Loading...
HomeMy WebLinkAboutAQ_F_3200251_20210427_PRMT_PmtRvwNORTH CAROLINA DIVISION OF AIR QUALITY Application Review Issue Date: 04/27/2021 Facility Data Applicant (Facility's Name): North Carolina Central University Facility Address: North Carolina Central University 1801 Fayetteville Street Durham, NC 27707 SIC: 8221 / Colleges And Universities, Nee NAICS: 61131 / Colleges, Universities, and Professional Schools Facility Classification: Before: Synthetic Minor After: Synthetic Minor Fee Classification: Before: Synthetic Minor After: Synthetic Minor Facility Contact Carl Locus Director of Utilities (919) 530~7282 1801 Fayetteville Street Durham, NC 27707 Contact Data Authorized Contact Carl Locus Director of Utilities (919) 530-7282 1801 Fayetteville Street Durham, NC 27707 Review Engineer: Mary Rose Fontana Technical Contact Carl Locus Director of Utilities (919) 530-7282 1801 Fayetteville Street Durham, NC 27707 Region: Raleigh Regional Office County: Durham NC Facility ID: 3200251 Inspector's Name: Lisa Whitaker Date of Last Inspection: 08/07/2019 Compliance Code: 5 / In Physical Compliance Permit Applicability (this application only) SIP: NSPS: NESHAP: PSD: PSD Avoidance: NC Toxics: 112(r): Other: Application Data Application Number: 3200251.21A Date Received: 11/12/2021 Application Type: Modification Application Schedule: State Existing Permit Data Existing P~rmit Number: 08512/R08 Existing Perm it Issue Date: 02/24/2017 Existing Permit Expiration Date: 01/31/2025 Comments I Recommendations: Issue 08512/R09 Permit Issue Date: 04/27 /202 l Permit Expiration Date: 01/31/2025 1. Purpose of Application: North Carolina Central University is a four-year degree University with on campus housing and classrooms that has boilers and generators. The purpose of this application is to add four (4) natural gas-fired boilers and four (4) diesel- fired emergency generators. 2. Application Chronology: November 12, 2020 Linda Lamb, PE, Principal Professional for Kleinfelder, emailed Dena Pittman, Permit Coordinator, an unsigned PDF copy ofNCCU's permit application. Ms. Lamb sent a copy of the toxics modeling directly to Tom Anderson, AQAB, for review. This application January 14, 2021 contained the necessary forms modeling analysis, zoning consistency determination, and supporting calculations. It did not include the $400 application fee nor the signature of the authorized official. An acknowledgement letter was sent noting the items required for completion. Mark Yoder, Meteorologist, AQAB, reached out to Linda Lamb about some inconsistencies with the toxics modeling for this application. Ms. Lamb said she would correct and resubmit the modeling. Page 1 of 11 January 15, 2021 January 22, 2021 January 25, 2021 January 27, 2021 January 28, 2021 February 3, 2021 February 9, 2021 March 8, 2021 March 9, 2021 I, Mary Rose Fontana Lee, emailed Ms. Lamb to follow-up on the hard copy of the application. She said that Kleinfelder already sent the application to NCCU to sign and submit to DAQ. She also said that she would reach out to NCCU and let me know where the application is. I reached back out to Ms. Lamb to inquire about the application fee, which has also not arrived to RRO. Ms. Lamb said that she spoke to the campus facilities manager, Carl Locus, and he does not remember receiving or signing a hard copy of the application. Mr. Locus is checking the mail room at NCCU to see if it was misplaced over the holiday season. Ms. Lamb emailed me that the facility manager found the package that Kleinfelder sent to NCCU containing the hard copy of the application. He said they would send the signed application and the check shortly. AQAB received the updated toxics dispersion modeling. Mr. Locus called Ms. Pittman and left a message requesting DAQ send NCCU an invoice for the application fee. I emailed Mr. Locus to let him know that we were waiting for the DEQ business office to confirm the details of the invoice prior to sending it to NCCU. I emailed Mr. Locus the invoice for the application fee. He said he would start that process today. I emailed Mr. Locus to follow-up on the submittal of the signed application and fee. I also informed him of the ePayment option. He told me that it is "in the system," and that they are trying to get it pushed along. I followed-up with Mr. Locus about the status of the application and fee. He said that he has the $400 check and asked if he could mail or hand-deliver the check to DAQ. I told him that either option is acceptable, and I informed him of the current policy for visiting the DAQ Office. We also clarified what information was still needed from NCCU for completing and submitting the application. Mark Yoder emailed RRO the toxics dispersion modeling review memo. RRO received. the completed signed hard copy of the application and the $400 check (#300779). This action started the clock for this application. 3. New Equipment/Change in Emission and Reguiatory Review: New Equipment: The following sources were added during this application: Emission Emission Source Control Control System Source ID Description System ID Description Boilers ES-B15 2.0 million BTU per hour natural gas-fired boiler NIA NIA (Farrison Newton Communications Building) ES-Bl6 0.75 million BTU per hour natural gas-fired boiler NIA NIA (Edwards Music Hall) ES-B17 0.75 million BTU per hour natural gas-fired boiler NIA NIA (Fine Arts Building) ES-Bl8 0.25 million BTU per hour natural gas-fired boiler NIA NIA (Art Museum) Page 2 of 11 Emission Emission Source Control Control System Source ID Description System ID Description Emergency Generators ES-EG28 154 kilowatt diesel-fired emergency generator NIA NIA (NSPS,NESHAP) (Chidley South Residence Hall) ES-EG29 154 kilowatt diesel-fired emergency generator NIA NIA (NSPS,NESHAP) (George Street Residence Hall) ES-EG30 154 kilowatt diesel-fired emergency generator NIA NIA (NSPS,NESHAP) (Lawson Street Residence Hall) ES-EG3 l 505 kilowatt diesel-fired emergency generator NIA NIA (NSPS,NESHAP) (New Student Center) Regulatory review: • 2D .0503: Particulate Control Requirements For Fuel Burning Indirect Heat Exchangers The four (4) new boilers are subject to this condition. The allowable emissions of particulate matter shall be calculated by the equation: E = 1.090 * Q -0·2594 Where "E" equals the allowable emission limit for particulate matter in lb/million Btu, and "Q" equals the maximum heat input in million Btu/hour. The maximum heat input for this equation is the sum of the maximum heat input of all fuel burning indirect heat exchang~rs at the facility. With the addition of these four (4) sources? Q = 172.65 million Btu/hour. The emission limits for the new boilers are as follows: Source Emission Limit (lbs/million Btu) 2.0 million BTU per hour natural gas-fired boiler (Farrison 0.286 Newton Communications Building) (ID No. ES-B 15) 0.75. million BTU per hour natural gas-fired boiler (Edwards 0.286 Music Hall) (ID No. ES-B16) 0.75 million BTU per hour natural gas-fired boiler (Fine Arts 0.286 Building) (ID No. ES-B 17) 0.25 million BTU per hour natural gas-fired boiler (Art 0.286 Museum) (ID No. ES-Bl8) Compliance with this regulation is expected and will be confirmed during inspections. • 2D .0516: Sulfur Dioxide Control Requirement The four ( 4) new boilers and four ( 4) new emergency generators are subject to this condition. Sulfur dioxide emissions from combustion sources shall not exceed 2.3 pounds per million Btu heat input. Since the new boilers are natural gas-fired only, and natural gas is inherently low in sulfur, they meet this emission limit. The emergency generators are required to operate using ultra low sulfur diesel, which also meets the emission limit. Compliance is expected and will be confirmed during inspections. • 2D .0521: Visible Emissions Control Requirement The four (4) new boilers and four (4) new emergency generators are subject to this condition. Visible emissions from these sources shall not be more than 20 percent opacity when averaged over a six-minute period. Compliance with this condition will be determined during inspections. • 2D .0524: NSPS Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (CI ICE), Emergency Engines Only This condition is applicable to the four (4) new diesel-fired emergency generators. The Permittee shall comply with all applicable provisions, including the notification, testing, reporting, record keeping, and monitoring requirements contained in 40 CFR 60, Subpart IIII. Compliance with this condition will be determined during inspections. Page 3 of 11 • 2D .0540: Fugitive Dust Control ~equirement This condition is applicable to the facility. The Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. Compliance with this condition will be determined during inspections and potential complaint investigations. • 2D .1100: Toxic Air Pollutant Emissions Limitation And Reporting Requirement This condition is app,Iicable to each new source. Details regarding this condition are provided in Section 5. Compliance with this condition is expected and will be confirmed during inspections. • 2D .1111: NESHAP Subpart ZZZZ, Maximum Achievable Control Technology for Stationary Reciprocating Internal Combustion Engines This condition is applicable to the four (4) new diesel-fired emergency generators. The Permittee shall meet the requirements of 40 CFR 63 Subpart ZZZZ by meeting the requirements of 40 CFR 60 (NSPS) Subpart IIII. Compliance with this condition will be determined during inspections. • 2D .1806: Control and Prohibition of Odorous Emissions This condition is applicable to the facility. The Permittee shall not operate the facility without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. Compliance with this condition will be determined during inspections and potential complaint investigations. • 20 .0315: Limitation to Avoid ISA NCAC 2Q .0501 This condition is applicable to the facility. As previously requested by the Permittee, facility-wide emissions for each SO2 and NOx shall be limited to 100 tons per consecutive 12-month period. However, a change in NC DAQ sulfur content requirements for fuel oil combustion has reduced the Title V Potential Emissions for SO2 to below 100 tons per year. Therefore, the facility is no longer limited by SO2 emissions. The Permittee shall still comply with all applicable provisions to remain below I 00 tons NOx per year, including the operation, reporting, and record keeping requirements contained in this stipulation. Operation restrictions and corresponding reporting and record keeping requirements for facility SO2 emissions were removed with this permit revision. Compliance with this condition will be determined during inspections. See Section 7 for emissions calculations. • 20 .0317: Limitation to Avoid 15A NCAC 2Q .0530 "Prevention of Significant Deterioration" This condition is no longer applicable to the facility. As previously requested by the Permittee, facility- wide emissions for SO2 would be limited to 250 tons per consecutive 12-month period. However, a change in NC DAQ sulfur content requirements for fuel oil combustion has reduced the Title V Potential Emissions for SO2 to below 100 tons per year. This condition was removed with this permit revision. See Section 7 for emissions calculations. • 20 .0711: Toxic Air Pollutant Emissions Limitation Requirement This condition is applicable to the facility. For each of the toxic air pollutants(_ I APs) listed below, the Permittee has demonstrated that facility-wide actual emissions, where one or more emission release points are obstructed or non-vertically oriented, do not exceed the TPERs listed in 2Q .071 l(a). Pollutant IAcetaldehyde (75-07-0) IAcrolein (107-02-8) Benzo(a)pyrene (Component of 83329/POMTV & 56553/7PAH) (50-32-8) IButadiene, 1,3-(106-99-0) !Hexane, n-(110-54-3) !Manganese & compounds (MNC) Carcinogens (lb/yr) 2.2 11 Page 4 of 11 Chronic Toxicants (lb/day) 23 0.63 Acute Irritants (lb/hr) 6.8 0.02 I Pollutant I Carcinogens ! Chronic Toxicants I Acute Irritants (lb/yr) (lb/day) (lb/hr) !Methyl chloroform (71-55-6) I I 250 I 64 !Nickel metal (Component ofNIC) (7440-02-0) I I 0.13 I !Toluene (108-88-3) I I 98 I 14.4 jxylene (mixed isomers) (1330-20-7) I I 57 I 16.4 Mercury, vapor (Component of HGC) (7439-97-6) and Chromium (VI) Soluble Chromate Compounds (Component of CRC) (SolCR6) were removed from this table with this application, as they are now emitted above the TPERs in 2Q .071 l(a) and are included in the stipulation for Rule 2D .1100. Further details regarding this condition are provided in Section 5. Compliance with this condition will be determined during inspections. Emissions review: Unlike other emergency generators at the facility, the new emergency generator toxics emissions were calculated assuming 500 hours per year. Therefore, the new sources do not have any operation limits to remain in compliance with their emission limits. The new emission sources have the following potential emissions. New Source Potential Emissions (tpy) ~ Pollutant ES-ES-ES-ES-ES-ES-ES-ES-Total B158 B168 B178 B188 EG28b EG29b EG30b EG31c Emissions PM 0.00 0.00 0.00 0.00 0.13 0.13 0.13 0.13 0.53 PMl0 0.00 0.00 0.00 0.00 0.13 0.13 0.13 0.13 0.53 SO2 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.01 NOx 0.86 0.32 0.32 0.11 1.82 1.82 1.82 4.62 11.68 voe 0.05 0.02 0.02 0.01 0.15 0.15 0.15 0.26 0.79 co 0.72 0.27 0.27 0.09 0.39 0.39 0.39 1.06 3.59 Notes: a) Boiler emissions calculations assume no controls for NOx emissions. Emissions were calculated using NC DAQ Spreadsheet for Natural Gas Combustion (Rev. N). b) Emergency generator (ID Nos. ES-EG28 -ES-EG20) calculations assume 500 hours of operation per year. Emissions were calculated using NC DAQ Spreadsheet for Small (<600 hp) Diesel-Fired Engines (Rev. S). c) Emergency generator (ID No. ES-EG31) calculations assume 500 hours of operation per year. Emissions were calculated using NC DAQ Spreadsheet for Large (>600 hp) Diesel-Fired Engines (Rev. J). See Section 7 for details on facility-wide Permit Potential and Title V Potential Emissions. 4. NSPS, NESHAPS, PSD, 112(r), and Attainment Status: NSPS: • Subpart 1111, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines is applicable to ES-EG21, ES-EG22, ES-EG23, ES-EG24, ES-EG25, ES-EG27, ES-EG28, ES-EG29, ES- EG30, and ES-EG3 l. • Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Combustion Engines is applicable to ES-EG26. • Subpart De is applicable to the natural gas/No. 2 fuel oil-fired boilers (ID Nos. ES-81, ES-82a, and ES- B3a). Page 5 of 11 NESHAP: • Subpart JJJJJJ (6J) is applicable to the natural gas/No. 2 fuel oil fired boilers. The facility has chosen to avoid this condition by only using No. 2 fuel oil during times of gas curtailment, gas supply interruptions, startups, or for periodic testing. • Subpart ZZZZ is applicable to all generators. Generators subject to NSPS Subparts 1111 and JJJJ must meet those requirements in order to be in compliance with Subpart ZZZZ. Since this an institutional facility, the remaining existing emergency generators are avoiding this condition. This facility is now a PSD minor source for criteria pollutants. The facility is not subject to l 12(r). Durham County is in attainment. 5. Facility Wide Air Toxics: The addition of four (4) natural gas-fired boilers and four (4) diesel-fired emergency generators triggered a toxics modeling review for this facility. Typically, natural gas-fired boilers and small diesel-fired emergency generators would not trigger toxics modeling, as they are insignificant sources. Since these sources emit toxic air pollutants that were already modeled for this facility (see 2Q .0102(b)(2)), and the diesel-fired emergency generators have the potential to present an unacceptable risk to human health based on the acceptable ambient levels (AALs) in 2D .1104 (see 2Q .0702(a)(27)(B), 2Q .0702(b), and 2Q .0712), an updated toxics dispersion modeling analysis was required for this application, and these sources are no longer considered exempt from permitting. The inclusion of these eight (8) new sources shows that Mercury, vapor (Component of HOC) (7439-97-6) and Chromium (VI) Soluble Chromate Compounds (Component of CRC) (SolCR6) now emit from the facility above the TPERs in 2Q .071 l(a). As a result, they were included as pollutants in the toxics dispersion modeling demonstration and were removed from the table provided in the stipulation for Rule 2Q .071 1. The modeling was initially received on November 12, 2020. A revision was submitted on January 25, 2021. Table 5- 1 provides the modeled emission rates of each TAP that exceeds the corresponding Toxic Permit Emission Rate (TPER) listed in 2Q .071 l(a) emitted from each permitted source. At least one or more of the emission release points at this facility are either obstructed or non-vertically oriented. Table 5-2 lists the emission rate limits of each TAP per permitted source, which is calculated by scaling up the modeled data in Table 5-1 by multiply 8760 hours/year for pollutants with yearly limits or 24 hours/day for pollutants with daily limits. Pollutants with hourly limits remained unchanged from the value listed in Table 5-1. The TPER limits for each emission source are provided in the emission rate unit stipulated in Rule 2Q .0711. More details about how these values were calculated is described in the memo from AQAB on March 8, 2021. Page 6 of 11 Table 5-1. Point Source Modeline: TAPs Emission Rates Fmission Rate (]b/hr} Modeling Source ID Arsenic Benzm.e Beryllimn Cadmimn Chromium (VI} Flourides Fmmaldehyde Men::my Bl 2.89E-04 L42E-03 2.17E-04 2.17E-04 2.17E-04 L92E-02 2.48E-02 2.17E-04 B2 3.00E-04 L47E-03 2.25E-04 225E-04 225E-04 2.00E-02 2.57E-02 2.25E-04 B3 8.40E-05 4.13E-04 6.30E-05 630E-05 6.30E-05 5.60E-03 720:E:-03 6.30E-05 B4 -7.41E-06 ----2.65E-04 - BS -U0E-05 ----4.63E-04 - B6 -138E-05 ----5.51E-05 - B7 -L38E-05 ----4.93E-04 - B11 -L38E-05 ----4.93E-04 - B13 -4.12E-06 ----L47E-04 - B14 -4.12E-06 ----L47E-04 - B15 -4.12E-06 ----L47E-04 - B16 -L54E-06 ----5.SIE-05 - B17 -L54E-06 ----5.SIE-05 - B18 -5.15E-07 ----L84E-05 - EGl L88E-06 220E-05 L41E-06 L41E-06 L41E-06 -5.54E-04 L41E-06 EG2 L31E-05 L54E-04 9.86E-06 9.86E-06 9.86E-06 -3.88E-03 9.86E-06 EG3 5.67E-06 6.64E-05 4.25E-06 4.25E-06 425E-06 -l.67E-03 4.25E-06 EG4 2.82E-06 330E-05 2.llE-06 2.l .E-06 2.llE-06 -831E-04 2.llE-06 EGS 2.82E-06 330E-05 2.llE-06 2.llE-06 2.llE-06 -8.31E-04 2.llE-06 EG6 9.39E-07 U0E-05 7.04E-07 7.04E-07 7.04E-07 -2.77E-04 7.04-E-07 EG7 Ll3E-06 L32E-05 8.45E-07 8.45E-07 8.45E-07 -3.32E-04 8.45E-07 EG8 2.82E-06 6.56E-06 2.llE-06 2.llE-06 2.llE-06 -8.31E-04 2.llE-06 EG9 7.SIE-07 8.SOE-06 5.63E-07 5.63E-07 5.63E-07 -222E-04 5.63E-07 EG12 5.63E-06 6.60E-05 4.22E-06 4.22E-06 422E-06 -L66E-03 4.22E-06 EG13 2.60E-05 2.88E-04 L95E-05 L95E-05 L95E-05 -5.13E-04 L95E-05 EG18 6.40E-05 624E-04 4.S0E-05 4.S0E-05 4.S0E-05 -126E-03 4.SOE-05 EG15 -5.0lE-08 ----3.14E-05 - EG16 L88E-06 220E-05 L41E-06 L41E-06 L41E-06 -5.54E-04 L4lE-06 EG17 L31E-05 L32E-05 8.45E-07 8.45E-07 8.45E-07 -3.32E-04 8.45E-07 EG19 3.75E-07 4.40E-06 2.82E-07 2.82E-07 2.82E-07 -LllE-04 2.82E-07 EG20 5.82E-06 4.45E-05 4.37E-06 4.37E-06 4.37E-06 -L72E-03 4.37E-06 EG21 6.40E-05 7.09E-04 4.SOE-05 4.80E-05 4.S0E-05 -126E-03 4.S0E-05 EG22 9.95E-06 Ll7E-04 7.46E-06 7.46E-06 7.46E-06 -2.94E-03 7.46E-06 EG23 5.07E-06 3.89E-05 3.80E-06 3.80E-06 3.S0E-06 -LS0E-03 3.S0E-06 EG24 l.31E-06 L54E-05 9.86E-07 9.86E-07 9.86E-07 -3.88E-04 9.86E-07 EG25 9.95E-06 Ll7E-04 7.46E-06 7.46E-06 7.46E-06 -2.94E-03 7.46E-06 EG26 -5.0IE-08 ----3.76E-05 - EG27 6.57E-06 7.70E-05 4.93E-06 4.93E-06 4.93E-06 -L94E-03 4.93E-06 EG28 5.78E-06 7.70E-05 4.34E-06 4.34E-06 4.34E-06 -L71E-03 4.34E-06 EG29 5.78E-06 7.70E-05 4.34E-06 4.34E-06 4.34E-06 -L71E-03 4.34E-06 EG30 5.78E-06 7.70E-05 4.34E-06 434E-06 4.34E-06 -L71E-03 4.34E-06 EG31 2.15E-05 239E-04 L62E-05 L62E-05 L62E-05 -4.25E-04 L62E-05 Page 7 of 11 Table 5-2. Permitted Emission Rate Limits Emission Rate (in TPER unit) • Modding Arsenic Bmzm.e B~Uium Calmium Chromium Flourides F ormaldeb.yde Mmmy SourceID (VI) (lb/yr) (lb/yr) (lb/yr) (lb/yr) (lb/day) (lb/day) (lb/hr) (lb/day) Bl 2.53 12.44 1.90 1.90 5.21E-03 0.46 2.48E-02 5.21E--03 B2 2.63 12.88 191 1.97 5.40E-03 0.48 2.57E-02 5.40E--03 B3 0.74 3.62 0.55 0.55 l.51E-03 0.13 720E--03 l.51E--03 B4 -6.49E-02 ----2.65E-04 - B5 -0.11 ----4.63E-04 - B6 -0.12 ----5.51E-05 - B7 -0.12 ----493E-04 - Bll -0.12 ----4.93E-04 - B13 -3.61E-02 ----l.47E-04 - B14 -3.61E-02 ----l.47E-04 - Bl5 -3.61E-02 ----l.47E-04 - B16 -135E-02 ----5.51E-05 - B17 -135E-02 ----5.51E-05 - Bl8 -4.51E-03 ----l.84E--05 - EGI l.65E-02 0.19 124E--02 1.24E-02 3.38E-05 -5.54E-04 3.38E--05 EG2 0.11 135 8.64-E--02 8.64-E-02 2.37E-04 -3.88E-03 2.37E--04 EG3 0.05 0.58 3.72E--02 3.72E-02 l.02E-04 -1.67E-03 1.02E--04 EG4 2.47E-02 ·029 1.85E--02 1.85E-02 5.06E-05 -831E-04 5.06E--05 EG5 2.47E-02 029 1.85E--02 1.85E-02 5.06E-05 -831E-04 5.06E--05 EG6 823E-03 0.10 6.17E--03 6.17E-03 1.69E-05 -2.77E-04 l.69E--05 EG7 9.90E-03 0.12 7.40E-03 7.40E-03 2.03E-05 -332E-04 2.03E--05 EG8 2.47E-02 5.75E-02 1.85E--02 1.85E-02 5.06E-05 -831E-04 5.06E--05 EG9 6.58E-03 7.71E-02 493E--03 4.93E-03 1.35E-05 -222E-04 l.35E--05 EG12 4.93E-02 0.58 3.70E--02 3.70E-02 1.0lE-04 -l.66E-03 1.0IE--04 EG13 023 2.52 0.17 0.17 4.68E-04 -5.13E-04 4.68E--04 EG18 0.56 5.41 0.42 0.42 l.15E-03 -126E-03 l.15E--03 EG15 -439E-04 ----3.14E-05 - EG16 l.65E-02 0.19 124E--02 l.24E-02 3.38E-05 -5.54E-04 3.38E--05 EG17 0.11 0.12 7.40E--03 7.40E-03 2.03E-05 -332E-04 2.03E--05 EG19 329E-03 3.85E-02 2.47E--03 2.47E-03 6.77E-06 -l.llE-04 6.77E--06 EG20 • 5.IOE-02 039 3.83E--02 3.83E-02 l.05E-04 -l.72E-03 1.05E--04 EG21 0.56 6.21 420E--01 4.20.E-01 l.15E-03 -126E-03 1.15E--03 EG22 8.72E-02 1.02 6.53E-02 6.53E-02 l.79E-04 -294E-03 l.79E--04 EG23 ·4.44E-02 034 3.33E--02 3.33E-02 9.12E-05 -l.50E-03 9.12E--05 EG24 l.15E-02 0.13 8.64-E--03 8.64-E-03 2.37E-05 -3.88E-04 2.37E--05 EG25 8.72E-02 1.02 6.53E--02 6.53E-02 l.79E-04 -294E-03 l.79E--04 EG26 0.OOE+oo 0.00 0.OOE+OO 0.OOE+OO 0.OOE+oo -3.76E-05 0.OOE+oo EG27 5.76E-02 0.67 4.32E--02 4.32E-02 l.18E-04 -194E-03 l.18E--04 EG28 5.06E-02 0.67 3.80E--02 3.S0E-02 1.04E-04 -l.71E-03 1.04E--04 EG29 5.06E-02 0.67 3.80E--02 3.80E-02 1.04E-04 -l.71E-03 J.04E--04 EG30 5.06E-02 0.67 3.80E--02 3.SOE-02 1.04E-04 -l.71E-03 l.04E--04 EG31 0.19 2.09 0.14 0.14 3.89E-04 -425E-04 3.89E--04 Mark Yoder, Meteorologist, AQAB, reviewed the dispersion modeling analysis and provided the following results (Table 5-3) on March 8, 2021 (Memo attached): Page 8 of 11 Table 5-3. Maxim um Modeled Im pacts Pollutant A vera2:ing Period AAL (t1i!/m3) %of AAL Arsenic Annual 2.lOE-03 55.2 % Beryllium Annual 4.lOE-03 21.2 % Benzene Annual 0.12 10.8 % Cadmium Annual 5.50E-03 14.36 % Soluble chromate 24-hour 0.62 0.8% compounds Fluorides I-hour 250 0.2% 24-hour 16 1.0% Formaldehyd~ I-hour 150 14.3 % Mercury 24-hour 0.6 0.8% Based on Mark Yoder's review, ''the modeling adequately demonstrates compliance with the Acceptable Ambient Limits (AALs) for all modeled toxics on a source-by-source basis." 6. Compliance Status: The facility was last inspected on August 7, 2019 by Lisa Whitaker and found to be in compliance. However, the facility failed to submit an NSPS semi-annual report prior to its due date, July 30, 2020. An NOV/NRE was issued. All violations have been resolved. 7. Facility Emissions Review: Table 7-1. Permit Potential Emissions (tpy} Natural Gas/ No. 2 Boilers Natural Diesel Diesel Natural Carpentry Total Pollutants (ID Nos. ES-Gas Generatorsh Generatorsh Gas Bl, ES-B2a, Boilers <600 hp >600 hp Generatorsb Shope Emissions ES-B3a)8 TSP 13.93 0.08 2.06 0.70 0.00 24.78 41.55 PM-10 4.22 0.08 2.06 0.70 0.01 24.78 31.85 SO2 0.90 0.10 0.01 0.01 0.00 -1.02 NOx 101.29 16.21 29.05 23.91 0.85 -171.31 * voe 27.52 0.89 2.36 1.34 0.03 -32.15 co 33.91 13.62 6.26 5.48 0.10 -59.37 ,Notes: a) Natural Gas/No.2 Fuel Oil-Fired Boilers emissions taken from worst case scenario per pollutant. Calculations assume no controls for NOx emissions. Sulfur Content for No. 2 Fuel Oil is 15 ppm (0.0015%). b) Generators were calculated at varying hours of operation per year based on limits outlined in the stipulation for 2D .1100 for toxics modeling. c) Since this source did not change, the Carpentry Shop emissions were taken from R08 review. * Total Permit Potential Emissions for NOx will remain below 100 tons per year using the equation provided in the permit stipulation for 2Q .0315. Page 9 of 11 Table 7-2. Title V Potential Emissions (tpy) Natural Gas/ No. 2 Boilers Natural Diesel Diesel Natural Carpentry Total Pollutants (ID Nos. ES-Gas Generatorsh Generatorsh Gas Bl, ES-B2a, Boilers < 600 hp > 600 hp Generatorsb Shope Emissions ES-JJ3a)0 TSP 13.93 0.08 2.37 0.70 0.00 24.78 41.87 PM-10 4.22 0.08 2.37 0.70 0.01 24.78 32.17 SO2 0.90 0.10 0.01 0.01 0.00 -1.02 NOx 101.29 16.21 33.46 23.91 0.85 -175.71 voe 27.52 0.89 2.71 1.34 0.03 -32.50 co 33.91 13.62 i.21 5.48 0.10 -60.32 Notes: a) Natural Gas/No.2 Fuel Oil-Fired Boilers emissions taken from worst case scenario per pollutant. Calculations assume no controls for NOx emissions. Sulfur Content for No. 2 Fuel Oil is 15 ppm (0.0015%). b) All generators were calculated at 500 hours of operation per year. c) Since this source did not change, the Carpentry Shop emissions were taken from R08 review. A breakdown of the emissions calculations is available in an Excel spreadsheet in the facility's SharePoint folder. The facility is correctly classified as Synthetic Minor. Page 10 of 11 8. Summary of Permit Changes: • Added eight (8) new emission sources (ID Nos. ES-815 -ES-B 18 and ES-EG28 -ES-EG3 l ). • Updated the stipulation for Rule 20 .0503 to include the four (4) new natural-gas fired boilers (ID Nos. ES- B 15 -ES-818) and the corresponding particulate matter emissions limits. • Updated the stipulation for Rule 20 .0521 to better reflect the rule language. • Updated the stipulation for Rule 20 .0524 for NSPS Subpart 1111 to include the four (4) new diesel-fired emergency generators (ID Nos. ES-EG28 -ES-EG3 l). • Updated the stipulation for Rule 20 .1111 for NESHAP Subpart ZZZZ to include the four ( 4) new diesel- fired emergency generators (ID Nos. ES-EG28 -ES-EG3 l). • Updated the stipulation for Rule 20 .1100 to include the dates the most recent toxics dispersion modeling occurred and were reviewed as well as the newly modeled sources and their corresponding emission limits. • Updated the stipulation for Rule 2Q .0315 to remove emission limits, operation restrictions, and reporting and recorq keeping requirements for SO2. Potential emissions were recalculated using the sulfur content of 15ppm for ultra-low sulfur diesel, which reduced SO2 potential emissions to less than 100 tons per year. • Removed the stipulation for Rule 2Q .0317 for Limitation to Avoid 15A NCAC 20 .0530 "Prevention of Significant Deterioration" due to the reduction of SO2 potential emissions. • Updated the stipulation for Rule 2Q .0711 to remove the following pollutants, as they are now emitted above the TPERs in 2Q .071 l(a) and are included in the stipulation for Rule 20 .1100: Mercury, vapor (Component of HOC) (7439-97-6) and Chromium (VI) Soluble Chromate Compounds (Component of CRC) (SolCR6). 9. Conclusions, Comments, and Recommendations: I recommend issuance of Permit No. 08512R09. Permit Coordinator: _____ .(_· _L ________ Q_-'~'------'--"-~----=----Date: Dena Pittman, P .E. Regional Supervisor: -~-~o»bt-.....c......;.,1t---u./--.a..-:............,;; ~-'--··frdt-: ___,;;;...++'---·-'-=--~~~-Date: 04/27/2021 ~ Taylor Page 11 of 11