntsman Petrochemical LLC Port Neches Jefferson Renewal and Amend Cara Hill Huntsman Port Neches Permit Number Project Numbers Account Number Regulated Entity Number Customer Reference Number 19823 245236 and 242850 JE-0052-V RN100219252 CN603839317 Project Overview Huntsman Petrochemical, LLC (Huntsman) owns and operates the A3 Olefins Unit which produces ethylene and propylene in Port Neches, Jefferson County, Texas. Huntsman submitted a renewal application with a concurrent amendment. Huntsman requested an increase in emissions resulting from updated flare calculations and an increase in the number of hydrogenation reactor regeneration cycles. Permit by Rule (PBR) Registration Nos. 91994, 109215, and 139463 are being incorporated into the permit by reference. Maintenance, startup, and shutdown (MSS) emissions are authorized under Permit No. 83816. Emission Summary Air Contaminant Current Allowable Emission Rates (tpy) Proposed Allowable Emission Rates (tpy)* Change in Allowable Emission Rates (tpy) Project Changes at Major Sources (Baseline Actual to Allowable)** PM 0.00 72.54 72.54 0.18 PM10 72.53 72.54 0.01 0.18 PM2.5 0.00 72.54 72.54 0.18 VOC 142.83 143.27 0.44 9.44 NOX 497.06 501.91 4.85 4.85 CO 338.58 374.06 35.48 40.04 SO2 69.05 69.25 0.20 0.98 * Emissions of PM and PM2.5 will be added to the MAERT upon issuance of this project. These emissions were previously quantified and authorized as PM10, but were not speciated in the MAERT. These emissions will be speciated based on current guidance and policy to demonstrate compliance with current standards for PM, PM10, and PM2.5. ** The project changes were calculated by summing the proposed emissions increases (without considering decreases) and subtracting the baseline emissions. Baseline emissions for the flare (EPN UER044) exceeded the current allowable emissions for CO and NOx, and the baseline emissions were reduced to the current allowable emissions for these pollutants. The project change does not exceed the major modification significance levels for any contaminant. Compliance History Evaluation - 30 TAC Chapter 60 Rules A compliance history report was reviewed on: Site rating & classification: Company rating & classification: If the rating is 50<RATING<55, what was the outcome, if any, based on the findings in the formal report: Has the permit changed on the basis of the compliance history or rating? October 4, 2016 18.24 / Satisfactory 6.47 / Satisfactory N/A No NEICVP1446E01 Appendix P Page 211 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Permit No. 19823 Page 2 Permit Renewal & Amendment Source Analysis & Technical Review Regulated Entity No. RN100219252 Public Notice Information - 30 TAC Chapter 39 Rules Rule Citation Requirement 39.403 Is Public Notice Required? If no, give reason: 39.603 Date Application Received: Date Administratively Complete: Small Business Source? Date Leg Letters mailed: Date Published: Publication Name: Pollutants: 39.604 Date Affidavits/Copies Received: Is bilingual notice required? Language: Date Published: Publication Name: Date Affidavits/Copies Received: Date Certification of Sign Posting / Application Availability Received: Public Comments Received? Hearing Requested? Meeting Request? Date Response to Comments sent to OCC: Consideration of Comments: Renewal Yes N/A November 30, 2015 December 16, 2015 December 17, 2015 January 15, 2016 Beaumont Enterprise Organic compounds, nitrogen oxides, sulfur dioxide, carbon monoxide, and particulate matter including particulate matter with diameters of 10 microns or less and 2.5 microns or less January 29, 2016 Yes Spanish January 15, 2016 El Perico February 22, 2016 Amendment No A public notice is not required for amendments involving an increase in emissions below the thresholds in 30 TAC 39.402(a)(3)(B) N/A N/A No N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A February 22, 2016 No No No N/A N/A N/A N/A N/A N/A N/A N/A NEICVP1446E01 Appendix P Page 222 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Permit No. 19823 Page 3 Permit Renewal & Amendment Source Analysis & Technical Review Regulated Entity No. RN100219252 Rule Citation 39.419 Requirement Is 2nd Public Notice required? If no, give reason: Renewal No A second notice is not required for permit renewals where there is no increase in emissions, no new contaminants, and the applicant has a satisfactory or better compliance history. Amendment N/A N/A Renewal Requirements - 30 TAC Chapter 116 Rules Rule Citation Requirement 116.315(a) Date of permit expiration: 116.310 Date written notice of review was mailed: 116.315(a) Date application for Renewal (PI-1R) received: 116.311(a)(1) Do dockside vessel emissions associated with the facility comply with all regulations? 116.311(a)(2) Is the facility being operated in accordance with all requirements and conditions of the existing permit, including representations in the application for permit to construct and subsequent amendments, and any previously granted renewal, unless otherwise authorized for a qualified facility? If no, explain: 116.311(a)(3) Subject to NSPS? Subparts A, Kb, GG, VV, NNN, & RRR 116.311(a)(4) Subject to NESHAPS? Subparts A, J, & FF 116.311(a)(5) Subject to NESHAPS (MACT) for source categories? Subparts A, XX, & YY 116.311(a)(6) Does this project require case-by-case MACT? 116.311(b) Was there a condition of air pollution that had to be addressed during this project review? If yes, explain: 116.314(a) Does the facility meet all permit renewal requirements? 116.313 Permit Renewal Fee: $ 10,000.00 Fee certification: Applicable Outstanding Fees: May 26, 2016 September 22, 2015 November 30, 2015 N/A Yes N/A Yes Yes Yes No No N/A Yes M608321 None Amendment Requirements - 30 TAC Chapter 116 Rules Rule Citation Requirement 116.111(a)(2)(G) Is the facility expected to perform as represented in the application? Yes 116.111(a)(2)(A)(i) Are emissions from this facility expected to comply with all TCEQ air Yes quality Rules & Regulations, and the intent of the Texas Clean Air Act? 116.111(a)(2)(B) Emissions will be measured using the parametric monitoring, recordkeeping, and following method: calculations NEICVP1446E01 Appendix P Page 233 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Permit No. 19823 Page 4 Permit Renewal & Amendment Source Analysis & Technical Review Regulated Entity No. RN100219252 Rule Citation 116.111(a)(2)(D) 116.111(a)(2)(E) 116.111(a)(2)(F) 116.111(a)(2)(H) 116.111(a)(2)(I) Requirement Comments on emission verification: None Subject to NSPS? Yes Subparts A, Kb, GG, VV, NNN, & RRR Subject to NESHAP? Yes Subparts A, J, & FF Subject to NESHAP (MACT) for source categories? Yes Subparts A, XX, & YY Nonattainment review applicability: The facility is a major source and is located in Jefferson County, which is classified as attainment for all criteria pollutants. Nonattainment review is not applicable. PSD review applicability: This site is a major source and is located in a county which is in attainment for all criteria pollutants. The project increases (tpy) were calculated by summing the proposed emissions increases (without considering decreases) and subtracting the baseline emissions. Baseline emissions for the flare (EPN UER044) exceeded the current allowable emissions for CO and NOx, and the baseline emissions were reduced to the current allowable emissions for these pollutants. Project increases do not exceed major modification significance levels as shown in the table below. PSD review is not applicable. 116.111(a)(2)(L) 116.140 - 141 Project increases PSD significance level CO (tpy) 40.04 100 SO2 (tpy) 0.98 40 NOx (tpy) 4.85 40 VOC (tpy) 9.44 40 PM (tpy) 0.18 25 Is Mass Emissions Cap and Trade applicable to the new or modified facilities? If yes, did the proposed facility, group of facilities, or account obtain allowances to operate: Permit Fee: $ 900.00 Fee certification: PM10 (tpy) 0.18 15 PM2.5 (tpy) 0.18 10 No N/A M602142 Title V Applicability - 30 TAC Chapter 122 Rules Rule Citation Requirement 122.10(14) Title V applicability: The site is subject to the Title V program because it is a major source. operates under Site Operating Permit No. O-2288. The facility currently 122.602 Periodic Monitoring (PM) applicability: PM is applicable because the site is a major source. The following provisions for monitoring are being included in the special conditions: Monthly recordkeeping of the annual production of ethylene and propylene; Monthly recordkeeping of the firing rate heat duty for the furnaces; Continuous flow and composition monitoring of the waste gas stream to the flare; Recordkeeping of tank emissions; Weekly monitoring of cooling tower VOC emissions; Daily/weekly monitoring of TDS in the cooling tower cooling water; Implementation of the 28MID and 28CNTQ leak detection and repair (LDAR) program for VOC fugitive emissions; Continuous emission monitoring system (CEMS) to measure and record the NEICVP1446E01 Appendix P Page 244 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Permit No. 19823 Page 5 Permit Renewal & Amendment Source Analysis & Technical Review Regulated Entity No. RN100219252 concentrations of NOx, CO, and O2 in the waste heat boiler exhaust; and Daily monitoring of the carbon adsorption systems (CAS) VOC breakthrough. 122.604 Compliance Assurance Monitoring (CAM) applicability: CAM is not applicable because no facility has a pre-controlled potential to emit greater than the amount required for the site to be classified as a major source under 30 TAC 122. Request for Comments Received From Program/Area Name Reviewed By/Date Comments Region: 10 Ms. Judy Granger/ Missing PBR Registration No. 139463 in January 3, 2017 Special Conditions. Consider adding alternate flare names to MAERT. Check cooling tower EPN. City: Port Neches County: Jefferson Comment PBR Registration No. 139463 is being added to SC 32. The applicant will use name resolution and/or listed in MAERT. Applicant confirmed cooling tower EPN on the MAERT is the correct unresolved number. The Region reviewer was given responses to the comments and had no issues: objections to issuance. Process Description A-3 Olefins Unit manufactures ethylene and propylene. Raw materials, primarily ethane and propane, and steam enter nine cracking furnaces. The cracked gas is then compressed and sent to the recovery section. In the recovery section, the material is processed in a series of distillation columns to separate the materials into the products, which ethylene, propylene, residue gas, C4s, and aromatic distillate. The residue gas is used as fuel gas for the furnaces, heaters, and boilers. The C4s are stored in tanks which are routed to the C4 facility for further processing. The aromatic distillate is separated and stored for further processing. Unreacted ethane and propane are recycled back to the cracking furnaces. Project Description Huntsman submitted a renewal application with a concurrent amendment. Huntsman requested an increase in emissions resulting from updated flare calculations resulting from increased fuel gas usage and an increase in the number of hydrogenation reactor regeneration cycles on an annual basis. Registration Nos. 91994, 109215, and 139463 are being incorporated into the permit by reference. Special Condition No. 5.A relating to control projects that were required to be completed is being removed because all projects were completed in 2006. In addition to the changes discussed in the Pollution Prevention, Sources, Controls BACT section below, the following changes will be made to the Special Conditions upon issuance: Special Condition No. Change 6 Requirements relating to an expired schedule of compliance will be removed. 9 The condition allowing a period of time to come into compliance with the Nox/MMBtu requirement will be removed. 17 Recordkeeping requirements for the cooling tower VOC emissions will be increased from 2 to 5 years. 19 Conditions addressing PM emissions will be added. NEICVP1446E01 Appendix P Page 255 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Permit No. 19823 Page 6 Permit Renewal & Amendment Source Analysis & Technical Review Regulated Entity No. RN100219252 30 Recordkeeping requirements will be increased from 2 to 5 years. 32 This condition identifying the PBRs being incorporated by reference will be added. In addition to the changes discussed in the Pollution Prevention, Sources, Controls section below, the following changes will be made to the MAERT upon issuance: Particulate matter will be speciated to include PM, PM10, and PM2.5, because PM and PM2.5 were not previously represented. PM emissions will be added to the cooling tower emissions Footnote 9 will be updated because these pollution control projects were completed. Pollution Prevention, Sources, Controls BACT- [30 TAC 116.311(b)(2) & 30 TAC 116.111(a)(2)(C)] Flares (EPN UER044 and EPN UER046) Flare No. 1 and Flare No. 2 are existing flares that receive captured VOC vapors from several process streams and are designed to meet the requirements of 40 CFR 60.18. Annual and hourly emissions from the flares are increasing as a result of updated calculations. The emission cap for the flares is being updated on the MAERT. Special Condition 10 is being updated to include continuous flow monitoring and a BTU analyzer. The flare is designed to achieve a VOC compound destruction efficiency of 99% for compounds with up to three carbons, and 98% for compounds with four or more carbon atoms. BACT is satisfied for the flare. Spray Drum (EPN A3FA350) The spray drum is an existing unit for decoking of the cracking furnaces and catalyst regeneration. Annual emissions are increasing as a result of the proposed increase in hydrogenation reactor regeneration cycles. Emissions are being updated on the MAERT. The number of hydrogenation reactor cycles is being updated from five cycles to ten cycles in Special Condition No. 7. The spray drum is operated with good combustion practices to the extent possible during decoking and hydrogenation cycles, and the decoking duration and frequency limited by maximizing furnace run time between furnace decoking. This is consistent with recent permit reviews for a similar process. BACT is satisfied for the spray drum. Impacts Evaluation - 30 TAC 116.111(a)(2)(J) Was modeling conducted? Yes Will GLC of any air contaminant cause violation of NAAQS? Is this a sensitive location with respect to nuisance? [116.111(a)(2)(A)(ii)] Is the site within 3000 feet of any school? Additional site/land use information: industrial Type of Modeling: SCREEN3 No No No Summary of Modeling Results NAAQS and State Property Line Standard Proposed emission increases of CO, NO2, SO2, PM10, and PM2.5 were modeled using SCREEN3 dispersion modeling software to demonstrate that the emissions will not cause an exceedance of the NAAQS or the State Property Line Standard. PM10 and PM2.5 hourly emissions are not increasing, and the 24-hour averaging time is not required to be evaluated. The maximum ground level concentrations (GLCmax) of all pollutants were below the significant impact level (SIL) for the NAAQS analysis. The GLCmax of SO2 was below the SIL for the State Property Line Standard analysis. The results are shown in the tables below. NEICVP1446E01 Appendix P Page 266 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Permit No. 19823 Page 7 Permit Renewal & Amendment Source Analysis & Technical Review Regulated Entity No. RN100219252 Pollutant CO NO2 PM10 PM2.5 SO2 (NAAQS) SO2 (State Property Line) Averaging Time 1-hr 8-hr 1-hr annual annual annual 1-hr 3-hr 24-hr annual 30-min SIL 2,000 500 7.5 1 1 0.3 7.8 25 5 1 20.4 GLCmax (g/m3) 9.0 6.3 1.00 0.017 0.02 0.02 0.0488 0.0439 0.0195 0.0233 0.0488 Because the EPA vacated the 24-hr and annual SILs for PM2.5, an appropriate background concentration was subtracted from the NAAQS, yielding differences of 19.33 g/m3 and 4.79 g/m3, respectively. Because these values are greater than the corresponding SIL, the use of the SIL is justified. Background concentrations for PM2.5 were obtained from the EPA AIRS Monitor No. 220190009 located at 2284 Paul Bellow Road, Vinton, Calcasieu Parish, Louisiana. The applicant used a three-year average 2013-2015 of the 98th percentile of the daily average concentrations for the 24-hr value (15.67 g/m3) and a three-year average 2013-2015 of the annual concentrations for the annual value (7.21 g/m3). The differences were less than the PM2.5 SIL values for both the 24-hour and annual averages. This monitor is reasonable based on a quantitative analysis of source emissions located within ten kilometers (km) of the project site and monitor location. Based on the modeled concentrations, this project is not expected to cause an exceedance of the NAAQS. State Health Effects Review The applicant provided a health effects analysis using the TCEQ Modeling and Effects Review Applicability (MERA) guidance document (APDG 5874) and SCREEN3 dispersion modeling software to evaluate potential offsite impacts. The constituents evaluated include benzene, 1,3-butadiene, butane, ethylene, pentane, propane, and propylene. Propane and propylene are simple asphyxiates and do not require an effects review, which satisfies Step 2 of the MERA analysis. Based on the proposed emission increases, the annual effects screening level (ESL) is greater than or equal to 10% of the short-term ESL, and the short term emission rate increases are within the appropriate ranges to be considered a de minimis level increase in emissions for butane and pentane. This satisfies Step 4C of the MERA analysis and no further review of these constituents is required. SCREEN3 modeling software was used to obtain the concentrations due to the emission increases of the remaining contaminants. The predicted concentrations of benzene, butadiene, and ethylene were below 10% of the short-term and long-term ESLs, which satisfies Step No. 5 of the MERA. No further review of these constituents is required. NEICVP1446E01 Appendix P Page 277 of 28 Indorama Ventures Oxides LLC Port Neches, Texas Permit No. 19823 Page 8 Permit Renewal & Amendment Source Analysis & Technical Review Regulated Entity No. RN100219252 Pollutant Benzene 1,3-Butadiene Ethylene Short Term ESL (g/m3) 170 510 1400 Long Term ESL (g/m3) 4.5 9.9 34 Short Term GLCmax (g/m3) 0.002 0.002 0.047 Long Term GLCmax (g/m3) 0.0002 0.0002 0.0038 Permit Concurrence and Related Authorization Actions Is the applicant in agreement with special conditions? Company representative(s): Contacted via: Date of contact: Other permit(s) or permits by rule affected by this action: List permit and/or PBR number(s) and actions required or taken: Yes Ms. Sarah Thom (Waid Environmental) Email February 7, 2017 None N/A Project Reviewer Cara Hill 2/7/2017 Date Team Leader Cheryl Covone 2/9/17 Date NEICVP1446E01 Appendix P Page 288 of 28 Indorama Ventures Oxides LLC Port Neches, Texas