ARMS CA Reports

=20 =20

SITE NAME:	AIRS=20 ID:
ASCEND PENSACOLA = PLANT	0330040
OWNER/COMPANY NAME:	COUNTY:
ASCEND PERFORMANCE MATERIALS=20 OPERATIONS	ESCAMBIA
SITE ADDRESS:	TITLE=20 V:
3000 OLD CHEMSTRAND = RD	Yes
ACTIVITY CODE:	INSPECTION DATE:
INS2 -=20 COMPLIANCE INSPECTION WALK THROUGH	6/26/2013

SECTION I: = FACILITY CONTACT=20 INFORMATION
Contact Name	Title	Phone	Email Address
Roy W. Noble	Enviromental Engineer	850-968-8721	rwnobl@solutia.com

SECTION II: FACILITY-WIDE = CONDITIONS=20 (STATUS)	COMMENTS
OBJECTIONABLE ODORS: IN
PM AND VE: IN
UNREGULATED EU's: IN
INSIGNIFICANT EU's: IN
VOC's & ORGANIC SOLVENTS: IN
OTHER NON-EU REQUIREMENTS: IN
BASED ON THE ABOVE, THE = FACILITY-WIDE=20 COMPLIANCE CONDITION IS: IN (last = update:=20 7/26/2013)

SECTION III: REGULATED = EMISSION=20 UNIT(S) CONDITIONS

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	2	ADIPIC ACID SYNTHESIS, NOX THERMAL REDUCTION = UNIT #1=20 TRU/SCR	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 2 F.	IN COMPLIANCE

SCC:	30100104	SCC Units:	Tons Adipic Acid Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Adipic Acid; Nitric Acid Reaction;
Segment Description:	Adipic Acid Synthesis
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	39000699	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	Industrial Processes; In-process Fuel = Use;=20 Natural Gas; General;
Segment Description:	TRU for Adipic Acid Synthesis = NOx
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
VOC	2	95	PERCENT REDUCTION IN EMISSIONS
NOX	1	500	PARTS PER MILLION DRY GAS VOLUME

Continuous = Monitors
Monitor Description	Monitor ID	Monitored = Pollutants	Calibrated = Reading
EMISSION	1	NOX

Permit Condition	Observations
Permitted Capacity. The process/operation rate for = the Area=20 II Process Equipment; Product Synthesis, Refining and Raw Material = Recovery, shall not exceed the maximum operating rate of 98,000 = lbs KA=20 feed/hr (hourly average basis), up to 990 Million Pounds Adipic = Acid=20 produced per year based on a 12-month rolling total basis. =	Records were reviewed for the period of September = 1, 2012=20 through May 31, 2013. During this monitoring period the KA feed = rate was=20 maintained below 98,000 lbs/hr. Records of daily, monthly and 12 = month=20 rolling totals for adipic acid production are being maintained.=20
Methods of Operation - Gases Processed. The Area II = TRU/SCR=20 I shall be used to control CO, VOC and NOx emissions from the Area = I=20 HALCON process off gas stream, and the emissions from Area II. =	The Area II TRU/SCR I is being used to control CO, = VOC and=20 NOx emissions from the Area I HALCON process off gas stream, and = the=20 emissions from Area II.
Methods of Operation - Fuels. The Area II TRU/SCR I = shall=20 only use natural gas, ethane or butane as primary fuels. =	The Area II TRU/SCR I is currently being operated = on=20 natural gas as the primary fuel.
Volatile Organic Compounds (VOC) emissions tests = are=20 required to show compliance with the standards of the Department = at the=20 TRU/SCR I and SCR II INLET and OUTLET. The test method for VOC = emissions=20 shall be EPA Method 25A, incorporated and adopted by reference in = Rule=20 62-297.401(7), F.A.C. The test results must provide reasonable = assurance=20 that the source is capable of compliance at the permitted maximum=20 operating rate. Such tests shall be conducted once during each = federal=20 fiscal year (1 Oct - 30 Sept). The Department shall be notified at = least=20 15 days prior to testing to allow witnessing. Results shall be = submitted=20 to the Department within 45 days after testing. A special = requirement for=20 the first test conducted under this permit shall be to run a = standard=20 sample with a known KA concentration through the sampling train to = determine and report testing methodology accuracy.	Volatile Organic Compounds (VOC) emissions testing = was last=20 performed on August 21, 2012. Test results provide reasonable = assurance=20 that the source is capable of compliance at the permitted maximum=20 operating rate. Notification of testing was received by the = Department on=20 July 24, 2012.
KA feed and Adipic Acid Production. Permittee shall = maintain records of KA feed on an hourly and 12 month rolling = averages.=20 Permittee shall also maintain records of adipic acid production on = monthly=20 totals and 12-month rolling totals. Permittee shall also maintain = records=20 of adipic acid sales monthly totals and 12-month rolling totals. = These=20 records shall be made available for Department = inspection.	Good records of KA feed and Adipic acid production = are=20 being maintained on-site and were available for=20 inspection.
These emissions units shall comply with all = applicable=20 requirements of 40 CFR 60 Subparts A, VV, and NNN, incorporated by = reference.	The emission unit complies with all applicable = requirements=20 of 40 CFR 60 Subparts A, VV, and NNN.
Permittee shall comply with all the applicable = standards=20 and requirements of 40 CFR 63 Subpart FFFF - National Emission = Standards=20 for Hazardous Air Pollutants: Miscellaneous Organic Chemical=20 Manufacturing, attached and incorporated by reference.	There are no applicable requirements of 40 CFR 63 = Subpart=20 FFFF that apply to this emission unit.
Hours of Operation. This emissions unit is allowed = to=20 operate continuously, i.e., 8,760 hours/year, as long as the = annual=20 production limit is observed. A log of TRU/SCR I and SCR II, NOx=20 Compressor 1 and Backup NOx Compressor 2 on-line time shall be = maintained=20 and made available for Department inspection. The log time-keeping = requirement may be modified if, after compliance testing, it is = shown that=20 emissions from the TRU/SCR I and the SCR II are sufficiently = equivalent to=20 obviate this requirement.	This emission unit is allowed to operate = continuously,=20 i.e., 8,760 hours/year, as long as the annual production limit is=20 observed. Good records are being maintained of TRU/SCR I and SCR = II, Nox=20 Compressor 1 and Backup Nox Compressor 2 on-line times. =
The NOx emission concentration shall not exceed 500 = ppm, on=20 a 30-day rolling average, from each of the TRU/SCR I or SCR II. = This shall=20 be demonstrated by means of a NOx Continuous Emissions Monitor = (CEM),=20 which is operated under a Department approved QC plan, while = firing the=20 process gases from Area I and Area II.	Continuous emissions monitoring records were = reviewed for=20 the period of September 1, 2012 through May 31, 2013. During this=20 monitoring period the Nox emission concentration did not exceed = 500 ppm on=20 any 30-day rolling average.
During startup, shutdown and control system = malfunctions=20 (SSM) this source shall comply with the following emission limits: = NOx=20 Compressor 1/ Backup NOx Compressor and TRU/SCR I/SCR II. Maximum = Vent=20 Hrs: 2 hours Pounds NO: 1,302 Pounds NO2: 1,996	Quarterly excess emissions reports are being = submitted to=20 report venting events as a result of start-ups, shutdowns and=20 malfunctions.
Startup, Shutdown, and Malfunction Log. A log shall = be=20 maintained of all uncontrolled NO and NO2 emissions resulting from = startup, shutdown and control system malfunctions. Emission = records shall=20 be maintained and available for inspection by the Department. =	A log is being maintained of all uncontrolled NO = and NO2=20 emissions resulting from startup, shutdown and control system=20 malfunctions.
Considering operational variations in types of = industrial=20 equipment operations affected by this rule, the Department may = adjust=20 maximum and minimum factors to provide reasonable and practical = regulatory=20 controls consistent with the public interest.	No adjustments were recommended during this = compliance=20 inspection.
In case of excess emissions resulting from = malfunctions,=20 each owner or operator shall notify the Department in accordance = with Rule=20 62-4.130, F.A.C. A full written report on the malfunctions shall = be=20 submitted in a quarterly report.	The Department is being notified of all = malfunctions that=20 could result in excess emissions via telephone and written reports = are=20 also being submitted to the Department when = necessary.
Continuous Compliance - NOx Emissions = Concentrations.=20 Permittee shall demonstrate continuous compliance that the NOx = emissions=20 concentration from each of the TRU/SCR I or SCR II stacks do not = exceed=20 500 ppm on a 30-day rolling average by proper maintenance and = operation of=20 Continuous Emission Monitors (CEMs) for NOx from the exhaust = stacks of the=20 TRU/SCR I and SCR II, in conformance with a Department approved QC = plan=20 and annual CEMs RATA testing. CEMs readings shall be recorded=20 continuously, and rolling 30-day and 12-month calculated averages = shall be=20 recorded and made available for Department inspection. Annual = compliance=20 testing may be waived if the Department receives reasonable = assurance that=20 the CEMs and data processing/recording systems have been = functioning=20 properly.	Compliance with the Nox emission limitations is = being=20 demonstrated by proper maintenance and operation of Continuous = Emission=20 Monitors (CEMs) for Nox from the exhaust stacks of the TRU/SCR I = and SCR=20 II. Continuous Emission Monitors are calibrated and maintained in=20 accordance to the manufactures recommendation. Relative accuracy = testing=20 is being performed annually to ensure that the CEMs are accurate. = Relative=20 accuracy testing was last performed on March 27,=20 2013.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	3	B & W BOILER #8 (STACK #1)	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 6 A. Pwr	IN COMPLIANCE

SCC:	10200601	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Natural=20 Gas; > 100 Million Btu/hr;
Segment Description:	Boiler #8
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:	1100	Observed:
SCC:	10200799	SCC Units:	Million Cubic Feet Process Gas = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Process=20 Gas; Other: Specify in Comments;
Segment Description:	MA off-gas - Boiler #8
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
VOC	1	7.04	POUNDS/HOUR
SO2	2	4628.91	TONS/YEAR
PM	2	0.1	POUNDS PER MILLION BTU HEAT INPUT
NOX	1	22.5	POUNDS/HOUR
CO	1	54.8	POUNDS/HOUR

Continuous = Monitors
Monitor Description	Monitor ID	Monitored = Pollutants	Calibrated = Reading
EMISSION	1

Permit Condition	Observations
Capacity The maximum operational heat input of each = boiler=20 (Boiler No. 7 and Boiler No.8) is 388 MMBtu per hour. Heat input = (MMBtu)=20 is calculated using the previous year average natural gas fuel = analysis=20 provided by the vendor. .	Heat input rates for each boiler are being = monitored=20 continuously. Records were reviewed for the period of September 1, = 2012=20 through May 31, 2013. Records indicate compliance with the maximum = heat=20 input rates.
Methods of Operation - Fuels Boiler Nos. 7 and 8 = may be=20 fueled by natural gas, ethane rich natural gas, maleic anhydride=20 production off gas, pentane vapor stream. The maximum total = natural gas=20 usage shall be limited to 1,100 million standard cubic feet per = year for=20 each boiler (Boiler No. 7 and Boiler No. 8). Records of monthly = total and=20 annual total natural gas usage and landfill gas from Perdido = Landfill=20 usage shall be maintained and available for Department inspection. =	Records of fuel usage are being maintained and were = available for inspection. For calendar year 2012 the annual total = natural=20 gas usage was 705 MMSCF for boiler No.7 and 810 MMSCF for boiler = No. 8. No=20 landfill gas from Perdido landfill was used in the past=20 year.
Visible emissions shall not exceed 20% opacity = except for=20 up to one six-minute period per hour of up to 27%. The test method = for=20 visible emissions shall be EPA test method 9 (one hour), = incorporated and=20 adopted by reference in Chapter 62-297, F.A.C.	Visible emissions testing is being performed = annually as=20 required. Testing was last performed on August 22 and 23, 2012. = Test=20 results indicate an average opacity of 0% on both boilers. Visible = emission test results indicate that EPA Method 9 (one hour) is = being used=20 to determine compliance with the opacity = limit.
Particulate Matter Particulate matter emissions = from each=20 boiler (Boiler No. 7 and Boiler No. 8) shall not exceed 0.1 pounds = per=20 MMBtu. The test method for particulate matter shall be EPA test = method 5,=20 incorporated and adopted by reference in Chapter 62-297, = F.A.C.	Particulate matter emissions testing is being = performed=20 annually as required. Testing was last performed on August 22, = 2012. Tests=20 results indicate an average PM emissions rate of 0.018 lb/mmBtu = for boiler=20 7 and 0.10 lb/mmBtu for boiler 8. Test results indicate that EPA = test=20 Method 5 was used to determine compliance.
Carbon Monoxide Carbon monoxide emissions from each = boiler=20 (Boiler No. 7 and Boiler No. 8) shall not exceed 54.8 pounds per = hour. The=20 test method for carbon monoxide shall be EPA test method 10, = incorporated=20 and adopted by reference in Chapter 62-297, F.A.C.	Carbon monoxide emissions testing is being = performed=20 annually as required. Testing was last performed on August 22, = 2012. Test=20 results indicate an average CO emissions rate of 0.0 lb/hr for = both=20 boilers. Test results indicate that EPA test Method 10 was used to = determine compliance.
Nitrogen Oxides Nitrogen oxides emissions from each = boiler=20 (Boiler No. 7 and Boiler No. 8) shall not exceed 22.5 pounds per = hour. The=20 test method for nitrogen oxides shall be EPA test method 7E, = incorporated=20 and adopted by reference in Chapter 62-297, F.A.C.	Nitrogen oxides emissions testing is being = performed=20 annually as required. Testing was last performed on August 22, = 2012. Test=20 results indicate an average nitrogen oxides emissions rate of 2.80 = lb/hr=20 for boiler 7 and 2.14 lb/hr for boiler 8. Test results indicate = that EPA=20 test Method 7E was used to determine compliance. =
Volatile Organic Compounds Volatile organic = compounds=20 matter emissions from each boiler (Boiler No. 7 and Boiler No. 8) = shall=20 not exceed 7.04 pounds per hour. The test method for volatile = organic=20 compounds shall be EPA test method 25A, incorporated and adopted = by=20 reference in Chapter 62-297, F.A.C. Testing is required only upon = permit=20 renewal.	Volatile organic compounds emissions testing is = being=20 performed annually as required. Testing was last performed on = August 22,=20 2012. Test results indicate an average volatile organic compound = emissions=20 rate of .10 lb/hr for boiler 7 and 0.89 lb/hr for boiler 8. Test = results=20 indicate that EPA test Method 25A was used to determine = compliance.=20
Emissions Limitation for SO2. For a period of ten = years=20 from January 4, 2011 (the effective date of permit = 0330040-035-AC), SO2=20 emissions from activities allowed by permit 0330040-035-AC shall = not=20 result in emissions increases of 25 or more tons per year. For a = period of=20 ten years from the effective date of this permit, the project SO2=20 emissions from fuel oil firing shall not exceed 4,628.91 TPY in = any=20 12-month rolling period.	Facility records indicate that for the calendar = year 2012,=20 SO2 emissions were 0.24 tpy.
Operation and Downtime Log. An operation and = downtime log=20 will be maintained indicating the operational status of Boilers = Nos. 7 and=20 8. Operation and downtime logs will be maintained indicating the = status of=20 Boilers Nos. 4, 5 and 6 and the Cogeneration Facility.	Operations and downtime logs are being maintained=20 indicating the status of Boilers Nos. 4, 5, 6, 7, 8 and the = Cogeneration=20 Facility.
Hours of Operation These emissions units are = allowed to=20 operate continuously, i.e., 8,760 hours/year.	There are no limits on the hours of operation for = the two=20 boilers, provided that the heat input or annual fuel usage is not=20 exceeded.
The owner or operator of an emissions unit for = which=20 compliance tests are required shall install, operate, and maintain = equipment or instruments necessary to determine process variables, = such as=20 process weight input or heat input, when such data are needed in=20 conjunction with emissions data to determine the compliance of the = emissions unit with applicable emission limiting = standards.	Equipment or instruments necessary to determine = process=20 variables are being operated and maintained in accordance with the = manufactures instructions.
Continuous Emissions Monitoring. Permittee shall = operate=20 and maintain a carbon monoxide (CO) continuous emission monitor = (CEM) on=20 the exhaust stack for measurement of CO concentration. The CEM = shall be=20 properly operated and maintained to ensure accurate and reliable=20 monitoring, recording, and reporting data. Permittee shall = implement and=20 maintain a quality control program, which, at a minimum, follows = the=20 quality assurance procedures set forth in 40 CFR 60 Appendix F - = Quality=20 Assurance Procedures and Appendix B - Performance Specifications. = Such=20 data may be used directly or indirectly for compliance = determination. CO=20 CEM data calculation is a rolling hourly average calculated every = 15=20 minutes. VOC and NOx compliance is assumed as long as CO CEM data=20 demonstrates compliance with the CO emission limit.	Continuous monitors are used to measure CO = emissions. The=20 facility`s instrumentation and electronics department maintains = the=20 continuous monitors in accordance to the manufactures = recommendations.=20 Relative accuracy test are performed annually on the CO meters. = Relative=20 accuracy testing was last performed November 27, = 2012.
Operation and Downtime Log An operation and = downtime log=20 will be maintained indicating the operational status of Boilers = Nos. 7 and=20 8. Operation and downtime logs will be maintained indicating the = status of=20 Boilers Nos. 4, 5 and 6 in specific condition A.11 and the = Cogeneration=20 Facility in specific condition E.15.	Operation and downtime are being tracked by fuel = usage and=20 steam generation.
Natural Gas Usage Natural gas usage heat input will = be=20 calculated on an hourly basis and reported in units of MMBtu/hr = for=20 Boilers Nos. 7 and 8.	Natural gas usage and heat input are calculated on = an=20 hourly basis and reported in units of MMBtu/hr for Boilers Nos. 7 = and=20 8.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	4	B & W BOILER #7 (STACK #2)	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 6 A. Pwr	IN COMPLIANCE

SCC:	10200601	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Natural=20 Gas; > 100 Million Btu/hr;
Segment Description:	Boiler #7
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:	1100	Observed:
SCC:	10200799	SCC Units:	Million Cubic Feet Process Gas = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Process=20 Gas; Other: Specify in Comments;
Segment Description:	MA off-gas - Boiler #7
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
VOC	1	7.04	POUNDS/HOUR
SO2	2	4628.91	TONS/YEAR
PM	2	0.1	POUNDS PER MILLION BTU HEAT INPUT
NOX	1	22.5	POUNDS/HOUR
CO	1	54.8	POUNDS/HOUR

Continuous = Monitors
Monitor Description	Monitor ID	Monitored = Pollutants	Calibrated = Reading
EMISSION	1

Permit Condition	Observations
See EU 003 for consolidated = observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	5	#1 DOWTHERM VAPORIZER -NAT. GAS,OR #2 OIL = (COMMON=20 STACK W #	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Yrn/Nyln G.	IN COMPLIANCE

SCC:	30190001	SCC Units:	1000 Gallons Distillate Oil (No. 2)=20 Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Distillate Oil (No. 2): Process Heaters;=20
Segment Description:	Vaporizer #1 - fuel oil
Maximum % Ash:		Observed:
% Sulfur Limit:	0.5	Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	30190003	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Natural Gas: Process Heaters; =
Segment Description:	Vaporizer #1 - natural = gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Permit Condition	Observations
Methods of Operation- Fuels. The primary fuel shall = be=20 natural gas. No. 2 fuel oil with a maximum of 0.5% sulfur by = weight may be=20 use as an emergency fuel only. Permittee shall immediately notify = the=20 Department of each emergency use of No. 2 fuel oil and if such use = exceeds=20 four days a visible emissions compliance test shall be conducted = on each=20 unit burning fuel oil. No. 2 fuel oil burned during routine = interlock=20 Preventive Maintenance is exempt from this notification = requirement.=20	Records were reviewed for the monitoring period of=20 September 1, 2012 through May 31, 2013. During this monitoring = period,=20 natural gas was the primary fuel used. No number 2 fuel oil was = used=20 during this review period.
This emissions unit is allowed to operate = continuously,=20 i.e., 8,760 hours/year.	There are no limits on the hours of operation for = the=20 vaporizers.
Visible emissions shall not exceed 10% opacity = under normal=20 operating conditions.	There were no visible emissions observed during the = inspection.
Visible Emissions. The test method for visible = emissions=20 shall be EPA test method 9 (30 minute), incorporated and adopted = by=20 reference in Chapter 62-297, F.A.C. On each Vaporizer burning No. = 2 fuel=20 oil, if such use exceeds four days, a visible emissions compliance = test=20 shall be conducted. Further, visible emissions compliance tests = shall be=20 conducted upon Department request. No annual visible emissions = compliance=20 testing is required.	For the monitoring period of September 1, 2012 = through May=20 31, 2013, the vaporizers did not operate using fuel oil for more = than four=20 days, therefore, visible emissions testing was not required for = this=20 monitoring period.
Natural Gas Usage. An aggregate natural gas usage = heat=20 input will be calculated on an hourly basis and recorded in units = of=20 MMBtu/hr for Vaporizers 1 through 8 combined.	Natural gas usage heat input is being calculated on = an=20 hourly basis and recorded in units of MMBtu/hr for vaporizers 1 = through 8=20 combined.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	7	`2 VAPORIZER- NAT. GAS OR #2 OIL	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Yrn/Nyln G.	IN COMPLIANCE

SCC:	30190001	SCC Units:	1000 Gallons Distillate Oil (No. 2)=20 Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Distillate Oil (No. 2): Process Heaters;=20
Segment Description:	Vaporizer #2 - fuel oil
Maximum % Ash:		Observed:
% Sulfur Limit:	0.5	Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	30190003	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Natural Gas: Process Heaters; =
Segment Description:	Vaporizer #2 - natural = gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	136	Observed:
Annual Rate Limit:		Observed:

Permit Condition	Observations
EU 005, 007, 008, 009, 010, 011, 013, and 075 are = subject=20 to the same specific permit condition in Subsection H. See EU 005 = for=20 consolidated observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	8	#3 DOWTHERM VAPORIZER- NAT. GAS,OR #2 OIL = (COM. STACK=20 W #5)	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Yrn/Nyln G.	IN COMPLIANCE

SCC:	30190001	SCC Units:	1000 Gallons Distillate Oil (No. 2)=20 Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Distillate Oil (No. 2): Process Heaters;=20
Segment Description:	Vaporizer #3 - fuel oil
Maximum % Ash:		Observed:
% Sulfur Limit:	0.5	Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	30190003	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Natural Gas: Process Heaters; =
Segment Description:	Vaporizer #3 - natural = gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	136	Observed:
Annual Rate Limit:		Observed:

Permit Condition	Observations
EU 005, 007, 008, 009, 010, 011, 013, and 075 are = subject=20 to the same specific permit condition in Subsection H. See EU 005 = for=20 consolidated observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	9	#4 DOWTHERM VAPORIZER- NAT.GAS, OR #2 OIL, = (COM. STACK=20 W #1)	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Yrn/Nyln G.	IN COMPLIANCE

SCC:	30190001	SCC Units:	1000 Gallons Distillate Oil (No. 2)=20 Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Distillate Oil (No. 2): Process Heaters;=20
Segment Description:	Vaporizer #4 - fuel oil
Maximum % Ash:		Observed:
% Sulfur Limit:	0.5	Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	30190003	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Natural Gas: Process Heaters; =
Segment Description:	Vaporizer #4 - natural = gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	136	Observed:
Annual Rate Limit:		Observed:

Permit Condition	Observations
EU 005, 007, 008, 009, 010, 011, 013, and 075 are = subject=20 to the same specific permit condition in Subsection H. See EU 005 = for=20 consolidated observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	10	#5 DOWTHERM VAPORIZER- NAT.GAS, OR #2 OIL = (COM.STACK W=20 #3)	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Yrn/Nyln G.	IN COMPLIANCE

SCC:	30190001	SCC Units:	1000 Gallons Distillate Oil (No. 2)=20 Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Distillate Oil (No. 2): Process Heaters;=20
Segment Description:	Vaporizer #5 - fuel oil
Maximum % Ash:		Observed:
% Sulfur Limit:	0.5	Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	30190003	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Natural Gas: Process Heaters; =
Segment Description:	Vaporizer #5 - natural = gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	136	Observed:
Annual Rate Limit:		Observed:

Permit Condition	Observations
EU 005, 007, 008, 009, 010, 011, 013, and 075 are = subject=20 to the same specific permit condition in Subsection H. See EU 005 = for=20 consolidated observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	11	#6 DOWTHERM VAPORIZER- NAT. GAS OR #2 = OIL(COMMON STACK=20 #7)	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Yrn/Nyln G.	IN COMPLIANCE

SCC:	30190001	SCC Units:	1000 Gallons Distillate Oil (No. 2)=20 Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Distillate Oil (No. 2): Process Heaters;=20
Segment Description:	Vaporizer #6 - fuel oil
Maximum % Ash:		Observed:
% Sulfur Limit:	0.5	Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	30190003	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Natural Gas: Process Heaters; =
Segment Description:	Vaporizer #6 - natural = gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	136	Observed:
Annual Rate Limit:		Observed:

Permit Condition	Observations
EU 005, 007, 008, 009, 010, 011, 013, and 075 are = subject=20 to the same specific permit condition in Subsection H. See EU 005 = for=20 consolidated observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	13	#7 VAPORIZER (COMMON STACK #6)	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Yrn/Nyln G.	IN COMPLIANCE

SCC:	30190001	SCC Units:	1000 Gallons Distillate Oil (No. 2)=20 Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Distillate Oil (No. 2): Process Heaters;=20
Segment Description:	Vaporizer #7 - fuel oil
Maximum % Ash:		Observed:
% Sulfur Limit:	0.5	Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	30190003	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Natural Gas: Process Heaters; =
Segment Description:	Vaporizer #7 - natural = gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	136	Observed:
Annual Rate Limit:		Observed:

Permit Condition	Observations
EU 005, 007, 008, 009, 010, 011, 013, and 075 are = subject=20 to the same specific permit condition in Subsection H. See EU 005 = for=20 consolidated observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	14	CE BOILER #4 (USES STACK #5 IN COMMON WITH CE = BOILER=20 #3)	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 6 A. Pwr	IN COMPLIANCE

SCC:	10200401	SCC Units:	1000 Gallons Residual Oil (No. 6) = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Residual=20 Oil; Grade 6 Oil;
Segment Description:	Boiler #4 - waste oil
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	10200601	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Natural=20 Gas; > 100 Million Btu/hr;
Segment Description:	Boiler #4 - natural gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	10201301	SCC Units:	1000 Gallons Liquid Waste = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Liquid=20 Waste; Specify Waste Material in Comments;
Segment Description:	Boiler #4 - KATT, AGS, = amines
Maximum % Ash:		Observed:
% Sulfur Limit:	1.1	Observed:
Hourly Rate Limit:	400.63	Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
SO2	1	57.5	TONS/DAY
NOX	1	132.55	POUNDS/HOUR

Permit Condition	Observations
Permitted Capacity. The maximum allowable heat = input rate=20 is as follows: Emission Unit Heat Input 014, 015, 016 723 During = periods=20 of outage of the cogeneration plant (EU 032). Emission Unit Heat = Input=20 014, 015, 016 864	Records of heat input were reviewed for the period = of=20 September 1 2012 through May 31, 2013. During this monitoring = period,=20 facility records indicate compliance.
Methods of Operation The fuels that are allowed to = be=20 burned in these units are: (1) Natural gas, or ethane-rich natural = gas,=20 (2) No. 6 fuel oil, (3) On-specification used oil Burning of=20 on-specification used oil is allowed in this emissions unit in = accordance=20 with all other conditions of this permit and the following = conditions:=20 On-specification Used Oil Emissions Limitations: This emissions = unit is=20 permitted to burn on-specification used oil. On-specification used = oil is=20 defined as used oil that meets the specifications of 40 CFR 279 -=20 Standards for the Management of Used Oil, listed below. The owner = shall=20 maintain records to demonstrate that each shipment of used oil = meets the=20 specifications of 40 CFR 279.11. =BFOff-specification=BF used oil = shall not be=20 burned. Used oil which fails to comply with any of these = specification=20 levels is considered =BFoff-specification=BF used oil.	Good records of fuel usage are being maintained for = each=20 emission unit.
Hours of Operation These emissions units is allowed = to=20 operate continuously, i.e., 8,760 hours/year.	There are no limits on the hours of=20 operation.
Visible Emissions Visible emissions shall not = exceed 20%=20 opacity except for up to two minutes in any one-hour at not more = than 40%=20 opacity.	Visible emissions testing is being performed = annually as=20 required. Emission Units 015 and 016 was last tested for visible = emissions=20 on June 26, 2013. Test results indicate that the average opacity = was 0.0%=20 for EU 016 when using natural gas mixed with supplemental fuel. = Test=20 results indicate that the average opacity was 6.46% for EU 015 = when using=20 natural gas mixed with supplemental fuel. Visible emissions = testing was=20 perfromed on emissions unit 014 on July 24, 2013. The test report = was not=20 available for review at the time of this inspection=20 report.
Sulfur Dioxide The aggregate maximum total sulfur = dioxide=20 emissions from Boiler Nos. 4, 5 and 6 shall be less than 57.5 tons = in any=20 24-hour period. Monthly records of sulfur dioxide emissions, based = on fuel=20 usage and sulfur content, shall be maintained and made available = for=20 inspection by the Department.	Monthly records of sulfur dioxide emissions, based = on fuel=20 usage and sulfur content were reviewed for the period September 1, = 2012=20 through May 31, 2013. Facility records indicated that during this=20 monitoring period the maximum sulfur dioxide emission rate less = than 57.5=20 tons in any 24 hour period.
Natural Gas Usage. An aggregate natural gas usage = heat=20 input will be calculated on an hourly basis and recorded in units = of=20 MMBtu/hr for Boiler Nos. 4, 5 and 6 combined.	Heat input records indicate = compliance.
Operation and Downtime Log. An operation and = downtime log=20 will be maintained indicating the operational status of each of = Boiler=20 Nos. 4, 5 and 6.	An operation and downtime log is being maintained=20 indicating the operational status of each = Boiler.
Sulfur Dioxide. Monthly records of sulfur dioxide=20 emissions, based on fuel usage and sulfur content, shall be = maintained and=20 made available for inspection by the Department.	Records of sulfur dioxide emissions, based on fuel = usage=20 and sulfur content, are being maintained and were made available = during=20 the inspection.
Visible Emissions The test method for visible = emissions=20 shall be EPA test method 9 (one hour), incorporated and adopted by = reference in Chapter 62-297, F.A.C.	Test results indicate that EPA Method 9 (one hour) = is being=20 used to determine=20 compliance.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	15	CE BOILER #5 (USES STACK #3 IN COMMON WITH CE = BOILER=20 #6)	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 6 A. Pwr	IN COMPLIANCE

SCC:	10200401	SCC Units:	1000 Gallons Residual Oil (No. 6) = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Residual=20 Oil; Grade 6 Oil;
Segment Description:	Boiler #5 - waste oil
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	10200601	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Natural=20 Gas; > 100 Million Btu/hr;
Segment Description:	Boiler #5 - natural gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	10201301	SCC Units:	1000 Gallons Liquid Waste = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Liquid=20 Waste; Specify Waste Material in Comments;
Segment Description:	Boiler #5 - KATT, AGS, = amines
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
SO2	1	57.5	TONS/DAY

Permit Condition	Observations
EU 014, 015, and 016 are subject to the same = specific=20 permit conditions under Subsection A. See EU 014 for consolidated=20 observations on Emission Units 014, 015, and 016..

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	16	CE BOILER #6 (USES STACK #3 IN COMMON WITH CE = BOILER=20 #5)	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 6 A. Pwr	IN COMPLIANCE

SCC:	10200401	SCC Units:	1000 Gallons Residual Oil (No. 6) = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Residual=20 Oil; Grade 6 Oil;
Segment Description:	Boiler #6 - waste oil
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	10200601	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Natural=20 Gas; > 100 Million Btu/hr;
Segment Description:	Boiler #6 - natural gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
SO2	1	57.5	TONS/DAY

Permit Condition	Observations
EU 014, 015, and 016 are subject to the same = specific=20 permit conditions under Subsection A. See EU 014 for consolidated=20 observations on Emission Units 014, 015, and 016.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	20	CYCLOHEXANE OXIDATION PROCESS OPERATION &=20 EXPANSION	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 1 I.	IN COMPLIANCE

SCC:	10200602	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Natural=20 Gas; 10-100 Million Btu/hr;
Segment Description:	Cyclohexane Process - natural = gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	30100103	SCC Units:	Tons Adipic Acid Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Adipic Acid; Cyclohexane Oxidation;
Segment Description:	Cyclohexane Process = production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
VOC	2	10.4	POUNDS/HOUR
CO	2	28.1	POUNDS/HOUR

Permit Condition	Observations
Capacity. The maximum allowable operating rate for = the=20 Cyclohexane Oxidation Process is 82,000 pounds per hour process = air.=20	Daily operating records were reviewed for the = period of=20 September 1, 2012 through May 31, 2013. For this monitoring = period, the=20 maximum operating rate was recorded below 82,000 pounds per hour = of=20 process air.
Methods of Operation. Oil flow through each of the=20 high-pressure scrubbers shall be maintained at or above 3,600 = pounds per=20 hour during reactor train operation. Flow rate indicator values = shall be=20 monitored and averaged values logged at no larger than one-hour = intervals.=20 Records shall be maintained and made available for Department = inspection.=20 VOC and CO emissions are reduced by venting the high pressure = scrubbers to=20 the NOx TRU or thermal oxidizer. The KA recovery column shall vent = to the=20 condenser and from there to the low-pressure scrubbers. The KA = recovery=20 column/condenser shall maintain a total resource effectiveness = value=20 greater than 1.0, as applicable under 40 CFR 60 Subpart = NNN.	Records of continuous monitoring of the oil flow to = the=20 high-pressure scrubbers indicate that the oil flow is being = maintained=20 above 3,600 pounds per hour.
Hours of Operation This emissions unit is allowed = to=20 operate continuously, i.e., 8,760 hours/year.	There are no limitations on the hours of operation = for this=20 emission unit.
Visible Emissions. Visible emissions from the = backup=20 thermal oxidizer shall not exceed 5% opacity except for up to 20% = for one=20 three-minute period during any hour. The test method for visible = emissions=20 shall be DEP test method 9 (one-hour minimum observation period),=20 incorporated and adopted by reference in Chapter 62-297, = F.A.C	Visible emissions testing is being performed = annually.=20 Results from the December 11, 2012 test indicate an average = opacity of=20 2.0%. Test results indicate that EPA Method 9 was used to = determine=20 compliance and the duration of the test was 60 minutes. =
Volatile Organic Compounds. VOC emissions from the = backup=20 thermal oxidizer shall not exceed 10.4 pounds per hour, based on a = 24-hour=20 average, or 45.5 tons per year, based on a 12-month rolling total. = Emissions calculations shall be conducted monthly to demonstrate=20 compliance with the VOC limit. Emission records shall be = maintained and=20 available for inspection by the Department. Volatile Organic = Compounds The=20 test method for VOC shall be EPA Method 25A incorporated and = adopted by=20 reference in Chapter 62-297, F.A.C.	Records of 12-month rolling totals were reviewed = for the=20 period of September 1, 2012 through May 31, 2013. Records indicate = compliance with the permit limit. VOC emissions testing was last = performed=20 on December 11, 2012. Test results indicate that EPA Method 25A = was used=20 to determine compliance. The average VOC emission rate during the = three=20 hour test was 0.92 lbs/hr.
Carbon Monoxide. CO emissions from the backup = thermal=20 oxidizer shall not exceed 28.1 pounds per hour, based on a 24-hour = average, or 123 tons per year, based on a 12 month rolling total.=20 Emissions calculations shall be conducted monthly to demonstrate=20 compliance with the CO limit. Emission records shall be maintained = and=20 available for inspection by the Department. Carbon Monoxide The = test=20 method for CO shall be EPA Method 10 incorporated and adopted by = reference=20 in Chapter 62-297, F.A.C.	Records of 12-month rolling totals were reviewed = for the=20 period September 1, 2012 through May 31, 2013. Records indicate = compliance=20 with the permit limit. Carbon Monoxide emissions testing was last=20 performed on December 11, 2012. Test results indicate that EPA = Method 10=20 was used to determine compliance. The average CO emission rate = during the=20 three hour test was 24.0 lbs/hr.
Permitted Capacity. The process/operation rate for = the=20 Cyclohexane Oxidation Process (Halcon), EU 020, shall not exceed = the=20 maximum operating rate given in the Company Confidential Appendix = in=20 million pounds KA per year based on a 12-month rolling total = basis.=20 Permitted Capacity. The process/operation rate for the Cyclohexane = Oxidation Process (Halcon), EU 020, and the Area 480 KA Expansion, = EU 088,=20 apportioned to Adipic Acid Synthesis, EU 002, shall not exceed the = combined maximum operating rate given in the Company Confidential = Appendix=20 in million pounds KA per year based on a 12-month rolling total=20 basis.	Facility records indicate that the = process/operation rate=20 for the period of September 1, 2012 through May 31, 2013 was below = the=20 company confidential operating rate.
For the KA Recovery Column applicable reporting and = record=20 keeping requirements of 40 CFR 60 Subpart NNN regulations shall be = adhered=20 to. Records shall be maintained and kept available for inspection = by the=20 Department.	Facility records indicate compliance with the = requirements=20 of 40 CFR 60 Subpart NNN. Stack temperature is being monitored=20 continuously. Records show that temperature of the recovery column = is=20 being maintained below 50 degree Celsius.
Permittee shall comply with all the applicable = standards=20 and requirements of 40 CFR 63 Subpart FFFF - National Emission = Standards=20 for Hazardous Air Pollutants: Miscellaneous Organic Chemical=20 Manufacturing, attached and incorporated by reference.	The applicable standards and requirements of 40 CFR = 63=20 Subpart FFFF are being followed.
Thermal Oxidizer Temperature. When process gases = are being=20 controlled by the backup thermal oxidizer, a minimum temperature = of 1,300=20 degrees Fahrenheit shall be maintained. Temperature shall be = monitored and=20 recorded continuously, and the records made available for = Department=20 inspection. The temperature devices shall be certified by the = manufacturer=20 to be accurate to within 1 percent of the temperature being = measured. The=20 above minimum temperature set point may be adjusted upon = demonstration of=20 compliance (current stack test). Any change to the temperature set = point=20 is subject to Department approval.	Temperature records of the back-up oxidizer were = reviewed=20 during the inspection. Records indicate compliance with the 1,300 = degrees=20 minimum temperature requirement.
For the KA Recovery Column applicable monitoring = and=20 recording devices shall be operated and maintained as per 40 CFR = 60=20 Subpart NNN regulations to monitor the operation of the=20 condenser.	Monitoring and recording devices being operated and = maintained as per 40 CFR 60 Subpart NNN regulations to monitor the = operation of the condenser.
Process Air Rate. Monitor and record total process = air rate=20 on an hourly basis (lbs/hr air).	Process air rates are being monitored continuously. = The=20 process air flow metering system is being calibrated annually.=20
High-Pressure Scrubber Oil Flow Rate. Monitor and = record=20 high-pressure scrubber oil flow rate on an hourly basis (lbs/hr = oil).=20	The high-pressure scrubber oil flow rate is being = monitored=20 continuously.
KA Recovery Column Condenser Sump Temperature. = Monitor and=20 record hourly-average sump temperature on an hourly basis (ave. = C/hr).=20	The KA Recovery Column condenser sump temperature = is being=20 monitored and recorded on a continuous = basis.
This emissions unit is subject to the CAM = requirements=20 contained in the attached Appendix CAM. Failure to adhere to the=20 monitoring requirements specified does not necessarily indicate an = exceedance of a specific emissions limitation; however, it may = constitute=20 good reason to require compliance testing pursuant to Rule=20 62-297.310(7)(b), F.A.C.	The compliance assurance monitoring plan is being = followed=20 when the back-up thermal oxidizer is being used to control VOC and = CO=20 emissions from the cyclohexane oxidation = process.
40 CFR 60 Subpart NNN. For the KA Recovery Column, = the=20 owner or operator shall comply with the testing method, = recordkeeping, and=20 reporting requirements under 40 CFR 60 Subpart NNN - Standards of=20 Performance of VOC emissions from SOCMI Distillation = Processes.	Daily process parameters and environmental control=20 equipment operations are being closely monitored. Records are = being=20 maintained onsite and were available for inspection. Reporting=20 requirements are being followed. Facility records indicate = compliance with=20 the requirements of 40 CFR 60 Subpart NNN. Stack temperature is = being=20 monitored continuously. Records show that the temperature of the = recovery=20 column is being maintained below 50 degree Celsius. =
Determination of Process Variables The owner or = operator of=20 an emissions unit for which compliance tests are required shall = install,=20 operate, and maintain equipment or instruments necessary to = determine=20 process variables, such as process weight input or heat input, = when such=20 data are needed in conjunction with emissions data to determine = the=20 compliance of the emissions unit with applicable emission limiting = standards. Equipment or instruments used to directly or indirectly = determine process variables, including devices such as belt = scales, weight=20 hoppers, flow meters, and tank scales, shall be calibrated and = adjusted to=20 indicate the true value of the parameter being measured with = sufficient=20 accuracy to allow the applicable process variable to be determined = within=20 10% of its true value.	Equipment and instruments used to determine process = variables are being operated and maintained as recommended by the=20 = manufacturer.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	32	COGENERATION PLANT	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 6 D. Pwr	IN COMPLIANCE

SCC:	20200203	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	Internal Combustion Engines; = Industrial; Natural=20 Gas; Turbine: Cogeneration;
Segment Description:	Cogen Plant - natural = gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	184	Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
VOC	1	10.9	POUNDS/HOUR
NOX	1	106.6	POUNDS/HOUR
CO	1	83.5	POUNDS/HOUR

Continuous = Monitors
Monitor Description	Monitor ID	Monitored = Pollutants	Calibrated = Reading
Explain in comment field	1

Permit Condition	Observations
Capacity The maximum allowable heat input is 184 = MMBtu per=20 hour for the heat recovery steam generator Duct Burner. The = maximum=20 allowable heat input for the Combustion Turbine varies with the = ambient=20 air temperature as specified in Table A-1, attached and = incorporated by=20 reference. Table A-1 is used to determine rated capacity. Ambient=20 temperatures other than table values can be linearly interpolated = or=20 extrapolated. .	Records of heat input were reviewed for the period = of=20 September 1, 2012 through May 31, 2013. Facility records of heat = input for=20 the Combustion Turbine indicate compliance with the maximum heat = input=20 limit of 184 MMBtu per hour.
Methods of Operation This emissions unit shall be = fueled by=20 natural gas. Natural Gas Usage. Natural gas usage heat input will = be=20 calculated on an hourly basis and recorded in units of MMBtu/hr. =	This emissions unit is fueled only by natural=20 gas.
Visible Emissions Visible emissions shall not = exceed 20%=20 opacity under normal operation except for up to one six-minute = period per=20 hour during which opacity shall not exceed 27% opacity. =	Visible emission testing was last performed on = August 23,=20 2011. Results of the test indicate 0% opacity during the hour long = test.=20 Visible Emissions testing shall be conducted once before permit = renewal,=20 but prior to the permit application renewal due date of October = 17,=20 2016.
Monitor and record the steam to fuel ratio on an = hourly=20 basis.	Steam/fuel ratio is being monitored and recorded=20 continuously.
Nitrogen Oxides. Total combined NOx emissions from = the=20 Cogeneration Plant Turbine and Duct Burner shall not exceed 106.6 = pounds=20 per hour at the maximum allowable heat input rate for the = Combustion=20 Turbine (as specified in Table A-1) and the maximum allowable = operating=20 rate of 184 MMBtu/hr heat input for the duct burner. Nitrogen = Oxides. NOx=20 emissions (expressed as NO2) from the duct burner, less emissions=20 creditable to the combustion Turbine, shall not exceed 0.2 pounds = per=20 million Btu (i.e., 36.8 pounds per hour at the maximum allowable = operating=20 rate of 184 MMBtu per hour heat input).	Testing for Nitrogen Oxides was last performed on = August=20 10, 2010. The test report indicates an average NOx emission rate = of 44.3=20 lb/hr. Stack tests for NOX, SO2, CO, VOC, and VE shall be = conducted once=20 before permit renewal, but prior to the permit application renewal = due=20 date of October 17, 2016, such that the stack test report can be = submitted=20 with the permit renewal application.
Carbon Monoxide. Carbon monoxide (CO) emissions = shall not=20 exceed 83.5 pounds per hour.	Testing for Carbon Monoxide was last performed on = August=20 10, 2010. The test report indicates an average CO emission rate of = 36.8=20 lb/hr. Stack tests for NOX, SO2, CO, VOC, and VE shall be = conducted once=20 before permit renewal, but prior to the permit application renewal = due=20 date of October 17, 2016, such that the stack test report can be = submitted=20 with the permit renewal application.
Volatile Organic Compound. Volatile organic = compound (VOC)=20 emissions shall not exceed 10.9 pounds per hour.	Testing for volatile organic compounds was last = performed=20 on August 10, 2010. The test report indicates an average VOC = emission rate=20 of 0.8 lb/hr. Stack tests for NOX, SO2, CO, VOC, and VE shall be = conducted=20 once before permit renewal, but prior to the permit application = renewal=20 due date of October 17, 2016, such that the stack test report can = be=20 submitted with the permit renewal = application.
Operation and Downtime Log. An operation and = downtime log=20 will be maintained indicating the operational status of the = Cogeneration=20 Facility. Operation and downtime logs will be maintained = indicating the=20 status of Boilers Nos. 4, 5 and 6 (EUs 014, 015 AND 016), and = Boilers Nos.=20 7 and 8 (EUs 004 AND 003).	An operation and downtime log is being maintained=20 indicating the operational status of the Cogeneration Facility. = Operation=20 and downtime logs are also being maintained indicating the status = of=20 Boilers Nos. 4, 5 and 6 (Eus 014, 015 AND 016), and Boilers Nos. 7 = and 8=20 (Eus 004 AND 003). =

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	40	HEXAMETHYLENE DIAMINE SYNTHESIS PROCESS	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 4 K.	IN COMPLIANCE

SCC:	30103420	SCC Units:	Tons Material Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Aniline/Ethanolamines; Hexamethylenediamine;
Segment Description:	HMD Process production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Continuous = Monitors
Monitor Description	Monitor ID	Monitored = Pollutants	Calibrated = Reading
Explain in comment field	1

Permit Condition	Observations
These emissions units are allowed to operate = continuously,=20 i.e., 8,760 hours/year. Permitted Capacity. The process/operation = rate for=20 the HMD Synthesis and Stripper Distillation Column, EU=BFs 040 and = 041,=20 shall not exceed the maximum operating rate given in the Company=20 Confidential Appendix in million pounds HMD per year based on a = 12-month=20 rolling total basis.	There are no limits on the hours of operation. = Records were=20 reviewed for the period of September 1, 2012 through May 31, 2013. = Facility records indicate compliance with the maximum operating = rate given=20 in the Company Confidential Documents.
Total Resource Effectiveness Index. A total = resource=20 effectiveness (TRE) index shall be maintained at a value greater = than or=20 equal to 1.0. Details of the calculation(s) shall be submitted = with any=20 testing required and when any process changes that may impact the = TRE=20 index are made. TRE Index Value Verification. Permittee shall = recalculate=20 the TRE index value whenever process changes are made. = Recalculated TRE=20 index values less than or equal to 1.0, require performance=20 testing.	By maintaining the head pressure of the column = below 100mm=20 Hg, the total resource effectiveness index will be greater than=20 1.0.
Continuous monitoring of stripper columns head = pressure is=20 required and serves as a surrogate parameter to control HMD = emissions. The=20 maximum column head pressure shall be maintained at or below 100 = mm Hg.=20 Records of stripper column head pressure logged hourly shall be = maintained=20 and be available for inspection by the Department.	Records of column head pressure were reviewed = during the=20 inspection. The head pressure is being maintained below 60mm Hg. = If the=20 head pressure goes above 100mm Hg, the column is shut=20 down.
Condensation of steam and solution of HMD between = stages of=20 a series of steam vacuum jets are determined to be vapor control = devices=20 deemed necessary by the Department. Permittee shall maintain = operations=20 and maintenance of the jets and condensers sufficient to minimize = HMD=20 emissions pursuant to the Specific Condition in this subsection = addressing=20 the Total Resource Effectiveness Index.	Records of calibration and maintenance were = available for=20 inspection. Differential pressure gauges are being calibrated = every 2=20 years. Facility records indicate that the B stripper`s pressure = gauge was=20 last calibrated on March 12, 2013 and the C stripper`s pressure = gauge was=20 last calibrated on July 24, 2012.
Permittee shall comply with all the applicable = standards=20 and requirements of 40 CFR 63 Subpart FFFF - National Emission = Standards=20 for Hazardous Air Pollutants: Miscellaneous Organic Chemical=20 Manufacturing, attached and incorporated by reference.	The emissions unit is in compliance with the = applicable=20 portions of 40 CFR 63 Subpart FFFF.
L.6. This emissions unit shall comply with all = applicable=20 requirements of 40 CFR 60 Subpart NNN, Standards for Performance = for=20 Volatile Organic Compound (VOC) Emissions for Synthetic Organic = Chemical=20 Manufacturing Industry (SOCMI) Distillation Operations.	The emissions unit is in compliance with the = applicable=20 portions of 40 CFR 60 Subpart NNN.
L.7. EU-041 Head Pressure Records of B AND C = stripper=20 column head pressure logged hourly when the column is in service, = shall be=20 maintained and be available for inspection by the Department. =	Records of the B and C stripper column head = pressure is=20 being logged continuously and were available for=20 inspection.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	41	STRIPPER COLUMN B & C	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 4 K.	IN COMPLIANCE

SCC:	30103420	SCC Units:	Tons Material Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Aniline/Ethanolamines; Hexamethylenediamine;
Segment Description:	HMD Process production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
VOC	2	999990.99	TEST REQUIRED (NO ALLOWABLE EMISSION)

Continuous = Monitors
Monitor Description	Monitor ID	Monitored = Pollutants	Calibrated = Reading
Explain in comment field	1

Permit Condition	Observations
EU 040 and 041 are subject to the same specific = permit=20 conditions under Subsection L. See EU 040 for consolidated = observations.=20

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	42	NITRIC ACID PLANT E	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 1 L.	IN COMPLIANCE

SCC:	30101302	SCC Units:	Tons Pure Acid Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Nitric Acid; Absorber Tail Gas (Post-1970 Facilities); =
Segment Description:	Nitric Acid Plant = production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:	547500	Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
NOX	1	3	POUNDS PER TON OF PRODUCT

Continuous = Monitors
Monitor Description	Monitor ID	Monitored = Pollutants	Calibrated = Reading
EMISSION	1	NOX
EMISSION	2	NOX

Permit Condition	Observations
Capacity The maximum allowable operating rate is = 1,500 tons=20 of 100% nitric acid produced per day.	The maximum allowable operating rate is dependent = upon the=20 operating rate achieved during the annual compliance testing. At = the time=20 of the inspection the maximum operating rate was 1,376 tons of = 100% nitric=20 acid produced per day. Records of acid production were reviewed = during the=20 inspection. Records indicate compliance with the maximum operating = rate.=20
Methods of Operation. The SCR unit shall be = operating=20 whenever the Nitric Acid Plant is in operation. When the SCR unit = is not=20 employed, the absorber column chilled water shall be monitored and = water=20 flow shall be maintained at a minimum of 200 gallons per minute or = higher,=20 and water temperature shall be maintained at 54F or = lower.	When the SCR unit is not employed, the absorber = column`s=20 chilled water is continuously monitored. Water flow is maintained = above=20 400 gallons per minute and water temperature is being maintained = at 54=20 degrees F or lower.
Hours of Operation This emissions unit is allowed = to=20 operate continuously, i.e., 8,760 hours/year.	This emissions unit is allowed to operate = continuously as=20 long as the daily production rate is not = exceeded.
No owner or operator subject to the provisions of = this=20 subpart shall cause to be discharged into the atmosphere from any = affected=20 facility any gases which: (1) Contain nitrogen oxides, expressed = as NO2,=20 in excess of 1.5 kg per metric ton of acid produced (3.0 lb per = ton), the=20 production being expressed as 100 percent nitric acid. The maximum = allowable annual NOx emissions are 360 tons of NOx per year based = on a=20 365-day rolling total amount as determined by the CEMs data and = stack flow=20 rate. Records shall be kept for a 365-day rolling total amount = calculated=20 in tons of NOx per year. (2) Exhibit 10 percent opacity, or = greater.=20	Rolling totals for Nox emissions were reviewed for = the=20 period of September 1, 2012 through May 31,2013. For this = monitoring=20 period, the 12 month rolling total for Nox was below 285. Testing = was last=20 performed on March 26, 2013. The test report indicates an average=20 emissions rate of 1.18 pounds per ton of Nitric Acid produced. No = visible=20 emissions were observed during the inspection. =
Test Methods and Procedures Emissions tests are = required to=20 show continuing compliance with the standards of the Department. = The test=20 results must provide reasonable assurance that the source is = capable of=20 compliance at the permitted maximum operating rate. Tests shall be = conducted once per federal fiscal year (October 1 - September 30), = unless=20 otherwise specified in specific conditions. Results shall be = submitted to=20 the Department within 45 days after testing. The Department shall = be=20 notified at least 15 days prior to testing to allow witnessing. = Testing of=20 emissions shall be conducted with the emissions unit operating at=20 permitted capacity, which is defined as 90 to 100 percent of the = maximum=20 operation rate allowed by the permit. If it is impracticable to = test at=20 permitted capacity, an emissions unit may be tested at less than = the=20 minimum permitted capacity (i.e., at less than 90 percent of the = maximum=20 operation rate allowed by the permit); in this case, subsequent = emissions=20 unit operation is limited to 110 percent of the test load until a = new test=20 is conducted, provided however, operations do not exceed 100 = percent of=20 the maximum operation rate allowed by the permit. Once the = emissions unit=20 is so limited, operation at higher capacities is allowed for no = more than=20 15 consecutive days for the purpose of additional compliance = testing to=20 regain the authority to operate at the permitted capacity. =	Compliance testing is being performed annually as = required.=20 The test results provide reasonable assurance that the source is = capable=20 of compliance at the permitted maximum operating rate. Testing was = last=20 performed on March 26, 2013. Notification of the test was received = by the=20 Department on February 26, 2013 . Results of the testing were = received by=20 the Department on April 24, 2013.
Visible Emissions The test method for visible = emissions=20 shall be EPA test method 9 (one hour), incorporated and adopted by = reference in Chapter 62-297, F.A.C.	Test results indicate that EPA test Method 9 (one = hour) was=20 used to determine compliance with the opacity = limit.
Nitrogen Oxides The test method for nitrogen oxides = shall=20 be EPA test method 7, 7A, 7B, 7C, 7D, 7E or other Department = approved=20 method(s), incorporated and adopted by reference in Chapter = 62-297, F.A.C.=20 If Method 7C or 7D is used, the sampling time shall be at least = one hour.=20 If Method 7E is used, NO2 must be used as the calibration = gas.	Test results indicate that EPA test Method 7E was = used to=20 determine compliance with the nitrogen oxide limit. Test results = also=20 indicate that NO2 was used as the calibration = gas.
Determination of Process Variables The owner or = operator of=20 an emissions unit for which compliance tests are required shall = install,=20 operate, and maintain equipment or instruments necessary to = determine=20 process variables, such as process weight input or heat input, = when such=20 data are needed in conjunction with emissions data to determine = the=20 compliance of the emissions unit with applicable emission limiting = standards. Equipment or instruments used to directly or indirectly = determine process variables, including devices such as belt = scales, weight=20 hoppers, flow meters, and tank scales, shall be calibrated and = adjusted to=20 indicate the true value of the parameter being measured with = sufficient=20 accuracy to allow the applicable process variable to be determined = within=20 10% of its true value.	Equipment or instruments necessary to determine = process=20 variables are being operated and maintained in accordance with the = manufactures instructions.
Records of daily production, hours of operation, = absorber=20 column operating parameters and continuous emission monitor = maintenance=20 (down time, calibrations, and adjustments) shall be maintained and = be=20 available for inspection by the Department.	Records of daily production, hours of operation, = absorber=20 column operating parameters and continuous emissions monitor = maintenance=20 are being maintained and were available for = inspection.
The zero and span drift of the continuous emission = monitor=20 for Nox shall be checked at least once daily, and adjustments made = in=20 accordance 40 CFR 60.13(d).	The zero and span drift of the continuous emission = monitor=20 for Nox is automatically checked daily.
Permittee shall routinely monitor the performance = of the=20 Selective Catalytic Reduction (SCR) unit to ensure compliance with = the=20 emission limit. The following monitoring information shall be = maintained=20 and available for inspection by the Department: -SCR Inlet flow = -Ammonia=20 flow to SCR (or ammonia valve position) -Air flow to SCR =	Air flow to the Selective Catalytic Reduction unit, = Ammonia=20 flow to SCR and SCR Inlet flow are being monitored=20 continuously.
The owner or operator shall establish a conversion = factor=20 for the purpose of converting monitoring data into units of the = applicable=20 standard (kg/metric ton, lb/ton). The conversion factor shall be=20 established by measuring emissions with the continuous monitoring = system=20 concurrent with measuring emissions with the applicable reference = method=20 tests. Using only that portion of the continuous monitoring = emission data=20 that represents emission measurements concurrent with the = reference method=20 test periods, the conversion factor shall be determined by = dividing the=20 reference method test data averages by the monitoring data = averages to=20 obtain a ratio expressed in units of the applicable standard to = units of=20 the monitoring data, i.e., lb/ton per ppm. The conversion factor = shall be=20 reestablished during any performance test under 40 CFR 60.8 or any = continuous monitoring system performance evaluation under 40 CFR=20 60.13=A9.	Conversion factors have been = established.
Continuous Emissions Monitoring The source owner or = operator shall calibrate, maintain, and operate a continuous = monitoring=20 system for measuring nitrogen oxides (Nox). The pollutant gas = mixtures=20 under Performance Specification 2 and for calibration checks under = 40 CFR=20 60.13(d) of this part shall be nitrogen dioxide (NO2). The span = value=20 shall be 500 ppm of NO2.	Continuous monitoring systems are being calibrated = and=20 maintained in accordance with the manufactures recommendations. = Continuous=20 meters are tested annually for accuracy. Testing was last = performed on=20 March 26, 2013. Results of the test indicate that the continuous = Nox=20 monitoring system was within 13.0 percent of the reference=20 monitor.
During startup, shutdown and control system = malfunctions=20 this source shall comply with the following emission limits: = Startup=20 Shutdown Malfunction Pounds NO 643.5 643.5 643.5 Pounds NO2 594 = 594 594=20 The maximum venting hours shall not exceed three hours in any = 24-hour=20 period.	Records of emissions during startup, shutdown and=20 malfunctions are being maintained. Facility records were reviewed = for the=20 monitoring period of September 1, 2012 through May 31, 2013. = During the=20 monitoring period, at no time did emission unit vent more than = three hours=20 in any 24-hour period.
Startup, Shutdown, and Malfunction Log A log shall = be=20 maintained of all uncontrolled NO and NO2 emissions resulting from = startup, shutdown and control system malfunctions. Emission = records shall=20 be maintained and available for inspection by the Department. =	Emissions records for Startups, Shutdowns, and = Malfunctions=20 are being maintained and were available for = inspection.
Excess emissions which are caused entirely or in = part by=20 poor maintenance, poor operation, or any other equipment or = process=20 failure which may reasonably be prevented during startup, = shutdown, or=20 malfunction shall be prohibited.	Controls have been implemented to help prevent = excess=20 emissions. Standard operating procedures are followed prior to = Start-up=20 and Shut-down events to avoid excess = emissions.
Considering operational variations in types of = industrial=20 equipment operations affected by this rule, the Department may = adjust=20 maximum and minimum factors to provide reasonable and practical = regulatory=20 controls consistent with the public interest.	No adjustments were recommended during this = compliance=20 inspection.
In case of excess emissions resulting from = malfunctions,=20 each owner or operator shall notify the Department in accordance = with Rule=20 62-4.130, F.A.C. A full written report on the malfunctions shall = be=20 submitted in a quarterly report.	The Department is being notified of all = malfunctions that=20 could result in excess emissions and written reports are being = submitted=20 to the Department when=20 necessary.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	49	HYDROGEN GENERATION FACILITY, PLANT #1	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 4 J.	IN COMPLIANCE

SCC:	30190003	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Natural Gas: Process Heaters; =
Segment Description:	Hydrogen Plant #1 - natural = gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	180	Observed:
Annual Rate Limit:		Observed:
SCC:	30190004	SCC Units:	Million Cubic Feet Process Gas = Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Process Gas: Process Heaters; =
Segment Description:	Hydrogen Plant #1 - waste = gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
PM	2	999999	TEST REQUIRED (NO ALLOWABLE EMISSION)
NOX	2	14.4	POUNDS/HOUR
VOC	2	1.8	POUNDS/HOUR
CO	2	10	POUNDS/HOUR

Permit Condition	Observations
Capacity The maximum allowable operating rate is = 180 MMBtu=20 per hour heat input.	The maximum allowable operating rate is based off = the=20 latest visible emissions test. The fuel heat input rate during the = February 12, 2013 visible emissions test was 155.20 MMBtu/hr. As a = result,=20 the maximum allowable operating rate is now 170.72 MMBtu/hr until = testing=20 can be performed at a higher rate. Records were reviewed for the = period of=20 September 1, 2012 through May 31, 2013. During this monitoring = period the=20 heat input was maintained below 160 = MMBtu/hour.
Methods of Operation - Fuels This emissions unit = shall be=20 fueled by natural gas and/or process waste gas.	Facility personnel indicated that the emissions = unit is=20 being operated on natural gas and process = gas.
Hours of Operation This emissions unit is allowed = to=20 operate continuously, i.e., 8,760 hours/year.	There are no limits on the hours of operation, = provided=20 that the heat input rate is not exceeded.
Visible Emissions Visible emissions shall be less = than 20%=20 opacity.	Visible emissions testing is being performed = annually as=20 required. Testing was last performed on February 12, 2013. Test = results=20 indicate an average opacity of 0% during the 30 minute=20 test.
Emissions tests are required to show continuing = compliance=20 with the standards of the Department. The test results must = provide=20 reasonable assurance that the source is capable of compliance at = the=20 permitted maximum operating rate. Tests shall be conducted once = per=20 federal fiscal year (October 1 - September 30), unless otherwise = specified=20 in specific conditions. Results shall be submitted to the = Department=20 within 45 days after testing. The Department shall be notified at = least 15=20 days prior to testing to allow witnessing.	The test results provide reasonable assurance that = the=20 source is capable of compliance at the permitted maximum operating = rate.
Visible Emissions The test method for visible = emissions=20 shall be EPA test method 9 (30 minute), incorporated and adopted = by=20 reference in Chapter 62-297, F.A.C.	Test results indicate that EPA Method 9 (30 minute) = was=20 used to determine compliance with the opacity = limit.
The owner or operator of an emissions unit for = which=20 compliance tests are required shall install, operate, and maintain = equipment or instruments necessary to determine process variables, = such as=20 process weight input or heat input, when such data are needed in=20 conjunction with emissions data to determine the compliance of the = emissions unit with applicable emission limiting = standards.	Equipment and instruments used to determine process = variables are being operated and maintained as recommended by the=20 manufacturer. Flow meters for gas are being calibrated every 18 = months.=20 Facility records indicate that the flow meters were last = calibrated on=20 June 21, 2012. =

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	60	ADIPIC ACID BEPEX DRYER BUILDING 485	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 2 E.	IN COMPLIANCE

SCC:	30100108	SCC Units:	Tons Adipic Acid Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Adipic Acid; Dryer;
Segment Description:	Adipic Dryer 485 = production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
PM	1	0.015	GRAINS PER DRY STANDARD CUBIC FOOT

Permit Condition	Observations
Operating Rates. The maximum and minimum operating = rates of=20 these emissions units is as follows: Exhaust air blower, design = maximum=20 flow rate: EU 061 AND 062 - 8,000 SCFM EU 063, 064, 079 - 10,500 = SCFM EU=20 060 - 10,200 CSFM Dryer exhaust scrubber, water minimum = circulation flow=20 rate: EU 061, 062, 063, 064 - 3,000 PPH Hourly average basis EU = 060 5,500=20 PPH Hourly average basis Discharge air, design basis particulate=20 concentration: EU 061, 062, 063, 064 - 0.10 grains/SCF EU 060, 079 = - 0.015=20 grains/SCF .	Flow rates for the dryer exhaust scrubbers are = being=20 monitored continuously. If the flow rate drops below the minimum = operating=20 rate, the flow of adipic acid automatically switches to the salt=20 process.
Permitted Capacity. The combined process/operation = rate for=20 the Adipic Acid Drying, EU 060, 061, 062, 063, 064, and 079, shall = not=20 exceed the amount given in the Company Confidential Appendix in = Million=20 Pounds dried Adipic Acid per year based on a 12-month rolling = total=20 basis.	Process rates were reviewed for the period of = September 1,=20 2012 through May 31, 2013. During this period, the combined=20 process/operation rate did not exceed the amount given in the = Company=20 Confidential Appendix in Million Pounds dried Adipic Acid per year = based=20 on a 12-month rolling total basis.
Hours of Operation. The emissions units listed = above are=20 allowed to operate continuously, i.e., 8,760 = hours/year.	This emissions unit is allowed to operate=20 continuously.
Visible Emissions. The emissions units listed above = shall=20 not exceed 5% opacity.	Stack tests for PM and VE testing are to be = conducted once=20 before permit renewal, but prior to the permit application renewal = due=20 date, such that the stack test report can be submitted with the = permit=20 renewal application. Testing was last performed June 5, 2013. = Results=20 indicate 0% opacity.
Reasonable Assurances. The following work practices = shall=20 be followed to insure reasonable control of particulate matter: = Scrubbers=20 or bag filters, associated with solids handling, are to be in = service=20 prior to commencement of activities such as loading, unloading, = storing,=20 handling or other industrially related activities. Solids material = handling equipment shall be interlocked to shut down if the PM = control=20 devices are not operational.	Flow rates for the dryer exhaust scrubbers are = being=20 monitored continuously. If the flow rate drops below the minimum = operating=20 rate, the flow of adipic acid automatically switches to the salt=20 process.
Blower Capacity. Maintain records of blower = capacity, motor=20 size and model number for each dryer. Blower capacity will be = confirmed=20 with pitot tube during required particulate matter = testing.	Records of blower capacity, motor size and model = number for=20 each dryer are maintained on-site. If the results of the visible = emissions=20 tests show greater than 5 percent opacity, the Permittee shall = conduct a=20 particulate matter test within 30 days to show compliance with the = dryer=BFs=20 design standard.
Scrubber Water Flow. Maintain hourly average = scrubber water=20 flow rate for EU=BFs 060, 061, 062, 063, and 064.	Hourly average scrubber water flow rates are being=20 continuously monitored.
Compliance with the dryer=BFs design emission = standard may be=20 assumed, and a waiver of the PM testing requirements may be = granted, if=20 visible emissions are not greater than 5 percent opacity. If the = results=20 of the visible emissions tests show greater than 5 percent = opacity,=20 Permittee shall conduct a particulates matter test within 30 days = to show=20 compliance with the dryer=BFs design standard.	Facility personnel are aware of the PM testing=20 requirements.
Common Testing Requirements. Unless otherwise = specified,=20 tests shall be conducted in accordance with the requirements and=20 procedures specified in Combined Appendices, Appendix TR, = Facility-Wide=20 Testing Requirements, of this permit. Stack tests for PM and VE = testing=20 are conducted once before permit renewal, but prior to the permit=20 application renewal due date, such that the stack test report can = be=20 submitted with the permit renewal application.	Facility personnel are aware of the testing = requirements.=20 Stack tests for PM and VE testing are to be conducted once before = permit=20 renewal, but prior to the permit application renewal due date, = such that=20 the stack test report can be submitted with the permit renewal=20 = application.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	61	ADIPIC ACID DRYER A, BLDG. 405	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 2 E.	IN COMPLIANCE

SCC:	30100108	SCC Units:	Tons Adipic Acid Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Adipic Acid; Dryer;
Segment Description:	Adipic Dryer405A = production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	1.5	Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
PM	1	0.1	GRAINS PER DRY STANDARD CUBIC FOOT

Permit Condition	Observations
Emissions Units 060, 061, 062, 063, 064, 079, share = permit=20 conditions. See emissions unit 060 for permit conditions and=20 observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	62	ADIPIC ACID DRYER B, BLDG. 405	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 2 E.	IN COMPLIANCE

SCC:	30100108	SCC Units:	Tons Adipic Acid Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Adipic Acid; Dryer;
Segment Description:	Adipic Dryer 405B = production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	1.5	Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
PM	1	0.1	GRAINS PER DRY STANDARD CUBIC FOOT

Permit Condition	Observations
Emissions Units 060, 061, 062, 063, 064, 079, share = permit=20 conditions. See emissions unit 060 for permit conditions and=20 observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	63	ADIPIC ACID DRYER A, BLDG. 465	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 2 E.	IN COMPLIANCE

SCC:	30100108	SCC Units:	Tons Adipic Acid Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Adipic Acid; Dryer;
Segment Description:	Adipic Dryer 465A = production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	1.5	Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
PM	1	0.1	GRAINS PER DRY STANDARD CUBIC FOOT

Permit Condition	Observations
Emissions Units 060, 061, 062, 063, 064, 079, share = permit=20 conditions. See emissions unit 060 for permit conditions and=20 observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	64	ADIPIC ACID DRYER B, BLDG. 465	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 2 E.	IN COMPLIANCE

SCC:	30100108	SCC Units:	Tons Adipic Acid Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Adipic Acid; Dryer;
Segment Description:	Adipic Dryer 465B = production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	1.5	Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
PM	1	0.1	GRAINS PER DRY STANDARD CUBIC FOOT

Permit Condition	Observations
Emissions Units 060, 061, 062, 063, 064, 079, share = permit=20 conditions. See emissions unit 060 for permit conditions and=20 observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	75	VAPORIZER NO.8	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Yrn/Nyln G.	IN COMPLIANCE

SCC:	30190003	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Fuel Fired Equipment; Natural Gas: Process Heaters; =
Segment Description:	Vaporizer #8
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	136	Observed:
Annual Rate Limit:		Observed:

Permit Condition	Observations
EU 005, 007, 008, 009, 010, 011, 013, and 075 are = subject=20 to the same specific permit condition in Subsection H. See EU 005 = for=20 consolidated observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	76	MALEIC ANHYDRIDE (MA)PLANT-UNCONTROLLED OFF = GASES	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 5 C.	IN COMPLIANCE

SCC:	30110002	SCC Units:	Tons Maleic Anhydride = Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Maleic Anhydride; Product Recovery Absorber;
Segment Description:	MA Plant production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	30110080	SCC Units:	Each-Year Process Unit = Operating
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Maleic Anhydride; Fugitive Emissions;
Segment Description:	MA Plant fugitives
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:
SCC:	40700404	SCC Units:	1000 Gallons Maleic Anhydride = Throughput
Process/Fuel = Description:	Petroleum and Solvent Evaporation; = Organic=20 Chemical Storage; Fixed Roof Tanks - Acid Anhydrides; Maleic = Anhydride:=20 Working Loss;
Segment Description:	MA Plant tank = throughput
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
VOC	1	1750	OTHER (SPECIFY IN COMMENT)
CO	1	1750	OTHER (SPECIFY IN COMMENT)

Continuous = Monitors
Monitor Description	Monitor ID	Monitored = Pollutants	Calibrated = Reading
EMISSION	1	VOC;CO

Permit Condition	Observations
Capacity The maximum gas flow rate from the Maleic=20 Anhydride Plant to each boiler shall not exceed 6.5 MMSCF/hr (13.0 = MMSCF/hr total to both Boilers Nos. 7 and 8).	Gas flow rate records were reviewed during the = inspection.=20 Records indicate that the average gas rate is being maintained = below 6=20 MMSCF/hr.
Hours of Operation This emissions unit is allowed = to=20 operate continuously, i.e., 8,760 hours/year.	There are no limits on the hours of operation, = provided=20 that the gas flow rate of 6.5 MMSCF/hr is not = exceeded.
During startup, shutdown, and control system = malfunctions=20 this source shall not exceed emissions resulting from a production = rate of=20 130 MM pounds MA per year and shall comply with the following = emission=20 limits. Emissions shall not exceed 1,750 pounds of either VOC = (calculated=20 as butane) or CO per reactor hour for startups and malfunctions; = or 875=20 pounds of either VOC or CO per reactor hour for shutdowns; No more = than=20 one and one-half reactor hours shall be used for an individual = Reactor=20 startup or shutdown; No more than eight reactor hours shall be = used for a=20 total production startup; and No more than six hours shall be used = during=20 a control system malfunction to allow sufficient time to trouble = shoot and=20 correct the problem.	Excess emission reports are being submitted = quarterly as=20 required. Reports were reviewed for the period of September 1, = 2012=20 through May 31, 2013. During this monitoring period, there were no = instances where the excess emissions exceeded the permit limit.=20
Process Off-gas Rate. Permittee shall monitor and = record=20 process off-gas flows to Boilers Nos. 7 and 8 on an hourly basis=20 (MMSCF/hr).	Process off-gas flows to Boilers Nos. 7 and 8 are = being=20 monitored and recorded continuously.
Startup, Shutdown and Malfunction Log. A log shall = be=20 maintained of all uncontrolled VOC and CO emissions resulting from = startup, shutdown, and malfunctions.	Startup, Shutdown and Malfunction events are being=20 maintained on the facility`s common computer drive.=20

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	77	DIMETHYL ESTER (DME) PRODUCTION UNIT	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
	IN COMPLIANCE

SCC:	30113799	SCC Units:	Tons Material Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Esters Production; Acrylates: Specify in Comments; =
Segment Description:	DME Plant production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
H054	1	6	POUNDS/HOUR
NOX	1	48	POUNDS/HOUR
VOC	1	15	POUNDS/HOUR

Permit Condition	Observations
Capacity. The maximum allowable operating rate is = 30=20 million pounds per year of 80% AGS.	Facility records were reviewed for the period of = September=20 1, 2012, through May 31, 2013. Records indicated that the emission = unit is=20 being operated below the maximum allowable annual operating=20 rate.
Methods of Operation. DME process air emissions = shall be=20 controlled during temporary outages of the Hydrogen Plant #1 = reformer=20 furnace by a Calgon Activated Carbon Bed Vapor Pac unit. Permittee = may use=20 one or two carbon beds to achieve the desired minimum 90% VOC = removal=20 efficiency.	Activated Carbon Bed Vapor Pac units are being used = to=20 control VOC emissions during temporary outages. Records of online = times=20 and carbon bed maintenance are being = maintained.
40 CFR 63.104 - Heat exchange system requirements = Permittee=20 shall monitor each heat exchange system used to cool process = equipment in=20 Emission Unit ID No. 077 Dimethyl Esters (DME), according to the=20 provisions of 40 CFR 63.104(b) and 63.104(b)(1) through (b)(6). If = a leak=20 is detected according to the criteria of 40 CFR 63.104(b), = Permittee shall=20 comply with the requirements of paragraphs 40 CFR 63.104(d)(1) and = (d)(2),=20 except as provided in 40 CFR 63.104(e).	Leak testing is being performed quarterly. The last = leak=20 test was performed during the month of June 2013. No leaks were=20 detected.
40 CFR 63.983 - Closed vent systems Permittee shall = design=20 and operate, at all times emissions are vented to, or collected = by, each=20 closed vent system to collect the regulated material vapors from = Emission=20 Unit ID. No. 077. The collected regulated material vapors are = routed to a=20 Calgon Activated Carbon Bed Vapor Pac Unit.	The collected regulated material vapors are routed = to a=20 Calgon Activated Carbon Bed Vapor Pac Unit.
40 CFR 63.998 - Recordkeeping requirements = Permittee shall=20 comply with the applicable recordkeeping requirements of 40 CFR=20 63.998(d).	Good records are being maintained of daily=20 operations.
40 CFR 63.1025 - =BFValves in Gas and Vapor Service = and In=20 Light Liquid Service Standards=BF Except as specified in 40 CFR = 63.1021(b),=20 63.1025(e),or 63.2480, Permittee shall monitor all valves in = accordance=20 with 40 CFR 63.1025(b)(1) through (b)(4) and 63.1025(e). If a leak = is=20 detected, Permittee shall repair the leak as specified in 40 CFR = 63.1024.=20 Permittee shall monitor a repaired valve according to the = provisions of 40=20 CFR 63.1025(d)(2).	At the time of the inspection, valves were being = monitored=20 semi-annually and pumps are being checked for leaks=20 monthly.
40 CFR 63.1026 - Pumps in light liquid service = standards=20 Except as provided in 40 CFR 63.1026(e), Permittee shall monitor = each=20 pump, associated with Emission Unit ID No. 077, monthly in = accordance with=20 40 CFR 63.1023(b)(1) through (b)(6). If the instrument reading = indicates a=20 leak is detected, 10,000 ppmv or more, as specified in 40 CFR=20 63.2480(b)(5), it shall be repaired using the procedures in 40 CFR = 63.1024. In addition, each pump shall be visually inspected for = leaks=20 weekly and inspection results shall be recorded in accordance with = 40 CFR=20 63.1026(b)(4). If a leak is visually detected, Permittee shall = comply with=20 the provisions of 40 CFR 63.1026(b)(4)(i) and (ii).	Pumps are cheeked for leaks monthly and visually = inspected=20 for leaks weekly.
40 CFR 63.1030 - =BFPressure Relief Devices In Gas = And Vapor=20 Service Standards=BF Except during pressure releases as provided = in 40 CFR=20 63.1030(c) or 63.1030(d), 63.1030(e), 63.1036, or 63.1037, = Permittee shall=20 operate each pressure relief device, associated with Emission Unit = ID No.=20 077, with an instrument reading of less than 500 parts per million = as=20 measured by the method specified in 40 CFR 63.1023(b) and, as = applicable,=20 40 CFR 63.1023(c). After each pressure release, the pressure = relief device=20 shall be returned to a condition indicated by an instrument = reading of=20 less than 500 parts per million, as soon as practical, but no = later than 5=20 calendar days after each pressure release, except as provided in = 40 CFR=20 63.1024(d). The pressure relief device shall be monitored no later = than=20 five calendar days after the pressure to confirm the condition = indicated=20 by an instrument reading of less than 500 parts per million above=20 background, as measured by the method specified in 40 CFR = 63.1023(b) and,=20 as applicable, 40 CFR 63.1023(c). Permittee shall record the dates = and=20 results of the required monitoring required following a pressure = release=20 including the background level measured and the maximum instrument = reading=20 measured during the monitoring.	Pressure relief valves are being checked for leaks=20 annually.
40 CFR 63.1111 - Startup, shutdown, and malfunction = Permittee shall maintain a current startup, shutdown, and = malfunction plan=20 in accordance with 40 CFR 63.1111. This plan shall be maintained = on-site=20 and available for Department inspection.	Records of startup, shutdown, and malfunction = activities=20 are being maintained on the facility`s data = system.
40 CFR 63.2450 - What are my general requirements = for=20 complying with this Subpart? For each absorber used to control = organic=20 compounds with water as a scrubbing fluid, Permittee shall monitor = and=20 record flow using a flow meter capable of providing a continuous = record of=20 the absorber influent liquid flow.	Flow rates are continuously monitored. Records of = flow=20 rates are being maintained on the facility`s data=20 system.
40 CFR 63.2450(p) - General Requirements Permittee = shall=20 only open safety devices, when conditions require opening such = devices to=20 avoid an unsafe condition, as defined in 40 CFR = 63.2550.	Facility personnel are aware of the General = Requirements of=20 40 CFR 63.2450(p).
40 CFR 63.2460 - What requirements must I meet for = batch=20 process vents? Permittee shall reduce uncontrolled organic HAP = emissions=20 from one or more batch process vents within the DME process by = venting=20 through a closed-vent system to carbon canisters. Compliance with = these=20 emission limitations shall be demonstrated in accordance with all=20 applicable provisions of 40 CFR 63.2460(c).	Organic HAP emissions are reduced from the batch = process=20 vents within the DME process by venting through a closed-vent = system to=20 Activated Carbon Bed Vapor Pac=20 units.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	79	ADIPIC ACID NIRO DRYER BUILDING 485	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 2 E.	IN COMPLIANCE

SCC:	30100108	SCC Units:	Tons Adipic Acid Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Adipic Acid; Dryer;
Segment Description:	Adipic Dryer 485 NIRO = production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
PM	1	0.015	GRAINS PER DRY STANDARD CUBIC FOOT

Permit Condition	Observations
Emissions Units 060, 061, 062, 063, 064, 079, share = permit=20 conditions. See emissions unit 060 for permit conditions and=20 observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	81	CONTINUOUS POLYMERIZATION LINES, DISTILLATION = COLUMN,=20 SCRUBR	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Yrn/Nyln H.	IN COMPLIANCE

SCC:	30102406	SCC Units:	Tons Fiber Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Synthetic Organic Fiber Manufacturing; Nylon#66: Controlled; =
Segment Description:	CP Lines production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
VOC	1	715	POUNDS/DAY

Permit Condition	Observations
Hours of Operation This emissions unit is allowed = to=20 operate continuously, i.e., 8,760 hours/year.	There are no limits on the hours of operation for = emission=20 units 81 and 82.
The maximum allowable emissions rate for VOC is 715 = lbs/day=20 as a rolling annual average. This limit includes reasonable down = time of=20 up to 10% of the total operations time for necessary operation and = maintenance. As long as the emission limit is met, down time is = not=20 considered a violation of this permit.	Records for VOC emissions were reviewed for the = period of=20 September 1, 2012 through May 31, 2013. Records indicate that the = annual=20 rolling average is below the 715 lbs/day permit = limit.
VOC emissions testing shall be conducted biennially = (every=20 two years) using the Yarn Plant Emissions Sampling Protocol. = Notification=20 of the testing including the latest Yarn Plant Emissions Sampling = Protocol=20 will be provided per Rule 62-297.310, F.A.C.	VOC emissions testing was last performed on = November 16,=20 2011. Test results indicate an emission rate of 15.8 pounds of=20 HMD/day.
Emission factors shall be revalidated biennially = (every two=20 years). The results shall be submitted no later than 45 days after = completion of testing.	Emission factors are updated following completion = of=20 testing.
Permittee shall maintain a log of down time for = each=20 control device, which controls emissions of organic = compounds.	Records of downtime for the control device are = being=20 maintained.
Permitted Capacity. The combined process/operation = rate for=20 EU=BFs 081 and 082 shall not exceed the maximum operating rate = given in the=20 Company Confidential Appendix in million pounds nylon per year = based on a=20 12-month rolling total basis, as measured by nylon salt fed to=20 polymerization.	Process rates indicate compliance with the = operating rate=20 given in the Company Confidential Appendix in million pounds nylon = per=20 year.
Permittee shall calculate at a minimum once = annually or as=20 requested by the Department, a 365-day rolling average of total = organic=20 emissions from EU-I.D. Nos. 081 and 082 using current emissions = factors. A=20 summary graph identifying each day`s average shall be attached to = and=20 submitted with each annual operating report.	A 365-day rolling average is calculated daily using = the=20 current emission factors.
Distillation Column. Permittee shall monitor the = operation=20 and performance of the distillation column. As a minimum, the = monitoring=20 shall include the following: a) Monthly monitoring of off gas HMDA = concentrations. b) Monitoring and maintaining a minimum acceptable = column=20 reflux flow of 5,000 lbs/hr hourly average. c) Records shall be = maintained=20 and made available for Department inspection.	Off gas is condensed and analyzed on a weekly basis = and=20 records of column reflux flow are being=20 maintained.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	82	BATCH NYLON POLYMERIZATION:4 EVAPORATORS, 12 = BATCH=20 REACTORS	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Yrn/Nyln H.	IN COMPLIANCE

SCC:	30102406	SCC Units:	Tons Fiber Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Synthetic Organic Fiber Manufacturing; Nylon#66: Controlled; =
Segment Description:	Batch Nylon Reactors = production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
VOC	1	715	POUNDS/DAY

Permit Condition	Observations
EU 081 and 082 are subject to the same specific = permit=20 conditions. See EU 081 for consolidated observations.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	88	AREA 480 K/A EXPANSION, BACKUP VOC CONTROL = FLARE	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 480 KA M.	IN COMPLIANCE

SCC:	30109199	SCC Units:	Tons Material Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Acetone/Ketone Production; Ketone: Other Not Classified; =
Segment Description:	KA 480 production
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	27.38	Observed:
Annual Rate Limit:		Observed:

Permit Condition	Observations
N.1. Capacity. The maximum allowable operating rate = for the=20 VOC Control Flare, and its back-up, shall not exceed the rate of = all=20 combined process gases from the Area 480 process at the maximum = permitted=20 operating rate 54,795 lb/hr of KA mixture. {permitting note: = 54,795 lb/hr=20 is 120% of the annual average rate.} Compliance shall be = determined at the=20 Area 480 maximum operating rate of 54,795 lb/hr of KA mixture. = Permittee=20 shall maintain hourly records of KA mixture production and a = 24-hour=20 rolling average available for Department inspection.	Records of KA mixture production is being tracked=20 continuously. Records for the monitoring period of September 1, = 2012=20 through May 31, 2013, indicate compliance with the maximum = operating=20 rate.
N.2. Methods of Operation. The flare or backup = flare shall=20 be used to control VOC emissions from the Area 480 KA = process.	The flare or backup flare is being used to control = VOC=20 emissions from the Area 480 KA process.
N.4. The flare or equivalent and the associated = backup unit=20 shall be in place and operational, before the Area 480 process is = brought=20 into service.	The flare or backup flare is being used to control = VOC=20 emissions from the Area 480 KA process. Area 480 is shut down if = the=20 flares are not operational.
Permitted Capacity. The process/operation rate for = the Area=20 480 KA (P2K) Synthesis, EU 088, shall not exceed 400 million = pounds KA per=20 year based on a 12-month rolling total basis.	Facility records indicate compliance with the 400 = million=20 pounds KA per year based on a 12-month rolling = total.
Permitted Capacity. The process/operation rate for = the=20 Cyclohexane Oxidation Process (Halcon), EU 020, and the Area 480 = KA=20 Expansion, EU 088, apportioned to Adipic Acid Synthesis, EU 002, = shall not=20 exceed the combined maximum operating rate given in the Company=20 Confidential Appendix in million pounds KA per year based on a = 12-month=20 rolling total basis.	Facility records indicate compliance with the = maximum=20 operating rate given in the Company Confidential=20 Appendix.
Permittee shall maintain a list of all Volatile = Organic=20 Liquid Vessels, including description of construction and emission = control=20 device(s), location, service, size, and characteristics of liquid = stored=20 (ref. to 40 CFR 60.116b), with a written determination of: 40 CFR = 60.110b=20 emission control device(s), 40 CFR 60.112b, testing and procedures = requirements of 40 CFR 60.113b, and the reporting and = recordkeeping=20 requirements of 40 CFR 60.115b, as applicable to this emission = unit and=20 its segments.	Good records are being maintained of all Volatile = Organic=20 Liquid Vessels. During the inspection, records were reviewed of = testing=20 procedures, frequencies and inventories of = equipment.
Permittee shall maintain a list of all equipment = (defined=20 in 40 CFR 60.481) affected under 40 CFR 60.480, affected equipment = location, service, size, and characteristics of material(s) = handled (ref.=20 to 40 CFR 60.481), with a written determination of: standards = requirements=20 of 40 CFR 60.482-(1-10), test methods and procedures of 40 CFR = 60.485 and=20 the reporting and recordkeeping requirements of 40 CFR 60.487, as=20 applicable to this emission unit and its segments.	Good records are being maintained of all Volatile = Organic=20 Liquid Vessels. During the inspection, records were reviewed of = testing=20 procedures, frequencies and inventories of = equipment.
Permittee shall maintain a list of all reactor = process=20 equipment (defined in 40 CFR 60.701) affected under 40 CFR 60.700, = affected equipment location, service, size, and characteristics of = material(s) handled (ref. to 40 CFR 60.701), with a written = determination=20 of: the standards requirements of 40 CFR 60.702, monitoring of = emissions=20 and operations of 40 CFR 60.703, test methods and procedures of 40 = CFR=20 60.704 and the reporting and recordkeeping requirements of 40 CFR = 60.705,=20 as applicable to this emission unit and its segments.	Good records are being maintained of all Volatile = Organic=20 Liquid Vessels. During the inspection, records were reviewed of = testing=20 procedures, frequencies and inventories of=20 equipment.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	89	AREA 480 K/A EXPANSION - FUGITIVE = EMISSIONS	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 480 KA M.	IN COMPLIANCE

SCC:	30109199	SCC Units:	Tons Material Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Acetone/Ketone Production; Ketone: Other Not Classified; =
Segment Description:	KA 480 Plant - = fugitives
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:	27.38	Observed:
Annual Rate Limit:		Observed:

Permit Condition	Observations
This emissions unit shall comply with all = applicable=20 requirements of 40 CFR 60 Subparts A and VV, incorporated by=20 reference.	Applicable requirements of 40 CFR 60 Subparts A and = VV are=20 being followed.
This emissions unit shall comply with all = applicable=20 requirements of 40 CFR 63 Subparts A and H, incorporated by=20 reference.	Semi-annual Hazardous Organic NESHAP (HON) reports = are=20 being submitted as required.
Area 480 KA - Fugitive Emissions (EU 089) are = subject to=20 leak detection and repair (LDAR) requirements, as applicable, = pursuant to=20 40 CFR 60 Subpart VV and 40 CFR 63 Subpart H. Emissions testing = will be=20 satisfied by conformance with these regulations.	Semi-annual Hazardous Organic NESHAP (HON) reports = are=20 being submitted as required by Subpart=20 H.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	90	AREA II ADIPIC ACID EXPANSION, FUGITIVES	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Area 2 F.	IN COMPLIANCE

SCC:	30100180	SCC Units:	Each-Year Process Unit = Operating
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Adipic Acid; Fugitive Emissions: General;
Segment Description:	Adipic Area II Plant - = fugitives
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Permit Condition	Observations
This emissions unit shall comply with all = applicable=20 requirements of 40 CFR 60 Subparts A and VV, incorporated by=20 reference.	The emissions unit complies with all applicable=20 requirements of 40 CFR 60 Subparts A,=20 VV.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	97	NSPS Storage Tanks	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
Tnks-Stor N.	IN COMPLIANCE

SCC:	30102499	SCC Units:	Tons Material Produced
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Synthetic Organic Fiber Manufacturing; Other Not Classified; =
Segment Description:	Tanks 486TA19 & 480TA602 -=20 fugitives
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Permit Condition

Observations

40 CFR 60 Subpart Kb Provisions. Permittee shall = maintain a=20 list of all Volatile Organic Liquid Vessels, including description = of=20 construction and emission control device(s), location, service, = size, and=20 characteristics of liquid stored (ref. to 40 CFR 60.116b), with a = written=20 determination of: 40 CFR 60.110b emission control device(s), 40 = CFR=20 60.112b, testing and procedures requirements of 40 CFR 60.113b, = and the=20 reporting and recordkeeping requirements of 40 CFR 60.115b, as = applicable=20 to this emission unit and its segments.

Records are being maintained for all Volatile = Organic=20 Liquid storage = vessels.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	99	Boiler No. 9	Regulated Emissions Unit	ACTIVE

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
	IN COMPLIANCE

SCC:	10200602	SCC Units:	Million Cubic Feet Natural Gas = Burned
Process/Fuel = Description:	External Combustion Boilers; = Industrial; Natural=20 Gas; 10-100 Million Btu/hr;
Segment Description:	Boiler 9 - natural gas
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:	1845.7	Observed:

Pollutant	Allow Seq. No.	Allowable Emissions	Units	Observed Emissions
NOX	1	0.2	POUNDS PER BILLION BTU HEAT INPUT
CO	1	93.9	TONS/YEAR

Continuous = Monitors
Monitor Description	Monitor ID	Monitored = Pollutants	Calibrated = Reading
EMISSION	1
EMISSION	2

Permit Condition	Observations
Capacity The heat input for each boiler (Boilers = Nos. 9 and=20 10) shall not exceed 344 million Btu per hour (monthly basis). = Heat Input=20 Limit. For a period of ten years from January 4, 2011 (the = effective date=20 of permit 0330040-035-AC), total heat input for EU 003, 004, 014, = 015,=20 016, 032 and 099 shall not exceed more than 16,374,276 MMBtu/yr = from all=20 fuels in any 12-month rolling period and the total No. 6 fuel oil=20 combustion in EU 014, 015 and 016 shall not exceed 3,439,781.33 = MMBtu in=20 any 12-month rolling period.	Facility records for the period of September 1, = 2012=20 through May 31, 2013 were reviewed. During this period the maximum = hourly=20 heat input was below 344 MMBtu/hour. The total heat input for EU = 003, 004,=20 014, 015, 016, 032 and 099 for the 2012 calendar year was = 12,947,937=20 MMBtu.
Methods of Operation The fuel that is allowed to be = burned=20 in this unit is natural gas. Boiler No. 9 shall not exceed = 1,845,732=20 thousand standard cubic feet per 12-month rolling period of = natural gas.=20	Facility records for the twelve month rolling = period for=20 fuel usage indicate that 875,465 thousand standard cubic feet of = natural=20 gas was consumed during the previous twelve month=20 period.
Hours of Operation This emissions unit is allowed = to=20 operate continuously, i.e., 8,760 hours/year, provided the above = fuel=20 limitation is not exceeded.	Currently, there are no limits on the hours of = operation=20 provided the fuel limitation is not = exceeded.
Nitrogen oxide emissions, for each and every Phase = as=20 described above, are limited to 34.6 tons per year. Nitrogen oxide = emissions are limited to 0.20 pounds per million Btu (lb/MMBtu) = (30-day=20 rolling average).	Nitrogen oxide emissions are being monitored = continuously=20 using continuous emissions monitoring equipment. Facility records = show=20 nitrogen oxide emissions for the calendar year 2012 were measured = at 19.40=20 tons. Rolling averages are being maintained for pounds of Nitrogen = oxide=20 emissions per million Btu. Records of 30-day rolling averages were = reviewed for the period of September 1, 2012 through May 31, 2013. = Records=20 show nitrogen oxide emissions below the 0.20 lbs/MMBtu permit=20 limit.
Carbon monoxide emissions, for each and every Phase = as=20 described above, are limited to 93.9 tons per year.	Carbon monoxide emissions are being monitored = continuously=20 using continuous emissions monitoring equipment. Facility records = show=20 that carbon monoxide emissions for the calendar year 2012 were = measured at=20 17.2 tons.
Permittee is required to install, calibrate, = maintain, and=20 operate a continuous monitoring system, and record the output of = the=20 system, for measuring nitrogen oxides emissions discharged to the=20 atmosphere. The procedures under 40 CFR 60.13 (Attachment 40 CFR = 60=20 Subpart A- General provisions) shall be followed for installation, = evaluation, and operation of the continuous monitoring system. The = continuous monitoring systems shall be operated and data recorded = during=20 all periods of operation of the affected facility except for = continuous=20 monitoring system breakdowns and repairs. Data is recorded during=20 calibration checks, and zero and span adjustments. 1-hour average = nitrogen=20 oxides emission rates measured by the continuous nitrogen oxides = monitor=20 shall be expressed in ng/J or lb/MMBtu heat input and shall be = used to=20 calculate the average emission rates. Span values for nitrogen = oxides CEM=20 is 500 ppm. When nitrogen oxides emission data are not obtained = because of=20 continuous monitoring system breakdowns, repairs, calibration = checks and=20 zero and span adjustments, emission data will be obtained by using = standby=20 monitoring systems, Method 7, Method 7A, or other approved = reference=20 methods to provide emission data for a minimum of 75 percent of = the=20 operating hours in each steam generating unit operating day, in at = least=20 22 out of 30 successive steam generating unit operating = days.	Continuous emissions monitors (CEMS) are being used = to=20 monitor for nitrogen oxides emissions discharged to the = atmosphere.=20 Facility records indicate that the span on the meter is 0 -500 = ppm.=20 Calibration checks are automatically performed daily and relative = accuracy=20 testing is being performed annually. Data from the CEMS is = recorded at all=20 times except when the monitor is down for maintenance or=20 repairs.
Permittee shall notify the Department, at least 15 = days=20 prior to the date on which each formal compliance test is to = begin, of the=20 date, time, and place of each such test, and the test contact = person who=20 will be responsible for coordinating and having such test = conducted for=20 Permittee. Notification may be electronically submitted to=20 nwdair@dep.state.fl.us. Testing of emissions shall be conducted = with the=20 source operating at capacity. Capacity is defined as 90-100% of = rated=20 capacity. If it is impractical to test at capacity, sources may be = tested=20 at less than capacity; in this case subsequent source operation is = limited=20 to 110% of the test load until a new test is conducted. Once the = unit is=20 so limited, operation at higher capacities is allowed for no more = than 15=20 days for purposes of additional compliance testing to regain the = rated=20 capacity in the permit, with prior notification to the=20 Department.	The required 15 day notification is being submitted = to the=20 Department for each formal compliance test. Compliance with the = nitrogen=20 oxides emission standards shall be determined through performance = testing=20 of the NOX CEMS.
Compliance with the nitrogen oxides emission = standards=20 shall be determined through performance testing of the NOX CEMS. = For the=20 initial compliance test, nitrogen oxides from each boiler are = monitored=20 for 30 successive operating days and the 30-day average emission = rate is=20 used to determine compliance with the nitrogen oxides emission = standards.=20 The 30-day average emission rate is calculated as the average of = all=20 hourly emissions data recorded by the CEMS during the 30-day test = period.=20 A new 30-day rolling average emission rate is calculated each = operating=20 day as the average of all of the hourly nitrogen oxides emission = data for=20 the preceding 30 operating days.	The NOX CEMS is tested for accuracy on an annual = basis.=20 Testing was last peformed on August 21, 2012. Results of the = testing=20 indicate compliance. Records of 30-day average emission rates are = being=20 maintained and were available for review.
Permittee must keep records of the daily and = monthly fuel=20 (natural gas) used by the Boilers and annual NOX and CO emissions. = An=20 annual capacity factor, determined on a 12-month rolling average = basis,=20 shall be calculated, with a new annual capacity factor calculated = at the=20 end of each calendar month. Annual NOX and CO emissions shall = comply with=20 limits set forth in specific conditions C.4 and C.5.	Daily records of fuel usage and annual Nox and CO = emissions=20 are being maintained. The annual capacity factor is being = calculated=20 monthly.
C.12. Permittee shall submit to the Administrator=20 notification of the date of initial startup as provided by 40 CFR = 60.7=20 (Attachment 40 CFR 60 Subpart A =BF General provisions), the = performance=20 test data from the initial performance test and the performance = evaluation=20 of the CEMS using the applicable performance specifications in = Appendix B=20 (Attachment 40 CFR 60 Appendix B), as required in 40 CFR 60.49b. = The=20 initial startup notification shall include: (1) The design heat = input=20 capacity of the affected facility and identification of the fuels = to be=20 combusted in the affected facility, (2) If applicable, a copy of = any=20 Federally enforceable requirement that limits the annual capacity = factor=20 for any fuel or mixture of fuels under 40 CFR 60.42b(d)(1), = 60.43b(a)(2),=20 (a)(3)(iii), (c)(2)(ii), (d)(2)(iii), 60.44b(c), (d), (e), (i), = (j), (k),=20 60.45b(d), (g), 60.46b(h), or 60.48b(i), (3) The annual capacity = factor at=20 which the owner or operator anticipates operating the facility = based on=20 all fuels fired and based on each individual fuel fired, and, =	The initial notification of start-up was received = by the=20 Department on June 6, 2007.
C.13. Permittee shall maintain records of the = following=20 information for each steam generating unit operating day: (1) = Calendar=20 date. (2) The average hourly nitrogen oxides emission rates (ng/J = or=20 lb/million Btu heat input) measured or predicted. (3) The 30-day = average=20 nitrogen oxides emission rates (ng/J or lb/million Btu heat input) = calculated at the end of each steam generating unit operating day = from the=20 measured or predicted hourly nitrogen oxide emission rates for the = preceding 30 steam generating unit operating days. (4) = Identification of=20 the steam generating unit operating days when the calculated = 30-day=20 average nitrogen oxides emission rates are in excess of the = nitrogen=20 oxides emissions standards with the reasons for such excess = emissions as=20 well as a description of corrective actions taken. (5) = Identification of=20 the steam generating unit operating days for which pollutant data = have not=20 been obtained, including reasons for not obtaining sufficient data = and a=20 description of corrective actions taken. (6) Identification of the = times=20 when emission data have been excluded from the calculation of = average=20 emission rates and the reasons for excluding data. (7) = Identification of=20 =BFF`=BF factor used for calculations, method of determination, = and type of=20 fuel combusted. (8) Identification of the times when the pollutant = concentration exceeded full span of the continuous monitoring = system. (9)=20 Description of any modifications to the continuous monitoring = system that=20 could affect the ability of the continuous monitoring system to = comply=20 with Performance Specification 2 or 3. (10) Results of daily CEMS = drift=20 tests and quarterly accuracy assessments as required under 40 CFR = 60=20 Appendix F, Procedure 1 (attached). All records shall be = maintained for a=20 period of two years following the date of such record.	Good records of daily operations are being = maintained.=20 Semi-annual reports are being submitted to the Department with the = required daily operating information.
C.14. Permittee shall submit semiannual reports = containing=20 the information recorded in specific condition C.13. Electronic = reports=20 may be submitted with a Department approved format. Reports shall = be=20 postmarked by the 30th day following the end of the reporting=20 period.	The semi-annual report for the period of December = 1, 2012=20 through May 31, 2013, was received by the Department on June 19,=20 2013.

AIRS ID	EU#	Emission Unit Description	EU Class	ARMS Status
0330040	101	Adipic Acid New Fugitives (1080 MAR)	Regulated Emissions Unit	CONSTRUCTION

Grouping	EU Compliance Status	EU Noncompliance Comment	Other EU Comments
	IN COMPLIANCE		The emission unit is in compliance with the = monitoring and=20 record keeping requirements of 40 CFR 60 Subpart VV. Semi-annual = reports=20 are being submitted as = required.

SCC:	30100180	SCC Units:	Each-Year Process Unit = Operating
Process/Fuel = Description:	Industrial Processes; Chemical = Manufacturing;=20 Adipic Acid; Fugitive Emissions: General;
Segment Description:	Adipic Accid fugitives
Maximum % Ash:		Observed:
% Sulfur Limit:		Observed:
Hourly Rate Limit:		Observed:
Annual Rate Limit:		Observed:

Permit Condition

Observations

These emissions units consist of fugitive equipment = leaks=20 from pumps, compressors, agitators, pressure relief devices, = sampling=20 connection systems, open-ended valves or lines, valves, and = connectors in=20 VOC service but not also in HAP service located within the unit = boundaries=20 of the adipic acid process and the proposed new KA barge loading=20 facilities. The new emissions unit EU101 is created to capture = emissions=20 from new equipment added to support the increase from 850 MAR to = 1080 MAR=20 adipic. As a result of this project, these emissions units become = subject=20 to 40 CFR part 60 subpart VVa.

The emission unit is in compliance with the = monitoring and=20 record keeping requirements of 40 CFR 60 Subpart VV. Semi-annual = reports=20 are being submitted as required.=20

SECTION IV: OTHER = COMMENTS/RECOMMENDATIONS/PERMIT EXPIRATION DATES FOR FACILITY = 0330040=20
On June 25 and 26, 2013, a compliance = inspection=20 was performed at the Ascend Performance Materials Pensacola Plant. = During=20 the inspection, records for each emission unit were reviewed to = determine=20 compliance with the conditions of the Air Title V operating = permit. Good=20 records of operation and maintenance are being maintained and = appear to be=20 incompliance with the conditions of the permit. A walking tour of = the=20 facility and visual observation of the emission units were also = performed=20 during the inspection.
INSPECTOR(S): =
Name	Office	Phone	Email Address	Inspector of = Record
Christopher M. Stoll	NWD	850-595-0654	christopher.stoll@dep.s= tate.fl.us	Y

OVERALL COMPLIANCE STATUS FOR FACILITY=20 0330040 - IN =


*COMPLIANCE STATUS = KEY*
IN =3D In Compliance
MNC =3D Minor Non-Compliance
SNC =3D Significant Non-Compliance=20

Printed Monday, November 4 = , 2013=20