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):
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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.
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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
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