THE DOW CHEMICAL COMPANY. and TRINSEO LLC SRN: A4033. Located at

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1 State Registration Number Michigan Department of Environmental Quality Air Quality Division RENEWABLE OPERATING PERMIT ROP Number A4033 STAFF REPORT MI-ROP-A THE DOW CHEMICAL COMPANY and TRINSEO LLC SRN: A4033 Located at The Dow Chemical Company, 1790 Building, Washington Street, Midland, Midland County, Michigan and Trinseo LLC, 1604 Building, Barth Street, Midland, Midland County, Michigan Permit Number: MI-PTI-A Staff Report Date: December 12, 2016 This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions of the Renewable Operating Permit (ROP). Page 1 of 15 (Rev. 06/01/16)

2 TABLE OF CONTENTS DECEMBER 12, 2016 STAFF REPORT 3 FEBRUARY 21, STAFF REPORT ADDENDUM 14 APRIL 2, STAFF REPORT ADDENDUM 15 Page 2 of 15

3 State Registration Number A4033 Michigan Department of Environmental Quality Air Quality Division RENEWABLE OPERATING PERMIT DECEMBER 12, 2016 STAFF REPORT ROP Number MI-ROP-A Purpose Major stationary sources of air pollutants, and some non-major sources, are required to obtain and operate in compliance with an ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan s Administrative Rules for Air Pollution Control pursuant to Section 5506(1) of Act 451. Sources subject to the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a stationary source s applicable requirements and compliance with them by consolidating all state and federal air quality requirements into one document. This Staff Report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the draft ROP terms and conditions including citations of the underlying applicable requirements, an explanation of any equivalent requirements included in the draft ROP pursuant to Rule 212(5), and any determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the stationary source. General Information Stationary Source Mailing Address: Section 1: The Dow Chemical Company 1790 Building, Washington Street Midland, Michigan Source Registration Number (SRN): rth American Industry Classification System (NAICS) Code: Section 2: Trinseo LLC 1604 Building, Barth Street Midland, Michigan A4033 Section 1: Section 2: Number of Stationary Source Sections: 2 Is Application for a Renewal or Initial Issuance? Renewal Application Number: Responsible Official: Section 1: Scott Bemis, EH&S Responsible Care Leader AQD Contact: Page 3 of 15 Section 2: Justin Huscke, Responsible Care Leader Date Application Received: September 18, 2015 Date Application Was Administratively Complete: September 18, 2015 Kathy Brewer, Environmental Quality Analyst

4 Is Application Shield In Effect? Yes Date Public Comment Begins: December 12, 2016 Deadline for Public Comment: January 11, 2017 Page 4 of 15

5 Source Description Section 1 of the ROP covers The Dow Chemical Company (Dow). Dow is a chemical manufacturer located in Midland, Michigan. Dow manufactures chemical products using a variety of process equipment including: reactors, distillation/fractionation columns, separators, storage tanks/silos, condensers, thermal heat recovery and oxidation units, scrubbers, etc. Dow also maintains and operates: Research and development facilities A wastewater treatment plant A hazardous waste incineration complex Hazardous waste and solid waste landfill Storage tank farms Office buildings Ancillary equipment (i.e., boilers, etc.) Section 2 of the ROP was established to cover assets previously owned and operated by Dow. In 2010, these assets were divested from Dow and purchased by Styron LLC. The assets are currently owned by Trinseo LLC (Trinseo). The assets include: EU31, EU33, EU34, EUB1, and FGSTYRENICSHTRS. The following table lists stationary source emission information for the Dow and Trinseo s Midland, Michigan operations as reported to the Michigan Air Emissions Reporting System (MAERS) for the year 2015 TOTAL STATIONARY SOURCE EMISSIONS Pollutant Tons per Year Carbon Monoxide (CO) 20 Lead (Pb) 0 Nitrogen Oxides (NO x ) 206 Particulate Matter (PM) 46 Sulfur Dioxide (SO 2 ) 11 Volatile Organic Compounds (VOCs) 266 The facility does not report individual calculated Hazardous Air Pollutant emissions for the year. The potential to emit greenhouse gas (GHG) CO2 equivalent emissions (CO2e) reported in the ROP application is 136,461 tons CO2e. CO2e is a calculation of the combined global warming potentials of six Greenhouse Gases (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride). Parts C and D in the ROP for summary tables of all processes at the stationary source that are subject to process-specific emission limits or standards. Regulatory Analysis The following is a general description and history of the source. Any determinations of regulatory nonapplicability for this source are explained below in the n-applicable Requirement part of the Staff Report and identified in Part E of the ROP. The stationary source is located in Midland County, which is currently designated by the U.S. Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants. Page 5 of 15

6 The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR) Part 70 because the potential to emit each of the following criteria pollutants exceeds 100 tons per year: nitrogen oxides (NOx), Particulate Matter (PM), and volatile organic compounds (VOCs). The stationary source is considered a major source of Hazardous Air Pollutant (HAP) emissions because the potential to emit of any single HAP regulated by the federal Clean Air Act, Section 112, is equal to or more than 10 tons per year and/or the potential to emit of all HAPs combined is equal to or more than 25 tons per year. The facility is an existing Major Stationary Source for federal Prevention of Significant Deterioration (PSD) (40 CFR 52.21) regulations. The 32 hazardous waste incinerator at Dow is considered a synthetic minor source with regard to PSD as Dow accepted legally enforceable permit conditions limiting the potential to emit from the incinerator for sulfur dioxide (SO 2 ), PM, (particulate matter), PM-10 (PM less than 10 microns in diameter), PM2.5 (PM less than 2.5 microns in diameter), carbon monoxide (CO), fluorides, and sulfuric acid. The 32 incinerator originally was able to net out of PSD for NOx. Some processes at Dow have emission limits associated with categories based on applicable AQDestablished initial threshold screening level or > micrograms per cubic meter for any averaging time. Equipment previously included in the FGRULE604-S1 and FGRULE605-S1 is no longer in service or the Rule 604 or Rule 605 requirements are no longer applicable. Therefore the FGRULE604-S1 and FGRULE605-S1 flexible groups have been removed from the ROP. Due to a restructuring of the ownership of Dow Corning, the Dow Corning Corporation became a wholly owned subsidiary of The Dow Chemical Company, effective June 1, The Dow Corning Midland Plant Facility is located at 3901 South Saginaw Road, adjacent to the Dow Midland, Michigan site. The Dow Corning Midland Plant Facility and the Dow Midland, Michigan site are now considered one Stationary Source for New Source Review, PSD, and Title V Major Source determinations. Dow Corning remains the legal entity owning and operating the Dow Corning Midland Plant Facility. The Dow Corning Midland Plant Facility will retain its current State Registration Number (SRN) of A4043 and separately issued ROP. Each facility will continue to separately report billable annual emissions. Applicable NSPS, NESHAP, and MACT Standards Portions of the stationary source are subject to the following NSPS (New Source Performance Standards), NESHAP (National Emission Standards for Hazardous Air Pollutants), and MACT (Maximum Achievable Control Technology) standards. For the purpose of this staff report, 40 CFR Part 60, 61, and 63 regulations are referred to as NSPS, NESHAP, and MACT standards, respectively. The applicable standards are in each Emission Unit or Flexible Group s Special Conditions. The 40 CFR Part 60, 61, and 63 each have a Subpart A that contains requirements applicable to portions of the stationary source subject to one or more NSPS, NESHAP, or MACT standards below. Applicable NSPS, NESHAP, and MACT Standards Standards of performance for volatile organic liquid storage vessels (including petroleum liquid storage vessels) National emission standard for mercury National emission standard for asbestos National emission standard for benzene waste operations National emission standards for organic hazardous air pollutants from the synthetic organic chemical manufacturing industry National emission standards for organic hazardous air pollutants from the synthetic organic chemical manufacturing industry for process vents, storage vessels, transfer operations, and wastewater Page 6 of 15 Federal Citation 40 CFR 60, Subpart Kb 40 CFR 61, Subpart E 40 CFR 61, Subpart M 40 CFR 61, Subpart FF 40 CFR 63, Subpart F 40 CFR 63, Subpart G

7 Applicable NSPS, NESHAP, and MACT Standards National emission standards for organic hazardous air pollutants for equipment leaks NESHAP for industrial process cooling towers National emission standards for hazardous air pollutant emissions: Group I polymers and resins NESHAP from off-site waste and recovery operations NESHAP from hazardous waste combustors National emission standard for hazardous air pollutant emissions: Group IV polymers and resins NESHAP for pesticide active ingredient production Organic liquids distribution NESHAP Miscellaneous organic chemical manufacturing NESHAP (MON) NESHAP for cellulose products manufacturing NESHAP for stationary reciprocating internal combustion engines Industrial/Commercial/Institutional Boilers and Process Heaters National Emission Standards for HAPs NESHAP for site remediation NESHAP for miscellaneous coatings manufacturing NESHAP for hydrochloric acid production Federal Citation 40 CFR 63, Subpart H 40 CFR 63, Subpart Q 40 CFR 63, Subpart U 40 CFR 63, Subpart DD 40 CFR 63, Subpart EEE 40 CFR 63, Subpart JJJ 40 CFR 63, Subpart MMM 40 CFR 63, Subpart EEEE 40 CFR 63. Subpart FFFF 40 CFR 63, Subpart UUUU 40 CFR 63, Subpart ZZZZ 40 CFR 63, Subpart DDDDD 40 CFR 63, Subpart GGGGG 40 CFR 63, Subpart HHHHH (including Subpart UU - National Emission Standards for Equipment Leaks - Control Level 2 Standards) 40 CFR 63, Subpart NNNNN Pursuant to 40 CFR 63.10(a)(6), Dow is currently utilizing a common schedule on which periodic reports required by the following standards shall be submitted throughout the year. The report date for each of the following applicable standards is March 15 (reporting period July 1 December 31) and September 15 (January 1 June 30) of each year. For future MACT standards, Dow has suggested that they will continue to request a common reporting schedule pursuant to the provisions of 40 CFR 63.10(a)(6). Applicable NSPS, NESHAP, and MACT Standards National emission standards for organic hazardous air pollutants from the synthetic organic chemical manufacturing industry National emission standards for organic hazardous air pollutants from the synthetic organic chemical manufacturing industry for process vents, storage vessels, transfer operations, and wastewater National emission standards for organic hazardous air pollutants for equipment leaks National emission standards for hazardous air pollutant emissions: group I polymers and resins NESHAP from off-site waste and recovery operations National emission standard for hazardous air pollutant emissions: group IV polymers and resins NESHAP from hazardous waste combustors NESHAP for pesticide active ingredient production NESHAP for cellulose products manufacturing NESHAP for miscellaneous organic chemical manufacturing(mon) Federal Citation 40 CFR 63, Subpart F 40 CFR 63, Subpart G 40 CFR 63, Subpart H 40 CFR 63, Subpart U 40 CFR 63, Subpart DD 40 CFR 63, Subpart JJJ 40 CFR 63, Subpart EEE 40 CFR 63, Subpart MMM 40 CFR 63, Subpart UUUU 40 CFR 63, Subpart FFFF Page 7 of 15

8 Applicable NSPS, NESHAP, and MACT Standards NESHAP for miscellaneous coatings manufacturing NESHAP for site remediation NESHAP for hydrochloric acid production NESHAP for stationary reciprocating internal combustion engines Federal Citation 40 CFR 63, Subpart HHHHH (including Subpart UU - National Emission Standards for Equipment Leaks - Control Level 2 Standards) 40 CFR 63, Subpart GGGGG 40 CFR 63, Subpart NNNNN 40 CFR 63, Subpart ZZZZ Included in the ROP Special conditions are references to EPA Consent Decree.1:11-cv TLL- CEB which is in Appendix 9 of the ROP. EPA Consent Decree.1:11-cv TLL-CEB includes requirements for Dow to implement an Enhanced Leak Detection and Repair Program which imposes leak monitoring and repair requirements more stringent than existing LDAR regulations, including more frequent monitoring, more stringent repair practices, and the use of low-emissions valve technology. The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring Submittals." The Dow Chemical Company has emission units at the stationary source subject to the federal Compliance Assurance Monitoring (CAM) rule under 40 CFR, Part 64. The CAM subject emission units (described in the table below) have control devices and potential pre-control emissions of PM-10, VOC, and/or HAPs greater than the major source threshold level. Emission Unit ID Pollutant/ Emission Limit UAR(s) EU11 VOC 40 CFR Part 63, Subpart Page 8 of 15 Control Equipment Scrubber.1 (T- 302) NNNNN EU11 VOC Scrubber. 2 (Venturi) EU11 VOC Absorber 1A & 1B EU11 VOC 40 CFR Part Absorber 2 63, Subpart (T-402) NNNNN EU11 VOC 40 CFR Part 63, Subpart NNNNN EU13 VOC FG954THROX EU35 VOC & HAPs FG954THROX & FGSARANTTU FGHCLMA CT FG954THR OX FG954THR OX FGSARANT TU EU89 VOC Thermal Oxidation Unit (TOX - 4 MMBtu/hr) Monitoring Flow, ph Flow Flow, Temperature Flow, Temperature FGHCLMACT FG954THROX FG954THROX & FGSARANTTU Temperature EUANION_XCHG VOC 40 CFR Part Scrubber 4 Flow Yes Presumptively Acceptable Monitoring? Yes Yes Yes

9 Emission Unit ID Pollutant/ Emission Limit UAR(s) Control Equipment 63, Subpart FFFF EUANION_XCHG VOC FG963THROX FG963THR OX EUB2 VOC & PM-10 Eleven baghouses EUB2 VOC & PM CFR Part Water 63, Subpart scrubber UUUU (T-1001) EUB2 VOC & PM-10 FG954THROX FG954THR OX EUB2 VOC & PM-10 FG963THR FG963THROX OX EUB5 PM fug.dust scrubber EUB5 PM pkg scrubber EUB5 PM raw mtrl scrubber EUB5 PM blender baghouse EUB5 PM Blender cyclone EUB5 PM10 FG954THR FG954THROX OX EU32INCINERAT PM & VOC OR 40 CFR Part 63, Subpart EEE and Subpart DD quench tower, condenser, venturi scrubber, chlorine scrubber, nine ionizing wet scrubbers EUDCEP VOC &HAPs FG858TOX FG858TOX FG954THROX VOC & HAPs 20,000 BTU/hr fire tube boiler located at 954 Building referred to as TTU-954. This boiler burns natural gas and process waste from various Monitoring FG963THROX Differential pressure, VE Flow FG954THROX FG963THROX Flow Flow Flow Differential pressure, VE Flow FG954THROX Numerous FG858TOX Temperature, %O2, Flow, ph Presumptively Acceptable Monitoring? Yes Yes Yes Page 9 of 15

10 Emission Unit ID Pollutant/ Emission Limit UAR(s) Control Equipment emission units at Dow. Quench Column.1, Scrubber.1 FG963THROX VOC & HAPs 28.2MMBtu/ hr thermal oxidizer w/heat recovery followed by quench & Scrubber 6 FGSARANTTU VOC & HAPs thermal incinerator and a vent gas holding system located at 989 Building Water quench, water scrubber, & caustic scrubber FG858TOX VOC & HAPs Five million BTU/hr vent gas afterburner used to combust selected vent streams prior to discharge to the atmosphere. Equipment located in 858 Building., quench, & packed tower scrubber Monitoring Temperature, Flow, ph Temperature, Flow, ph, differential pressure Temperature, Flow, ph Presumptively Acceptable Monitoring? Page 10 of 15

11 The emission limitations or standards for NOx, SO2, and CO, from EU32INCINERATOR at the stationary source are exempt from the federal Compliance Assurance Monitoring (CAM) regulation under 40 CFR 64.2(b)(1)(vi), because the continuous emission rate monitors, monitoring, recordkeeping & reporting requirements meet the CAM exemption for a continuous compliance determination method. Therefore, EU32INCINERATOR is exempt from CAM requirements for NOx, SO2, and CO. Original CAM Plans were submitted where applicable. Subsequent to the original plan submittals, when the facility has been issued a Permit To Install, the PTI contained CAM required emission control monitoring and recordkeeping which are considered updated CAM Plan elements. Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the stationary source. Part A contains regulatory citations for general conditions. Source-wide Permit to Install (PTI) Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a footnote designation in the integrated ROP/PTI document. The following table lists all individual PTIs that were incorporated into previous ROPs. PTIs issued after the effective date of ROP. MI-ROP-A are identified in Appendix 6 of the ROP. PTI Number (EU01) (EU02) (EU9) (EU10) B (EU11) (EU12) C (EU13) (EU14) C (EU15) A (EU18) (EU35) 4-04 (EU82) (EU85) C (EU86) 63-76E, (EU88) B (EU89) A (EU91) A (EU_RESIN_DRYER) i (EUANION_XCHG) (EUANION_XCHG & EUSPECIALTY) , (EU93) C (EU94) A (EU95) 7-04 (EUB2) B (EUB5) A (EUB7) A, (EUC3) (EU32INCINERATOR) (FG954THROX) (FGBOILERS21&22) B (FGSITEBOILERS) 3-04A (EU31-S2) A (EU33-S2) 49-07A (EUB1-S2) Streamlined/Subsumed Requirements This ROP does not include any streamlined/subsumed requirements pursuant to Rules 213(2) and 213(6). n-applicable Requirements Part E of the ROP lists requirements that are not applicable to this source as determined by the AQD, if any were proposed in the ROP Application. These determinations are incorporated into the permit shield provision set forth in Part A (General Conditions 26 through 29) of the ROP pursuant to Rule 213(6)(a)(ii). Page 11 of 15

12 Processes in Application t Identified in Draft ROP The following table lists processes that were included in the ROP Application as exempt devices under Rule 212(4). These processes are not subject to any process-specific emission limits or standards in any applicable requirement. Exempt Emission Unit ID EUCOLDCLEANERS1 EURULE282a-S1 EURULE282b-S1 EURULE284b-S1 EURULE284g-S1 EURULE284i-S1 EURULE285g-S1 EURULE285vi-S1 Description of Exempt Emission Unit Any existing cold cleaner (placed into operation prior to 7/1/79) or new cold cleaner (placed into operation after 7/1/79) that is exempt from NSR permitting by R (h) or R (r)(iv). Processes or process equipment which are electrically heated or which fire sweet gas fuel or no. 1 or no. 2 fuel oil at a maximum total heat input rate of not more than 10,000,000 Btu per hour and meet the criteria of R (a). Fuel-burning equipment which is used for space heating, service water heating, electric power generation, oil and gas production or processing, or indirect heating and which only burns the fuels specified in R (b). Storage of butane, propane, or liquefied petroleum gas in a vessel that has a capacity of less than 40,000 gallons. Gasoline or natural gas storage and handling equipment, as follows: Gasoline storage and handling equipment at loading facilities handling less than 20,000 gallons per day or at dispensing facilities. Storage or transfer operations of volatile organic compounds or noncarcinogenic liquids in a vessel that has a capacity of not more than 40,000 gallons where the contents have a true vapor pressure of not more than 1.5 psia at the actual storage conditions. Internal combustion engines that have less than 10,000,000 Btu/hour maximum heat input. Equipment for carving, cutting, routing, turning, drilling, machining, sawing, surface grinding, sanding, planing, buffing, sand blast Rule 201 Exemption Rule 281(h) Rule 282(a) Rule 282(b) Rule 284(b) Rule 284(g) Rule 284(i) Rule 285(g) Rule 285(vi) Rule 212(4) Exemption Rule 212(4)(a) Rule 212(4)(b) Rule 212(4)(b) Rule 212(4)(c) Rule 212(4)(c) Rule 212(4)(c) Rule 212(4)(d) Rule 212(4)(d) Page 12 of 15

13 Exempt Emission Unit ID EURULE290-S1 Description of Exempt Emission Unit cleaning, shot blasting, shot peening, or polishing ceramic artwork, leather, metals, graphite, plastics, concrete, rubber, paper stock, wood, or wood products which meets the subsequent requirements of 285(vi). Permit to install exemptions; emission units with limited emissions. Rule 201 Exemption Rule 290 Rule 212(4) Exemption Rule 212(4)(g) Draft ROP Terms/Conditions t Agreed to by Applicant This draft ROP does not contain any terms and/or conditions that the AQD and the applicant did not agree upon pursuant to Rule 214(2). Compliance Status The AQD finds that the stationary source is expected to be in compliance with all applicable requirements as of the effective date of this ROP. Action taken by the MDEQ, AQD The AQD proposes to approve this ROP. A final decision on the ROP will not be made until the public and affected states have had an opportunity to comment on the AQD s proposed action and draft permit. In addition, the USEPA is allowed up to 45 days to review the draft ROP and related material. The AQD is not required to accept recommendations that are not based on applicable requirements. The delegated decision maker for the AQD is Chris Hare, District Supervisor. The final determination for ROP approval/disapproval will be based on the contents of the ROP Application, a judgment that the stationary source will be able to comply with applicable emission limits and other terms and conditions, and resolution of any objections by the USEPA. Page 13 of 15

14 State Registration Number Purpose A4033 Michigan Department of Environmental Quality Air Quality Division RENEWABLE OPERATING PERMIT FEBRUARY 21, STAFF REPORT ADDENDUM ROP Number MI-ROP-A A Staff Report dated February 21, 2017, was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R (1). The purpose of this Staff Report Addendum is to summarize any significant comments received on the draft ROP during the 30-day public comment period as described in R (3). In addition, this addendum describes any changes to the draft ROP resulting from these pertinent comments. General Information Responsible Official: Section 1: Scott Bemis, EH&S Responsible Care Leader AQD Contact: Section 2: Justin Huscke, Responsible Care Leader , Kathy Brewer, Environmental Quality Analyst Summary of Pertinent Comments An inquiry was received regarding which stack or vent listed in EU04-S1 Special Condition VIII was associated with which control device listed for the emission unit. Changes to the December 12, 2016 Draft ROP A more detailed description was added to the stack or vent table in EU04-S1 Special Condition VIII. Page 14 of 15

15 State Registration Number Michigan Department of Environmental Quality Air Quality Division RENEWABLE OPERATING PERMIT ROP Number A4033 APRIL 2, STAFF REPORT ADDENDUM MI-ROP-A Purpose A Staff Report dated December 12, 2016, was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R (1). The purpose of this Staff Report Addendum is to summarize any significant comments received on the draft ROP during the EPA 45 day comment period as described in R (5). In addition, this addendum describes any changes to the proposed ROP resulting from these pertinent comments. General Information Responsible Official: Section 1: Scott Bemis, EH&S Responsible Care Leader AQD Contact: Section 2: Justin Huscke, Responsible Care Leader Kathy Brewer, Environmental Quality Analyst Summary of Pertinent Comments Appendices 6-S1 and 6-S2 Permits to Install/ROP Revision Applications tables were changed to correctly identify six ROP application revision tracking numbers for ROP changes made since June 23, Two of the six ROP application revisions were not previously listed in the Appendix 6 tables. The Pubic tice Draft ROP and the Proposed ROP contained the conditions and other requirements of the ROP application revisions associated with changed tracking numbers. Page 15 of 15