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HomeMy WebLinkAboutAQ_F_1900134_20190605_PRMT_Permit ROY COOPER Governor , MICHAEL S.REGAN Secretary MICHAEL A13RACZINSKAS ', ' Director NORTH CAROLINA Environmental Qkafitr June 5,2019 Jon Kerin VP CCP Gov. & Op. Support Duke Energy Progress LLC 410 South Wilmington Street Raleigh,NC 27601 SUBJECT: Air Quality Permit No. 10583R00 Facility TD: 1900134 Duke Energy Progress LLC-Cape Fear STAR'Facility Moncure,North Carolina Chatham County Fee Class: Title V PSD Status: Minor Dear Mr. Kerin: -In accordance with your completed Air Quality Permit Application for a Greenfield facility received July 24,2018 and addendum received November 9,2018,we are forwarding herewith Air Quality Permit No. 10583R00 to Duke Energy Progress LLC - Cape Fear STAR'Facility, 500 C P and L Road, Moncure,North Carolina, authorizing the construction and operation, of the emission source(s)and associated air pollution control device(s)specified herein. Additionally,any emissions activities determined from your Air Quality Permit Application as being insignificant per 15A North Carolina Administrative Code 02Q .0503(8) have been listed for informational purposes as an "ATTACHMENT." As the designated responsible official, it is your responsibility to review, understand, and abide by all of the terms and conditions ofthe attached permit. It is also your responsibility to ensure that any person who operates any emission source and associated air pollution control device subject to any term or condition of the attached permit reviews,understands, and abides by the condition(s) of the attached permit that are applicable to that particular emission source. If any parts, requirements, or limitations contained in this Air Quality Permit are unacceptable to you, you have the right to request a formal adjudicatory hearing within 30 days following receipt of this permit, identifying the specific issues to be contested. This hearing request must be in the form of a written petition, conforming to NCGS (North Carolina General Statutes) 15013-23, and filed with both the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh,North Carolina 27699-6714 and the Division of Air Quality,Permitting Section, 1641 Mail Service Center,Raleigh,North Carolina 27699-1641. The form for requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings. Please note that this permit will be stayed in its entirety upon receipt of the request for a hearing.Unless a request for a hearing is made pursuant to NCGS 150B-23,this Air Quality Permit shalt be final and binding 30 days after issuance. North Carolina Department of Environmental Qualtry I division of Air Quality D,EQ �.- 217 West Jones Streer 11641,MMI service Center{ Raleigh,North Camllna 276941641 919.707.8400 Mr. Kerin June 5,2019 Page 2 You may request modification of your Air Quality Permit through informal means pursuant to NCGS 150B-22. This request must be submitted in writing to the Director and must identify the specific provisions or issues for which the modification is sought. Please note that this Air Quality Permit will become final and binding regardless of a request for informal modification unless a request for a hearing is also made under NCGS 150B-23. The construction of new air pollution emission source(s)and associated air pollution control device(s), or modifications to the emission source(s)and air pollution control device(s)described in this permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior to construction unless the Permittee has fulfilled the requirements of NCGS 143-215-108A(b) and received written approval from the Director ofthe Division ofAir Quality to commence construction. Failure to receive an Air Quality Permit or written approval prior to commencing construction is a. violation of NCGS 143-215.108A and may subject the Permittee to civil or criminal penalties as described in NCGS 143-215.114A and 143-215.114B. Chatham County has triggered increment tracking under PSD for PMIo, S02 and NO,. This modification will result in an increase of 22.5 pounds per hour of PMIo, 25.7 pounds per hour of S02, and 50.6 pounds per hour of NO,,. This Air Quality Permit shall be effective from June 5, 2019 until May 31, 2027, is nontransferable to future owners and operators,and shall be subject to the conditions and limitations as specified therein. Should you have any questions concerning this matter, please contact Betty Gatano,P.E.,at(919) 707-8736 or BeM.Gatanoaa cdenr.gov. Sincerely yours, r William D. Willets,P.E., Chief,Permitting Section Division of Air Quality,NCDEQ c; EPA Region 4 Ray Stewart, Supervisor,Raleigh Regional Oflice Central Files Connie Home (Cover letter only) ATTACHMENT Insignificant Activities per 15A NCAC 02Q .0102(h)(5) Emission Emission Source Description Source ID 1-1 Wet ash receiving(transfer to shed and hopper) I-3 Unloading pile I-4 Feed silo with a maximum 125 tons per hour filling rate and maximum 75 tons per hour unloading rate with a bin vent filter I-10 EHE silo with a maximum 125 tons per hour filling rate and maximum 75 tons per hour unloading rate with a bin gent filter 1-12 Loadout silo with a maximum 75 tons per hour filling rate and maximum 100 tons per hour unloading rate with a bin vent filter 1-13,1-14 Two truck loadout spouts, each with a bin vent filter I-15 Ash Basin I-16 Ash Handling 1-19 Screener with 165 tons per hour nominal fly ash processing rate 1-20 Crusher with 165 tons per hour nominal fly ash processing rate I-21 Haul Roads 1-22 Screener diesel-fired engine(91 horsepower) NSPS IIII CACT ZZZZ I-24 Ball mill classifier with a process rate of 10 tons per hour,with a baghouse inherent to the process 1-25 1 Ball mill feed silo with a maximum 15 tons per hour tilling rate with a.bin vent filter 1, Because an activity is insignificant does not mean that the activity is exempted from an applicable requirement or that the owner or operator of the source is exempted from demonstrating compliance with any applicable requirement. 2. When applicable,emissions from stationary source activities identified above shall be included in determining compliance with the permit requirements for toxic air pollutants under 15A NCAC 02D.1100"Control of Toxic Air Pollutants"or 02Q .0711 "Emission Rates Requiring a Permit". 1 For additional information regarding the applicability of CACT see the DAQ nanP titled "Tha RPmelatnry n7 i ide for Insignificant Activities/Permits Exempt Activities".The link to this site is as follows:bM://daq.state.ne.us/pennits/insigf State of North Carolina er. E Q2� Department of Environmental Quality r D7:;Om ta9 �ra = � Division of Air Quality AIR QUALITY PERMIT Permit No. Replaces Permit No.(s) Effective Date Expiration Date 10583R00 NIA June 5,2019 May 31, 2027 Until such time as this permit expires or is modified or revoked,the below named Permittee is permitted to construct and operate the emission source(s)and associated air pollution control device(s)specified herein. in accordance with the terms,conditions, and limitations within this permit. This permit is issued under the provisions of Article 21B of Chapter 143, General Statutes of North Carolina as amended, and Title 15A North Carolina Administrative Codes (15A NCAC), Subchapters 02D and 02Q,and other applicable Laws. Pursuant to Title 15A NCAC, Subchapter 02Q, the Permittee shall not construct, operate, or modify any emission source(s)or air pollution control device(s)without having first submitted a complete Air Quality Permit Application to the permitting authority and received an A it Quality Permit,except as provided in this permit. Permittee: Duke Energy Progress, LLC - Cape Fear STAR® Facility Facility ID: 1900134 Facility Site Location: 500 C P and L Road City, County, State,Zip: Moncure, Chatham County,North Carolina 27559 Mailing Address: 410 South Wilmington Street City, State,Zip: Raleigh,Wake County,North Carolina 27601 Application Number: 1900134.18A Complete Application Date: November 9,2018 Primary SIC Codes: 4911 Division of Air Quality, Raleigh Regional Office Regional Office Address: 3800 Barrett Drive, Suite 101 Raleigh,North Carolina 27609 Table of Contents SECTION 1: PERMITTED EMISSION SOURCE(S)AND ASSOCIATED AIR POLLtJTION CONTROL DEVICE(S)AND APPURTENANCES SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS 2.1- Emission Source(s) Specific Limitations and Conditions (Including specific requirements,testing, monitoring, recordkeeping,and reporting requirements) 2.2- Multiple Emission Source(s) Specific Limitations and Conditions (Including specific requirements,testing, monitoring, recordkeeping,and reporting requirements) SECTION 3: GENERAL PERMIT CONDITIONS Air Quality Permit No. 10583R00 Page 3 SECTION 1- PERMITTED EMISSION SOURCE (S) AND ASSOCIATED AIR POLLUTION CONTROL DEVICE (S) AND APPURTENANCES The following table contains a summary of all permitted emission sources and associated air pollution control devices and appurtenances: Emission Control Iage Source Emission Source Description Device Control Device O(s} ID Na. ID No. Description 4 ES-5 STAR®(Staged Turbulent Air Reactor) CD-5A Dry FGD scrubber in ash beneficiation process with a 140 series with a million Btu per hour total maximum firing rate,processing feedstock(fly ash and CD-5B Baghouse(26,790 square other ingredient materials)into feet of surface area) commercial products and equipped with propane low-NOx start-up burners(60 million Btu per hour maximum total capacity)for use during start-up or when necessary to maintain the desired reactor temperature; an integral cyclone and bag filter for product recover 8 ES-6 FGD byproduct silo(capacity to be CD-6 Bin vent filter(259 determined) square feet of surface areal 8 ES-7 FGD hydrate lime silo with a maximum CD-7 Bin vent filter(259 25 tons per hour filling rate and maximum square feet of surface 0.475 tons per hour unloading rate area) 8 ES-8 External heat exchanger A with 70 tons CD-8 Baghouse(20,925 square er hour nominal ca pacit\ feet of surface area) 8 ES-9 External heat exchanger B with 70 tons CD-9 Baghouse(20,925 square per hour nominal ca pacit\ feet of surface areal 8 ES-11 Product storage dome with a maximum 75 CD-11 Bin vent filter(2,260 tons per hour tilling rate and maximum square feet of surface 275 tons per hour unloading rate areal 10 ES-23 Crusher diesel-fired engine(300 NIA NIA NSPS 111H horsepower) GACT ZZZZ Air Quality Permit No. 10583R00 Page 4 SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS 2.1- Emission Source(s) and Control Devices(s) Specific Limitations and Conditions The emission source(s)and associated air pollution control device(s)and appurtenances listed below are subject to the following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and reporting requirements as specified herein: A. STAR'(Staged Turbulent Air Reactor)ash beneliciation process(ID No.ES-5) equipped with propane low-NOx startup burners controlled by a FGD scrubber(ID No.CD-5A)and a baghouse(ID No.CD-5B) The following table rovides a summai�, of limits and standards for the emission source(.s)described above: Regulated Limits/Standards Applicable Regulation Pollutant Particulate matter For P:!�30, E=4.10 x P°d7 15A NCAC 02D .0515 For P>30, E= 55.0xPO11 -40 Where: E=allowable emission rate in pounds per hour P= process weight in tons per hour Sulfur dioxide 2.3 pounds per million Btu heat input 15A NCAC 02D .0516 Visible emissions 20 percent opacity except during startup, shutdown and 15A NCAC 02D .0521 malfunctions Toxic air pollutants State Enforceable Only 15A NCAC 02D :1100 See Section 2.2 A.3 Toxic air pollutants State Enforceable Only 15A NCAC 02Q .0711 See Section 2.2 A.4 NIA Submit Title V permit application within one year from 15A NCAC 02Q.0504 the date of beginning operation of applicable sources — See Section 2.2 A.7 1. 15A NCAC 02D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES a. Emissions of particulate matter from this source(ID No.ES-5)shall not exceed an allowable emission rate as calculated by the following equation: For P e 30, E=4.10 x pa.67 For P>30, E= 55.0 x P01 -40 Where: E=allowable emission rate in pounds per hour P=process weight in tons per hour Liquid and gaseous fuels and combustion air are not considered as part of the process weight. Testing[15A NCAC 02Q.0308(a)] b. Under the provisions of NCGS 143-215.108,the Permittee shall demonstrate compliance with the emission limit above by testing the reactor(ID No.ES-5)for particulate emissions. Testing shall be performed in accordance with General Condition 17 and with a testing protocol approved by the DAQ. Testing shall be Air Quality Permit No. 10583R00 Page 5 completed within 90 days of initial startup' of the reactor(ID No.ES-5). The final air emission test report shall be submitted to the DAQ not later than 30 days after sample collection, in accordance with 15A NCAC 02D .2602(h). Monitorin ecordkee in [15A NCAC 02Q .0308(a)] c. Particulate matter emissions from this source(ID No.ES-5)shall be controlled by a bagfilter(ID No. CD-5B). To ensure compliance,the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer's inspection and maintenance recommendations,or if there are no manufacturer's inspection and maintenance recommendations,as a minimum,the inspection and maintenance requirement shall include the following: i. a monthly visual inspection of the system ductwork and material collection unit for leaks; ii. a monthly reading of the pressure gauges on the bagfilter(ID Nos.CD-511);and ii. an annual(for each 12-month period following the initial inspection)internal inspection of the bagfilter structural,noting the structural integrity and the condition of the filters. d. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each inspection; iii. the results of any maintenance performed on any control device; and iv. any variance from manufacturer's recommendations, if any, and corrections made. Reporting [15A NCAC 02Q .0308(a)] e. The Permittee shall submit the results of any maintenance performed on any control device within 30 days of a written request by the DAQ. 2. 15A NCAC 02D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES a. Emissions of sulfur dioxide from this source(ID No. ES-5)shall not exceed 2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels,wastes, ores, and other substances shall be included when determining compliance with this standard. Testing[15A NCAC 02Q .0308(a)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition 17. Monitorinf!IRecordkeepin [15A NCAC 02Q .03 08(a), 15A NCAC 02D.0605, I SA NCAC 02D .0611, 15A NCAC 02D .0613] c. The Permittee shall operate the FGD scrubber(ID No. CD-5A)at any time the reactor is in operation other than during startup, shutdown or malfunction. d. To ensure compliance,the Permittee shall install a sulfur dioxide continuous emissions monitoring (CEM)system including any required diluent monitor system with the following requirements: i. The CEM system shall be installed,calibrated,maintained,tested, and operated in accordance with 40 CFR Part 60,Appendix B. ii. Compliance with the sulfur dioxide emission standard shall be demonstrated based on a three-hour rolling average of the sulfur dioxide exhaust gas concentration measured by the CEM system. iii. Pursuant to 15A NCAC 02D ,0613 "Quality Assurance Program," the Permittee shall develop and implement a written quality assurance program containing information required by 40 CFR Part 60, Appendix F, Section 3,Quality Assurance Procedures. 'The initial startup is considered to be after the reactor has been through commissioning and turned over to operations. Air Quality Permit No. 10583R00 Page 6 Reporting [15A NCAC 02Q .0308(a), 15A NCAC 02D .0605,02D .0611] e. The Permittee shall submit the results of any maintenance performed on any control device within 30 days of a written request by the DAQ. f. For the CEMs,the Permittee shall submit semiannually an excess emissions and monitoring systems summary report.The report shall be calculated on a quarterly basis in a.format as provided by the Director. The report shall include any quality assurance assessments,as stated in the quality assurance program, and shall be submitted by July 30 for the period between January 1 and June 30 and by January 30 for the period between July 1 and December 31 of each year. g. The Permittee shall submit semiannually an emission report based on CEMs data on or before January 30 of each calendar year for the preceding six-month period between July and December, and July 30 of each calendar year for the preceding six-month period between January and June. The report shall contain the monthly sulfur dioxide emissions for the previous 17 months. The emissions must be calculated for each of the 12-month periods over the previous 17 months. 3. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS a. Visible emissions from this source(ID No.ES-5)shall not be more than 20 percent opacity(except during startups, shutdowns, and malfunctions)when averaged over a six-minute period. However, six- minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event,shall the six minute average exceed 87 percent opacity Testing[15ANCAC 02Q .0308(a)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition 17. Monitorina/Recordkeepin [15A NCAC 02Q .0308(a)] c. To ensure compliance, once every month,the Permittee shall observe the STAR®reactor stack for any visible emissions above normal. The Permittee shall establish"normal"for this source in the first 30 days following the effective date of beginning operation. If visible emissions from this source are observed to be above normal, the Permittee shall either: i. take appropriate action to correct the above-normal emissions as soon as practicable and within the monitoring period and record the action taken as provided in the recordkeeping requirements below, or ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A NCAC 02D.2610 (Method 9)for 12 minutes is below the limit given in Section 2.1 A.3.a above. d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each visible observation; iii. the results of each observation and/or test noting any corrective actions taken to reduce visible emissions; and iv. the results of any corrective actions performed. 4. 15A NCAC 02D.0611: MONITORING EMISSIONS FROM OTHER SOURCES a. Emissions of sulfur dioxide (SO2) from the STAR' (Staged Turbulent Air Reactor) ash beneficiation process(ID No.ES-5)shall be controlled by a FGD scrubber(ID No. CD-5A)at all times,except during periods of startup, shutdown or malfunction. Monitorin,2IRecordkeeping [15A NCAC 02Q.0308(a)] b. To ensure compliance,the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer's inspection and maintenance recommendations, or if there are no manufacturer's inspection and maintenance recommendations, as a minimum,the inspection and maintenance requirement shall include an annual(for each 12-month period following Air Quality Permit No. 10583R00 Page 7 the initial inspection)internal inspection of the dry FGD scrubber, including inspection of the injection nozzles,pumping systems, and associated controls. c. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; H. the results of each inspection; iii. the results of any maintenance performed on any control device;and iv. any variance from manufacturer's recommendations, if any,and corrections made. Reporting [15A NCAC 02Q .0308(a)] d. The Permittee shall submit the results of any maintenance performed on any control device within 30 days of a written request by the DAQ. 5. NCGS 143-215.108: CONTROL OF SOURCES OF AIR POLLUTION; PERMITS REQUIRED Under the provisions of NCGS 143-215.108,the Permittee shall verify the NOx emission factor specified in Permit Application No. 1900134.18A by testing the reactor(ID No.ES-5)for NOx emissions. Testing shall be performed in accordance with General Condition 17 and with a testing protocol approved by the DAQ. Testing shall be completed within 90 days of initial startup'of the reactor(ID No.ES-5). The final air emission test report shall be submitted to the DAQ not later than 30 days after sample collection, in accordance with 1.5A NCAC 02D .2602(h). 'The initial startup is considered to be after the reactor has been through commissioning;and turned over to operations. Air Quality Permit No. 10583RO0 Page 8 B. FGD byproduct silo(ID No.ES-6)with bin vent filter(El)No.CD-6) FGD hydrate lime silo(El)No.ES-7)with bin vent filter(ID No. CD-7) Two external heat exchangers A and B(El)Nos.ES-8 and ES-9)with baghouses(ID Nos.CD-8 and CD-9) Product storage dame(ID No.ES-11)with bin vent filter(ID No.CD-11) The following table provides a summar, of limits and standards for the emission source(s)described above: Regulated Limits/Standards Applicable Regulation Pollutant Particulate matter For P:�30, E=4.10 x P0,67 15A NCAC 02D.0515 For P>30, E=55.0 x po." -40 Where: E=allowable emission rate in pounds per hour P= process weig lit in tons per hour Visible emissions 20 percent opacity except during startup, shutdown and 15A NCAC 02D .0521 malfunctions Toxic air pollutants State Enforceable Only 15A NCAC 02D .1100 See Section 2.2 A.3 Toxic air pollutants State Enforceable Only 15A NCAC 02Q .0711 See Section 2.2 A.4 NIA Submit Title V permit application within one year from 15A NCAC 02Q.0504 the date of beginning operation of applicable sources See Section 2.2 A.7 1. 15A NCAC 02D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES a. Emissions of particulate matter from these sources(El)Nos.ES-6 through ES-9 and ES-11)shall not exceed an allowable emission rate as calculated by the following equation: For P c 30, E=4.10 x pO-67 For P>30, E=55.0 x P0.11 -40 Where: E=allowable emission rate in pounds per hour P=process weight in tons per hour Liquid and gaseous fuels and combustion air are not considered as part of the process weight. Testing [15A NCAC 02Q .0308(a)] b. Under the provisions of NCGS 143-215.108,the Permittee shall demonstrate compliance with the emission limit above by testing either external heat exchangers A or B(ID Nos.ES-8 or ES-9) for particulate emissions. Testing shall be performed in accordance with General Condition 17 and with a testing protocol approved by the DAQ. Testing shall be completed within 90 days of initial startup'of either source(ID Nos.ES-8 or ES-9). The final air emission test report shall be submitted to the DAQ not later than 30 days after sample collection, in accordance with 15A NCAC 02D .2602(h). 3The initial startup is considered to be after these units have been through commissioning and tumed over to operations. Air Quality Permit No. 10593R00 Page 9 Monitorin eeordkee inQ [15A NCAC 02Q .0308(a)] c. Particulate matter emissions from these sources(ED Nos.ES-b,ES-7,and ES-11) shall each be controlled by a bin vent filter(ID Nos.CD-b,CD-7,and CD-11)and particulate matter emissions from these sources(ID Nos.ES-8 and ES-9)shall each be controlled by a bagfilter(ID Nos.CD-8 and CD- 9)as described above. To ensure compliance,the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer's inspection and maintenance recommendations,or if there are no manufacturer's inspection and maintenance recommendations, as a minimum;the inspection and maintenance requirement shall include the following: i. a monthly visual inspection of the system ductwork and material collection unit for leaks; ii. monthly reading of the pressure gauges on the bagfilters(ID Nos.CD-8 and CD-9); and iii, annual(for each 12-month period following the initial inspection)internal inspection of the bagfilters(ID Nos. CD-8 and CD-9),noting the structural integrity and the condition of the filters. d. The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each inspection; iii. the results of any maintenance performed on any control device; and iv. any variance from manufacturer's recommendations, if any,and corrections made. Reporting[15A NCAC 02Q .0308(a)] e. The Permittee shall submit the results of any maintenance performed on any control device within 30 days of a written request by the DAQ. Z. 15A NCAC 02D .4521: CONTROL OF VISIBLE EMISSIONS a. Visible emissions from these sources(ID Nos.ES-6 through ES-9 and ES-11)shall not be more than 20 percent opacity(except during startups, shutdowns,and malfunctions)when averaged over a six- minute period. However,six-minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event; shall the six-minute average exceed 87 percent opacity. Testing [15A NCAC 02Q .0308(a)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition 17. Monitoring/Reeordkeel)in [15A NCAC 02Q .0308(a)] c. To ensure compliance, once a month the Permittee shall observe the emission points of these sources (ID Nos.ES-6 through ES-9 and ES-11) for any visible emissions above normal. The monthly observation must be made for each month of the calendar year period to ensure compliance with this requirement. The Permittee shall establish`normal"for these sources in the first 30 days following the effective date of beginning operation. If visible emissions from these sources are observed to be above normal,the Permittee shall either: i. take appropriate action to correct the above-normal emissions as soon as practicable and within the monitoring period and record the action taken as provided in the recordkeeping requirements below, or ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 15ANCAC 02D .2610(Method 9)for 12 minutes is below the limit given in Section 2.1 B.2.a above. d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each ohservation and/or test noting any corrective actions taken to reduce visible emissions;and iii. the results of any corrective actions performed, Air Quality Permit No. 10583ROO Page 10 C. Crusher diesel-fired engine(11)No.ES-23) The following table provides a summary of limits and standards for the emission source(0 described above: Regulated Limits/Standards Applicable Regulation Pollutant Sulfur dioxide 2.3 pounds )er million Btu heat input 15A NCAC 02D .0516 Visible emissions 20 percent opacity except during startup, 15A NCAC 02D .0521 shutdown and malfunctions NMHC+NOx New Source Performance Standards for stationary 15A NCAC 02D.0524 Particulate internal combustion engines. (40 CFR Part 60 Subpart I11I) emissions Hazardous air Comply with the requirements of 40 CFR Part 60, 1 SA NCAC 02D .1111 -pollutants Subpart 1111. (40 CFR 63 Subpart ZZZZ) Toxic air pollutants State Enforceable Only 15A NCAC 02D .1100 See Section 2.2 A.3 Toxic air pollutants State Enforceable Only 15A NCAC 02Q .0711 See Section 2.2 A.4 NIA Submit Title V permit application within one year 15A NCAC 02Q .0504 from the date of beginning operation of applicable sources See Section 2.2 A.7 1. 15A NCAC 02D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES a. Emissions of sulfur dioxide from this source(ID No.ES-23) shall not exceed 2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels,wastes, ores,and other substances shall be included when determining compliance with this standard. Testing [15A NCAC 02Q .0308(a)] b. If emissions testing is required,the testing shall be perfonned in accordance with General Condition 17. Monitoring/Recordkeeuine/Reportin [15A NCAC 02Q.0308(a)] c. No monitoring/recordkeeping/reporting is required for sulfur dioxide emissions from the firing of No.2 fuel oil in this source(ID No.ES-23). 2. 15A NCAC 02D.0521: CONTROL OF VISIBLE EMISSIONS a. Visible emissions from this source (ID No.ES-23) shall not be more than 20 percent opacity(except during startup,shutdowns,and malfunctions)when averaged over a six-minute period. However, six- minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event, shall the six-minute average exceed 87 percent opacity Testing[15A NCAC 02Q .0308(a)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition 17. MonitoringlRecordkeeping/Reporting [l5A NCAC 02Q .0308(a)] c. No monitoring/recordkeeping/reporting is required for visible emissions from the firing of No. 2 fuel oil in this source(ID No.ES-23). Air Quality Permit No. 10583R00 Page 11 3. 15A NCAC 02D.0524: NEW SOURCE PERFORMANCE STANDARDS Applicability [15A NCAC 02Q .0308(a),40 CFR 60.4200(a)(2)(i)] a. For this engine(ID No.ES-23),the Permittee shall comply with all applicable provisions, including the requirements for emission standards,notification,testing,reporting,record keeping, and monitoring, contained in Environmental Management Commission Standard 15A NCAC 02D.0524"New Source Performance Standards(NSPS)"as promulgated in 40 CFR Part 60 Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines,"including Subpart A "General Provisions." General Provisions [15A NCAC 02Q -0308(a)] b. Pursuant to 40 CFR 60 .4218,The Permittee shall comply with the General Provisions of 40 CFR 60 Subpart A as presented in Table 8 of 40 CFR 60 Subpart IIII. Emission Standards [15A NCAC 02Q .0308(a)] c. The Permittee shall comply with the emission standards for new nonroad CI engines in 40 CFR 60.4201 for the same model year and maximum engine power for this engine. [40 CFR 60.4204(b)] Fuel Requirements [15A NCAC 02Q .0308(a)] d. The Permittee shall use diesel fuel in the engine with: i. a maximum sulfur content of 15 ppm; and ii. a minimum cctanc index of 40 or a maximum aromatic content of 35 volume percent. [40 CFR 60.4207(b)and 40 CFR 80.510(b)] Testing [15A NCAC 02Q .0308(a)] e. If emissions testing is required, the testing shall be performed in accordance with General Condition 17. Monitoring[15A NCAC 02Q A308(a)] f. The engine,if equipped with a diesel particulate filter,must be installed with a backpressure monitor that notifies the owner or operator when the high backpressure limit of the engine is approached. [40 CFR 60.4209(b)] Compliance Requirements g. The Permittee shall: i. operate and maintain the engines and control devices according to the manufacturer's emission related-written instructions over the entire life of the engine; ii. change only those emission-related settings that are permitted by the manufacturer;and iii. meet the requirements of 40 CFR 89,94 and/or 1068 as applicable. [40 CFR 60.4206 and 60.4211(a)] h. The Permittee shall comply with the emission standards in Section 2.1 C.3.c by purchasing an engine certified to the emission standards in Section 2.1 C.3.c. The engine shall be installed and configured according to the manufacturer's emission-related specifications. [40 CFR 60.4211(c)] Recordkeepin [15A NCAC 02Q .0308(a)] i. To ensure compliance,the Permittee shall perform inspections and maintenance on the engine as recommended by the manufacturer per 40 CFR 60.4206 and 40 CFR 60.421 l(a).The results of inspection and maintenance shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following; i. the date and time of each recorded action; ii. the results of each inspection; iii. the results of any maintenance performed on the engine; iv. any variance from manufacturer's recommendations,if any,and corrections made; Air Quality Permit No. 10583R00 Page 12 v. if a PM filter is used,records of any corrective action taken after the backpressure monitor has notified the owner or operator that the high backpressure limit of the engine is approached [40 CFR 60.4214(c)]; and vi. documentation from the manufacturer that the engine is certified to meet the emission standards in Section 2.1 C.3.c. 4. 15A NCAC 02D .1111 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY Applicability [40 CFR 63.6585, 6590(a)(2)(iii)] a. For this source(new stationary RICE located at an area source of HAP emissions),the Permittee shall comply with all applicable provisions,including the monitoring,recordkeeping, and reporting contained in Environmental Management Commission Standard 15A NCAC 02D .1111 "Maximum Achievable Control Technology" (MALT)as promulgated in 40 CFR 63, Subpart ZZZZ, "National Emission Standards For Hazardous Air Pollutants For Stationary reciprocating Internal Combustion Engines" and Subpart A"General Provisions." Stationary RICE subiect to Regulations under 40 CFR Part 60 b. Pursuant to 40 CFR 63.6590(c)(1),this source must meet the requirements of 40 CFR 63 Subpart ZZZZ and Subpart A by meeting the requirements of 40 CFR 60 Subpart IIII.No further requirements apply for these engines under 40 CFR 63 Subpart ZZZZ and Subpart A. Air Quality Permit No. 10583R00 Page 13 2.2- Multiple Emission Source(s) A. Facility-wide affected sources The followinu,table provides a summan of limits and/or standards for the emission source(s)described above. Regulated Limits/Standards Applicable Regulation Pollutant NIA Reporting of excess emissions 15A NCAC 02D.0535 Fugitive dust Minimize fugitive dust beyond properIN boundary 15A NCAC 02D.0540 Toxic air pollutants State-enforceable only 15A NCAC 02D .1100 Modeled emission rates Toxic air pollutants State-enforceable only 15A NCAC 02Q .0711 Facility wide emissions limits for toxic air pollutant emission rates 1. 15A NCAC 02D.0535 EXCESS EMISSIONS REPORTING AND MALFUNCTION As required by 15A NCAC 2D .0535,the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions,shall: a. Notify the Director or his designee of any such occurrence by 9:00 a.m.Eastern time of the Division's next business day of becoming aware of the occurrence and describe: i. the name and location of the facility, ii. the nature and cause of the malfunction or breakdown, iii. the time when the malfunction or breakdown is first observed, iv. the expected duration,and v. an estimated rate of emissions. b. Notify the Director or his designee immediately when the corrective measures have been accomplished. This reporting requirement does not allow the operation of the facility in excess of Environmental Management Commission Regulations. State-Enforceable Onlv 2. 15A NCAC 02D.0540:PARTICULATES FROM FUGITIVE DUST EMISSION SOURCES a. For the purpose of this Rule the following definitions shall apply: i. "Fugitive non-process dust emission"means particulate matter that is not collected by a capture system and is generated from areas such as pit areas,process areas,hail roads,stockpiles,and plant roads. ii. "Substantive complaints" means complaints that are verified with physical evidence acceptable to the DAQ. b. The Permittee shall not cause or allow fugitive non-process dust emissions to cause or contribute to substantive complaints. c. If fugitive non-process dust emissions from a facility required complying with this Rule cause or contributing to substantive complaints,the Permittee shall: i. Within 30 days upon receipt of written notification from the Director of a second substantive complaint in a 12-month period,submit to the Director a written description of what has been done and what will be done to reduce fugitive non-process dust emissions from that part of the facility that caused the second substantive complaint; ii. Within 90 days of receipt of written notification from the Director of a second substantive complaint in a 12-month period,submit to the Director a control plan as described in Section 2.2 A.Le;and iii. Within 30 days after the Director approves the plan, be in compliance with the plan. Air Quality Permit No. 10583R00 Page 14 d. The Director may require that the Pcrmittec develop and submit a fugitive non-process dust control plan as described in Section 2.2 A.1.e if- i. Ambient air quality measurements or dispersion modeling acceptable to the DAQ show violation or a potential for a violation of an ambient air quality standard for particulates in 15A NCAC 02D.0400 "Ambient Air Quality Standards;"or . ii. If the DAQ observes excessive fugitive non-process dust emissions from the facility beyond the property boundaries. The control plan shall be submitted to the Director no later than 90 days after notification. The facility shall be in compliance with the plan within 30 days after the Director approves the plan. e. The fugitive dust control plan shall: i. Identify the sources of fugitive non-process dust emissions within the facility; ii. Describe how fugitive non-process dust will be controlled from each identified source; iii. Contain a schedule by which the plan will be implemented; iv. Describe how the plan will be implemented, including training of facility personnel;and v. Describe methods to verify compliance with the plan. f. The Director shall approve the plan if: i. The plan contains all required elements in Section 2.2 A.l.e; ii. The proposed schedule contained in the plan will reduce fugitive non-process dust emissions in a timely mariner; iii. The methods used to control fugitive non-process dust emissions are sufficient to prevent fugitive non- process dust emissions from causing or contributing to a violation of the ambient air quality standards for particulates;and iv. The described compliance verification methods are sufficient to verify compliance with the plan. If the Director finds that the proposed plan does not meet these requirements,he shall notify the Permittee of any deficiencies in the proposed plan. The Permittee shall have 30 days after receiving written notification from the Director to correct the deficiencies. g. If,after a plan has been implemented,the Director finds that the plan inadequately controls fugitive non- process dust emissions, the Permittee shall be required to correct the deficiencies in the plan. Within 90 days after receiving written notification froin the Director identifying the deficiency, the Pcrmittee shall submit a revision to his plan to correct the deficiencies. State Enforceable Only 3. 15A NCAC 02D .1100: CONTROL OF TOXIC AIR POLLUTANTS a. The Permittee has demonstrated compliance with the following permit limits in accordance with the addendum to the completed application(1900134,18A)received November 9,2018. The Permittee has evaluated all toxic air pollutants(TAPs)covered in 15A NCAC 02D.1104 for all sources at the facility, excluding the sources exempt from evaluation under 15A NCAC 02Q_0702., Emission Source Toxic Air Pollutant Emission Limit Feed silo(ID No. I-4) Arsenic 0.115 IN Bervllium 0.212 lb1 °r STAR®process(I❑No. ES-5) Arsenic 0.606 lb1 r Beryllium 0.751 lbl yr Sulfuric Acid 154 lblhr 909 lb/day FGD Byproduct Silo(ID No.ES-6) Arsenic 1.70E-03 lblvr Beryllium 2.09E-03 lbl r FGD hydrated lime silo(ID No.ES-7) Arsenic ].70E-02 lbl r Servllium 2.09E-02lb1 r a The Permittee elected to include emissions sources exempted by 15A NCAC 02Q ,0702(a)(27)in facility-wide air modeling conducted to demonstrate compliance with 15A NCAC 02D.l 100. Air Quality Permit No. 10583R00 Page 15 Emission Source Toxic Air Pollutant Emission Limit EHE A(ID No.ES-8) Arsenic 73 lb/.-r Beryllium 135lb/N-r EHE B (113 No.ES-9) .Arsenic 73 lbl r Beryllium 135 lblyr EHE Silo(ID No. I-10) 'Arsenic 0.115 lbl r Bervllium 0.212 blvr Product Storagc Dome(ID No.ES-11) Arsenic 0.200 lb1 r Berylliurn 0.371 lbl r Loadout Silo(ID No.I-12) Arsenic 4.30E-02 lbl r Beryllium 7.93E-02 lb/yr Loadout Silo Spouts Arsenic 0.115 lbly r (ID No. I-13 and I-14,combined) Bervllium 0.213 IM r Screener diesel-fired engine Arsenic 0.505 lbl r (ID No. I-22) Benzene 362 lb1vr Beryllium 3.301b1 r Crusher diesel-Bred engine Arsenic 1.67 lblvr (ID No.ES-23) Benzene 1,1891b1vr Beryllium 10.8lb1vr Wet Ash Transfer(ID No.I-1) Arsenic 0.152 ]blur Beryllium 0.280 lb/):r Unloading Pile(11)No. I-3) Arsenic 1.79E-03 lbIvr Beryllium 3.30E-03 W r Ash Basin(ID No. I-15) Arsenic 0.509 lbl °r Be fA llium 0.946 lblvr Ash handling(ID No.I-16) Arsenic 0.213 lbl r (includes windrows, screenerlcrusher Beryllium 0.392 lblyr drn i and screenerlcrusher stock pile) Screener(113 No. 1-19) Arsenic 3.871b1 r Beryllium 7.16 lb/vr Crusher(ID No.I-20) Arsenic 2.11 lblvr Beryllium 3.90 lb1N r Ball mall classifier(ID No.I-24) Arsenic 8.48 lblvr Beryllium 15.7lb1vr Ball mall feed silo(113 No.I-25) 1 Arsenic 1.72E-021bhr Beryllium 3.18E-021b/yr b. No testing!monitoring/recordkeeping/reporting shall be required to demonstrate compliance with 15A NCAC 02D .1100. State-Enforceable Only 4. 15A NCAC 02Q.0711: EMISSION RATES REQUIRING A PERMIT a.. Pursuant to 15A NCAC 02Q .0711 "Emission Rates Requiring a Permit", for each of the below listed toxic air pollutants (TAPS), the Permittee bas made a demonstration that facility-wide actual emissions do not exceed the Toxic Permit Emission Rates(TPERs)listed in 15A NCAC 02Q.0711(a). The facility shall be operated and maintained in such a manner that emissions of any listed TAPs from the facility, including fugitive emissions, will not exceed TPERs listed in 15A NCAC 02Q .0711. i. A permit to emit any of the below listed TAPS shall be required for this facility if actual emissions from all sources will become greater than the corresponding TPERs. Air Quality Permit No. 10593R00 Page 16 ii. PRIOR to exceeding any of these listed TPERs, the Permittee shall be responsible for obtaining a permit to emit TAPs and for demonstrating compliance with the requirements of 15A NCAC 02D .1100 "Control of Toxic Air Pollutants". iii. In accordance with the approved application, the Permittee shall maintain records of operational information demonstrating that the TAP emissions do not exceed the TPERs as listed below: Chronic Acute Acute Pollutant(CAS Number) Carcinogens Toxicants Systemic Irritants Toxicants (lblvr) (lb/day) lb/hr (lblhr Acetaldehyde (75-07-0) 6.8 Acrolein(107-02-8) 0.02 Benzo(aj vrene(50-32-8) 2.2 1,3-Butadiene (106-99-0) 11 Cadmium(7440-43-9) 0.37 Fonnaldehyde(50-00-0) 0.04 Hydrogen chloride(7647-01-0) 0.18 Hydrogen fluoride(7664-39-3) 0.63 0.064 Manganese 0.63 Mercury,vapor(7439-97-6) 0.013 Nickel metal(7440-02-0) 0.13 Soluble chromate compounds, 0.013 as chromium (VI)equivalent Toluene(108-88-3) 98 14.4 Xylene(1330-20-7) 57 16.4 Testing)Monitoring/Recordkeeping/Reportin [15A NCAC 02D A611] b. No testing/monitoring/recordkeepinglreporting shall be required to demonstrate compliance with 15A NCAC 02Q ,0711. 5. 15A NCAC 02Q .0207:ANNUAL ENIISSIONS REPORTING The Permittee shall report by June 30 of each year the actual emissions of each air pollutant listed in 15A NCAC 02Q .0207(a)from each emission source within the facility during the previous calendar year. The report shall be in or on such form as may be established by the Director. The accuracy of the report shall be certified by the responsible official of the facility. 6. 15A NCAC 02Q.0304: APPLICATIONS The Permittee,at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter in accordance with 15A NCAC 02Q .0304(d)and(f). Pursuant to 15A NCAC 02Q .0203(i),no permit application fee is required for renewal of an existing air permit. The renewal request should be submitted to the Regional Supervisor,DAQ. Air Quality Permit No. 10583ROO Page 17 7. 15A NCAC 02Q .0504: OPTION FOR OBTAINING CONSTRUCTION AND OPERATION PERMIT a. The Permittee shall file a Title V Air Quality Permit Application pursuant to 15A NCAC 02Q .0504.to modify the construction and operation permit on or before 12 months after commencing operation of any of the sources listed in this permit. Reporting [l.SA NCAC 02Q.0504] b. The Permittee shall notify the Regional Office in writing of the date of beginning operation of any of the sources listed in this permit,postmarked no later than 30 days after such date. Air Quality Permit No. 10583R00 Page 18 SECTION 3 - GENERAL CONDITIONS 1. In accordance with G.S. 143-215.108(c)(1),TWO COPIES OF ALL DOCUMENTS,REPORTS.TEST DATA.MONITORING DATA. NOTIFICATIONS.REQUESTS FOR RENEWAL.AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall be submitted to: Ray Stewart Regional Air Quality Supervisor North Carolina Division of Air Quality Raleigh Regional Office 3800 Barrett Drive, Suite 101 Raleigh, North Carolina 27609 (919)791-4289 For identification purposes,each submittal should include the facility name as listed on the permit,the facility identification.number,and the permit number. 2. RECORDS RETENTION REQUIREMENT-In accordance with 15A NCAC 02D .0605,any records required by the conditions of this permit shall be kept on site and made available to DAQ personnel for inspection upon request. These records shall be maintained in a form suitable and readily available for expeditious inspection and review. These records must be kept on site for a minimum of 2 years,unless another time period is otherwise specified. 3. ANNUAL FEE PAYMENT-Pursuant to 15A NCAC 02Q .0203(a),the Permittee shall pay the annual permit fee within 30 days of being billed by the DAQ.Failure to pay the fee in a timely manner will cause the DAQ to initiate action to revoke the permit. 4. EQUIPMENT RELOCATION-In accordance with 15A NCAC 02Q .0301,a new air permit shall be obtained by the Permittee prior to establishing,building, erecting, using, or operating the emission sources or air cleaning equipment at a site or location not specified in this permit. 5. REPORTING REQUIREMENT -In accordance with 15A NCAC 02Q .0309,any of the following that would result in previously unpermitted,new,or increased emissions must be reported to the Regional Supervisor,DAQ: a. changes in the information submitted in the application regarding facility emissions; b. changes that modify equipment or processes of existing permitted facilities;or c. changes in the quantity or quality of materials processed. If appropriate, modifications to the permit may then be made by the DAQ to reflect any necessary changes in the permit conditions.In no case are any new or increased emissions allowed that will cause a violation of the emission limitations specified herein. 6. In accordance with 15A NCAC 02Q .0309,this permit is subject to revocation or modification by the DAQ upon a determination that information contained in the application or presented in the support thereof is incorrect,conditions under which this permit was granted have changed, or violations of conditions contained in this permit have occurred.In accordance with G.S. 143-215.108(c)(1),the facility shall be properly operated and maintained at all times in a manner that will effect an overall reduction in air pollution.Unless otherwise specified by this permit,no emission source may be operated without the concurrent operation of its associated air cleaning device(s)and appurtenances. 7. In accordance with G.S. 143-215.108(c)(1),this permit is nontransferable by the Permittee.Future owners and operators must obtain a new air permit from the DAQ. Air Quality Permit No. 10583R00 Page 19 8. In accordance with G.S. 143-215.108(c)(1),this issuance of this permit in no way absolves the Permittee of liability for any potential civil penalties which may be assessed for violations of State law which have occurred prior to the effective date of this permit. g. In accordance with G_S. 143-215.108(c)(1),this permit does not relieve the Permittee of the responsibility of complying with all applicable requirements of any Federal, State, or Local water quality or land quality control authority. 10. In accordance with 15A NCAC 02 D .0605,reports on the operation and maintenance of the facil ity shall be submitted by the Permittee to the Regional Supervisor,DAQ at such intervals and in such form and detail as may be required by the DAQ. Information required in such reports may include,but is not limited to, process weight rates,firing rates, hours of operation, and preventive maintenance schedules. 11. A violation of any term or condition of this permit shall subject the Permittee to enforcement pursuant to G.S. 143-215.114A, 143-215.114B,and 143-215.114C, including assessment of civil and/or criminal penalties. 12. Pursuant to North Carolina General Statute 143-215.3(a)(2),no person shall refuse entry or access to any authorized representative of the DAQ who requests entry or access for purposes of inspection,and who presents appropriate credentials,nor shall any person obstruct,hamper, or interfere with any such representative while in the process of carrying out his official duties.Refusal of entry or access may constitute grounds for permit revocation and assessment of civil penalties. 13. In accordance with G.S. 143-215.108(c)(1),this permit does not relieve the Permittee of the responsibility of complying with any applicable Federal, State,or Local requirements governing the handling, disposal;or incineration of hazardous,solid;or medical wastes, including the Resource Conservation and Recovery Act (RCRA)administered by the Division of Waste Management. 14. PERMIT RETENTION REQUIREMENT-In accordance with 15A NCAC 02Q .0110,the Permittee shall retain a current copy of the air permit at the site. The Permittee must make available to personnel of the DAQ,upon request,the current copy of the air permit for the site. 15. CLEAN AIR ACT SECTION 112t r f Ra)UIR.EMENTS -Pursuant to 15A NCAC 02D .2100 "Risk Management Program," if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r)of the Federal Clean Air Act,then the Pennittee is required to register this plan with the USEPA in accordance with 40 CFR Part 68. lb. PREVENTION OF ACCIDENTAL RELEASES-GENERAL DUTY-Pursuant to Title I Part A Section l 12(r)(1)of the Clean Air Act"Hazardous Air Pollutants-Prevention of Accidental Releases-Purpose and General Duty," although a risk management plan may not be required,if the Permittee produces,processes, handles,or stores any amount of a listed hazardous substance,the Permittee has a general duty to take such steps as are necessary to prevent the accidental release of such substance and to minimize the consequences of any release. This condition is federally-enforceable only. 17. GENERAL EMISSIONS TESTING.AND REPORTING REQUIREMENTS-If emissions testing is required by this permit,or the.DAQ, or if the Permittee subunits emissions testing to the DAQ in support of a permit application or to demonstrate compliance,the Permittee shall perform such testing in accordance with 15A NCAC 02D .2600 and follow all DAQ procedures including protocol approval,regional notification,report submittal,and test results approval Air Quality Permit No. 10583ROO Page Za Permit issued this the 5'h day of June, 2019 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION .� -C� William D.Vdillets,P.E., Chief, Permitting Section Division of Air Quality.NCDEQ By Authority of the Environmental Management Commission Air Permit No. 10583ROO