notice of intent to issue an air pollution control …air pollution control permit to construct...

NOTICE OF INTENT TO ISSUE AN

AIR POLLUTION CONTROL

PERMIT TO CONSTRUCT

Take notice that the North Dakota Department of Environmental Quality proposes to issue an Air

Pollution Control Permit to Construct to the North Dakota National Guard in accordance with the

North Dakota Air Pollution Control Rules. The project involves taking an operational limit on

the four coal-fired boilers at the Camp Grafton North located at 4417 Hwy 20, Devils Lake in

Ramsey County, ND.

A 30-day public comment period for the proposed permit will begin April 2, 2020 and end on

May 2, 2020 Direct comments, in writing, to the North Dakota Department of Environmental

Quality, Division of Air Quality, 918 E Divide Avenue, Bismarck, ND 58501-1947 or

[email protected], Re: Public Comment Permit Number PTC20005. Please note that, to be

considered, comments submitted by email must be sent to the email address listed; comments sent

to any other email address will not be considered. Comments must be received by 11:59 p.m.

central time on the last day of the public comment period to be considered in the final permit

determination.

A public meeting regarding issuance of the Permit to Construct will be held if a significant degree

of public interest exists as determined by the Department. Requests for a public meeting must be

received in writing by the Department before the end of the public comment period. The

application, Department analysis and draft permit are available for review at the above address and

on-line at http://deq.nd.gov/AQ/PublicCom.aspx. A copy of these documents may be obtained

by writing to the Division of Air Quality or contacting Rheanna Kautzman at (701)328-5186 or by

email at [email protected].

Dated this 31st day of March 2020

James L. Semerad

Director

Division of Air Quality

mailto:[email protected]

AIR POLLUTION CONTROL

PERMIT TO CONSTRUCT Pursuant to Chapter 23.1-06 of the North Dakota Century Code, and the Air Pollution Control Rules of the State of North Dakota (Article 33.1-15 of the North Dakota Administrative Code), and in reliance on statements and representations heretofore made by the owner designated below, a Permit to Construct is hereby issued authorizing such owner to construct and initially operate the source unit(s) at the location designated below. This Permit to Construct is subject to all applicable rules and orders now or hereafter in effect of the North Dakota Department of Environmental Quality (Department) and to any conditions specified below: I. General Information:

A. Permit to Construct Number: PTC20005

B. Source:

1. Name: North Dakota National Guard Camp Grafton North

2. Location: 4417 Hwy 20

Devils Lake, ND Ramsey County

3. Source Type: Heating Plant 4. Existing Equipment at the Facility: [No new equipment, this permit action only authorizes changes to emission

limits for the coal-fired boilers to meet the requirements of 40 CFR 63, Subpart JJJJJJ.]

Emission Unit Description Emission Unit (EU)

Emission Point (EP)

Air Pollution Control

Equipment

Two Hurst F65-1950 coal-fired underfeed stoker boilers with a maximum heat input rating of 6.5 x 106 Btu/hr each [JJJJJJ (6J)] BLDG #6850

1 & 2 1 & 2 Cyclone A

Two Kewanee 7L289 Model C coal-fired underfeed stoker boilers with a maximum heat input rating of 6.5 x 106 Btu/hr each (6J) BLDG #6850

3 & 4 3 & 4 Cyclone A

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PTC No. PTC20005


Emission Point (EP)


Equipment

Webster natural gas-fired boiler rated at 10.5 x 106 Btu/hr. Installed 2017 (Dc) BLDG #6850

5 5 None

Hurst natural gas-fired boiler rated at a maximum heat input of 11.072 x 106 Btu/hr (Dc) BLDG #6850

6 6 None

1,850 bhp Cummins KTA-50-G3 diesel engine-driven generator (2001, ZZZZ) Near back gate

7 B 7 None

Paint booth located at the CSMS. Painting activities include: touch-up work and major painting and repainting of National Guard equipment. Various methods of paint application are used, including roller and brush painting, spray using aerosol cans, and air-atomized spray painting done with guns. BLDG #5825

8 8

Dry PM Filter

(No VOC control is used.)

3,634 bhp Caterpillar Model 3516 diesel engine-driven emergency generator (Nov. 17, 2008, IIII) BLDG #1500

9 B 9 None

92 bhp Ford CSG-6491-6005-F natural gas engine-driven generator (1997, ZZZZ) BLDG #5825

10 B 10 None

1,474 bhp Caterpillar Model C32 diesel engine-driven emergency generator set at the Readiness Center (November 11, 2011, IIII) BLDG #6400

11 B 11 None

107 bhp Cummins Model QSB5 series diesel engine-driven emergency generator set (April 2013, IIII) BLDG #7950

12 B 12 None

Approximately 4 miscellaneous natural gas-fired boilers with nominal ratings of 1 to 3 x 106 Btu/hr each (total rating approx. 8.5 x 106 Btu/hr) BLDG #1500 (two boilers), #3000, and #5260

13 to 16 13 to 16 None

A Each boiler is equipped with a Breslove cyclone with a design efficiency of 80%. B The potential to emit for an emergency stationary reciprocating internal combustion engine

(RICE) is based on operating no more hours per year than is allowed by the subparts (40

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PTC No. PTC20005

CFR 60, Subpart IIII and 40 CFR 63, Subpart ZZZZ) for situations that are non-emergency. For engines to be considered emergency stationary RICE under the RICE rules, engine operations must comply with non-emergency operating hour limits as specified in the applicable subparts. There is no time limit on the use of emergency stationary RICE in emergency situations.

C. Owner/Operator (Permit Applicant):

1. Name: North Dakota National Guard 2. Address: Office of the Adjutant General P.O. Box 5511 Bismarck, ND 58506-55113 3. Application Date: December 6, 2019

II. Conditions: The source may be operated under this Permit to Construct until a Permit to

Operate is issued unless this permit is suspended or revoked. The source is subject to all applicable rules, regulations, and orders now or hereafter in effect of the North Dakota Department of Environmental Quality and to the conditions specified below.

A. Emission Limits: Emission limits from the operation of the new equipment

identified in Item I.B of this Permit to Construct (hereafter referred to as "permit")

are as follows. Minor source units not listed are subject to the applicable

emission limits specified in the North Dakota Air Pollution Control Rules.

Emission Unit Description

EU EP Pollutant/ Parameter

Emission Limit A

Four Coal-fired boilers, 6.5 x 106 Btu/hr each

1 to 4 1 to 4

PM

SO2

Annual

Actual Heat Input

Opacity

0.6 lb/106 Btu B

3.0 lb/106 Btu C

5,694 x 106 Btu/yr D

See Condition II.B.

20 % E

Natural gas-fired boilers rated at 10.5 x 106 Btu/hr and 11.072 x 106 Btu/hr, respectively

5 & 6 5 & 6 Opacity 20 % E

Emergency generators 7, 9 to

12 7, 9 to 12 Opacity 20 % E

Miscellaneous natural gas-fired boilers

13 to 16 13 to 16 Opacity 20 % E

A Applies to each emission unit.

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PTC No. PTC20005

B Limit from NDAC 33.1-15-05-02.2.g. C Limit from NDAC 33.1-15-06-01.2 D Max heat input per coal-fired boiler to meet the definition of limited use boiler per

40 CFR §63.11225(c)(2)(vi). E 40% permissible for not more than one six-minute period per hour.

B. Annual Heat Input Capacity Emissions Calculation:

1. By the 15th day of each month, the owner/operator shall calculate the annual

heat input capacity from each coal-fired boiler (EUs 1 through 4). The

following calculation will be used to calculate emissions for each individual

coal-fired boiler:

Annual Heat Input EU1 = COAL * HHV

Where:

COAL = Amount of coal combusted per unit in tons per

calendar year (January to December)

HHV A = High Heating Value of Coal combusted in 106 Btu/yr

A The emission factor shall be based on the most recent coal analysis

for the coal combusted during the reporting period.

2. Each coal-fired boiler is restricted to an actual heat input value of 5,694 x

106 Btu/yr in any calendar year, January to December (see 40 CFR

§63.11237 Annual capacity factor).

C. Rescind: All conditions limited SO2 emissions to less than 100 tons per 12-month

period (12-month rolling total) in any existing permit to construct or permit to

operate are hereby rescinded and replaced by the annual actual heat input limits and

coal combustion limits listed in Condition II.A.

D. Fuel Restriction: The coal-fired boilers (EUs 1 through 4) are restricted to

combusting only pre-heated subbituminous coal with the option to combust lower

heating value subbituminous or lignite coal only if prior authorization from the

Department and provided that emission testing demonstrates compliance with the

limits indicated in Condition 7.A.

The natural gas-fired boilers (EUs 5 through 6 and 13 through 16) are restricted to

combusting only natural gas containing no more than 2 grains of sulfur per 100

standard cubic feet.

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PTC No. PTC20005

The emergency generators (EUs 7, and 9 through 12) are restricted to combusting

only distillate oil containing no more than 0.0015 percent sulfur by weight.

C. New Source Performance Standards (NSPS): The permittee shall comply with

all applicable requirements of the following NSPS subparts as referenced in

Chapter 33.1-15-12 of the North Dakota Air Pollution Control Rules and 40 CFR

60.

1. 40 CFR 60, Subpart Dc - Standards of Performance for Small Industrial-

Commercial-Institutional Steam Generating Units (EUs 5 and 6).

2. 40 CFR 60, Subpart IIII - Standards of Performance for Stationary

Compression Ignition Internal Combustion Engines (EUs 9, 11 & 12).

D. Maximum Achievable Control Technology Standards (MACT): The

permittee shall comply with all applicable requirements of the following MACT subparts as referenced in Chapter 33.1-15-22 of the North Dakota Air Pollution Control Rules and 40 CFR 63.

1. 40 CFR 63, Subpart ZZZZ - National Emissions Standards for Hazardous

Air Pollutants for Stationary Reciprocating Internal Combustion Engines

(EUs 7 and 10). The North Dakota Department of Environmental Quality

has not adopted the area source provisions of this subpart. Please send all

documentation to EPA at the following address:

U.S. EPA Region 8 1595 Wynkoop Street Mail Code 8ENF-AT Denver, CO 80202-1129

2. 40 CFR 63, Subpart JJJJJJ - National Emission Standards for Hazardous Air

Pollutants for Area Sources: Industrial, Commercial and Institutional Boilers. a. Boilers (EUs 1 through 4) combust coal and are subject to the rule

to include tune-ups, minimizing startup/shutdown periods and preparing reports.

1] Conduct an initial tune-up as specified in §63.11214, and

conduct a tune-up of the boiler every five years (no later than 61 months after the previous tune-up) as specified in §63.11223.

2] Implement work practice standards for startups and

shutdowns: Table 2, Subpart 6J and §63.11201.

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PTC No. PTC20005

3] The permittee shall prepare a biennial or 5-year compliance

report as specified in paragraphs (b)(1) and (2) of section

§63.11225 and submit the report to the implementing and

enforcement authority upon request.

4] EUs 1 through 4 are each classified as a limited-use boiler.

In order to maintain the limited-use boiler classification as

defined in 40 CFR 63 Subpart JJJJJJ, EUs 1 through 4 are

limited to the federally enforceable average annual capacity

factor of no more than 10 percent. See Condition II.B.

The North Dakota Department of Environmental Quality has not

adopted the provisions of this subpart applicable to boilers with a

heat input of less than ten million Btu per hour. Please send all

required documentation for EUs 1 through 4 to the EPA at the

address listed above.

Note: The natural gas-fired boilers (EUs 5, 6 and 13 through 16) are not

subject to 40 CFR 63, Subpart 6J.

E. Like-Kind Engine Replacement: This permit allows the permittee to replace the

existing engine(s) with a like-kind engine. Replacement is subject to the following

conditions.

1. The Department must be notified within 10 days after change-out of the

engine.

2. The replacement engine shall operate in the same manner, provide no

increase in throughput and have equal or less emissions than the engine it is

replacing.

3. The date of manufacture of the replacement engine must be included in the

notification. The facility must comply with any applicable federal

standards (e.g. NSPS, NESHAP, MACT) triggered by the replacement.

E. Construction: Construction of the above described facility shall be in accordance

with information provided in the permit application as well as any plans,

specifications and supporting data submitted to the Department. The Department

shall be notified ten days in advance of any significant deviations from the

specifications furnished. The issuance of this Permit to Construct may be

suspended or revoked if the Department determines that a significant deviation

from the plans and specifications furnished has been or is to be made.

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PTC No. PTC20005

Any violation of a condition issued as part of this permit to construct as well as any

construction which proceeds in variance with any information submitted in the

application, is regarded as a violation of construction authority and is subject to

enforcement action.

F. Organic Compounds Emissions: The permittee shall comply with all applicable

requirements of NDAC 33.1-15-07 – Control of Organic Compounds Emissions.

G. Permit Invalidation: This permit shall become invalid if construction is not

commenced within eighteen months after issuance of such permit, if construction

is discontinued for a period of eighteen months or more; or if construction is not

completed within a reasonable time.

H. Fugitive Emissions: The release of fugitive emissions shall comply with the

applicable requirements in NDAC 33.1-15-17.

I. Annual Emission Inventory/Annual Production Reports: The owner/operator

shall submit an annual emission inventory report and/or an annual production report

upon Department request, on forms supplied or approved by the Department.

J. Source Operations: Operations at the installation shall be in accordance with

statements, representations, procedures and supporting data contained in the initial

application, and any supplemental information or application(s) submitted

thereafter. Any operations not listed in this permit are subject to all applicable

North Dakota Air Pollution Control Rules.

K. Alterations, Modifications or Changes: Any alteration, repairing, expansion, or

change in the method of operation of the source which results in the emission of an

additional type or greater amount of air contaminants or which results in an increase

in the ambient concentration of any air contaminant, must be reviewed and

approved by the Department prior to the start of such alteration, repairing,

expansion or change in the method of operation.

L. Air Pollution from Internal Combustion Engines: The permittee shall comply

with all applicable requirements of NDAC 33.1-15-08-01 – Internal Combustion

Engine Emissions Restricted.

M. Recordkeeping: The owner/operator shall maintain any compliance monitoring

records required by this permit or applicable requirements. The owner/operator

shall retain records of all required monitoring data and support information for a

period of at least five years from the date of the monitoring sample, measurement,

report or application. Support information may include all calibration and

maintenance records and all original strip-chart recordings/computer printouts for

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PTC No. PTC20005

continuous monitoring instrumentation, and copies of all reports required by the

permit.

N. Nuisance or Danger: This permit shall in no way authorize the maintenance of a

nuisance or a danger to public health or safety.

O. Malfunction Notification: The owner/operator shall notify the Department of

any malfunction which can be expected to last longer than twenty-four hours and

can cause the emission of air contaminants in violation of applicable rules and

regulations.

P. Operation of Air Pollution Control Equipment: The owner/operator shall

maintain and operate all air pollution control equipment in a manner consistent with

good air pollution control practice for minimizing emissions.

Q. Transfer of Permit to Construct: The holder of a permit to construct may not

transfer such permit without prior approval from the Department.

R. Right of Entry: Any duly authorized officer, employee or agent of the North

Dakota Department of Environmental Quality may enter and inspect any property,

premise or place at which the source listed in Item I.B of this permit is located at

any time for the purpose of ascertaining the state of compliance with the North

Dakota Air Pollution Control Rules. The Department may conduct tests and take

samples of air contaminants, fuel, processing material, and other materials which

affect or may affect emissions of air contaminants from any source. The

Department shall have the right to access and copy any records required by the

Department’s rules and to inspect monitoring equipment located on the premises.

S. Other Regulations: The owner/operator of the source unit(s) described in Item

I.B of this permit shall comply with all State and Federal environmental laws and

rules. In addition, the owner/operator shall comply with all local burning, fire,

zoning, and other applicable ordinances, codes, rules and regulations.

T. Permit Issuance: This permit is issued in reliance upon the accuracy and

completeness of the information set forth in the application. Notwithstanding the

tentative nature of this information, the conditions of this permit herein become,

upon the effective date of this permit, enforceable by the Department pursuant to

any remedies it now has, or may in the future have, under the North Dakota Air

Pollution Control Law, NDCC Chapter 23.1-06. Each and every condition of this

permit is a material part thereof and is not severable.

U. Odor Restrictions: The owner/operator shall not discharge into the ambient air

any objectionable odorous air contaminant which is in excess of the limits

established in NDAC 33.1-15-16.

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PTC No. PTC20005

The owner/operator shall not discharge into the ambient air hydrogen sulfide (H2S)

in concentrations that would be objectionable on land owned or leased by the

complainant or in areas normally accessed by the general public. For the purpose

of complaint resolution, two samples with concentrations greater than 0.05 parts

per million (50 parts per billion) sampled at least 15 minutes apart within a two-

hour period and measured in accordance with Section 33.1-15-16-04 constitute a

violation.

V. Sampling and Testing: The Department may require the owner/operator to

conduct tests to determine the emission rate of air contaminants from the source.

The Department may observe the testing and may specify testing methods to be

used. A signed copy of the test results shall be furnished to the Department within

60 days of the test date. The basis for this condition is NDAC 33.1-15-01-12

which is hereby incorporated into this permit by reference. To facilitate preparing

for and conducting such tests, and to facilitate reporting the test results to the

Department, the owner/operator shall follow the procedures and formats in the

Department’s Emission Testing Guideline.

FOR THE NORTH DAKOTA DEPARTMENT

OF ENVIRONMENTAL QUALITY

Date________________________ By_______________________________________

James L. Semerad

Director


Air Quality Effects Analysis

for

Permit to Construct

PTC20005

I. Date of Review:

February 7, 2020 (Preliminary)

II. Applicant: North Dakota National Guard - Office of the Adjutant General P.O. Box 5511

Bismarck, ND 58506-5511

III. Source Location: North Dakota National Guard—Camp Grafton North SW ¼ SW ¼, Sec. 35, T150N, R98W

4417 Hwy 20 Devils Lake, ND 58301 Ramsey County

IV. Introduction and Background:

North Dakota National Guard - Camp Grafton North is an army national guard Major Training Center that consists of barracks and administrative support buildings with a central heating plant. The North Dakota National Guard (NDNG) has been switching out coal-fired units with natural gas fired units in their heating plant. Along with boilers, the facility consists of several diesel-fired emergency generators and a paint booth in their shop. The boilers (EUs 1 through 6) are subject to 40 CFR 63, Subpart JJJJJJ [MACT 6J], the NDNG is requesting federally enforceable limits on the four coal-fired units (EUs 1 through 4) in order for the units to be classified as a “limited-use” boiler and subject to tune-ups every five years. As such, this permit action establishes the necessary conditions to meet the definition of “limited-use” in MACT 6J and re-evaluates the SO2 synthetic minor permit limits in light of new limitations on the coal-fired units use.

No new equipment is being added to the facility, only a change in the synthetic minor limits

on the coal-fired boilers (EUs 1 through 4).

2

Table 1 - New & Existing Equipment List


Emission Point (EP)


Equipment

Two Hurst coal-fired underfeed stoker boilers with a maximum heat input rating of 6.5 x 106 Btu/hr each. [JJJJJJ (6J)] BLDG #6850

1 & 2 1 & 2 Cyclone A

Two Kewanee 7L289 Model C coal-fired underfeed stoker boilers with a maximum heat input rating of 6.5 x 106 Btu/hr each. (6J) BLDG #6850

3 & 4 3 & 4 Cyclone A

Webster natural gas-fired boiler rated at 10.5 x 106 Btu/hr. Installed 2017. (Dc) BLDG #6850

5 5 None

Hurst natural gas-fired boiler rated at a maximum heat input of 11.072 x 106 Btu/hr. (Dc) BLDG #6850

6 6 None

1,850 bhp Cummins KTA-50-G3 diesel engine-driven generator. (2001, ZZZZ) Near back gate

7 B 7 None

Paint booth located at the CSMS. Painting activities include: touch-up work and major painting and repainting of National Guard equipment. Various methods of paint application are used, including roller and brush painting, spray using aerosol cans, and air-atomized spray painting done with guns. BLDG #5825

8 8

Dry PM Filter

(No VOC control is used.)

3,634 bhp Caterpillar Model 3516 diesel engine-driven emergency generator. (Nov. 17, 2008, IIII) BLDG #1500

9 B 9 None

92 bhp Ford CSG-6491-6005-F natural gas engine-driven generator. (1997, ZZZZ) BLDG #5825

10 B 10 None

1,474 bhp Caterpillar Model C32 diesel engine-driven emergency generator set at the Readiness Center. (November 11, 2011, IIII) BLDG #6400

11 B 11 None

107 bhp Cummins Model QSB5 series diesel engine-driven emergency generator set. (April 2013, IIII) BLDG #7950

12 B 12 None

3


Emission Point (EP)


Equipment

Approximately 4 miscellaneous natural gas-fired boilers with nominal ratings of 1 to 3 x 106 Btu/hr each (total rating approx. 8.5 x 106 Btu/hr). BLDG #1500 (two boilers), #3000, and #5260

13 to 16 13 to 16 None

A Each boiler is equipped with a Breslove cyclone with a design efficiency of 80%. B The potential to emit for an emergency stationary reciprocating internal combustion engine

(RICE) is based on operating no more hours per year than is allowed by the subparts (40 CFR 60, Subpart IIII and 40 CFR 63, Subpart ZZZZ) for situations that are non-emergency. For engines to be considered emergency stationary RICE under the RICE rules, engine operations must comply with non-emergency operating hour limits as specified in the applicable subparts. There is no time limit on the use of emergency stationary RICE in emergency situations.

V. Potential to Emit (PTE) Emissions:

Emissions from the facility are as follows:

Table 3 - PTE Calculations (in tons per year) A

Emission Unit(s) EU PM/PM10/PM2.5 SO2 NOx CO VOCs

Hurst coal-fired underfeed stoker boilers with a maximum heat input rating of 6.5 x 106 Btu/hr

1 B 1.71/1.71/0.11 8.54 C 1.45 0.83 --


2 B 1.71/1.71/0.11 8.54 C 1.45 0.83 --

Kewanee 7L289 Model C coal-fired underfeed stoker boilers with a maximum heat input rating of 6.5 x 106 Btu/hr

3 B 1.71/1.71/0.11 8.54C 1.45 0.83 --


4 B 1.71/1.71/0.11 8.54 C 1.45 0.83 --

Webster natural gas-fired boiler rated at 10.5 x 106 Btu/hr

5 0.22/0.22/0.22 0.06 4.42 1.70 0.37

Hurst natural gas-fired boiler rated at a maximum heat input of 11.072 x 106 Btu/hr.

6 0.36/0.36/0.36 0.03 4.75 3.99 0.26

4

Emission Unit(s) EU PM/PM10/PM2.5 SO2 NOx CO VOCs

1,850 bhp Cummins KTA-50-G3 diesel engine-driven generator

7 D 1.02/1.02/1.02 0.95 13.88 3.05 1.14

Paint booth located at the CSMS

8 -- -- -- -- 8.90

3,634 bhp Caterpillar Model 3516 diesel engine-driven emergency generator

9 D 2.0/2.0/2.0 1.86 28.16 6.07 2.24

92 bhp Ford CSG-6491-6005-F natural gas engine-driven generator

10 D 0.71/0.71/0.71 0.05 0.71 0.15 0.06

1,474 bhp Caterpillar Model C32 diesel engine-driven emergency generator set

11 D 0.81/0.81/0.81 0.76 11.42 2.46 0.91

107 bhp Cummins Model QSB5 series diesel engine-driven emergency generator set

12 D 0.06/0.06/0.06 0.05 0.83 0.18 0.07

Approximately 4 miscellaneous natural gas-fired boilers with nominal ratings of 1 to 3 x 106 Btu/hr each (total rating approx. 8.5 x 106 Btu/hr)

13 to 16

0.28/0.28/0.28 0.02 2.65 3.07 0.20

New Total (w/o fugitives) F 9.48/9.48/7.88 37.94 73.62 23.99 51.41

A Pollutants are abbreviated as follows:

PM: particulate matter

PM10: particulate matter under 10 microns (<10 µg), includes PM2.5.

PM2.5: particulate matter under 2.5 microns (<2.5 µg)

SO2: sulfur dioxide

NOx: nitrogen oxides

VOC: volatile organic compounds (any compound of carbon, excluding carbon monoxide, carbon

dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate, which

participates in atmospheric photochemical reactions)

CO: carbon monoxide B PTE based on a max annual heat input of 5,694 106 Btu each. C Based on SO2 permit limit of 3.0 lb/106 Btu. D Based on PM permit limit of 0.6 lb/106 Btu. E PTE for emergency generators based on operating no more than 500 hours per year per

September 6, 1995 EPA Memo: Calculating Potential to Emit (PTE) for Emergency

Generators F Fugitive emissions not counted for PTE totals in determining major source status under the PSD

rules.

5

Table 4 - PTE Calculations (in tons per year)

Facility-wide

Emissions EU

Total HAPs A

Facility-wide ALL including

Fugitive 7.85

A HAPs: hazardous air pollutants as defined in Section 112(b) of the Clean Air Act Amendments of 1990

(see https://www.epa.gov/haps/initial-list-hazardous-air-pollutants-modifications)

VI. Applicable Standards:

Table 5 - Applicable Standards

Emission Unit Description Emission

Unit (EU) Applicable Standards


1

33.1-15-03-02 33.1-15-05-02

33.1-15-06-01.2 40 CFR 63, Subpart JJJJJJ [EPA A]


2

33.1-15-03-02 33.1-15-05-02



3

33.1-15-03-02 33.1-15-05-02



4

33.1-15-03-02 33.1-15-05-02


Webster natural gas-fired boiler rated at 10.5 x 106 Btu/hr

5 33.1-15-03-02

33.1-15-12-02, Subpart Dc

Hurst natural gas-fired boiler rated at a maximum heat input of 11.072 x 106 Btu/hr

6 33.1-15-03-02

33.1-15-12-02, Subpart Dc

1,850 bhp Cummins KTA-50-G3 diesel engine-driven generator

7 33.1-15-03-02

40 CFR 63, Subpart ZZZZ [EPA A]

Paint booth located at the CSMS

8

https://www.epa.gov/haps/initial-list-hazardous-air-pollutants-modifications

6

Emission Unit Description Emission

Unit (EU) Applicable Standards


9 33.1-15-03-02

33.1-15-12-02, Subpart IIII 40 CFR 63, Subpart ZZZZ [EPA A]


10 33.1-15-03-02

40 CFR 63, Subpart ZZZZ [EPA A]

1,474 bhp Caterpillar Model C32 diesel engine-driven emergency generator set

11 33.1-15-03-02



12 33.1-15-03-02


Approximately 4 miscellaneous natural gas-fired boilers with nominal ratings of 1 to 3 x 106 Btu/hr each (total rating approx. 8.5 x 106 Btu/hr)

13 to 16 33.1-15-03-02

A The Department has not adopted the area requirements of this subpart; EPA Region 8 is the implementing

and enforcement authority for this subpart at minor sources of hazardous air pollutants. B The Department has not adopted this subpart; all required documentation should be sent to EPA Region 8.

A. NDAC 33.1-15-02-Ambient Air Quality Standards

The facility must comply with the Ambient Air Quality Standards. Other requirements of this

chapter include general prohibitions against harming health, causing damage to plants, animals,

other property and visible degradation. In addition to these standards, compliance with the

Department’s Air Toxics Policy is required.

Applicability and Expected Compliance Status

Per the October 6, 2014 Department memorandum, Criteria Pollutant Modeling

Requirements for a Permit to Construct1 (see

Table ), the stack heights of all emission units are at least 1.5 times the nearby building and

less than the emission rates for NOx, SO2, PM10, and PM2.5; therefore, modeling is not

required to demonstrate compliance with the ambient air quality standards. Based on the

expected emissions, compliance with the AAQS is expected. For a source with these

expected emissions and proposed stack heights, compliance with the ambient air quality

standards is expected.

1October 6, 2014 NDDoH Memo: Criteria Pollutant Modeling Requirements for a Permit to Construct,

https://deq.nd.gov/publications/AQ/policy/Modeling/Criteria_Modeling_Memo.pdf

https://deq.nd.gov/publications/AQ/policy/Modeling/Criteria_Modeling_Memo.pdf

7

Table 6 - Projects not Subject to PSD modeling triggers

Pollutant

All emissions vent from stacks with

height ≥1.5 time nearby bldg.

height

Some emissions vent

from stacks<1.5 times

nearby bldg. height

NOx 100 tons per year 40 tons per year

SO2 100 tons per year 40 tons per year

PM10 40 tons per year 15 tons per year

PM2.5 25 tons per year 10 tons per year

B. NDAC 33.1-15-03 - Restriction of Emission of Visible Air Contaminants

This chapter restricts the amount of visible air contaminants primarily particulate matter,

from incinerators and fuel-burning units.


The facility must comply with an opacity limit of 20% except for one six-minute period per

hour when 40% opacity is permissible for the units listed in Table 7.

Table 7 - Opacity Limits

Emission Unit Description EU Pollutant/

Parameter Emission Limit A

Four Coal-fired boilers, 6.5 x 106

Btu/hr each 1 to 4 Opacity 20% (40% B)

Natural gas-fired boilers rated at 10.5

x 106 Btu/hr and 11.072 x 106 Btu/hr,

respectively

5 & 6 Opacity 20% (40% B)

Emergency generators 7, 9 to 12 Opacity 20% (40% B)

Miscellaneous natural gas-fired

boilers 13 to 16 Opacity 20% (40% B)

A Limit applies to each emission point. B Permissible for not more than one six-minute period per hour.

C. NDAC 33.1-15-06 - Emissions of Sulfur Compounds Restricted

This chapter applies to any installation in which fuel is burned in which the SO2 emissions

are substantially due to the sulfur content of the fuel burned and in which the fuel is burned

primarily to produce heat. This chapter is not applicable to installations which are subject

to a SO2 emission limit under Chapter 33.1-15-12, Standards for Performance for New

Stationary Sources, or installations which burn pipeline quality natural gas.

8


The natural gas-fired boilers (EUs 5, 6, and 13 to 16) are restricted to combusting only natural gas containing no more than 2 grains of sulfur per 100 standard cubic feet. The generators are restricted to combusting only low sulfur diesel fuel. The coal-fired units are restricted to 3.0 lb/106 Btu. Table 8 - Fuel Restrictions

Emission Unit Description EU Requirement A

Four coal-fired boilers, 6.5 x

106 Btu/hr each 1 to 4

- Restricted to 3.0 lb/106 Btu of SO2.

- Recordkeeping: Fuel log and analysis.

Natural gas-fired boilers rated

at 10.5 x 106 Btu/hr and

11.072 x 106 Btu/hr,

respectively

5 & 6 - Restricted to combusting only natural gas containing no more than 2 grains of sulfur per 100 standard cubic feet.

- Recordkeeping: Fuel log and analysis. Miscellaneous natural gas-

fired boilers 13 to 16

Emergency generators 7, 9 to 12

- Restricted to combusting only low sulfur diesel fuel.

- Recordkeeping: Fuel log and analysis.

A Requirement applies to each emission unit.

D. NDAC 33.1-15-12 - Standards of Performance for New Stationary Sources [40 Code

of Federal Regulations Part 60 (40 CFR Part 60)]

This chapter adopts most the Standards of Performance for New Stationary Sources

(NSPS) under 40 CFR Part 60. The facility is subject subparts listed in Table 9 under 40

CFR Part 60 which have been adopted by North Dakota.

Table 9 – Applicable NSPS

Emission Unit Description EU Applicable Standard

Natural gas-fired boilers rated at

10.5 x 106 Btu/hr and 11.072 x

106 Btu/hr, respectively

5 & 6 33.1-15-12-02, Subpart Dc

3,634 bhp Caterpillar Model

3516 diesel engine-driven

emergency generator

9 33.1-15-12-02, Subpart IIII

9



C32 diesel engine-driven

emergency generator set at the

Readiness Center

11 33.1-15-12-02, Subpart IIII

107 bhp Cummins Model QSB5

series diesel engine-driven

emergency generator set

12 33.1-15-12-02, Subpart IIII

A The Department has not adopted the area requirements of this subpart; EPA Region 8 is the

implementing and enforcement authority for this subpart at minor sources of hazardous air

pollutants. B The Department has not adopted this subpart; all required documentation should be sent to EPA

Region 8.

1. Subpart A - General Provisions

The facility is subject to one or more NSPS (NDAC 33.1-15-12/40 CFR 60) and is

subject to this subpart, compliance is expected.


Subpart A contains the NSPS General Provisions, compliance with the

requirements of Subpart A is expected through compliance with each applicable

NSPS subpart.

2. Subpart Dc - Standards of Performance for Small Industrial-Commercial-

Institutional Steam Generating Units

This subpart applies to manufacturers, owners, and operators of stationary ach steam

generating unit for which construction, modification, or reconstruction is commenced

after June 9, 1989 and that has a maximum design heat input capacity of 29 megawatts

(MW) (100 million British thermal units per hour (MMBtu/h)) or less, but greater than

or equal to 2.9 MW (10 MMBtu/h) and regulates SO2 emissions and particulate matter

emissions.


This subpart applies to the natural gas-fired boilers with a heat input rating of 10

MMBtu/hr or greater (EUs 5 & 6). These units combust only pipeline quality natural

gas an only have fuel log reporting requirements under this subpart.

10

Table 10 - NSPS Dc Applicable Requirements

Emission Unit Description EU Requirements A

Natural gas-fired boilers rated at 10.5 x 106 Btu/hr and 11.072 x 106 Btu/hr, respectively

5 & 6

- Fuel supplier certification listing

the potential sulfur emissions rate

or maximum potential sulfur

emissions rate of the fuel in ng/J

heat input; and A Requirement applies to each emission unit.

3. Subpart IIII - Standards of Performance for Stationary Compression Ignition

Internal Combustion Engines

This subpart applies to manufacturers, owners, and operators of stationary compression

ignition (CI) internal combustion engines (ICE) manufactured On or after July 11,

2005. Engines subject to this subpart are required to control NOx, CO, and VOC

emissions.

This subpart applies to compression ignition engines

- Constructed (ordered) after July 11, 2005, and manufactured after April 1,

2006 (July 1, 2006 for fire pump engines), or

- Modified or reconstructed after July 11, 2005.

- Except for engines > 30 liters per cylinder (l/cyl) displacement, performance

testing is not required - you achieve compliance by:

- purchasing a new engine that has been certified by EPA, and

- installing, configuring, operating, and maintaining the engine per the

manufacturer’s instructions.


Several engines (EUs 9, 11, and 12) have been manufactured to meet the requirements

of this subpart. These units are emergency units and must comply with the hour

limitations of §60.4211(f).

Table 11 - NSPS IIII Applicable Requirements


3,634 bhp Caterpillar Model 3516 diesel engine-driven emergency generator.

9 - Operate/maintain engine & control

device per manufacturer’s

instructions or owner-developed

maintenance plan.

- May use oil analysis program instead

of prescribed oil change frequency.

1,474 bhp Caterpillar Model C32 diesel engine-driven emergency generator set at the Readiness Center.

11

11


107 bhp Cummins Model QSB5 series diesel engine-driven emergency generator set.

12

- Emergency engines must have hour

meter and record hours of operation.

- Keep records of maintenance.

- Reporting and ULSD for emergency

engines used for local reliability.


Compliance with this subpart is expected.

The following footnote is included in the emission unit description table (Condition

I.B.4):

B The potential to emit for an emergency stationary reciprocating

internal combustion engine (RICE) is based on operating no more

hours per year than is allowed by the applicable subpart (40 CFR

60, Subpart IIII) except for emergency situations. For engines to be

considered emergency stationary RICE under the RICE rules,

engine operations must comply with non-emergency operating hour

limits as specified in the applicable subpart. There is no limit on the

use of emergency stationary RICE in emergency situations (40 CFR

60, Subpart IIII).

E. NDAC 33.1-15-13 - Emission Standards for Hazardous Air Pollutants [40 Code of

Federal Regulations Part 61 (40 CFR Part 61)]

This chapter adopts most the National Emission Standards for Hazardous Air Pollutants

(NESHAP) under 40 CFR Part 61.


The facility does not appear to have any requirements under this Chapter. If construction

on buildings occur, the facility will have to evaluate if Asbestos is contained in any of the

building materials and properly remediate then asbestos containing material per this

Chapter.

F. NDAC 33.1-15-14 - Designated Air Contaminant Sources, Permit to Construct, Minor

Source Permit to Operate, Title V Permit to Operate

This chapter requires the facility to obtain a Permit to Construct prior to installation of

sources of air pollution. This chapter also applies to Permit to Operate requirements for

facilities that have sources of air pollution.

12


The facility has submitted an application for modifications to the facility and for a permit

to construct.

This facility is not a major source under PSD nor Title V, but has taken a synthetic minor

operating limits for Emission Units 1 through 4 to meet the definition of “limited-use”

boiler under 40 CFR 63, Subpart JJJJJJ and therefore does require a public comment

period.

G. NDAC 33.1-15-15 - Prevention of Significant Deterioration of Air Quality

A Prevention of Significant Deterioration (PSD) review could potentially apply to this facility

if it is classified as a “major stationary source” under Chapter 33.1-15-15. To be classified as

a “major stationary source” the facility must have a potential to emit (PTE) of ≥100 tons per

year of any criteria air pollutant (CAP), ≥25 tons per year of combined hazardous air pollutants

(HAPs), or ≥10 tons per year of any single HAP.


The facility is not one of the 28 source categories to which fugitive emissions must be

considered in determining major or minor source status. The facility has included fugitive

emissions when calculating emissions, though these emissions are not included in determining

the facility’s major or minor status under the PSD rules.

This source is a minor source in regard to the PSD rules as the facility does not have the

potential to emit 100 tpy of any criteria pollutant.

H. NDAC 33.1-15-16 - Restriction of Odorous Air Contaminants

This chapter restricts the level of odorous air contaminants.


Odors from diesel, coal and natural gas combustion are expected to be minimal, and not

likely to result in a violation of this Chapter.

NDAC 33.1-15-17 - Restriction of Fugitive Emissions

This chapter requires the control of fugitive emissions.


Fugitive dust and gaseous emissions are required to be mitigated as needed via watering

or other methods of dust control and good maintenance practices.

13

I. NDAC 33.1-15-22 - Emissions Standards for Hazardous Air Pollutants for Source

Categories [40 Code of Federal Regulations Part 60 (40 CFR Part 63)]

This Chapter contains national emission standards for hazardous air pollutants (NESHAP)

established pursuant to section 112 of the Act as amended November 15, 1990. These

standards regulate specific categories of stationary sources that emit (or have the potential

to emit) one or more hazardous air pollutants listed in this part pursuant to section 112(b)

of the Act.

Table 12 – Applicable MACT Standards


Four Coal-fired boilers, 6.5 x

106 Btu/hr each 1 to 4 40 CFR 63, Subpart JJJJJJ [EPA A]

Natural gas-fired boilers rated at

10.5 x 106 Btu/hr and 11.072 x

106 Btu/hr, respectively

5 & 6 40 CFR 63, Subpart JJJJJJ [EPA A]

1,850 bhp Cummins KTA-50-

G3 diesel engine-driven

generator

7 40 CFR 63, Subpart ZZZZ [EPA A]


3516 diesel engine-driven

emergency generator


92 bhp Ford CSG-6491-6005-F

natural gas engine-driven

generator



C32 diesel engine-driven

emergency generator set at the

Readiness Center


107 bhp Cummins Model QSB5

series diesel engine-driven

emergency generator set


A The Department has not adopted the area requirements of this subpart; EPA Region 8 is the

implementing and enforcement authority for this subpart at minor sources of hazardous air

pollutants. B The Department has not adopted this subpart; all required documentation should be sent to EPA

Region 8.

1. Subpart A - General Provisions

The facility is subject to one or more MACT (NDAC 33.1-15-22/40 CFR 63) and

is subject to this subpart, compliance is expected.

14


Subpart A contains the MACT General Provisions, compliance with the

requirements of Subpart A is expected through compliance with each applicable

NSPS subpart.

2. Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants

for Stationary Reciprocating Internal Combustion Engines

This subpart applies to manufacturers, owners, and operators of stationary ach steam

generating unit for which construction, modification, or reconstruction is commenced

after June 9, 1989 and that has a maximum design heat input capacity of 29 megawatts

(MW) (100 million British thermal units per hour (MMBtu/h)) or less, but greater than

or equal to 2.9 MW (10 MMBtu/h) and regulates SO2 emissions and particulate matter

emissions.


This subpart applies to the emergency engines (EUs 7, 9 through 12). These units

combust only low sulfur diesel and are operated as emergency units.

Table 13 - MACT ZZZZ Applicable Requirements


1,850 bhp Cummins KTA-50-G3 diesel engine-driven generator.

7

- Operate/maintain engine & control



maintenance plan.

- May use oil analysis program

instead of prescribed oil change

frequency.

- Emergency engines must have

hour meter and record hours of

operation.


- Reporting and ULSD for

emergency engines used for local

reliability.

- May claim the existing intuitional

emergency stationary RICE

exemption under 40 CFR §63.6585

(f)(3).

15



9 - Comply with 33.1-15-12, Subpart

IIII


10

- Operate/maintain engine & control



maintenance plan.

- May use oil analysis program

instead of prescribed oil change

frequency.

- Emergency engines must have

hour meter and record hours of

operation.


- Reporting and ULSD for

emergency engines used for local

reliability.

- May claim the existing intuitional

emergency stationary RICE

exemption under 40 CFR §63.6585

(f)(3).

1,474 bhp Caterpillar Model C32 diesel engine-driven emergency generator set at the Readiness Center


IIII



IIII


3. Subpart JJJJJJ - National Emission Standards for Hazardous Air Pollutants

for Industrial, Commercial, and Institutional Boilers Area Sources

This subpart applies to, owners, and operators of stationary industrial, commercial, or

institutional boiler as defined in §63.11237 that is located at, or is part of, an area source

of hazardous air pollutants (HAP), as defined in §63.2, except as specified in

§63.11195. This subpart controls mercury, particulate matter, and carbon monoxide

emissions.

16


This subpart applies to the coal-fired boilers (EUs 1 through 4). With this permit

action, EUs 1 through 4 will be taking operation limits on each coal-fired boiler of

5,640 MMBtu/year to meet the definition of “limited-use” boiler under this subpart.

Compliance with this subpart is expected.

Table 14 - MACT JJJJJJ Applicable Requirements


Two Hurst coal-fired underfeed stoker boilers with a maximum heat input rating of 6.5 x 106 Btu/hr each. [JJJJJJ (6J)] BLDG #6850

1 & 2

- Restricted to 5,640 MMBtu/year

heat input. See permit condition

II.B.

- Boiler tune-ups every 5 years

Two Kewanee 7L289 Model C coal-fired underfeed stoker boilers with a maximum heat input rating of 6.5 x 106 Btu/hr each. (6J) BLDG #6850

3 & 4

- Restricted to 5,640 MMBtu/year

heat input. See permit condition

II.B.

- Boiler tune-ups every 5 years


VII. Summary:

It is recommended that PTC for the new operating limits on the coal-fired units be put on 30-day

public comment prior to making final permit decision.

VIII. Reviewed By:

Rheanna Kautzman

Environmental Scientist


RMK:saj

notice of intent to issue an air pollution control …air pollution control permit to construct...

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