ADEQ MINOR SOURCE AIR PERMIT Permit No. : 0010-AR-12 IS ISSUED TO: Stratcor, Inc. 4285 Malvern Road Hot Springs, AR 71901 Garland County AFIN: 26-00002 THIS PERMIT IS THE ABOVE REFERENCED PERMITTEE’S AUTHORITY TO CONSTRUCT, MODIFY, OPERATE, AND/OR MAINTAIN THE EQUIPMENT AND/OR FACILITY IN THE MANNER AS SET FORTH IN THE DEPARTMENT’S MINOR SOURCE AIR PERMIT AND THE APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THE PROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT (ARK. CODE ANN. SEC. 8-4-101 ET SEQ.) AND THE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Mike Bates Date Chief, Air Division Stratcor, Inc. Permit #: 0010-AR-12 AFIN: 26-00002 Table of Contents Section I: FACILITY INFORMATION.................................................................................... 4 Section II: INTRODUCTION...................................................................................................... 5 Summary of Permit Activity.................................................................................................... 5 Process Description................................................................................................................... 5 Regulations .............................................................................................................................. 10 Total Allowable Emissions ..................................................................................................... 10 Section III: PERMIT HISTORY............................................................................................... 11 Section IV: EMISSION UNIT INFORMATION..................................................................... 13 Section V: INSIGNIFICANT ACTIVITIES ............................................................................ 23 Section VI: GENERAL CONDITIONS.................................................................................... 24 Appendix A NSPS Subpart Dc 2 Stratcor, Inc. Permit #: 0010-AR-12 AFIN: 26-00002 List of Acronyms and Abbreviations A.C.A. Arkansas Code Annotated AFIN ADEQ Facility Identification Number CFR Code of Federal Regulations CO Carbon Monoxide HAP Hazardous Air Pollutant lb/hr Pound Per Hour No. Number NOx Nitrogen Oxide PM Particulate Matter PM10 Particulate Matter Smaller Than Ten Microns SO2 Sulfur Dioxide Tpy Tons Per Year UTM Universal Transverse Mercator VOC Volatile Organic Compound 3 Stratcor, Inc. Permit #: 0010-AR-12 AFIN: 26-00002 Section I: FACILITY INFORMATION PERMITTEE: Stratcor, Inc. AFIN: 26-00002 PERMIT NUMBER: 0010-AR-12 FACILITY ADDRESS: 4285 Malvern Road Hot Springs, AR 71901 MAILING ADDRESS 4285 Malvern Road Hot Springs, AR 71901 COUNTY: Garland CONTACT POSITION: Tim W. Scott, General Manager TELEPHONE NUMBER: (501) 262-1270 ext 236 REVIEWING ENGINEER: Michael H. Watt UTM North South (Y): Zone 15: 3814.5 km UTM East West (X): Zone 15: 503.4 km 4 Stratcor, Inc. Permit #: 0010-AR-12 AFIN: 26-00002 Section II: INTRODUCTION Summary of Permit Activity Stratcor Inc. operates a vanadium recovery facility in Hot Springs. This modification is to install a new Maleic Vanadium Oxide (MVO) conveying system, a new product packaging system, and the replacement of an existing boiler. Stratcor plans on installing a pneumatic conveying system to transfer MVO product to hoppers where material is sent through classifiers which separate the product into various sizes. The system will be equipped with three baghouses to capture dust in the conveying system. Additionally, this modification replaces the existing product repackaging system (SN-44) with four new packaging systems (MVO System #1, HPG System #2, AMV System #3, and Jet Mill System #5). There will be a total of nine baghouses associated with the blowers and dust collectors at the new packaging systems, although the total amount of product passing through the entire packaging system will not increase. This modification also removes the 46.5 MMBTU/hr boiler (SN-33). Stratcor will install a new natural gas-fired boiler (SN-34) equal in size to the existing 31.5 MMBTU/hr boiler (SN-32). The new boiler will be subject to 40 CFR Part 60, Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. Permitted particulate emissions at the facility will increase by 9.0 tons per year, permitted VOC emissions will increase by 0.4 tons per year, permitted CO emissions will increase 4.4 tons per year, and permitted NOX emissions will decrease by 21.1 tons per year. Process Description Leach Circuit Vanadium bearing material such as power plant ashes, refinery cokes, residues, and catalysts are used as feedstocks in the process. Fine residues are fed directly into the #5 Leach Tank (SN-27) and the #6 Leach Tank (SN-28) by blow truck and/or railcar. In the event that these tanks are offline, feedstocks can be offloaded into the Maleic Leach Circuit (SN-45) Residues (power plant ashes, refinery cokes and vanadium recovery residues) and catalysts are fed to a wet ball mill to be ground prior to leaching. Fine residues are fed to a feed storage bin prior to being slurried and sent to the leach circuits. Fine residues may be fed directly into the leach tanks or leach slurry storage tanks. Most catalysts and some residues are leached separately from the other materials. The material is leached with steam and caustic soda. An oxidant is often added to the leaching circuit. 5 Stratcor, Inc. Permit #: 0010-AR-12 AFIN: 26-00002 The leach circuit uses caustic to convert the vanadium to soluble sodium metavanadate. The leach slurry is pumped through a counter current decantation (CCD) circuit where the vanadium solution is washed from the leached solids. The washed solids are pumped to a settling pond. The drainage and runoff from this pond is then recycled to wash out more solids in the CCD circuit. The vanadium containing liquor from the CCD circuit is either pumped to a storage tank or directly to the product recovery circuit. Product Recovery Circuit Vanadium liquor from the CCD is acidified with sulfuric acid and fed to the first extraction stage of a two stage liquid-liquid ion exchange circuit. In the first stage, the vanadium is transferred into an organic phase (kerosene). The organic phase is separated from the aqueous phase by gravity. The vanadium depleted aqueous phase is sent to a raffinate thickener, where caustic is added to control metals and neutralize pH. Overflow from the thickener is sent to an effluent pond for storage and discharge. Solids from the thickener are sent back to the caustic leach circuit (described above) to recover the remaining vanadium. The organic phase is fed to a strip tank. The vanadium is stripped from the organic phase using aqueous ammonia and steam. The vanadium rich aqueous stream (strip liquor) is separated from the lean organic phase in a centrifugal type separator. The lean organic is recycled back to the extraction stage. Ammonia is added to the strip liquor in the crystallizer circuit. This converts the vanadium to ammonia metavanadate (AMV). Sulfuric acid is also added to the crystallizer circuit to decrease the solubility of the AMV. AMV crystals are removed from solution on a belt filter. Filtrate and the overflow from the crystallizer circuit are fed to the AMV thickener for additional settling. The thickener overflow is fed to a reverse osmosis unit to recover ammonia for recycle back to the crystalizers. AMV solids are dried in a rotary dryer. The AMV may be sold as product. AMV not sold as product is fed to one or two calciners. Both calciners are 30 feet in length and are indirectly fired with natural gas. The calciners have two different modes of operation. A reducing atmosphere produces vanadium trioxide (V2O3) and an oxidizing atmosphere produces vanadium pentoxide (V2O5). 6 Stratcor, Inc. Permit #: 0010-AR-12 AFIN: 26-00002 Maleic Catalyst Leach Circuit Maleic catalyst, primarily vanadyl phosphate, will be received in drums, bags, and bulk. These will be received on the concrete pad east of the new leach boiler. Bulk catalyst will be transferred pneumatically directly into the maleic catalyst tank (SN-45) while a wet scrubber is in operation. Other types of catalysts and fly ash may be slurried in this tank. The catalyst will be fed into a small hopper and directly into an elevator. The elevator will transport the material into the closed top maleic catalyst slurry tank. Oversized material will be dumped and fed into our process via the ball mill. These process emissions are also controlled by a wet scrubber. Calcium hydroxide slurry from the neutralization lime slurry tank (SN-14) will be fed to the maleic catalyst slurry tank and then agitated. The vanadyl phosphate and calcium hydroxide will react in the slurry tank to form calcium phosphate and soluble vanadium. This reaction is allowed to occur for up to 48 hours. Then the batch will be pumped through to the flexicoke leach system (SN-25 thru SN-30). Liquid Vanadium Chemicals Circuit The new circuit will utilize one 1,200 gallon reaction tank for batch preparation of both vanadyl sulfate and vanadyl oxalate, a vanadium oxide dry solids feeder, an oxalic acid feeder, and a product storage tank. The reaction tank is an agitated, closed top, fiberglass tank with a 14 inch vent. The vanadyl sulfate process involves first making a dilute sulfuric acid solution. The dilute sulfuric acid solution is heated to 75EC and then drums of vanadium oxide will be added using a dry solids