Yuhuang Chemical Inc. Methanol Plant
Proposed Part 70 Air Permit Modification
AI # 194165
Permit Number 2560-00295-V1
Activity Number PER 20160001
On behalf of Louisiana Environmental Action Network (LEAN) and its members in St.James Parish, the following comments are submitted to DEQ in response to the proposed Part 70 Air Permit Modification for the Yuhuang Chemical Inc. (YCI) Methanol Plant in St. James Parish, Louisiana.
DEQ issued the initial Part 70 Air Permit to YCI on May 5, 2015.On May 18, 2015, the Tulane Environmental Law Clinic on behalf of Louisiana Environmental Action Network and the Sierra Club filed a Title V petition with the Environmental Protection Agency concerning the final permit issued by DEQ for the YCI Methanol Plant. The petition objected to the issuance of the Title V Operating Permit and requested that EPA object to the final operating permit.
On August 31, 2016, EPA issued their decision granting in part and denying in part the petition for objection to the permit for YCI Methanol facility.The EPA decision indicated DEQ failed to insure that Carbon Monoxide (88.8 tons/year), Volatile Organic Compounds (78.39 tons/year) and Nitrogen Oxides (85.45 tons/year) emission limits were to be monitored and enforceable to insure that the emissions are below the 100 tons per year for CO, VOC and NOx emissions. EPA provided directions to DEQ to address the issues EPA granted to the petitioners on pages 26 through 28 of their August 31, 2016 EPA order.
Prior to EPA issuing their decision on August 31, 2016 concerning the final Part V operating permit issues, the following occurred:
- June 17, 2016 Ramboll Environ submitted, on behalf of YCI , an application for a minor modification to the Title V air permit.
- June 24, 2016 Ramboll Environ submitted the Environmental Assessment Statement to DEQ.
- An expedited review process was utilized for the permit modification review.
- August 18, 2016, the Public Notice for the Permit Modification was published and contained a request for public comments and a notice of a public hearing on September 29, 2016.
- August 18, 2016, the public notice was published in the Advocate and News Examiner Enterprise.
Thus the permit modification process was undertaken, the application reviewed by DEQ and noticed prior to EPA issuing their decision on the LEAN and Sierra Club petition. The EPA decision was not considered by DEQ in its review of the application for a permit modification and the issuance of a public notice.
DEQ is holding this public comment period and public hearing at an inappropriate time in the permitting process:
- Before modifying the Final Title V Air Permit, DEQ must follow the EPA directions in the EPA order to address the faults in the Final Title V Air Permit.
- Following the DEQ modifications to the Final Title V Air Permit required by EPA to insure issues such as the CO and VOC emission limits are enforceable as a practical matter, adequate to ensure emissions remain below major source thresholds and other issues are addressed, DEQ must hold a public comment period to allow interested individuals to review and comment on the changes to the permit.
- Once the Title V Air Permit is final and the time period for appeal has passed, then DEQ can consider accepting the YCI request for a permit modification.
Addressing Issues in the Modification Application
In the LEAN and Sierra Club petition it is demonstrated, YCI has the potential to emit CO, VOC and NOx in excess of the applicable 100 tons per year. In the minor modification application of June 7, 2016, NOx and VOC proposed emission will increase over those issued in the initial permit of May 5, 2015 and could result in an even greater chance of exceeding the 100 tons per year major stationary source threshold.
Changes to the following emission sources will result from the minor modification:
- Steam Methane Reformer
- Auxiliary Boilers
- Cooling Tower
The minor modification proposed to increase the VOC emissions from 78.39 to 85.12 tons per year.This could result in an even greater chance of exceeding the 100 tons per year Major Stationary Source Threshold.
The Steam Methane Reformer (SMR) is the largest source of VOC emissions (32.89 tons per year). The minor modification updated the VOC emission factor from 5.5 pounds per MMscf to 6.4 pounds per MMscf based on project design.
The new Methanol Scrubber serving a number of tanks will release 4.37 tons/year.
The largest emission source of NOx is the Steam Methane Reformer (SMR), 55.55 tons/year.
The minor permit modification revised the NOx maximum hourly emission factor from 0.04 pounds/mmBtu to 0.05 pounds/MMBtu.
The SMR also is the largest emission source of PM 10 (32.10 tons/year), PM2.5 (32.10 tons/year), SO2 (3.16 ton/year), CO (38.15 tons/year), CO2e (1,338,863 tons/year –Green House Gases) and ammonia (21.01 tons/year).
The Slop Vessel is routed to the flare. The emissions of CO from the Slop Vessel will increase from 1.98 tons/year to 28.72 tons/year.
The permit modification will increase the air emissions of Volatile Organic Compounds (85.11 tons/year), Oxides of Nitrogen (87.63 tons/year), Carbon Monoxide (87.17 tons/year), Ammonia (31.80 tons/year), Methanol (44.65 ton/year), n-hexane and dichlorobenzene. These increased emissions as well as the PM10 and PM2.5 emissions have the potential to exceed the 100 tons per year major emission thresholds.
YCI has also stated they currently have available space on their property for two additional capital projects.
Currently the Part 70 permit lacks adequate monitoring and enforceable measures to ensure the facility meets emission limits. The modification will only make that situation worse.
The Additional Monitoring and Testing Requirements contained in the Final Permit are the same as those contained in the modified permit available for public comment at this time.
DEQ must require monitoring and enforcement measures be included in the original permit to ensure the YCI facility is either a minor source or must be required to comply with all the requirements of a major source permit conditions. Once DEQ addresses the original permit issues required by the EPA response to the LEAN petition, a public comment period must be held. These conditions must be performed before DEQ considers a modification to the YCI air permit.