HomeMy WebLinkAbout(1) PR 14676: NEOFUELS USA, LLC & ALLY INVESTMENTS, LLC
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MEMORANDUM
To: Mayor, City Council, and City Manager
From: Mark T. Sokolow, City Attorney /~-j,_.,/ ~r~~,`~"'
Date: May 1, 2008 ~ ""'~
Subject: P. R. No. 14676; Council Meeting May 7, 2008
Attached is P. R. No. 14676 as it pertains to authorizing an
Incentive Agreement with NeoFuels USA, LLC and Ally Investments,
LLC. (Requested by Councilmember Beard).
MTS:ts
Attachment
cc: NeoFuel
Attn: Mr. Ally
Roger Mott
Director of Finance
Director of Utilities
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z.pr19696 memo
P. R. No. 14676
04/30/08 is
RESOLUTION NO.
A RESOLUTION AS IT PERTAINS TO AUTHORIZING AN
INCENTIVE AGREEMENT WITH ALLY INVESTMENTS, LLC
AND NEOFUEL USA, LLC (REQUESTED BY COIINCILMEMSER
BEARD AND COUNCILMEMBER CHATMAN)
WHEREAS, the City has received a proposal from Ally Investments,
LLC and NeoFuel USA, LLC to build a pyrolysis plant adjacent to Denbo
Avenue; and
WHEREAS, A11y Investments, LLC and NeoFuel USA, LLC have
requested incentives, which includes the waiver of building permit
fees, tap fees, and other City required fees for the new facility;
and
WHEREAS, Ally Investments, LLC and NeoFuel USA, LLC have
received a permit from the TCEQ; and
WHEREAS, the City Council wants to provide an incentive for this
development so that the pyrolysis plant will be built in such a way
that it will be conducive to orderly community redevelopment of the
West Side, will not act as a nuisance, and will be a positive
development for the area; and
WHEREAS, the proposed pyrolysis plant will create an annual
payroll of approximately $5 million in its first phase and will bring
up to 110 permanent new jobs to the City of Port Arthur.
NOW THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF PORT ARTHUR, TEXAS:
Section 1. That the facts and opinions in the preamble are
true and correct.
Section 2. That the City Manager is herein authorized to
execute the incentive agreement in substantially the same form as
denoted in Exhibit "A"
Section 3. That a copy of the caption of this Resolution be
spread upon the Minutes of the City Council.
READ, ADOPTED AND APPROVED on this day of
A.D., 2008, at a Meeting of the City Council of
the City of Port Arthur, Texas, by the following vote: AYES: Mayor
Councilmembers
NOES:
MAYOR
ATTEST:
ACTING CITY SECRETARY
APPROVED AS TO FORM:
CITY ATTORNEY
APPROVED FOR ADMINISTRATION:
CITY MANAGER
z.pr14676
EXHIBIT "A"
to the Resolution
THE STATE OF TEXAS §
COUNTY OF JEFFERSON §
INCENTIVE AGREEMENT
WHEREAS, the City of Port Arthur and NeoFuel USA, LLC and
Ally Investments, LLC desire to enter into an incentive
agreement; and
WHEREAS, Ally Investments, LLC and Neofuel USA, LLC are
herein referred to as Developer; and
WHEREAS, the Developer has indicated that it will build a
state of the art pyrolysis plant at 400 Denbo by December 31,
2009; and
WHEREAS, the Developer plans for this pyrolysis plant to be
a flagship and showpiece for the development of pyrolysis plants
nationwide; and
WHEREAS, the Developer has indicated that they will invest
from $50 million to $60 million in this plant, which will bring
in 110 permanent new jobs to Port Arthur with an annual payroll
of approximately $5 million in its first year of full operation
as delineated in their letters dated February_21, 2008 and March
7, 2008 described in Exhibits "A" and "B"; and
WHEREAS, the proposed facility will have three buildings
which will be the pyrolysis plant, office building and employee
building, as well as shield bins from public view, for the
z.incentive agreement ally and neofuel2
temporary storage of shredded tire, oil storage tanks, a
landscaped pond, parking areas and fencing surrounding the
facility.
WHEREAS, the Developer will locate the oil storage tanks at _
the rear of the property which will further provide an aesthetic
appearance for the West Side.
WHEREAS, the City Council of the City of Port Arthur
desires to provide such incentives for this pyrolysis plant as
to promote this plant being built with such safeguards as to
being conducive to the orderly development of the West Side and
prevent such plant from being an aesthetic nuisance, noise
nuisance or an environmental nuisance; and
WHEREAS, the City Council of the City of Port Arthur and
the Developer desires to promote the employment of Port Arthur
residents and contractors at the pyrolysis plant.
NOW THEREFORE, THE CITY OF PORT ARTHUR, ALLY INVESTMENTS,
LLC AND NEOFUEL USA, LLC HEREBY AGREE TO THE FOLLOWING:
Section 1. The facts and the opinions in the preamble
are true and correct.
Section 2. The Developer will provide documentation
that it has purchased the land as described in Exhibits "A" and
"B" by August 1, 2008 As part of said purchase, any and all
delinquent taxes, if any on said property, will be. paid by the
original owner or by the Developer.
z.incentive agreement ally and neofuel2
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Section 3. Once the Developer purchases the property,
the Developer will complete the design phase as to facilitate
the submittal of the designs to the City Departments for review
and inspection. The designs will facilitate the orderly
development and construction of the pyrolysis plant in
accordance with City, State and Federal guidelines and which
will be designed to avoid the plant from being an aesthetic
nuisance, noise nuisance or an environmental nuisance. Once the
designs are approved by the City, the Developer will take such
action as to maintain the progress of the construction without
delays and stoppages.
Section 4. The Developer is in the process of designing
the facility and has committed to designing the property as to
comply with all local, state and federal regulations and to
further design the property as to being aesthetic pleasing so
that it will be a show place
to the following
The Developer has further agreed
• The fapade facing Denbo on the three buildings will be
in the Mediterranean style as to stone appearance
• The area facing the railroad tracks-will also be
landscaped with a pond
• There will be minimal noise being emanated from the
premises.
• There will be minimal exhaust emissions from the.
premises as the pyrolysis operation is self contained
z.incentive agreement ally and neofuel2 7 _ ____..._
• There will be no storage areas for tires and only
shredded tires will be located on the site in four (4)
shielded bins in the rear bf the property
Section 5. The pyrolysis plant will not emit any fumes
or vapors in excess of the permitted requirements, as denoted in
the TCEQ permit attached hereto as Exhibit "C"
Section 6. The Developer herein agrees to first provide
Port Arthur residents with an opportunity to work at the plant
prior to soliciting non-residents therefore.
Section 7. The Developer agrees to provide
opportunities to Port Arthur contractors and subcontractors to
bid on or provide quotes for the building of the improvements.
Section 8. If the Developer complies with this
Agreement, the City of Port Arthur will waive any and all fees
as it pertains to building permits, water tap fees, and sewer
tap fees.
Section 9. If the Developer complies with the said
Agreement and abides by all state, local and federal laws, the
City of Port Arthur will, to the extent allowed to it under any
applicable bid laws or state laws, make available such excess
tires that the City of Port Arthur picks up from the public, as
a result of its trash pickup.
Section 10. All the Developer's books-and other records
as they pertain to emissions, as well as storm water discharges,
will be available to the City for inspection or review.
z.incentive agreement ally and neofuel2 a
Section 11. All the Developer's books and other records
as they pertain to the employment opportunities of Port Arthur
residents and contractors will be available for inspection and
review by the City. As to any documentation that the Developer
considers to be confidential, the Developer will mark the
documents as confidential that are delivered to the City, and
the City will maintain the confidentiality thereof in accordance
with the requirements of the Open Records Act. The City will
notify the Developer of any requests for information thereon as
to the documents marked confidential.
Section 12. This agreement will be construed in
accordance with the laws of Texas, as well as the Ordinances of
the City of Port Arthur.
Section 13. The venue of all causes of action will be in
Jefferson County, Texas.
Section 14. Reasonable delays not to exceed thirty (30)
days of the Incentive Agreement may be approved by the City
Manager, so long as the delays are not caused by the acts or
omissions of the Developer.
Section 15. Notice to the parties shall be as follows:
TO: CITY OF PORT ARTHUR
ATTN: Stephen Fitzgibbons
City Manager
444 Fourth Street
P. O. Box 1089
Port Arthur, TX 77641-1089
z.incentive agreement ally and neofuel2 5 _ _
TO: DEVELOPER
NEOFUEL IISA
ALLY~INVESTMENTS, LLC
ATTN: Saeed Ally, M. D.
Chief Executive Officer
2501 Jimmy Johnson Blvd., Suite 201
Port Arthur, TX 77640
Section 16. The City makes no representation as to the
marketability of said tract or the suitability of them as a
pyrolysis plant. Developer has relied on its own feasibility
studies thereon and its own inspections as to the condition and
existence of the utilities on or adjacent to the property.
Section 17: If the City does not comply with the terms
of this Agreement, then Developer may terminate this agreement
with thirty (30) days written notice. If Developer does not
comply with the terms of this Agreement, then the City may
terminate this agreement with thirty (30) days written notice.
Section 18. It is an essential term of this Agreement
that the pyrolysis plant. shall stay on the tax .rolls for a
period of twenty (20) years.
ection 19 If the Developer fails to comply with this
Agreement, then the Developer will pay all building permit fees,
water tap fees, and sewer tap fees within thirty (30) days of
notice of default, and the City will be entitled to terminate
this Agreement and seek such other remedies in law and in
z.incentive agreement ally and neofuel2 6 .,,_ .
equity, including but not limited to; seeking an injunction to
abate nuisances, civil fines and other fines, and attorney fees.
SIGNED AND AGREED TO on this the day of ,
2008.
CITY OF PORT ARTHUR
By:
STEPHEN FITZGIBBONS, CITY MANAGER
ACKNOWLEDGMENT
STATE OF TEXAS ~
COUNTY OF JEFFERSON ~
BEFORE ME, the undersigned Notary Public, on this day,
personally appeared Stephen Fitzgibbons, City Manager, known to
me to be the person whose name is described in the foregoing
instrument, and acknowledged to me that he/she executed the same
as the act and deed of the City of Port~Arthur, for the purposes
and considerations therein expressed, and the capacities therein
stated.
X
GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the day
of 2008.
Notary Public, State of Texas
z.incentive agreement ally and neofuel2 7 ~~
SIGNED AND AGREED TO on this the day of
2008.
ALLY INVESTMENTS, LLC
"DEVELOPER"
By:
(Printed Name)
ACRNOWLEDGMENT
STATE OF TEXAS ~
COUNTY OF ~
BEFORE ME, the undersigned Notary Public, on this day,
personally appeared known to me to be the person
whose name is described in the foregoing instrument, and
acknowledged to me that he/she executed the same as the act and
deed of ALLY INVESTMENTS, LLC, for the purposes and
considerations therein expressed, and the capacities therein
stated.
GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the day of
2008.
Notary Public, State of Texas
z.incentive agreement ally and neofuel2 8
SIGNED AND AGREED TO on this the day of ,
2008.
NEOFUEL USA, LLC
"DEVELOPER"
By:
(Printed Name)
ACKNOWLEDGMENT
STATE OF TEXAS §
COUNTY OF §
BEFORE ME, the undersigned Notary Public, on this day,
personally appeared known to me to be the person
whose name is described in the foregoing instrument, and
acknowledged to me that he/she executed the same as the act and
deed of NEOFUEL USA, LLC for the purposes and considerations
therein expressed, and the capacities therein stated.
GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the day of
2008.
Notary Public, State of Texas
z.incentive agreement_a11y and neofuel2 9 _, _,_„-_,I
EXHIBIT "A"
to the Agreement
-:. ~ ~
ALLY INVESTMENTS, LLC
February Zl, 2008
Mr. Steve Fitzgibbons, City Manager
City of Port Arthur _
City Hall , : ,;i
P.O. Box 1089
Port Arthur, Texas 77641- 1089
Re: NeoFuels USA, LLC
Dear Steve:
Pursuant to our conversations regarding our pyrolysis plant being built in Port Arthur, I
wanted to share a few facts about the project, as well as a few requests. NeoFuels USA plans to
build the first pyrolysis plant in the United States at 400 Denbo, as a major addition to the
Westend Development Project. This facility will require an initial investment of $50 million to
$60 million, while bringing 110 permanent new jobs to Port Arthur, with an annual payroll of
approximately $S million in its first phase. These numbers do not reflect the construction jobs
and construction payroll created over the next year. We expect to have the plant operational
prior to year end.
I am requesting the City of Port Arthur give favorable consideration to the following:
1) Waive all building permit fees, tap fees, and other city required fees for a new facility.
2) 'An exclusive contract for all scrap tires generated by the city, including all tires presently
stored in landfills under the City's jurisdiction.
3) Access to free advertising on the City owned television channel.
4) The City to create a monthly roundup to gather all scrap tires in and around the city,
including unincorporated areas contiguous to Port Arthur, which may affect the health
of the citizens of Port Arthur.
2501 Jimmy Johnson Blvd., Suite 201
Port Arthur, TX 77640
409J22.4001
409.722.4010 Fax
ALLY INVESTMENTS, r,Lc
Again, it has been a pleasure visiting with you regarding this exciting "green project",
which has zero emissions or pollutants. I think you will agree that this plant will showcase Port
Arthur as manufacturers, environmentalists, and retailers from around the world come to the
city to study the plant, the process, and this exciting new facility, which has such great
economic benefits to Port Arthur and environmental benefits to our region. I shall anxiously
await additional information from your office, as well as our next visit. In the interim, if I may be
of assistance or should you have any questions, please contact me at your earliest convenience.
Respectfully yours,
~J~
Saeed A. Ally, M.D.
Chairman and CEO
2501 Jimmy Johnson Bivd., Suite 201'
POrt Arthur, TX 77640
409.722.4001
409.722.4010 Fax
EXHIBIT "B"
to the Agreement
- ~ ®USA
{? U
2501 ,Jimmy Johnson Blvd.,$uite 201 ^ Pt. Arthur, TX 77640, ^ (409)-722-4001
March 7, 2008
Mr. Steve Fitzgibbons, City Manager
City of Port Arthur
City Hall
P.O. Box 1089
Port Arthur, Texas 77641 - 1089
Re: NeoFuels USA, LLC
Dear Steve:
I would like to address the two concerns of the City Council namely the issues regarding
emissions from the plant and the storage of tires on the facility. Regarding the former, the
plant and process produces no significant emissions and we are permitted by the TCEQ as such.
I have attached excerpts of the permit for your review.
Regarding the latter, the Neofuel plant will process 12 million tires per year. We will
have enclosed storage sheds for our feedstock. Given the high volume of tires to be processed,
eve will not have any significant volume of storage tires at the site. In addition, vde have a
separate staging site, away from the plant, that will be used for long term storage, if needed. I
have attached a copy of the plant layout with the storage facility outlined.
Thank you for your help.
Respectfully yours,
/~
Saeed A. Ally, M.D.
Chairman and CEO
EXHIBIT "C"
to the Agreement
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NQV~II.
GroupWise WebPublisher
Sectioaa I -Document
SPECIAL CONDITIONS
Permit Number 81058
GENERAL
1. This permit authorizes a Tire Recycling facility at 400 Denbo Avenue in Port Arthur, Texas.
The permit application and this permit authorizes normal operations including planned startup and
shutdown emissions only. Maintenance activities were not represented and are not authorized by
this permit.
EMISSION STANDARDS
2. SOZ emissions from the scrubber, EPN WSCB-1 shall not exceed 60 ppmv. Scrubbing liquid
level in the reservoir and pH of the scrubbing liquid shall be monitored to ensure proper scrubber
operation. Scrubbing liquid shall be maintained in a pH range of 9 to 11.
3. NOx emissions from the Reactor and Thermal Oxidizer, EPN WSCB-1 shall not exceed 150
ppmvd corrected to 7 percent oxygen. If the initial compliance test required by Special Condition
No. 12 demonstrates that the NOx emissions are less than 100 ppmvd, the permit will be altered to
reduce the allowable NOx emissions.. The adjustment shall consider the results of the stack testing
and the potential for data variability.
4. Except for those periods described in Title 30 Texas Administrative Code §§ 101.201 and 211
(30 TAC §§ 101.201 and 211), opacity of particulate matter emissions from point sources shall
not exceed five percent. This determination shall be made first by observing for visible
emissions. Observations shall be made at least 15 feet and no more than 0.25 mile from the
source. If visible emissions are observed ,then opacity shall be determined by Title 40 Code of
Federal Regulations Part 60 (40 CFR Part 60), Appendix A, Test Method 9. For all. sources no
visible emissions shall be observed crossing the property line as determined by 40 CFR Part 60,
Appendix A, Test Method 22. Contributions from uncombined water shall not be included in
determining compliance with this condition. Observations shall be performed and recorded
quarterly.
OPERATIONAL LIMITATIONS
5. The tire recycling facility shall be limited to processing 150 tons per day (TPD) of tire chips in , ;_ -
the reactor. ' ' -`
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6. Carbon black emissions From the carbon black bagging, metals removal system and carbon
conveying vents shall be exhausted through a baghouse with an outlet grain loading of no more
than 0.01 grain per standard cubic feet and maximum design capacity of 18,850 cubic feet per
minute air flow rate.
7. Fuels for the reactor and thermal oxidizer shall be syngas produced by the reactor or pipeline-
quality, sweet natural gas. Use of any other fuel requires prior approval of the Executive Director
of the TCEQ.
8. The thermal oxidizer shall operate at a minimum temperature of 1450°F averaged over a rivo
hour period. A temperature monitor shall be installed, calibrated, and maintained to measure and '
record temperature of the_ combustion chamber of the RTO when syngas is being routed to the
oxidizes
9. Oxidizer operating instructions shall be established and posted near the oxidizer controls such -
that they are available for all oxidizer operators. The posting shall be such that all instructions are
readily understandable by all operators.
10. All conveyors shall be covered or enclosed, as represented in the application, to minimize
fugitive particulate emissions. If visible emissions problems occur, additional controls may be
required. Coverings and enclosures are considered abatement equipment, and shall be kept in
good repair.
INITIAL DEMONSTRATION OF COMPLIANCE
11. Sampling ports and platform(s) shall be incorporated into the design of EPN WSCB-1
according to the specifications set forth in the attachment entitled "Chapter 2, Stack Sampling
Facilities" of the Texas Commission on Environmental Quality (TCEQ) Sampling Procedures
Manual. Alternate sampling facility designs must be submitted for approval to the TCEQ
Regional Manager or the TCEQ Office of Compliance and Enforcement, Compliance Support
Division.
12. The permit holder shall perform stack sampling and other testing as required to establish the
actual pattern and quantities.of air contaminants being emitted into the atmosphere from EPN
WSCB-I to demonstrate compliance with the MAERT. The permit holder is responsible for
providing sampling and testing facilities and conducting the sampling and testing operations at his
expense. Sampling shall be conducted in accordance with the appropriate procedures of the Texas
Commission on Environmental Quality (TCEQ) Sampling Procedures Manual and the U.S.
Environmental Protection Agency (EPA) Reference Methods.
Requests [o waive testing for any pollutant specified in this condition shall be submitted to the
TCEQ Office of Permitting, Remediation, and Registration, Air Permits Division.
A. The Beaumont Regional Office shall be notified not less than 45 days prior to sampling.
The notice shall include:
(1) Proposed date for pretest meeting.
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(2) Date sampling will occur.
(3) Name of fum conducting sampling.
(4) Type of sampling equipment to be used.
(5) Method or procedure to be used in sampling.
(6) Description of any proposed deviation from the sampling procedures specified in this
permit or TCEQ/EPA sampling procedures.
(7) Procedure/parameters to be used to determine worst case emissions during the sampling
period.
The purpose of the pretest meeting is to review the necessary sampling and testing
procedures, to provide the proper data forms for recording pertinent data, and to review the
format procedures for the test reports. The TCEQ Regional Director or the TCEQ Office of
Compliance and Enforcement (OCE), Compliance Support Division must approve any
deviation from specified sampling procedures.
B. Air contaminants emitted from EPN WSCB-1 to be tested for include (but are not limited
to) NOX, CO and SO2.
C. Sampling shall occur within 60 days after achieving the maximum operating rate, but no
later than 180 days after initial start-up of the facilities and at such other times as may be
required by the TCEQ Executive Director. Requests for additional time to perform
sampling shall be submitted to the appropriate regional office.
D. The facility being sampled shall operate at as close to the maximum production rate of
150 TPD of tire chips to the reactor as can be accomplished on the day of testing. If the
maximum production rate is not achieved during this initial test, production rate will be
limited to the tested rate until additional testing demonstrates compliance with the permit at
the maximum production rate. This parameter and any other primary operating parameters
that affect the emission rate shall be monitored and recorded during the stack test. Any
additional parameters shall be determined at the pretest meeting and shall be stated in the
sampling report. Permit conditions and parameter limits maybe waived during stack testing
performed under this condition if the proposed condition/parameter range is identified in the
test notice specified in paragraph A and accepted by the TCEQ Regional Office.
E. Copies of the final sampling report shall be forwarded to the offices below within
60 days after sampling is completed. Sampling reports shall comply with the attached
provisions entitled "Chapter 14, Contents of Sampling Reports" of the TCEQ Sampling
Procedures Manual. The reports shall be distributed as follows:
One copy to the appropriate TCEQ Regional Office:
One copy to the TCEQ OCE, Compliance Support Division, Austin.
SAMPLING/TESTING
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13. The oil tanks shall vent through a carbon adsorption system (CAS) consisting of at least two
activated carbon canisters that are connected in series.
A. The CAS shall be sampled to determine breakthrough. of volatile organic compounds
(VOC). Sampling shall be accomplished twice weekly until the VOC concentration reaches
80 ppmv and then the frequency shall be every two days until the VOC concentration
reaches 95 ppmv. After at least three canisters have been replaced a revised sampling
schedule can be requested based upon the time and or oil production that can best predict
the breakthrough.
B. The VOC sampling and analysis shall be performed using an instrument with a flame
ionization detector (FID), or a TCEQ-approved alternative detector. The instrument/FID
must meet all requirements specified in Section 8.1 of EPA Method 21 (40 CFR 60,
Appendix A). Sampling and analysis for VOC breakthrough shall be performed as follows:
(1) Immediately prior to performing sampling, the instrument/FID shall be calibrated with
zero and span calibration gas mixtures. Zero gas shall be certified to contain less than 0.1
ppmv total hydrocarbons. Span calibration gas shall be methane at a concentration within t
10 percent of 100 ppmv, and certified by the manufacturer to be f 2 percent accurate.
Calibration error for the zero and span calibration gas checks must be less than t 5 percent
of the span calibration gas value before sampling may be conducted.
(2) The sampling point shall be at the outlet of the initial canister but before the inlet to the
second or final polishing canister. Sample ports or connections must be designed such that
air leakage into the sample port does not occur during sampling.
(3) During sampling, data recording shall not begin until after two times the instrument
response time. The VOC concentration shall be monitored for at least 5 minutes, recording
1-minute averages, during truck loading.
C. Breakthrough shall be defined as the highest 1 minute average measured VOC
concentration at or exceeding100 ppmv. When the condition of breakthrough of VOC from
the initial saturation canister occurs, the waste gas flow shall be switched to the second
canister and afresh canister shall be placed as the new final polishing canister within 24
hours. Sufficient new activated carbon canisters shall be maintained at the site to replace
spent carbon canisters such that replacements can be done in the above specified time
frame.
D. Records of the CAS monitoring maintained at the plant site, shall include (but are not
limited to) the following:
(1) Sample time and date.
(2) Monitoring results (ppmv).
(3}Corrective action taken including the time and date of that action.
(4) Process operations occurring at the time of sampling.
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E. Alternate monitoring or sampling requirements that are equivalent or better may be
approved by the TCEQ Regional Manager or the TCEQ Regulatory Compliance Section
Manager. Alternate requirements must be approved in writing before they can be used for
compliance purposes.
14. A copy of this permit and the initial sampling report shall be kept at the plant site and be made
available. at the request of personnel from the TCEQ or any air pollution control agency with
appropriate jurisdiction for the life of the permit.
15. The following documentation and records shall be made and kept at a minimum on a rolling
24-month basis and shall be used to demonstrate compliance with the special conditions and the
MAERT '
A. Material Safety Data Sheets for the catalyst used to enhance the reaction in the reactor.
B. Records of visible emissions observations made and Method 9 opacity observations
conducted in accordance with Special Condition No. 3 must be created in accordance the
test methods and must be maintained on-site for at least two years from the date of the
observation. Visible emissions observation documentation shall include at a minimum, the
date, time and findings of the observation.
C. Records of oil and carbon black production.
D. Records of carbon canister testing and canister replacement.
E. Records of pH monitoring and scrubbing liquid level.
F. Records of fire chips processed to demonstrate compliance with the limits in Special
Condition No. 5.
G. Records ofthermal oxidizer temperature to demonstrate compliance with the combustion
chamber temperature limit in Special Condition No. 8.
GOOD INDUSTRIAL HOUSEKEEPING
16. Equipment covered by this permit shall be operated and maintained in accordance with the
manufacturer's instructions.
17. All permanent in-plant roads and parking areas shall be watered or paved and cleaned, as
necessary, to insure no visible emissions are observed leaving the plant boundary.
Dated August 10.2007
o-
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Headers
SPECIAL CONDITIONS
Permit Number 81058
Page
SPECIAL CONDITIONS
Permit Number 81058
Page
Published by GroupWise
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