ADEQ OPERATING AIR PERMIT
Pursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation #26: Permit #: 801-AOP-R1 IS ISSUED TO: Dow Chemical Corporation 3230 Dow Road Russellville, AR 72802 Pope County CSN: 58-0011
THIS PERMIT AUTHORIZES THE ABOVE REFERENCED PERMITTEE TO INSTALL, OPERATE, AND MAINTAIN THE EQUIPMENT AND EMISSION UNITS DESCRIBED IN THE PERMIT APPLICATION AND ON THE FOLLOWING PAGES. THIS PERMIT IS VALID BETWEEN: August 4, 2000 and August 3, 2005 AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Keith A. Michaels Date Modified SECTION I: FACILITY INFORMATION PERMITTEE: CSN: PERMIT NUMBER: FACILITY ADDRESS: COUNTY: CONTACT POSITION: TELEPHONE NUMBER: Dow Chemical Corporation 58-0011 801-AOP-R1 3230 Dow Road Russellville, AR 72802 Pope Gary Bratton (501) 968-3404 REVIEWING ENGINEER: Amanda Holloway UTM North-South (X): UTM East-West (Y): Zone 15 3899 km Zone 15 486 km 2 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SECTION II: INTRODUCTION Summary of Permit Activity Dow Chemical Corporation (Dow) is located at 3230 Dow Road, Russellville, Pope County, Arkansas. The company is involved in the business of manufacturing catalytic cathode and anode materials and polymeric concrete castings. Presently, operations at this site consist of support, service, and maintenance for other Dow sites. Air emissions from this facility are mainly volatile compounds and particulate matter. Permit 801-AOP-R1 is a minor modification to the existing Title V air permit. This minor modification allows Dow to replace an existing resin storage tank (SN-09) with a new tank. No increase in permitted emissions will result from this permit modification. Process Description Unit 5 (Cell Production) There are several groupings of sources called units. Unit 5 is the cell production area where casting operations are performed. Raw materials such as solvents, resins, and sand are delivered via trucks to the site. All raw materials are blended together at the bulk mixing area and then taken to the desired mold. Unit 6 (Catalytic Anode Repair Area) Unit 6 is the catalytic anode repair area. Anode backboards are delivered, unloaded, and inspected to determine the extent of the required repair. The copper spray coatings are also examined. Cutting, grit blasting, welding, spray metalizing, and assembling of fabricated parts are also performed in this area. Unit 7 (Catalytic Cathode Production Area) Unit 7 is the catalytic cathode production area. Perforated carbon steel/steel flat bars, rod bolts, and nuts constitute the primary raw materials for this process. Cutting, punching, trimming, forming, welding, spray oiling, and assembling are also performed in this area. The scrap metals are collected and sold to local metal dealers. 3 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 Membrane Cell Plant Operations The membrane cell production area includes cutting, forming, coating, and welding can be performed in this area. The wire mesh pans are prepared in this area. Castings are prepared and then assembled with the wire mesh pans. The assembled cells are then sent to coating where they are dipped a total of six times. After the dipping and drying, the cells are shipped to other facilities. Regulations This facility is subject to the following regulations: Regulation 18 - Arkansas Air Pollution Control Code, Regulation 19 - Regulations of the Arkansas Plan of Implementation for Air Pollution Control, and Regulation 26, Regulations of the Arkansas Operating Air Permit Program. Facility Emission Summary The following table is a summary of emissions from the facility. Specific conditions and emissions for each source can be found starting on the page cross referenced in the table. 4 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 EMISSION SUMMARY Source No. Description Pollutant Emission Rates lb/hr Total Allowable Emissions PM PM10 SO2 VOC CO NOx Acetic Acid* Acetone* Ammonia* Hydrochloric Acid* Methyl Chloroform* Methylene Chloride* Styrene 7.36 7.6 0.1 234.5 0.1 0.3 2.70 3.30 2.30 5.86 10.70 104.31 17.44 tpy 28.57 28.9 0.1 249.5 0.3 1.2 2.50 3.70 2.60 23.54 1.20 21.93 5.08 Cross Reference Page 01 02 03 04 05 06 Upper Sand Silo Lower Sand Silo Sand Hopper Grinding Process Dust Collector Sandblasting Process PM PM10 PM PM10 PM PM10 PM PM10 Not in use. 0.50 0.5 0.20 0.2 1.40 1.4 1.90 1.9 0.60 0.6 6.10 6.1 12 13 14 Not in use. 1.70 1.7 7.30 7.3 15 5 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 EMISSION SUMMARY Source No. Description Pollutant Emission Rates lb/hr 07 Unit 5 Ventilation System VOC Acetone* Methyl Chloroform* Methylene Chloride* Styrene VOC Styrene VOC Styrene VOC Styrene VOC Styrene Methylene Chloride* Methylene Chloride* PM PM10 VOC Hydrochloric Acid* 73.4 3.30 10.70 4.67 17.40 0.1 0.01 0.1 0.01 0.1 0.01 0.1 0.01 49.82 49.82 0.10 0.1 26.8 0.80 tpy 18.3 3.70 1.20 20.47 5.00 0.1 0.05 0.1 0.01 0.1 0.01 0.1 0.01 0.73 0.73 0.4 0.40 80.1 4.87 18 19 20 21 22 23 24 25 Cross Reference Page 16 08 08A 09 09A 10 10A 11 12 71717 Resin Storage Tank 71717 Resin Day Tank 510-N Resin Storage Tank 510-N Resin Totes Methylene Chloride Recovery Still Methylene Chloride Storage Tank Grit Blasting Anode Dip Tank 6 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 EMISSION SUMMARY Source No. Description Pollutant Emission Rates lb/hr 13 Anode Bake Oven PM10 SO2 VOC CO NOx Hydrochloric Acid* PM PM10 PM PM10 PM PM10 PM PM10 VOC Hydrochloric Acid* PM PM10 VOC Hydrochloric Acid* VOC Hydrochloric Acid* 0.1 0.1 0.1 0.1 0.3 0.50 1.29 1.3 0.10 0.1 0.10 0.1 0.27 0.3 26.8 0.80 0.20 0.2 41.8 2.40 0.4 0.20 tpy 0.2 0.1 0.1 0.3 1.2 1.00 5.66 5.7 0.10 0.1 0.40 0.4 1.19 1.2 80.1 4.87 0.89 0.9 59.8 10.40 1.6 0.61 Cross Reference Page 26 14 15 16 17 18 Metal Grit Blaster Fiberglass System Copper Flame Spray Vacuum Grinding System Dip Tank Drying Area Vent Grit Blaster Membrane Cell Component Dip Tank Electric Oven 28 29 30 31 32 19 20 33 34 21 35 7 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 EMISSION SUMMARY Source No. Description Pollutant Emission Rates lb/hr 22 Mix Tank Exhaust VOC Hydrochloric Acid* VOC Hydrochloric Acid* PM PM10 PM PM10 VOC PM PM10 VOC VOC Hydrochloric Acid* Deleted Source Plating Solution Evaporator VOC Ammonia* Hydrochloric Acid* 0.1 0.10 0.10 0.4 0.40 0.40 47 0.1 0.10 6.0 0.40 0.21 0.3 0.10 0.1 4.5 0.60 0.6 52.9 1.0 0.5 tpy 0.5 0.44 4.5 0.30 0.93 1.0 0.40 0.4 0.1 0.10 0.1 2.3 1.0 0.5 Cross Reference Page 36 23 Mix Room Exhaust 38 24 25 26 27 Dust Collector Cathode Weld Grinding Isopropanol Storage Tank Cathode Oil Coating 40 41 42 43 28 Coating Solvent Mix Tanks 45 29 30 31 32 Trash Incinerator Grit Blaster PM PM10 Source Deleted 0.59 0.6 2.60 2.6 49 8 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 EMISSION SUMMARY Source No. Description Pollutant Emission Rates lb/hr 33 34 35 Electric Oven Paint Booth V-307 Day Tank VOC Hydrochloric Acid* Acetic Acid* Ammonia* Hydrochloric Acid* VOC tpy Cross Reference Page Not in use. Deleted Source 0.1 0.01 2.70 2.20 0.05 0.1 0.1 0.01 2.50 2.20 0.05 0.2 50 36 37 38 DAC V Coating Area DAC III Coating Area Fueling Station * Not a VOC. 51 52 53 9 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SECTION III: PERMIT HISTORY Air permit 0801-A was issued to Dow Chemical U.S.A. on 01/07/87 to consolidate various air permits held by the facility. Air permit 0801-AR-1 was issued on 02/08/89 to remove two degreasing operations and add a process for oil coating of finished cathode assemblies. Air permit 0801-AR-2 was issued on 03/14/90. This permit was to construct a production facility to manufacture metal components for membrane cells. Air permit 0801-AR-3 was issued on 04/01/93. This permit was issued to account for changes in operating practices that lowered the facility emissions. This permit also included solvent emissions from storage tanks not previously permitted. The permit was reissued as 0801-AR-4 on 04/21/94. This modification allowed for reduction of the annual allowable VOC emissions. Permit 0801-AR-5 was issued on 12/07/94. The permit increased the production rate. Permit 0801-AR-6 was issued on 04/06/99 and established Dow as a synthetic minor source in regards to Title V Regulations. The facility updated throughput rates and factors to limit emissions to below the Title V thresholds. Permit 801-AOP-R0 was the first operating permit for this facility issued under Regulation #26 on 08/04/00. This permit allowed for a facility expansion to allow for greater production. This expansion established Dow as a major stationary source for VOC. 10 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SECTION IV: EMISSION UNIT INFORMATION Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-02 Lower Sand Silo Source Description A Halliburton DC-202 Baghouse is used to capture particulate from silica sand being transferred through a system to the production area. The dust collector uses 37 cotton bags, a pressure type suction blower, vacuum relief, air operated shaker, and self-supporting weather proof housing. Specific Conditions 1. Pursuant to �19.501 et seq of the Regulations of the Arkansas Plan of Implementation for Air Pollution Control (Regulation #19) effective February 15, 1999 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM10 2. lb/hr 0.5 tpy 1.9 Pursuant to �18.801 of the Arkansas Air Pollution Control Code (Regulation #18) effective February 15, 1999, and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM lb/hr 0.50 tpy 1.90 3. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from SN-02 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 12 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-03 Sand Hopper Source Description A Halliburton baghouse is used to remove particulate from sand prior to its use in the Unit 5 (polymer concrete casting) area. The dust collector uses 37 cotton bags, a pressure type suction blower, vacuum relief, and air operated shaker, and self-supporting weather proof housing. Specific Conditions 4. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM10 5. lb/hr 0.2 tpy 0.6 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM lb/hr 0.20 tpy 0.60 6. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from SN-03 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 13 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-04 Grinding Process Source Description A Buell Norblo bag dust arrester with a mechanical shaker and electrically controlled air reversal valve is used to control particulate matter emission from the Grinding Room adjacent to Unit #5. This control equipment is 99% efficient. Specific Conditions 7. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM10 8. lb/hr 1.4 tpy 6.1 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM lb/hr 1.40 tpy 6.10 9. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from SN-04 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 14 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-06 Sandblasting Process Source Description A Torit Jet continuous duty tube house dust collector captures particulate from the sandblasting of polymer concrete casting and metal plates. These blasting activities occur in a closed room. The baghouse captures dust generated by the blast sand breaking down during use. Specific Conditions 10. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM10 11. lb/hr 1.7 tpy 7.3 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM lb/hr 1.70 tpy 7.30 12. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from SN-06 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 15 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-07 Unit 5 Ventilation System Source Description The Unit 5 ventilation system collects and emits styrene emission from Derkane Resin use, methyl chloroform emission from the coating of the molds, methylene chloride emission from the cleaning of the mixer in the casting area, acetone emissions from the cleaning of hand tools and small parts within the casting area, and naphtha emissions from coating the flat surfaces of casting molds. Specific Conditions 13. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Conditions #15, #17, #19, #23, #29, and #35 and equipment limitations. Pollutant VOC 14. lb/hr 73.4 tpy 18.3 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Conditions #15, #17, #19, #23, #29, and #35 and equipment limitations. Pollutant Acetone* Methyl Chloroform* Methylene Chloride* Styrene * Not a VOC. lb/hr 3.30 10.70 4.67 17.40 tpy 3.70 1.20 20.47 5.00 15. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the 16 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 permittee shall not use in excess of 210 gallons of Chlorothene SM solvent (which contains 11.02 lb/gal methyl chloroform) in SN-07 during any consecutive twelve month period. 16. Pursuant to �19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #15. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department in accordance with General Condition #7. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall not use in excess of 4,275 gallons of Solvent Blend SM-1-VP (which is 100% VOC with no HAPs) in SN-07 during any consecutive twelve month period. Pursuant to �19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #17. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department in accordance with General Condition #7. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall not use in excess of 1,100 gallons of acetone in SN-07 during any consecutive twelve month period. Pursuant to �19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #19. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department in accordance with General Condition #7. 17. 18. 19. 20. 17 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-08 71717 Resin Storage Tank Source Description The 71717 Resin Storage Tank (V-501) was built by Pittsburgh-Des Moines Steel Company in 1971. This is a 15 foot fixed roof, insulated vessel. It is painted white and chilled in the summer months to maintain the storage temperature between 70EF and 80EF. Specific Conditions 21. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #23 and equipment limitations. Pollutant VOC 22. lb/hr 0.1 tpy 0.1 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #23 and equipment limitations. Pollutant Styrene lb/hr 0.01 tpy 0.05 23. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall not have a throughput in excess of 800 tons of resin in SN-08 and SN08A combined during any consecutive twelve month period. Pursuant to �19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #23. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel in accordance with General Condition #7. 24. 18 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-08A 71717 Resin Day Tank Source Description The 71717 Resin Day Use Tank (V-502) is a carbon steel vessel which was installed in 1992. This is a 8 foot diameter by 7.5 foot high fixed roof insulated tank. It is painted white and includes a 6 inch pressure vent pipe in the top of the tank. Specific Conditions 25. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #23 and equipment limitations. Pollutant VOC 26. lb/hr 0.1 tpy 0.1 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #23 and equipment limitations. Pollutant Styrene lb/hr 0.01 tpy 0.01 19 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-09 510-N Resin Storage Tank Source Description The 510-N Resin Storage Tank (V-503) is a 9.5 foot in diameter by 12 foot high fixed roof, insulated vessel. It is painted white and chilled in the summer months to maintain the storage temperature between 70EF and 80EF. A 3 inch by 2 inch pressure vent pipe exists in the top of the tank. Specific Conditions 27. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #29 and equipment limitations. Pollutant VOC 28. lb/hr 0.1 tpy 0.1 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #29 and equipment limitations. Pollutant Styrene lb/hr 0.01 tpy 0.01 29. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall not have a throughput in excess of 200 tons of resin in SN-09 and SN-9A combined during any consecutive twelve month period. Pursuant to �19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #29. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel in accordance with General Condition #7. 20 30. Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-09A 510-N Resin Totes Source Description The 510-N Resin Totes are 3.6 feet wide, 4.1 feet long, and 3.4 feet high. Each has a 350 gallon capacity. Specific Conditions 31. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #29 and equipment limitations. Pollutant VOC 32. lb/hr 0.1 tpy 0.1 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #29 and equipment limitations. Pollutant Styrene lb/hr 0.01 tpy 0.01 21 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-10 Methylene Chloride Recovery Still Source Description Waste methylene chloride from the Unit 5 bulk mixing area is collected and transferred to a recovery still. The material is redistilled to separate solids from the used solvent. The still is vented to the atmosphere. The recycled material is placed in barrels and reused within the facility. Specific Conditions 33. Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #35 and equipment limitations. Pollutant Methylene Chloride* * Not a VOC. lb/hr 49.82 tpy 0.73 22 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-10A Methylene Chloride Storage Tank Source Description The Methylene Chloride Storage Tank, which is a 10 foot by 20 foot vessel, was installed in 1975. This horizontal tank is equipped with a Conservent, which was installed in 1980, with a 3 inch valve set at 4 ounces of pressure. Specific Conditions 34. Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #35 and equipment limitations. Pollutant Methylene Chloride* * Not a VOC. 35. lb/hr 49.82 tpy 0.73 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not have a throughput in excess of 44,000 pounds of Methylene Chloride in SN-10 and SN-10A combined during any consecutive twelve month period. Pursuant to �18.1004 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #35. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel in accordance with General Condition #7. 36. 23 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-11 Grit Blasting Source Description A reworked aluminum oxide grit blaster located in the new M-83 Anode Blast Building is used to remove old coating material from used anodes. Particulate generated from these activities will be collected by a Torit baghouse. Specific Conditions 37. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM10 38. lb/hr 0.1 tpy 0.4 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM lb/hr 0.10 tpy 0.40 39. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from SN-11 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 24 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-12 Anode Dip Tank Source Description Blasted anodes from the M-83 Anode Blast Building are transferred to Unit 6 where coatings are applied. The anodes are dipped six times each in a tank filled with an isopropyl alcohol solution containing 2 metal salts and anhydrous hydrochloric acid. Specific Conditions 40. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #88. Pollutant VOC 41. lb/hr 26.8 tpy 80.1 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #42. Pollutant Hydrochloric Acid lb/hr 0.80 tpy 4.87 42. Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not use in excess of 19,494 pounds of hydrochloric acid in SN-12 during any consecutive twelve month period. Pursuant to �18.1004 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #42. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel in accordance with General Condition #7. SN-13 Anode Bake Oven 25 43. Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 Source Description A natural gas fired oven is used for baking anodes and heat treating metal parts. This controlled baking oven is rated at 2.6 MM Btu/hr. Specific Conditions 44. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #47. Pollutant PM10 SO2 VOC CO NOX 45. lb/hr 0.1 0.1 0.1 0.1 0.3 tpy 0.2 0.1 0.1 0.3 1.2 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #42. Pollutant Hydrochloric Acid lb/hr 0.50 tpy 1.00 46. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from SN-13 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 26 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 47. Pursuant to A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311 and 40 CFR 70.6, the permittee shall only use natural gas in SN-13. This equipment has been permitted for maximum burner capacity. 27 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-14 Metal Grit Blaster Source Description An aluminum oxide grit blaster is used for blasting metal sheets. Particulate generated from these blasting activities is collected by a DCE Vokes baghouse, which is equipped with a 5,100 cubic feet per minute fan, Dacron/poly bags, and an air shaker. Specific Conditions 48. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM10 49. lb/hr 1.3 tpy 5.7 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM lb/hr 1.29 tpy 5.66 50. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from sources SN-14 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 28 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-15 Fiberglass System Source Description A vacuum is used to transfer chopped fiberglass from a bulk container into the Unit 5 polymer concrete mixer. This system is equipped with a separator cartridge filter rated at 99.9% particulate removal efficiency. Specific Conditions 51. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM10 52. lb/hr 0.1 tpy 0.1 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM lb/hr 0.10 tpy 0.10 53. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from sources SN-15 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 29 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-16 Copper Flame Spray Source Description Large titanium sheets are copper coated through a flame spray process. This coating process, where 40 pounds of copper is melted and sprayed onto the backboard, lasts for approximately two hours. Particulate from the coating activities is captured by a Type N Roto-Clone hydrostatic precipitator. Specific Conditions 54. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM10 55. lb/hr 0.1 tpy 0.4 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM lb/hr 0.10 tpy 0.40 56. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from SN-16 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 30 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-17 Vacuum Grinding System Source Description This system is located on the West side of the Unit #5 Building. A vacuum system collects particulate from the grinding of frames and covers in the Unit #5 Cell Finishing Area. The captured dust passes through a Hoffman baghouse, which is rated at 99% efficient in capturing particulate matter. Specific Conditions 57. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM10 58. lb/hr 0.3 tpy 1.2 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM lb/hr 0.27 tpy 1.19 59. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from SN-17 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 31 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-18 Dip Tank Drying Area Vent Source Description This blower and vent is used to redirect a portion of the VOC and HAP emissions from the Anode Dip Tank (SN-12) to the atmosphere. Specific Conditions 60. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #88 and equipment limitations. Pollutant VOC 61. lb/hr 26.8 tpy 80.1 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #62 and equipment limitations. Pollutant Hydrochloric Acid lb/hr 0.80 tpy 4.87 62. Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not use in excess of 19,494 pounds of hydrochloric acid in SN-18 during any consecutive twelve month period. Pursuant to �18.1004 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #62. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel in accordance with General Condition #7. 32 63. Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-19 Grit Blaster Source Description An aluminum oxide grit blaster is used to blast titanium and nickel metal screens, which are used in the production of membrane cells. Particulate is collected by a DCE Vokes baghouse equipped with a 40 horsepower fan and air shaker. Specific Conditions 64. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM10 65. lb/hr 0.2 tpy 0.9 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM lb/hr 0.20 tpy 0.89 66. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from SN-19 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 33 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-20 Membrane Cell Component Dip Tank Source Description This dip tank is used to apply solvent alcohol containing 2 or 3 metal salts and hydrochloric acid to the membrane cells. Emissions include hanging and drying of the cell components. Specific Conditions 67. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #69 and equipment limitations. Pollutant VOC 68. lb/hr 41.8 tpy 59.8 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #69 and equipment limitations. Pollutant Hydrochloric Acid lb/hr 2.40 tpy 10.4 69. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not use in excess of 130,568 pounds of coating solutions in SN-20 during any consecutive twelve month period. Pursuant to �19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #69. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel in accordance with General Condition #7. 70. 34 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-21 Electric Oven Source Description An electric oven is used to bake coated membrane cell components. It takes 2 hours to convert the coating on each batch from the Membrane Cell Dip Tank (SN-20) to the oxide form. Only one batch will fit into this oven each baking cycle. Specific Conditions 71. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #69 and equipment limitations. Pollutant VOC 72. lb/hr 0.4 tpy 1.6 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #69 and equipment limitations. Pollutant Hydrochloric Acid lb/hr 0.20 tpy 0.61 35 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-22 Mix Tank Exhaust Source Description A mixture of hydrochloric acid and isopropanol is pumped into two mixing vessels in the Chemical Mix Room. The two 60 gallon mixing vessels are ducted to a blower that removes alcohol fumes. The fumes are generated during the batch mixing of raw materials with inorganic salts to prepare coating mixtures for the Unit 6 process. Specific Conditions 73. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #75 and equipment limitations. Pollutant VOC lb/hr 0.1 tpy 0.5 74. Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #75 and equipment limitations. Pollutant Hydrochloric Acid lb/hr 0.10 tpy 0.44 75. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall not have throughput in excess of 131,400 gallons of mixed solutions in SN-22 during any consecutive twelve month period. Pursuant to �19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee 36 76. Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #75. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel in accordance with General Condition #7. 37 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-23 Mix Room Exhaust Source Description A Mix Room exhaust blower is present to protect personnel from over-exposure to hydrochloric acid and isopropyl alcohol fumes during Unit 6 research testing operations on new coating formulations. Production type activities are rarely conducted under this exhaust system except occasionally when a need exists to coat a limited number of very small parts which cannot be coated in the large system. Specific Conditions 77. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #79 and equipment limitations. Pollutant VOC lb/hr 6.0 tpy 4.5 78. Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #79 and equipment limitations. Pollutant Hydrochloric Acid lb/hr 0.40 tpy 0.30 79. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall not use in excess of 4.7 tons of mixed solutions in SN-23 during any consecutive twelve month period. 38 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 80. Pursuant to �19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #79. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel in accordance with General Condition #7. 39 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-24 Dust Collector Source Description A Dayton baghouse is used to collect particulate from the mixing vessel used to mix catalytic cathode materials. A remote collection hood is positioned over the mixing vessel to capture any dust generated from the mixing of catalytic cathode materials. Specific Conditions 81. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM10 82. lb/hr 0.3 tpy 1.0 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM lb/hr 0.21 tpy 0.93 83. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from SN-24 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 40 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-25 Cathode Weld Grinding Source Description Dust from cathode weld grinding activities are captured by a Hoffman baghouse. This dust collector minimizes dust exposure to personnel. Specific Conditions 84. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM10 85. lb/hr 0.1 tpy 0.4 Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by equipment limitations. Pollutant PM lb/hr 0.10 tpy 0.40 86. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from SN-25 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. 41 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-26 Isopropanol Storage Tank Source Description The isopropanol storage tank is a 9.0 foot (inside diameter) by 17 foot vertical vessel. The carbon steel tank is equipped with a conservation vent (pressure relief and vacuum breaker valve). During unloading activities, the vessel is vented back into the tanker truck. Specific Conditions 87. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #88 and equipment limitations. Pollutant VOC 88. lb/hr 4.5 tpy 0.1 Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall not have throughput in excess of 106,870 gallons of isopropyl alcohol in SN-26 during any consecutive twelve month period. Pursuant to �19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #88. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel in accordance with General Condition #7. 89. 42 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-27 Cathode Oil Coating Source Description Finished cathode assemblies are sprayed with a kerosene-based oil in a paint arrester spray booth. Overspray from these activities is trapped by disposable fiberglass batting filters. The spray booth is 18.25 feet wide, 8.5 feet high, and 9.125 feet deep. Specific Conditions 90. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #93 and equipment limitations. Pollutant PM10 VOC lb/hr 0.6 52.9 tpy 0.1 2.8 91. Pursuant to �18.801 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition #93 and equipment limitations. Pollutant PM lb/hr 0.60 tpy 0.10 92. Pursuant to �18.501 of Regulation #18 and A.C.A. �8-4-203 as referenced by �8-4-304 and �8-4-311, the permittee shall not exceed 5% opacity from sources SN-27 as measured by EPA Reference Method 9. Compliance with this condition will be demonstrated by Plant Wide Condition #7. Pursuant to �19.501 et seq of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall not use in excess of 1,200 gallons of kerosene-based oil in SN-27 during 43 93. Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 any consecutive twelve month period. 94. Pursuant to �19.705 of Regulation #19 and 40 CFR Part 52 Subpart E, the permittee shall maintain records which demonstrate compliance with the emission limit set in Specific Condition #93. These records may be used by the Department for enforcement purposes. Records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel in accordance with General Condition #7. 44 Dow Chemical Corporation Permit #: 801-AOP-R1 CSN #: 58-0011 SN-28 Coating Solvent Mix Tanks Source Description A hydrochloric acid and isopropanol mixture will be prepared in two vessels which are controlled with a nitrogen pad. The excess pressure will be vented to the atmosphere on