Approval of a Class 1 Permit Modification to Temporarily Change Hazardous Waste Boiler and Industrial Furnace (BIF) Permit Operating Conditions at Dow Chemical
- SCH Number
- Lead Agency
- Toxic Substances Control, Department of (Department of Toxic Substances Control)
- Document Title
- Approval of a Class 1 Permit Modification to Temporarily Change Hazardous Waste Boiler and Industrial Furnace (BIF) Permit Operating Conditions at Dow Chemical
- Document Type
- NOE - Notice of Exemption
- Document Description
- Dow has requested DTSC to waive selected BIF hazardous waste operating limits during Dow's pretest ("Mini Burn") and Comprehensive Performance Test (CPT) for its Symtet Halogen Acid Furnaces (ST HAF) and Manufacturing Services Halogen Acid Furnace (MS HAF), collectively referred as "BIFs" or "HAFs". The Mini Burn and CPT are needed to demonstrate that air emission from the Dow's HAFs are in compliance with the recently adopted Maximum Achievable Control Technology (MACT) Rules, as specified in Clean Air Act and Chapter 40 Code of Federal Regulations Part 63, Subpart EEE.
- Contact Information
Department of Toxic Substances Control
Standardized Permitting and Corrective Action 700 Heinz Avenue, Suite 300
Berkeley, CA 94710
Phone : (510) 540-3932
- Contra Costa
Notice of Exemption
- Exempt Status
- Categorical Exemption
- Type, Section or Code
- Section 15306
- Reasons for Exemption
- 1. The automatic waste feed cut off limit for Carbon Monoxide (CO) in the stack gas will remain at 100 parts per million measured on volume basis (ppmv). Therefore the CO emission to air is not affected by these operating condition changes. The CO concentration of the stack gas is an indicator of destruction and removal efficiency (DRE) of hydrocarbons. By maintaining the CO limits at the stack this would avoid any public exposure from an off specification event upstream during testing procedures. 2. The project involves no construction or soil disturbance. 3. The site is not on Hazardous Waste and Substances Sites List pursuant to Government Code Section 62962.5. 4. The project duration is short. The HAFs are operated at the target rates for only 5 hours during the one-day pretest and 24 hours during the four-day CPT test. Thus, all emissions from the Mini Burn and CPT are confined to these short intervals. 5. The hazardous waste feed rates for total chloride/chlorine, as well as other test run conditions are not significantly different from the hazardous waste permit conditions during the pre-test and CPT.
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