United States . Regton 3 903/9-82-008a
Environmental Protection 6th rind Wakwt Streets
Agency Pntedefchia, PA 19106 June 1982
SEPA NSR AND PSD
PROGRAM ASSISTANCE
AND DEVELOPMENT IN
EPA REGION III
VOLUME 1
Region III Library
Ewkormwntal Protection
EPA Report Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
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Regional Center for Environmental Information
US EPA Region HI
1650 Arch St.
Philadelphia, PA 19103
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EPA Contract No. 68-02-2536
Work Assignment No. 14
EPA 903/9-82-008a
FINAL REPORT
NEW SOURCE REVIEW AND PREVENTION OF
SIGNIFICANT DETERIORATION PROGRAM ASSISTANCE
AND DEVELOPMENT IN EPA, REGION III
VOLUME 1
Robert Blaszczak - Project Officer
Thomas Blaszak - Project Manager
June, 1982
Prepared for:
Air Programs Branch
United States Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Prepared by:
Pacific Environmental Services, Inc.
Midwest Operations Division
465 Fullerton Avenue
Elmhurst, Illinois 60126
(312) 530-7272
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DISCLAIMER
This report was furnished to the Environmental Protection Agency
by Pacific Environmental Services, Inc., Midwest Operations Division,
465 Fullerton Avenue, Elmhurst, Illinois 60126 in fulfillment of
Contract No. 68-02-2536, Work Assignment No. 14. This document has
been reviewed by the Air Media and Energy Branch, U.S. Environmental
Protection Agency, Region III and approved for publication. Approval
does not signify that the contents necessarily reflect the views and
policies of the Environmental Protection Agency, nor does mention of
trade names or commercial products constitute endorsement or
recommendation for use.
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TABLE OF CONTENTS
VOLUME I
Section Page
1.0 BACKGROUND 1-1
2.0 ASSISTANCE IN THE REVIEW OF INDIVIDUAL PERMIT APPLICATIONS . . 2-1
2.1 Delmarva Power and Light Company: Vienna Unit No. 9 -
Vienna, Maryland 2-1
2.2 Domtar Industries, Inc. - Bellefonte, Pennsylvania . . . 2-2
2.3 Scott Paper Company - Chester, Pennsylvania 2-2
2.4 Pfizer, Inc. - Easton, Pennsylvania 2-3
2.5 Phillip Morris, Inc., Park 500 - Hopewell, Virginia ... 2-4
2.6 Pennsylvania Coke Technology, Inc. -
Lester, West Virginia 2-4
2.7 The Multitrade Group - Martinsville, Virginia 2-4
2.8 E.I. DuPont de Nemours and Company, Inc. -
Waynesboro, Virginia 2-5
2.9 Big Mountain Coal, Inc. (a subsidiary of Armco, Inc.) -
Prenter, West Virginia 2-5
2.10 A.E. Staley Manufacturing Co. - Morrisville, Pennsylvania 2-6
2.11 Consolidated Gas Supply Corporation - Hastings Compressor
Station - Wetzel County, West Virginia 2-6
2.12 Northeast Maryland Waste Disposal Authority -
Baltimore, Maryland 2-7
3.0 ASSISTANCE IN "PROGRAMMATIC" PSD AREAS 3-1
3.1 Status of PSD Applications within Region III 3-1
3.2 Determination of Significant Impact Radius for
PSD Sources 3-1
3.3 Determination of PSD Basline Dates 3-3
3.4 PSD Increment Tracking "Position Paper" 3-5
3.5 Implementation of the PSD Program by the States 3-5
3.6 Baseline Emission Inventory for the Washington, D. C.
Metropolitan Area 3-7
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Section Page
APPENDIX A DELMARVA POWER AND LIGHT COMPANY, VIENNA UNIT NO. 9
VIENNA, MARYLAND A-l
APPENDIX B DELMARVA POWER AND LIGHT COMPANY, VIENNA UNIT NO. 9
VIENNA, MARYLAND - PUBLIC COMMENT REVIEW B-l
APPENDIX C DOMTAR INDUSTRIES, INC. - BELLEFONTE, PENNSYLVANIA . . C-l
APPENDIX D SCOTT PAPER COMPANY - CHESTER, PENNSYLVANIA D-l
APPENDIX E PFIZER, INC. - EASTON, PENNSYLVANIA E-l
APPENDIX F PHILLIP MORRIS, INC., PARK 500 - HOPEWELL, VIRGINIA . . F-l
APPENDIX G THE MULTITRADE GROUP - MARTINSVILLE, VIRGINIA G-l
APPENDIX H E.I. DUPONT DE NEMOURS AND COMPANY, INC. -
WAYNESBORO, VIRGINIA H-l
APPENDIX I BIG MOUNTAIN COAL, INC. (A SUBSIDIARY OF ARMCO, INC.) -
PRENTER, WEST VIRGINIA 1-1
APPENDIX J A.E. STALEY MANUFACTURING COMPANY -
MORRISVILLE, PENNSYLVANIA J-l
APPENDIX K CONSOLIDATED GAS SUPPLY CORPORATION, HASTINGS
COMPRESSOR STATION - WETZEL COUNTY, WEST VIRGINIA . . . K-l
APPENDIX L NORTHEAST MARYLAND WASTE DISPOSAL AUTHORITY -
BALTIMORE, MARYLAND - BACT EVALUATION L-l
APPENDIX M NORTHEAST MARYLAND WASTE DISPOSAL AUTHORITY -
BALTIMORE, MARYLAND - ELECTROSTATIC PRECIPITATOR
EVALUATION M-l
APPENDIX N PSD PERMIT STATUS/CHECKLIST N-l
APPENDIX 0 DETERMINATION OF SIGNIFICANT IMPACT RADII FOR
PSD SOURCES 0-1
APPENDIX P REASSESSMENT OF THE SIGNIFICANT IMPACT RADIUS FOR THE
FIRESTONE PLASTIC COMPANY - PERRYVILLE, MARYLAND . . . P-l
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1.0 BACKGROUND
The Clean Air Act (CAA) as amended in 1977 included requirements
for the Prevention of Significant Deterioration (PSD) of present air
quality. The United States Environmental Protection Agency (U.S. EPA)
promulgated regulations to implement the PSD requirements on June 19,
1978. Each state was required to revise its State Implementation Plan
(SIP) to meet these new requirements within nine months. These SIP
revisions were due by March 19, 1979. Until such time that these SIP
revisions were submitted and approved, U.S. EPA administered the PSD
permit program. During this period, new sources proposing to con-
struct were required to be reviewed under the PSD program and/or the
Emission Offset Policy (EOP) as applicable. (The EOP review was con-
ducted by the state itself.) These reviews evaluated the acceptabil-
ity of the proposed source with respect to the applicable requirements
of the PSD or EOP programs. Of major significance is the fact that
the approval or disapproval of the source's application to construct
would impact the future growth characteristics of a particular area.
These proposed sources were reviewed with respect to their utilization
of the Best Available Control Equipment (BACT) for PSD subject sources
and the Lowest Achievable Emissions Reductions (LAER) for EOP subject
sources. Additionally, the impact of these proposed sources on the
air quality in their immediate location was quantified and reviewed
with respect to the National Ambient Air Quality Standards (NAAQS) and
the PSD increments as applicable.
On June 18, 1979, the United States Court of Appeals for the D.C.
Circuit issued a ruling in the case of Alabama Power Co. vs. Douglas
M. Costle (79-1006 and consolidated cases) which has had significant
impact on the U.S. EPA PSD program and permits issued thereunder. The
final ruling issued in December, 1979 re-emphasized and further clari-
fied the initial ruling. This Court's decision greatly affected the
applicability of a source being subject to a PSD review, the date on
which the increment begins to be consumed, the application of BACT,
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etc. In response to the Court's actions, U.S. EPA proposed a new set
of PSD regulations on September 5, 1979 (44 FR 51924) and stayed the
previously existing PSD rules for some sources on February 5, 1980 (45
FR 7800). The final PSD rules were promulgated on August 7, 1980 (45
FR 52676).
In order to assist U.S. EPA Region III and the individual states
within Region III in evaluating the PSD and EOF permit applications,
Pacific Environmental Services, Inc. (PES) had been contracted to
provide technical assistance to the Region III office in the evalua-
tion of specific PSD and EOP permit applications. Additionally, PES
provided technical assistance in the programatic areas of the PSD
rules. Specific task assignments included:
o Review of planned ambient monitoring networks and air quality
data for specific permit applications
o Engineering review of proposed source(s) including BACT/LAER
determinations
o Determination of the area of significant impact of proposed PSD
sources and all PSD permitted sources since the baseline date
o Preparation of Federal Register notices and other administra-
tive documents for PSD applications
o Attendance at public hearings, application conferences and
other project related meetings
o Determination of the pollutant-specific PSD baseline date(s)
for all geographic areas in Region III
o Preparation of a "Concept Paper" on tracking PSD increment
consumption within Region III
o Assistance to the states within Region III in the evaluation,
preparation and/or implementation of PSD delegation
o Determination of the status of all PSD permit applications/
inquiries within Region III.
The very nature of an application specific work assignment does
not lend itself to the preparation of a single, final report but
rather each specific subtask assignment "ended in a final report" for
that specific assignment. The purpose of this "final" report is to
briefly summarize each subtask assignment of this contract and to
provide an assemblage of the various "reports" prepared. It should be
noted that multiple areas of technical assistance were often required
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for a specific permit application. Therefore, the format of this
report will reflect case specific subtask assignments rather than the
type of technical assistance provided. Similarly, subtask assignments
in the programmatic area have been summarized together though they may
reflect multiple subtask assignments.
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2.0 ASSISTANCE IN THE REVIEW OF INDIVIDUAL PERMIT APPLICATIONS
Within the scope of this contract, technical assistance was
provided in various aspects of the review of individual applications.
Additionally, the review of some applications did not result in a
recommendation for the issuance or denial of a permit. Some reasons
for this include the fact that the application was incomplete and the
applicant did not pursue the application further or the permit review
was completed by the respective states after the PSD permit program
was delegated to them. Each of the following sections briefly
describe individual permit applications in which PES was involved in
some way. Reports prepared by PES are attached in the cited appen-
dices. (Note: Documents of solely an administrative nature are not
included.)
2.1 DELMARVA POWER AND LIGHT COMPANY: VIENNA UNIT NO. 9 -
VIENNA, MARYLAND
Delmarva Power and Light Company proposed to construct an addi-
tional power plant at their Vienna Power Station. This proposed new
unit would be designated as Unit Number 9. The facility, located in
Dorchester County at Vienna, Maryland, would consist of a coal-fired
5702 MBtu/hour electric utility steam generating unit and related coal
handling facilities.
Delmarva Power and Light Company's application dated April 25,
1980 was assigned to PES for review on June 9, 1980. PES's recommen-
dation to approve the application consistent with enumerated monitor-
ing requirements and emission limitations is contained in the
July, 1980 report. This full report is contained in Appendix A.
On March 16, 1981, PES was again contacted and asked to review
public comments and the applicant's response concerning the sulfur
dioxide emission limitation recommended as BACT. A letter report
dated April 9, 1981 concluded the BACT would be utilized by the
proposed source. This report is also presented herein as Appendix B.
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2.2 DOMTAR INDUSTRIES. INCORPORATED - BELLEFONTE, PENNSYLVANIA
Domtar Industries, Inc. proposed to expand the lime production
capacity at its Bellefonte Lime Plant in Centre County, Pennsylvania.
The proposed project included the rehabilitation of the No. 1
coal-fired rotary kiln to produce quick lime. In mid-1979, U.S. EPA
determined that this reactivation was a major modification requiring a
PSD permit.
Domtar Industries, Inc. submitted their permit application on
November 30, 1978. These materials were insufficient and additional
information was submitted by Domtar Industries, Inc. in correspondence
dated May 7, 1980, October 10, 1980, November 17, 1980, and January
29, 1981. PES's evaluation of this application recommended approval
of the application subject to monitoring requirements and emission
limitations. The full report dated February, 1981 is attached as
Appendix C.
2.3 SCOTT PAPER COMPANY - CHESTER, PENNSYLVANIA
Scott Paper Company proposed to modify the boilerhouse at their
Chester, Pennsylvania facility. The proposed modification to the
existing boilerhouse (comprised of four oil-fired boilers) was pre-
sented by the Scott Paper Company as one of three potential alterna-
tives. These alternatives were: 1) conversion of all four oil-fired
units to coal firing; 2) permanent retirement of two existing units,
conversion of the other two units from oil to coal and the installa-
tion of a new coal-fired boiler; and 3) the replacement of all four
oil-fired units by three new coal-fired units.
Although Scott Paper Company submitted their PSD application
during a meeting at Region III offices on June 2, 1980, several sup-
plemental packages of information followed. PES was assigned the
application to review on September 12, 1980. Additional data from the
Scott Paper Company was requested and ultimately received. In a
report dated December, 1980, PES recommended the approval of a PSD
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permit with conditions. All three alternatives were approvable but a
timetable for the Scott Paper Company to definitively select one of
the alternatives for implementation was recommended. The full report
is contained in Appendix D.
On May 1, 1981, the Scott Paper Company submitted a modification
to their PSD application describing the boilerhouse changes that would
be implemented. This finalized plan for the boilerhouse modification
was not one of the three alternatives previously examined. This
alternative consisted of retiring two existing units, using the
remaining two existing units on a standby basis only, and the con-
struction of a single 700 MBtu/hour coal-fired unit. On July 9, 1981,
PES was asked to reassess the BACT emission limitations and monitoring
recommendations. In a telephoned report on July 12, 1981, PES
informed the Project Officer that all the recommendations of the
December, 1980 report would be applicable to this new alternative.
Per the Project Officer's direction, no formal report was prepared.
2.4 PFIZER, INC. - EASTON, PENNSYLVANIA
Pfizer, Inc. proposed to expand the powerhouse at their Easton,
Pennsylvania facility. The proposed expansion would include the
installation of a 210 MBtu/hour oil-fired boiler. Contemporaneously,
a 90 MBtu/hour oil-fired boiler would be permanently shutdown. A
second oil-fired unit of 180 MBtu/hour would also be reduced to a
limited schedule. Pfizer, Inc. submitted a PSD application on June
25, 1980. PES was assigned the application's review on July 7, 1980,
and on July 14, 1980, a letter report was completed. This report
determined the application to be incomplete, and items of data needed
to complete the submittal were listed. This report is attached as
Appendix E. No further actions on this application were performed.
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2.5 PHILLIP MORRIS, INC., PARK 500 - HOPEwELL, VIRGINIA
Phillip Morris, Inc. proposed to construct a new boiler at their
Park 500 facility located in Chesterfield County at Hopewell,
Virginia. The planned 237 MBtu/hour coal-fired boiler and related
coal handling facilities would supplement the power supplied by the
existing two boilers. The PSD application dated September 8, 1980 was
forwarded to PES for review on September 29, 1980. In a letter report
dated October 27, 1980, PES determined that the application was incom-
plete and enumerated the deficiencies in the submittal. This report
can be found in Appendix F. Several subsequent discussions with U.S.
EPA staff followed, but no other substantive reports were prepared.
2.6 PENNSYLVANIA COKE TECHNOLOGY, INC. - LESTER, WEST VIRGINIA
Pennsylvania Coke Technology, Inc. proposed to construct a
coke-making facility in Lester, West Virginia. The proposed coke
battery was a non-recovery type which would be based on a new technol-
ogy. This application was assigned for review on October 10, 1980.
PES's evaluation concurred with the applicant that BACT would be
employed for particulates and NO^. However, PES determined that the
applicant did not demonstrate that BACT for S02 would be utilized.
The full report justifying these recommendations dated October, 1980
is not included here as an Appendix. Pennsylvania Coke Technology,
Inc. deemed materials in their application to be confidential.
Accordingly, PES's report was treated as containing confidential
materials and has been delivered to the Project Officer as a separate
document.
2.7 THE MULTITRADE GROUP - MARTINSVILLE, VIRGINIA
The Multitrade Group proposed to construct two coal and wood waste
fired boilers in Henry County near Martinsville, Virginia. The Multi-
trade Group would sell steam from these units to existing nearby
industry which would curtail operation of their individual power
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plants. The Multitrade Group's PSD application dated November 14,
1980 was received by PES for review on December 3, 1980. The applica-
tion was determined to be incomplete in providing the information
necessary to determine whether the PSD permit could be granted. In a
letter report dated December 17, 1980, these deficiencies were tabu-
lated. This report is presented in Appendix G. No further PES activ-
ity had been undertaken.
2.8 E.I. DUPONT DE NEMOURS AND COMPANY, INC. - WAYNESBORQ, VIRGINIA
E.I. DuPont de Nemours and Company, Inc. proposed major modifica-
tions at their synthetic fiber production manufacturing facilities at
Waynesboro, Virginia. E.I. DuPont planned to expand their nylon and
lycra production capability. The construction of a new Dowtherm unit
would also be part of this project. Contemporaneous with this expan-
sion, E.I. DuPont would shutdown cellulose acetate fiber and cellulose
acetate resin production. Finally, the existing boilerhouse would
reduce its emissions due to decreased power demand.
DuPont formally requested a determination that a PSD permit was
not required on January 27, 1981. Supplemental data was sent on
February 20, 1981. E.I. DuPont contended that no significant net
increase in emissions would result from the proposed modification.
PES was assigned the task of determining PSD applicability on March 3,
1981. In a letter report dated March 27, 1981, PES determined that
the materials available were insufficient to make an independent
determination of PSD applicability. The data needed for this evalua-
tion was enumerated in that letter report which is attached as Appen-
dix H. No additional data had been submitted to PES for evaluation.
2.9 BIG MOUNTAIN COAL, INC. (A SUBSIDIARY OF ARMCO, INC.) -
PRENTER, WEST VIRGINIA
Big Mountain Coal, Inc. proposed to construct a new coal mining
complex located near an existing mining complex at Prenter, West
Virginia. The existing coal mining complex included a coal prepara-
tion plant but no thermal dryer.
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Armco, Inc. submitted on Big Mountain Coal, Inc.'s behalf a
request for a determination that a PSD permit was not required. This
request dated May 8, 1981 was forwarded to PES on July 6, 1981. In a
letter report dated July 30, 1981, PES recommended that a determina-
tion of non-applicability of PSD be made. This recommendation was
made on the basis of the physical size of the preparation plant with-
out any restrictions in hours of operation or limitation of coal
throughput. This letter report can be found in Appendix I.
2.10 A. E. STALEY MANUFACTURING CO. - MORRISVILLE, PENNSYLVANIA
A. E. Staley Manufacturing Co. proposed to install a new 249
MBtu/hour coal-fired boiler at their corn processing plant in
Morrisville, Pennsylvania . A. E. Staley Manufacturing Co.'s PSD
application dated May 18, 1981 was forwarded to PES for review on June
8, 1981. In a letter report dated July 6, 1981, PES stated that the
application was incomplete and delineated those items which were
needed to supplement the materials received for review. PES also
provided an initial BACT determination for particulates and S0£
which differed from that suggested by the applicant. This letter
report in its entirety is reproduced as Appendix J. No further
requests have been received from the Project Officer regarding further
assistance on this application.
2.11 CONSOLIDATED GASSUPPLY CORPORATION - HASTINGS COMPRESSOR STATION
WETZEL COUNTY, WEST VIRGINIA
Consolidated Gas Supply Corporation was modernizing the gas pipe-
line distribution system in its service area. Part of this moderniza-
tion program is the proposed upgrading of the Hastings Compressor
Station located in Wetzel County, West Virginia. The planned expan-
sion of the Hastings Compressor Station consisted of relocating two 16
year-old 1600 hp Cooper Bessemer GMVH-8 internal combustion recipro-
cating engines with associated compressors.
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Consolidated Gas Supply Corporation submitted a PSD application on
June 5, 1981 with supplemental information submitted on July 9, 1981
and July 31, 1981. PES was assigned to evaluate the application on
July 7, 1981. By directly discussing data needs with the applicant's
consultant, the completion of PES's evaluation was expedited. Since
the proposed units, at 16 years of age, did not reflect the current
state-of-the-art design with respect to minimizing NO emissions,
/\
the case specific BACT analysis weighed technological feasibility,
energy impacts, economic impacts, and environmental impacts in the
final recommendations. The incremental cost of NO reductions and
/\
the significant loss of natural gas (caused by the time delay needed
to implement other alternatives) were the prime factors contributing
to the recommendation that BACT will be utilized and that the applica-
tion should be approved subject to the recommended permit conditions.
The full report can be found in Appendix K.
2.12 NORTHEAST MARYLAND WASTE DISPOSAL AUTHORITY - BALTIMORE. MARYLAND
The Northeast Maryland Waste Disposal Authority proposed to con-
struct a municipal waste disposal facility in Baltimore City,
Maryland, to be known as the Southwest Resource Recovery Facility.
This proposed facility will consist of three water wall incinerators
with a total design capacity of 2010 tons of refuse per day. Energy
recovery from the incinerator generated steam would result from elec-
tricity produced by a 50-MW turbine or by the direct sale of steam for
heating. Ferrous residue and other saleable materials would be recov-
ered from the incinerated refuse. Finally, in conjunction with the
proposed new construction, the existing pyrolisis plant located at the
proposed site would be permanently shutdown and razed.
The applicant requested an expeditious review, and as such, PES
was given the assignment in mid-June, 1981 when preliminary materials
were received. Arrangements for PES staff to perform the PSD review
at Region III offices were made. On July 7, 1981, the Northeast
Maryland Waste Disposal Authority submitted their application during a
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meeting at Region III offices. Additional materials were requested of
the applicant by PES to substantiate statements made during that meet-
ing. On July 8-9, 1981, PES completed the BACT review and left a
handwritten draft with the Project Officer. This evaluation was based
on the assumption that the supplemental materials requested from the
applicant would complete the application and substantiate conclusions
contained in their application. The final report was forwarded to the
Project Officer after receipt and review of the supplemental mater-
ials. The report in full is attached as Appendix L.
The location of the proposed Southwest Resource Recovery Facility
is a non-attainment area for particulates. As such, the above des-
cribed assignment to review the PSD application did not include an
assessment for that pollutant. On December 1, 1981, PES was requested
in an additional subtask assignment to assist the State of Maryland in
their review of this proposed source for particulates under the emis-
sion offset policy. Specifically, PES was assigned to perform an
engineering analysis of the electrostatic precipitator system proposed
for particulate control. Subject to reservations stated in the
report, PES determined that the proposed control device will achieve
the required emission limit. The draft report supporting these con-
clusions was forwarded directly to the State of Maryland on March 1,
1982. The final report which was substantively unchanged from the
draft can be found in Appendix M.
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3.0 ASSISTANCE IN "PROGRAMMATIC" PSD AREAS
The PSD/EOP program assistance was not limited solely to individ-
ual applications. Subtask assignments categorized as "programmatic"
provided assistance which transcended more than a specific applica-
tion. Indeed in some areas, review of future applications would be
expedited because these subtask assignments had been completed. The
specific assignments in the "programmatic" areas are summarized
briefly in the following sections.
3.1 STATUS OF PSD APPLICATIONS WITHIN REGION III
The PSD program required that a PSD permit either be issued or
denied within one year of the receipt of a complete application. A
completeness determination usually takes place within 30 days of the
receipt of the application. Relative to applications for which addi-
tional information has been requested by the reviewing agency, there
is no timetable for the applicant's response. In the past, Region III
had no formal mechanism to track the status of an application in the
review process. Since the number of applications had grown and con-
tinued growth was expected, a formal tracking mechanism was warran-
ted. Newly submitted applications were entered into Region III status
tracking mechanism but the task of entering past applications into the
system was assigned to PES. By physical inspection of the PSD files
at Region Ill's offices, the status of all PSD applications submitted
prior to August, 1980 was determined and the "PSD Permit
Status/Checklist" form provided by Region III was completed. A dupli-
cate set of these completed forms can be found in Appendix N.
3.2 DETERMINATION OF SIGNIFICANT IMPACT RADIUS FOR PSD SOURCES
The PSD regulations require that each applicant must demonstrate
that the incremental increase in ground level concentrations, not only
from his own proposed source but also from other new sources which
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interact with it, do not exceed the applicable increments. Region III
personnel planned to construct a data base which would enable future
PSD sources to easily obtain information from previously permitted
sources.
Generally, the impact of a source on air quality as a function of
distance increases to a maximum amount and then exponentially
declines. U.S. EPA guidance has quantitatively determined air quality
values below which an individual source's impact can be considered
insignificant. The distance at which the source's contribution to air
quality becomes insignificant is the maximum distance at which a
source usually must be evaluated individually. The quantification of
the radius of significant impact is a vital datum for Region Ill's
data base.
PES proposed a methodology to establish the radius of significant
impact using dispersion modeling screening procedures and calculated
this radius for each PSD source in Region III which had been previ-
ously reviewed. It should be noted that for the various averaging
times corresponding to the averaging times for the air quality stan-
dards, a separate impact radius could be developed. PES did calculate
radii for each averaging time but only the most conservative for each
pollutant was included in the report. PES's full report which also
contains the dispersion modeling input parameters for each source is
attached as Appendix 0. For PSD sources reviewed by PES subsequent to
the preparation of this report, the radii of significant impact was
calculated and included with the application specific evaluation
report.
One additional minor assignment relating to the radius of signifi-
cant impact dealt with a specific source. The Firestone Plastic
Company located in Perryville, Maryland received a PSD permit for the
modification of their boilerhouse. The approved modification per-
mitted the construction of Boiler No. 3. However, the entire boiler-
house was subject to operating restrictions and emission limitations.
Originally, emissions from the entire boilerhouse were analyzed to
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determine the radius of significant impact. Emissions from new boiler
No. 3 were reexamined separately in a later subtask assignment.
Though significant, emissions from this boiler alone totaled less than
the cumulative emissions from the boilerhouse operating consistent
with its permitted restrictions. The reanalysis showed that the
radius of significant impact for sulfur dioxide remained unchanged at
50.0 km (the maximum distance permitted by the approved methodology).
The letter report to the Project Officer is attached as Appendix P.
3.3 DETERMINATION OF PSD BASELINE DATES
The concept of a PSD increment implies a starting point from which
the increment begins to be consumed. In the original PSD regulations
(June 19, 1978), a calendar date was used. In the present PSD regula-
tions, the baseline date is triggered by the first complete PSD appli-
cation after August 7, 1977. The PSD triggering source establishes a
pollutant specific baseline date for the geographic area in which it
is located and also for other intrastate areas on which it has a sig-
nificant air quality impact. The geographic areas used for baseline
areas are those defined by the states themselves pursuant to Section
107 of the Clean Air Act.
PES provided technical assistance by delineating the baseline
areas and the baseline dates associated with them. This was done on a
pollutant specific basis. The report dated December, 1980, which
presents the results of this assistance, is included in Appendix Q.
Included in this report are pollutant specific maps for each state in
Region III illustrating the baseline areas and their respective base-
line dates. Larger maps (approximately 2 ft x 3 ft in size) were
prepared for and presented to each state. A complete set of all the
states' maps in Region III were sent to the Project Officer for future
reference.
Subsequent to this report, individual states within Region III
realized that the Section 107 designation areas were larger in size
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than desired. Specifically, the Section 107 designations included
phrasing such as "remainder of AQCR" or "remainder of state." The
State of Virginia was the first to recognize this and prepared a rule-
making package to utilize the county unit as the basic Section 107
designation area. In July, 1981, PES completed a reanalysis of the
baseline areas and baseline dates for the State of Virginia on a
county by county basis consistent with the concurrent Section 107
redesignation effort. This report is included as Appendix R.
In a similar manner, rulemaking occurred relating to Section 107
redesignations for Allegheny County, Pennsylvania. The effects of the
redesignations on the baseline dates and areas were examined and dis-
cussed with the Project Officer during November, 1981. No formal
reports reflecting this assistance were prepared.
Lastly, the baseline areas and baseline dates were reexamined for
the States of Maryland and West Virginia. These two states have not
formally proposed to use a smaller geographic area. However, the use
of a "county" as the basic geographic area has been proposed by U.S.
EPA on a national level. To prepare for the anticipated smaller geo-
graphic area as the basic Section 107 designation area, PES reevalu-
ated the baseline areas and baseline dates for these two areas. Addi-
tionally, the reexamination of the baseline for these two states util-
ized additional information and/or new PSD permits which had become
available subsequent to the December, 1980 report. For each of these
states, three baseline area determinations were made using increas-
ingly smaller geographic areas. First, the analysis utilized the
Section 107 designation as codified in 40 CFR 81 (as of March 31,
1982). Second, the air quality control region (AQCR) was examined as
the basic geographic area. Lastly, a county-by-county baseline
assessment was performed. Additionally, if either the present Section
107 designations or the AQCR descriptions identified a sub-county
area, these smaller geographical entities were included in all three
analyses. Letter reports presenting the results of this assignment
are contained in Appendix S for the State of Maryland and
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Appendix T for the State of West Virginia. These letter reports
reference the December, 1980 report for the description of the method-
ology and present only the input data utilized and the conclusions.
3.4 PSD INCREMENT TRACKING "POSITION PAPER"
The basic concept of PSD is to manage air quality resources by
recognizing that degradation in air quality up to NAAQS uniformly
throughout the United States is not necessarily desirable. Therefore,
the PSD regulations set incremental limits on the degree of degrada-
tion that would be permitted in various geographic areas. The quanti-
fication of this increment was varied depending on the desirability to
keep certain areas pristine or to encourage maximum industrialization
(without exceeding the NAAQS) in others. In all cases, however, a
starting point (namely, the baseline date) was established from which
the cumulative impact on air quality from new or modified sources
"uses up" the available increment.
While the PSD regulations implicitly require tracking of increment
consumption, neither the Clean Air Act nor U.S. EPA's rulemakings
illustrate the mechanics of PSD increment tracking. The purpose of
this subtask assignment was to discuss various concepts as to how the
PSD increment could be tracked. The development of the mechanics to
implement any of the concepts presented in the report was beyond the
scope of this analysis. The Draft PSD increment tracking position
paper was completed in July, 1981. The dynamic situation of the PSD
regulation led to the decision that this position paper would not be
developed beyond the draft stage. A copy of this draft position paper
is presented in Appendix U.
3.5 IMPLEMENTATION OF THE PSD PROGRAM BY THE STATES
The PSD program is basically a specialized new source review. As
such, it is desirable for the states themselves to evaluate the PSD
application simultaneously with the states' existing new source review
process. The implementation of the PSD review can be performed by the
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state either by amending their State Implementation Plan to include
PSD regulations or by accepting delegation of authority to implement
the Federal PSD program in part or in its entirety. Several task
assignments were performed to assist in the transfer of the PSD pro-
gram to the states within Region III for implementation.
The first state to receive assistance from PES was the State of
Delaware. Delaware desired to implement the PSD program as part of
their approved SIP. The assistance was divided into two areas. The
first area of assistance was in the development of the PSD regulations
themselves. PSD regulations were written consistent with the require-
ments of 40 CFR 51.21. This rule was also prepared consistent with
the language and format of the Delaware regulations. A copy of
Section 3 of the Delaware Regulation XXV is included as Appendix V.
PES also assisted in responding to public comments received during the
State's rulemaking process. The letter report evaluating the public
comments received is included as Appendix W.
The second area of assistance to the State of Delaware was to
examine the State's new source review procedures and to establish a
similar system for the implementation of PSD review on the state
level. To this end, two products were developed. First, a flow chart
of the PSD review process was developed. This flowchart was intended
to clarify the PSD permit process both for the reviewer and for any
potential applicant. The flowchart was simplified in that no grand-
father provisions or potential exemptions were included. Inclusion of
these provisions would only complicate further an already complex
process and additionally, applicants who potentially qualify for such
exceptions would be the appropriate persons to present them to the
reviewer. The PSD review process flowchart is included in Appendix
X. The second product was a procedures manual and checklist. This
manual was designed to assist a reviewing engineer familiar with the
PSD regulations in the processing of a PSD application. This manual
was tailored specifically for the State of Delaware. The manual and
PSD checklist is duplicated in Appendix Y.
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The second state provided technical assistance in implementing the
PSD program was the State of Virginia. U.S. EPA developed a workshop
on PSD as an aid to train both their own personnel and the staff of
the state air agencies in the PSD review process. In the State of
Virginia, the regional air offices review new source application
within the district office with the assistance of personnel at the
centralized state office. Consequently, approximately 25 engineers
from the district offices needed training in the PSD review process in
order to effectively implement PSD review in the State of Virginia.
To train these engineers, a two day PSD workshop was conducted by PES
in Richmond, Virginia during January, 1981.
The last state receiving assistance in the implementation of the
PSD process on the state level was the State of West Virginia. For
West Virginia, a set of PSD regulations was developed for the rule-
making process for the eventual incorporation into the West Virginia
SIP. Actually, two versions of the PSD rule for West Virginia were
developed. First, the short version met the minimal requirements of
40 CFR 52.21. This version eliminated all exceptions and optional
sections permitted by the 40 CFR 52.21 language. This version, in
some cases, would be more stringent than the second or long version of
the PSD rule prepared. This long version included all optional sec-
tions of a PSD rule that would be approvable by U.S. EPA. Lastly, a
comparative table describing the differences between the two versions
of the PSD rule was developed. Both versions were written in the
"style" of the West Virginia statutes. The letter report presenting
the products of this technical effort to the West Virginia Air
Pollution Control Commission is contained in Appendix Z.
3.6 BASELINE EMISSION INVENTORY FOR THE WASHINGTON, D. C.
METROPOLITAN AREA
The evaluation of a new source application in a non-attainment
area requires the evaluation of emission offset requirements. In such
an offset assessment, the baseline emissions inventory must be known.
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This is especially true if the offsets are not provided by the pro-
posed new source but rather offsets are provided by the state through
regional reductions. Since a significant amount of emission inventory
work in the Washington, D. C. Metropolitan Area had been previously
performed by PES on pollutant emissions which are precursors to ozone,
PES was assigned a task to summarize and compile this data in a format
most useful for a baseline assessment. While this inventory will be
useful for all future EOP applications in the area, a sense of urgency
prevailed at the time of this assignment due to the fact that two new
sources in the Washington, D. C. Metropolitan Area subject to EOP were
being proposed. These sources, a resource recovery facility in
Montgomery County, Maryland and a co-disposal or sludge incinerator in
the District of Columbia, are critical parts of the solid waste
management plans for the area. Consequently, the summarization and
quality assurance review of the baseline inventory will enable
expeditious review of these applications. The inventory compilation
and quality assurance review is included in Appendix AA.
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I APPENDIX A
IDelmarva Power and Light Company
Vienna Unit No. 9 - Vienna, Maryland
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EVALUATION OF THE PREVENTION OF SIGNIFICANT DETERIORATION
APPLICATION FOR THE PROPOSED VIENNA GENERATING STATION - UNIT 9
OF THE DELMARVA POWER AND LIGHT COMPANY
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EPA Contract No. 68-02-2536
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Work Assignment No. 14
Robert Blaszczak - Task Manager
Thomas Blaszak - Project Manager
Eddy Lin - Principal Author
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July, 1980
Prepared for:
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I U.S. Environmental Protection Agency
Region III
Air Programs Branch
I Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
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Prepared by:
Pacific Environmental Services, Inc.
465 Fullerton Avenue
Elmhurst, Illinois 60126
(312) 530-7272
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EXECUTIVE SUMMARY
1.0 INTRODUCTION
On April 25, 1980, Delmarva Power and Light Company (DP&L) for-
warded to the U.S. Environmental Protection Agency (U.S. EPA), Region
III, an application for a permit under the Prevention of Significant
Deterioration (PSD) requirements of the Clean Air Act. DP&L proposes
to construct an additional power plant to DP&L's Vienna Power Station,
and will be designated Vienna Unit 9. Vienna Power Station is located
in Dorchester County, at Vienna, Maryland on the west bank of the
Nanticoke River. The proposed facility would consist of a coal-fired
5702 MBtu/hr electric utility steam generating unit and related coal
handling facilities. Potential emissions from the proposed boiler
are: 2.62 x 105 tons per year (TPY) particulate; 1.36 x 105 TPY
of SO.; 1.84 x 104 TPY of NO ; 1.02 x 103 TPY of CO; and 307
C' A
TPY of HC. Additionally, 2106 TPY of particulates would be generated
by potential fugitive "sources".
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2.0 BEST AVAILABLE CONTROL TECHNOLOGY (BACT)
On June 11, 1979, the U.S. EPA published a final rule on the New
Source Performance Standards (NSPS) for Electric Utility System Gener-
ating units. This recent promulgation represents BACT for the proposed
boiler. DP&L will use an electrostatic precipitator (ESP) to meet the
particulate emission of 0.03 Ib/MBtu. The NO emission limitation
/\
of 0.60 Ib/MBtu will be achieved through proper boiler design and
operation. HC and CO emissions are likewise controlled to BACT levels
by proper design and operation of the boiler.
For S0?, DP&L proposes a limestone flue gas desulfurization pro-
cess to meet the 90 percent control efficiency requirement. It should
be noted that the lower NSPS emission limit of 0.6 Ib/MBtu which
corresponds to less than 90 percent control efficiency would be the
required emission level. The control efficiency of SOp will vary
from about 89.4 percent when 3.5 percent sulfur content coal is
burned, to 84.6 percent when the average 2.5 percent sulfur content
coal is burned. Also, the use of low sulfur coal could result in
emissions less than 0.6 Ibs SOp/MBtu. In this case, a control
efficiency of at least 70 percent would be required. The proposed
system is BACT and for computational purposes, an emission limit of
0.6 Ibs S02/MBtu will be used.
For the control of fugitive particulate emissions, a dust suppres-
sion spraying system utilizing wetting agents and crusting agents is
proposed for the coal and limestone unloading and transferring. The
outdoor conveyors are provided with covers; additionally, each trans-
fer point is enclosed and connected to a bag filter collection system.
Fly ash that collects in the hoppers of the ESP is removed by a vacuum
fly ash handling system, which includes two stage mechanical collectors
and a bag filter. These are BACT if properly designed and operated.
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The BACT level of emissions incorporating the following emission
limitations is given in Table 1.
t 0.03 Ibs particulate/MBtu heat input
0.60 Ibs S02/MBtu heat input and a
minimum of 70 % control efficiency
0.60 Ibs NO /MBtu heat input
A
0.04 Ibs CO/MBtu heat input
0.01 Ibs HC/MBtu heat input
Additionally, an opacity limit for fugitive emissions of five per-
cent is recommended to insure that the dust suppression system is
operated and maintained at BACT levels.
Table 1. BACT EMISSIONS
Pollutant Ibs/hr Ibs/day TPY
TSP
S02
NOX
HC
CO
Fugitive Emissions (TSP)
171
3.42 x 103
3.42 x 103
66.3
222
4.10
8.21
8.21
1.59
5.33
x 103
x 104
x 104
x 103
x 103
749
1.50 x
1.50 x
290
974
98.6
104
104
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3.0 MONITORING REQUIREMENTS
Included in the NSPS are monitoring requirements. The requirements
are referenced along with additional recommendations for this proposed
installation.
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Section 60.47a -
I Continuous emission monitoring for opacity, SCL, and NO
Section 60.48a -
I Data requirements for the overall percent reduction in
_ Section 60:49a -
I Reporting requirements for malfunctions, excess emissions, etc.
I* A preventive maintenance program (with definitive record
requirements) for the ESP, FGD, boiler, and dust suppression
system.
I« The placement/use of sprayers, covers, etc. proposed for the
control of fugitive emissions shall be consistent with that
described in the application.
| t Records of flowrates/solution usage to verify that the wetting/
crusting agents are utilized according to the manufacturer's
mj recommendations.
0 Opacity resulting from all transfer points/storage piles should
not exceed five percent.
t All records should be maintained and available for inspection
for a period of two years.
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4.0 EFFECTS ON VISIBILITY, SOILS, AND VEGETATION
The detailed examination of the effects of the proposed Vienna
Power Plant on visibility as estimated as two percent additional haze
under the worst meteorological conditions. Injury to plants will not
result from the expected criteria pollutants deposition rates and trace
metals impact on soils in insufficient to effect vegetative growth.
It has been concluded that no significant deterioration will result.
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5.0 AIR QUALITY IMPACT
The existing air quality in the region of interest is attainment
and is of sufficiently low baseline value such that the entire PSD
increments are available for the proposed power plant. The applicant
is the first in the area and has used acceptable U.S. EPA computer
dispersion modeling techniques (namely the CRSTER, CDMQC and PAL
models) to demonstrate that the maximum predicted impacts from the
proposed power plant will not exceed the PSD increments nor cause or
contribute to a violation of the NAAQS.
In a separate analysis, the use of a good engineering stack height
is proposed, and lastly, since there are no Class I areas within 100
kilometers, no impact is foreseen.
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* EVALUATION OF THE PREVENTION OF SIGNIFICANT DETERIORATION
APPLICATION FOR THE PROPOSED VIENNA GENERATING STATION - UNIT 9
OF THE DELMARVA POWER AND LIGHT COMPANY
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1.0 INTRODUCTION
On April 25, 1980, Delmarva Power and Light Company (DP&L) for-
warded to the U.S. Environmental Protection Agency (U.S. EPA), Region
III, an application for a permit under the Prevention of Significant
Deterioration (PSD) requirements of the Clean Air Act. DP&L proposes
to construct an additional power plant to DP&L's Vienna Power Station,
and will be designated Vienna Unit 9. Vienna Power Station is located
in Dorchester County, at Vienna, Maryland on the west bank of the
Nanticoke River. The proposed facility would consist of a coal-fired
5702 MBtu/hr electric utility steam generating unit and related coal
handling facilities.
Major emissions will result from the combustion of coal in the
boiler and from the handling of the coal and limestone. The potential
5
emissions from the coal-fired boiler are: 2.62 x 10 tons per year
(TPY) particulate; 1.36 x 105 TPY of S02; 1.84 x 104 TPY of
NO: 1.02 x 103 TPY of CO; and 307 TPY of HC. The potential fugi-
J\
tive emissions from coal and limestone handling operations are 2106
TPY of particulates.
An auxiliary boiler will be fired with No. 2 fuel oil, which will
be used to start up the boiler prior to burning of coal. It will also
be used as a source of ignition for coal. Because of this use and the
fact that normal operations of the coal-fired unit is the maximum
emissions "worst case," it will not be considered any further.
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2.0 ANALYSIS OF EMISSIONS
The calculations of potential emissions from a 5702 MBtu/hr boiler
combusting bituminous coal is based on the AP-42 emission factors.
The maximum coal firing rate of 234 tons/hr is used. This will result
in a maximum value for potential emissions and as such, is higher than
the emissions estimated in the application. These potential emissions
for all five criteria pollutants are listed in Table 1.
Table 1. UNCONTROLLED EMISSIONS
Pollutant Ibs/hr Ibs/day TPY
P articulate
so2
N0v
X
CO
HC
5.99 x 104
3.11 x 104
4.21 x 103
234
70.2
1.44 x 106
7.46 x 105
1.01 x 105
5.62 x 103
1.68 x 103
2.62 x 105
1.36 x 105
1.84 x 104
1.02 x 103
307
Additionally, uncontrolled fugitive particulate emissions will
result from the handling of coal and limestone. These potential emis-
sions are 2106 TPY particulates. Details of these estimates are given
in Appendix A by the reproduction of Table 2-3 of DP&L's application.
The emission estimates listed in this table, however, were indepen-
dently verified.
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3.0 BEST AVAILABLE CONTROL TECHNOLOGY
3.1 PARTICIPATES, SULFUR DIOXIDE. AND NITROGEN OXIDES
On June 11, 1979, the U.S. EPA published a final rule on the New
Source Performance Standards (NSPS) for Electric Utility Steam Gener-
ating Units. This standard reflects the use of Best Available Control
Technology (BACT) for the proposed Unit 9 at the Vienna Station.
Briefly, the following emission limits are applicable for this unit.
Particulate* 0.03 Ib/MBtu heat input.
Sulfur Dioxide 90% emission reduction, and a maximum emission
limitation of less than 1.20 Ibs/MBtu heat
input or if controlled emissions equal to or
less than 0.60 Ib/MBtu heat input, a minimum
of 70% emission reduction required.
Nitrogen Oxide* 0.60 Ib/MBtu heat input.
*Note: Percent reduction requirements for particulates and nitrogen
oxides are deemed met if the emission limitation is complied
with.
For the control of particule emissions, DP&L Service Corporation
proposes to utilize an electrostatic precipitator of 99.65 percent
collection efficiency. This control device does reflect BACT, but the
emission rate at control efficiency 99.65 percent with the worst situa-
tion coal (16 percent ash content, 11800 Btu/lb higher heat value of
coal used) will not meet the NSPS emission limitations. The NSPS
emission limitations can be achieved by using lower ash content coal
(less than 12.6 percent ash) or increasing the ESP control efficiency
up to 99.73+ percent. The proposed control device should be capable
of achieving this efficiency for the worst case coal. The applicant
does specify that the ESP will meet the emission rate of 0.03 Ib/MBtu
irrespective of the ESP's control efficiency. The controlled parti-
culate emissions at 0.03 Ib/MBtu are 171 Ibs/hr; 40.10 x 103 Ibs/day;
and 749 TPY.
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For the control of sulfur dioxide emissions, DP&L proposes a
limestone flue gas desulfurization system with a control efficiency of
90 percent. This control equipment does reflect BACT and will meet
the NSPS emission limitation. The controlled sulfur dioxide emissions
at the NSPS emission limitation at 0.6 Ib S02/MBtu are 3.42 x 10
Ibs/hr; 8.21 x 104 Ibs/day; and 1.50 x 104 TPY (Note DP&L is not
required to achieve an emission limit of less than 0.6 Ibs SOp/MBtu
as long as the control efficiency is at least 70 percent).
For the control of nitrogen oxides, BACT is simply the proper de-
sign and operation of a boiler incorporating combustion modification
techniques to reduce NO emissions. The boiler manufacturer has not
A
yet been selected; however, major boiler manufacturers have indicated
that they will provide a guarantee to meet a NO emission limitation
/\
of 0.6 Ib/MBtu. At this emission rate, the controlled emissions will
be 3.42 x 103 Ibs/day; 8.21 x 104 Ibs/day; and 1.50 x 104 TPY.
3.2 HYDROCARBONS AND CARBON MONOXIDES
At the present time, there are no mechanisms to control HC and CO
other than the proper design and operation of the boiler. For economic
reasons, DP&L will see that this is done. Therefore, BACT emissions
for HC at 0.012 Ib HC/MBtu will be 68.4 Ibs/hr; 1.64 x 103 Ibs/day;
and 300 TPY. BACT emissions for CO at 0.04 Ib/MBtu will be 228 Ibs/hr;
5.47 x 103 Ibs/day; and 999 TPY.
3.3 FUGITIVE PARTICULATE EMISSIONS
DP&L proposes to utilize a dust suppression system and crusting
agent for the control of fugitive emissions from coal or limestone
unloading and storage pile. Additionally, each transfer point is
enclosed and connected to a dust collection system. An exhaust fan
draws air through an opening in each enclosure and captures airborne
dust particles. The dust-laden air flows to a high-efficiency pulse
jet bag filter. The drawing in DP&L's application illustrates that if
the system installed at all points identified and properly operated,
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BACT will be implemented. The recommended opacity requirement preven-
tive maintenance program, and recordkeeping requirements will insure
that the BACT requirement. No further review as a permit condition is
required. The controlled emissions resulting from these fugitive dust
control techniques will be 99 TRY.
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4.0 MONITORING AND EMISSION LIMITATION RECOMMENDATIONS
To ensure the continued maintenance of BACT and level of emissions
as proposed, the following emission limitations are recommended:
0.03 Ib Particulate/MBtu heat input
0.60 Ib S02/MBtu heat input and a
minimum of 70% control efficiency
0.60 Ib NOx/MBtu heat input
0.04 Ib CO/MBtu heat input
0.01 Ib HC/MBtu heat input
The NSPS requires substantial monitoring and reporting require-
ments for this proposed boiler. Section 60.47a describes the require-
ments and equipment specifications for the continous monitoring of
opacity, S09, and NO . Section 60.48a describes the procedures
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for the calculation of the overall percent reduction in SO^. Lastly,
Section 60.49a contains the specific reporting requirements on mal-
functions, excess emissions, etc. Additionally, the following recom-
mendations are made:
A preventive maintenance program should be established not only
for the ESP, FGD scrubber, and boiler, but also for the dust
suppression system.
t Wetting agents and crusting agents should be used at the manu-
facturer's recommended dilution ratios.
Records should be maintained to establish proper usage of the
wetting/crusting agents in the dust suppression system (i.e.,
dilution/consumption rates, purchase records, etc.).
The placement/use of sprayers, covers, etc. proposed for the
control of fugitive emissions shall be consistent with that
described in the application.
Opacity resulting from all transfer points/storage piles should
not exceed five percent.
All records should be maintained and available for inspection
for a period of two years.
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5.0 DISPERSION MODELING PARAMETERS
The input parameters for a Gaussion dispersion model using the
emission limits recommended are:
Particulates - 171.1 Ibs/hr (21.55 g/sec)
t S02 - 3421 Ibs/hr (431.06 g/sec)
NOX - 3421 Ibs/hr (431.06 g/sec)
t CO - 222 Ibs/hr (27.97 g/sec)
Stack height - 530 ft (161.42 m)
Stack diameter - 26.6 ft (8.12 m)
Stack gas exit velocity - 40 ft/sec (12.19 m/sec)
t Stack gas exit temperature - 105°F (313.55°K)
The emission rates are appropriate for both the short-term and
annual model since this reflects operations whenever the boiler is
operational. An area source inventory cannot be developed from the
information available. The Appendix lists and quantifies the fugitive
emissions. However, the plot plan available in this application is of
insufficient scale to adequately quantify the juxtapositions of the
fugitive emission sources and the stack.
-7-
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6.0 AIR QUALITY IMPACTS
The air quality impact analysis of this application was done
independently by Region III staff. The results of this analysis are
summarized in a memo dated May 30, 1980 from Mr. Larry Budney to Jim
Sydnor through Lew Felleisen (see Appendix B).
Briefly, the applicant used approved U.S. EPA computer dispersion
models (namesly, CRSTER, CDMQC, and PAL) and acceptable techniques to
demonstrate that the proposed power plant will not exceed the avail-
able PSD increments (100 percent were available) and not cause or
contribute to a violation of the NAAQS.
Additionally, the use of good engineering stack height has been
adequately demonstrated. Finally, since there are no Class I areas
within 100 km, there will be no effect from the proposed power plant.
-8-
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7.0 VISIBILITY, SOIL, AND VEGETATION IMPACT
The effect of air pollutants associated with Vienna Unit 9 on
visibility, vegetation, and soil have been reviewed. It is concluded
that there are no significant impairment to visibility, vegetation,
and soil from Vienna Unit 9. The details of this review are discussed
below.
7.1 VISIBILITY
Visibility is determined by an observer looking around the horizon
and noting whether he can identify known landmarks or lights. It is
readily admitted that subjective factors can influence the visibility.
Even the reduction of visibility over a given region, it doe not
necessarily indicate air pollutant unless fog, marine, haze, blowing
dust, and other natural phenomena can be ruled out.
The visual impact from Vienna Unit 9 can be broadly classified
into plume visibility and regional haze. The opacity of the plume
near the stack exit is expected to be less than 20 percent, the NSPS
emission limitation. The visibility reduction caused by regional haze
under worst meteorological conditions is estimated about two percent
at 200 km downwind of the site.
The plume visibility is usually short-lived and local and two per-
cent visibility reduction from regional haze is a relative comparison
figure. Therefore, the overall effects of visibility from Vienna
Unit 9 are minor.
7.2 IMPACT ON VEGETATION
7.2.1 SULFUR DIOXIDE
Ground level SO^ concentrations from concurrent operation of
Vienna Units 8 and 9 were predicted using the CRSTER model with
meteorological data for the years 1973 through 1977. The highest/
-9-
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second-highest, 3-hour concentration of 389.3 ug/m occurred 1.0 km
east of the site, based on 1975 meteorological data. This highest
ground level SO^ concentration is less than 442 ug/m , the 3-hour
S0? threshold value for injury to soybeans and pine, which are the
two most important species in the Vienna area. Therefore, no injury
to vegetation from SO^ is expected.
7.2.2 NITROGEN OXIDES
The maximum 3-hour and 24-hour N02 levels calculated for Vienna
Unit 9 are 0.18 and 0.03 ppm, respectively. The 3-hour and 24-hour
N02 threshold values for injury to vegetation are 1.0 ppm and 0.4
ppm, respectively. Since the maximum expected values are below the
threshold values, no injury to vegetation from NO is expected.
/\
7.2.3 PARTICULATES
The maximum predicted TSP concentrations within 25 km of Vienna
3
Unit 9 is 55.2 ug/m . This TSP concentration is much lower than the
824 ug/m , and average concentration associated with the injury to
plants. Therefore, no injury to vegetation from TSP is expected from
Vienna Unit 9.
7.3 IMPACT ON SOIL
Soil can remove both S0? and N0? directly from the atmosphere
by absorption. The primary effect of SO,, and NO^ absorption by
soil is a reduction in soil pH, a slow process compared to the other
acid-forming processes, since both NOp and S02 are essential
plant nutrients, any small accumulation of these elements in the soil
would not be expected to cause harm to vegetation. Particulate
deposition may affect soil by changing pH and by increasing levels of
heavy metals. From the study of the Department of Interior
(FWS/OBS-78/29), the trace elements added to the soil through power
plant particulate deposition over the life of the plant were much less
than the average endogeneous levels. Therefore, the effects of parti-
culate deposition to the soil are minor.
-10-
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8.0 DETERMINATION OF THE AREA OF SIGNIFICANT IMPACT
The assessment of increment consumption must include all sources
which have been constructed since the baseline date. In order to
enable future sources to more easily obtain information on previously
approved PSD sources which could potentially interact with the appli-
cant's proposed source, Region III is preparing a data file to assist
in identifying potentially interacting sources which have (or are in
the process of obtaining) approved PSD permits. This report provides
the needed data on the maximum distance from which this source need
not be considered as potentially interacting for the Vienna Power
Plant, located in Dorchester County, at Vienna, Maryland.
8.1 METHODOLOGY
In order to assess the area of impact, the screening procedures as
described in the U.S. EPA "Guidelines on Air Quality Modeling" were
followed. Briefly, the PTMAX model of the UNAMAP package, together
with time correction factors (Ref: D.B. Turner, Workbook on Atmos-
pheric Dispersion Estimates) was used to determine a radius of signi-
ficant impact for this PSD source. The significant impact area is
defined as that area where ambient air pollutant concentrations equal
or exceed the following levels:
AVERAGING TIME
Pollutant
so2
TSP
N02
CO
Annual
q
1 ug/m
1 ug/m
1 ug/m
24-Hour
3
5 ug/m
5 ug/m
--
8-Hour
__
0.5 ug/m3
3-Hour
7
25 ug/m"3
--
1-Hour
-_
__
2 ug/m3
The boundary of the area of significant impact shall extend up to a
maximum of 50 kilometers from the source.
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While these proposed models may not be appropriate for quantifying
impact in complex terrain, they will be used since, for determining a
radius of impact, they are conservative. Since the Region III data
base will be used for identification of potential interacting sources
rather than quantification of the impact, the conservative radius
resulting from the assumption of flat terrain is desirable.
8.2 DISPERSION MODELING PARAMETERS
The input parameters for a Gaussion dispersion model for the
Vienna Power Plant permitted using the emission limits are:
t Particulates - 171.1 Ibs/hr (21.55 g/sec)
S02 - 3421 Ibs/hr (431.06 g/sec)
N0x - 3421 Ibs/hr (431.06 g/sec)
CO - 222 Ibs/hr (27.97 g/sec)
t Stack height - 530 ft (161.42 m)
Stack diameter - 26.6 ft (8.12 m)
Stack gas exit velocity - 40 ft/sec (12.19 m/sec)
t Stack gas exit temperature - 105°F (313.55°K)
The emission rates are appropriate for both the short-term and
annual model since this reflects operations whenever the boiler is
operational.
8.3 SIGNIFICANT IMPACT AREA
The significant impact area by pollutant and averaging time is
presented in the following table:
AVERAGING TIME
Pollutant Annual 24-Hour 8-Hour 3-Hour 1-Hour
S02 50 km 50 km 40 km
TSP 6.1 km 3.1 km
N02 50 km
CO 50 km 37 km
-12-
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8.4 GOOD ENGINEERING PRACTICE STACK HEIGHT
The evaluation of the use of a good engineering practice (GEP)
I height was performed in-house by Region III staff (see Appendix B).
The proposed power plant will use a GEP stack.
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APPENDIX A
EMISSION CALCULATIONS
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POTENTIAL EMISSIONS FROM BOILER
Based on the following assumptions:
AP-42 Emission Factors (Table 1.1-2)
Bituminous Coal of 3.5 percent sulfur and 16 percent ash
General type pulverized coal (boiler type is not available)
Maximum feed rate of coal: 234 ton/hr
Particulate
AP-42 Emission Factor - 16 A* Ibs/ton coal burned
16 (16 percent)(234 ton/hr) = 5.99 x 104 Ibs/hr
(5.99 x 104 lbs/hr)(24 hrs/day) = 1.44 x 106 Ibs/day
(1.44 x 106 lbs/day)(365 days/yr) = 2.62 x 105 TPY
2000 Ibs/ton
*A indicates the weight percentage of ash in the coal
Sulfur Dioxide
AP-42 Emission Factor - 38 S** Ibs/ton coal burned
38 (3.5)(234) = 3.11 x 104 Ibs/hr
(3.11 x 104 lbs/hr)(24 hrs/day) = 7.46 x 105 Ibs/day
(7.46 x 105 Ibs/day)(365 days/yr) = 1.36 x 105 TPY
2000 Ibs/ton
**S indicates the weight percentage of sulfur in the coal.
Nitrogen Oxide
AP-42 Emission Factor - 18 Ibs/ton coal burned
18 Ibs/ton x 234 ton/hr = 4.21 x 103 Ibs/hr
(4.21 x 103 Ibs/hr)(24 hrs/day)(365 days/yr) = 1.84 x 104 TPY
2000 Ibs/ton
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_ Carbon Monoxide
AP-42 Emission Factor - 1 Ibs/ton coal burned
- 1 Ibs/ton x 234 tons/hr = 234 Ibs/hr
(234 lbs/hr)(24 hrs/day)(365 days/yr) = 1.02 x 103 TRY
2000 Ibs/ton
Hydrocarbons
| AP-42 Emission Factor - 0.3 Ibs/ton coal burned
0.3 Ibs/ton x 234 ton/hr = 70.2 Ibs/hr
| (70.2 lbs/hr)(24 hrs/day)(365 days/yr) = 307 TRY
2000 Ibs/ton
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CONTROLLED EMISSIONS
Based on the following design data:
Design heat input to boiler 5702 x 10 Btu/hr
HHV of coal - 12900 Btu/lb
BACT Emission Limit
AP-42 Emission Factors (Table 1.1-2)
Part icu late
BACT Emission Limit - 0.03 Ibs/MBtu
(0.03 Ibs/MBtu) (5702 x 106 Btu/hr) = 171. Ibs/hr
(171 lbs/hr)(24 hrs/day)(365 days/yr) = 749 TRY
2000 Ibs/ton
Sulfur Dioxide
AP-42 Emission Factor 38 S (sulfur content of coal)
Worst case:
HHV of coal 11,800 Btu/lb
Sulfur content 3.5 percent
(38 lbs/ton)(3.5% S)(106 MBtuHlbs S0n/ton coal)
*_
(11,800 Btu/lb coal)(2000 Ibs/ton)
= 5.64 Ibs S00/MBtu
L.
Average case:
HHV of coal 12,200 Btu/lb of coal
Sulfur content 2.5 percent
c
(38 lbs/ton)(2.5% S)(10D MBtu)(lbs S00/ton coal)
(12,200 Btu/lb) (2000 Ibs/ton)
= 3.89 Ibs SO,/MBtu
c
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Optimum case:
HHV of coal 12,900 Btu/lb of coal
Sulfur content 0.8 percent
(38 lbs/ton)(0.8% S)(106Btu)(lbs SO^/ton coal)
(12,900 Btu/lb}(2000 Ibs/ton)
= 1.18 IDS S02/MBtu
For the worst and average cases, 90 percent control efficiency would
reduce the emission limits to 0.56 Ibs S02/MBtu and 0.393 Ib/MBtu,
respectively. The NSPS standard, however, does not require the
emission limit to be less than 0.60 Ibs S02/MBtu as long as the
control efficiency is a minimum of 70 percent for these cases, the
0.60 Ibs S02/MBtu would be the applicable emission limitation. In
the optimum case, however, an emission limit of 0.60 Ibs 502/MBtu
can be achieved with a control efficiency of only
1>18 " °-60 x 100 = 49.2*
1.18
In this instance, the NSPS requirement of a minimum of 70 percent
control efficiency (0.35 Ibs/MBtu) would be the ruling factor. For
the purposes of calculating controlled emissions, the highest possible
allowed emission rate of 0.60 Ibs SOp/MBtu will be used.
5702 MBtu/hr x 0.6 Ib/MBtu = 3.42 x 103 Ibs/hr
(3.42 x 103 lb/hr)(24 hrs/day)(365 days/yr) =
2000 Ibs/ton
Nitrogen Oxide
BACT Emission Limit - 0.6 Ib/MBtu
5702 MBtu/hr x 0.6 Ib/MBtu = 3.42 x 103 Ibs/hr
(3.42 x 103 lbs/hr)(24 hrs/day)(365 days/yr) = 1.50 x 104 TPY
2000 Ibs/ton
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Carbon Monoxide
AP-42 Emission Factor - 1 Ib/ton coal burned
(1 1b/ton)(106 Btu/MBtu) = 0.039 Ibs/MBtu
_ (12900 Btu/lb)(2000 Ibs/ton)
5702 MBtu/hr x 0.039 Ibs/MBtu = 222 Ibs/hr
(222 1bs/hr)(24 hrs/day)(365 days/yr) = 974 TRY
2000 Ibs/ton
Hydrocarbons
AP-42 Emission Factor - 0.3 Ibs/ton coal burned
* (0.3 lbs/ton)(106 Btu/MBtu) = 0.012 Ibs/MBtu
(12900 Btu/lb)(2000 Ibs/ton)
_ 0.012 Ibs/MBtu x 5702 MBtu/hr =66.3 Ibs/hr
(66.3 1bs/hr)(24 hrs/day)(365 days/yr) = 290 TRY
| 2000 Ibs/ton
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I APPENDIX B
MEMO CONCERNING AIR QUALITY IMPACTS
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Modeling Review of PSD Application for
Deliaarva Power's Vienna Unit 9
Larry Budney
Air Analysis & Energy Section (3AH13)
Jlo Sydnor, Chief
DC, MD, VA Section (3AH11)
THRU: Lew Pelleisen, Chief
Mr Analysis & Energy Section (3AH13)
The PSD application for the Delmarva Power and Light Company Vienna Unit
9 has been reviewed. The application is complete from a modeling
perspective. EPArecommended models are used, and the analysis shows
that the air quality inpact of Vienna Unit 9 is well within available
PSD increments. Maximum air quality inpact of Vienna Unit 9 in con-
junction with the impact of all other sources affecting the area is well
below the applicable NAAQS.
According to the application (p. 6-2) and recent input from Bob Blaszczak,
there have been no other PSD permit applications for any source within
the impact area of Vienna Unit 9. Also, the baseline concentrations for
S02 and TSP added to the maximum allowable PSD increments result in air
quality levels within the HAAQS. Therefore the full PSD increments are
available to Vienna Unit 9. The entire area within 50 kilometers of the
proposed source is designated Class II. There are no Class I areas
within 100 kilometers.
Fortunately, terrain is flat within 50 kilometers of the proposed
source. The EPA CRSTER, CCMQC and PAL models were used in the air quality
analysis. Five years of hourly surface meteorological data from Salisbury,
Maryland were used as input to the analysis. A GEP analysis was cotxductec
to justify the proposed stack height of 530 feet. Apparently, only
maximum (full-load) emission rates were assumed throughout the analysis.
(That should be verified in the engineering review.) However, even
through 50% and 75% full load conditions were not considered, that
should pose no problem because the estimated air quality impacts from
Vienna Unit 9 are low enough that even if a 10 or 20 percent increase in
impact were to occur under less than full-load conditions, the resulting
air quality impact would still be within the PSD increments.
According to the application, pre-construction monitoring is not required
in this case, as per a November 11, 1979 letter froii you to
Janes I. Owens of Delmarva Power. Thus, other than the question I
taentioned above concerning the assumed emission rate (the maximum rate
should have been assumed), I see no problems with the modeling and air
quality aspects of tlie application.
cc: V. Butler (3AH11)
L. Pelleisen (3AII13)
LBUDNEY:dpg:3AH13:5-30-80
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I APPENDIX B
_ Delmarva Power and Light Company
Vienna Unit No. 9 - Vienna Maryland
Public Comment Review
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Oi GST HBP
PACIFIC ENVIRONMENTAL SERVICES. INC.
April 9, 1981
Mr. Robert J. Blaszczak
Air Programs Branch
U.S. EPA, Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania
Dear Mr. Blaszczak:
I OS ANGf-LES CA
CHICAGO ILL
RfcSfARCH TRlANGLf PARK NC
WASHINGTON DC
19106
Pacific Environmental Services, Inc. (PES) has reviewed the following
comments received concerning BACT at the proposed Delmarva Power and
Light Company's Vienna Unit No. 9:
Letter dated November 15, 1980 from Mr. and Mrs. Allen T. Hurley
t Applicant's response dated February 23, 1981 prepared by Mr.
Donald P. Irwin of Hunton and Williams
The comments received do not address BACT directly but express a con-
cern that average sulfur content of the coal rather than the peak
sulfur content was utilized in reaching some of the conclusions in the
analysis. With respect to BACT for sulfur dioxide (the only pollutant
affected), both values were considered. The emphasis, however, in the
review was the peak condition since this reflects maximum emissions.
The recommended BACT emission limitation not to exceed 0.60 Ibs.
S02/MBtu and a minimum of 70 percent S02 removal efficiency will
be achieved both using 3.5 percent sulfur coal (the extreme condition)
and 2.5 percent sulfur coal (the average condition). This coal is the
design coal and should Delmarva Power and Light utilize significantly
different fuel, the scrubbing system's design should be reviewed to
insure its capability to achieve the BACT emission limits. The limits
themselves would still reflect BACT.
In conclusion, the comments reviewed do not alter PES1 initial conclu-
sion that BACT will be utilized at the proposed source.
Sine
Project Manager
Midwest Operations Division
TPB/cas/453
MIDWEST OPERATIONS 465 Fullerton Ave. Elmhurst, ILL 60126 (312) 530-7272
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APPENDIX C
Domtar Industries, Incorporated
Bellefonte, Pennsylvania
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EPA Contract No. 68-02-2536
Work Assignment No. 14
EVALUATION OF THE PREVENTION OF SIGNIFICANT
DETERIORATION APPLICATION FOR THE PROPOSED
NO. 1 ROTARY LIME KILN AT THE
LIME PLANT OF DOMTAR INDUSTRIES, INCORPORATED,
LOCATED IN BELLEFONTE, CENTRE COUNTY, PENNSYLVANIA
Robert Blaszczak - Task Manager
Thomas P. Blaszak - Project Manager
February, 1981
Prepared for:
U.S. Environmental Protection Agency
Region III
Air Programs Branch
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Prepared by:
Pacific Environmental Services, Inc.
465 Fullerton Avenue
Elmhurst, Illinois 60126
(312) 530-7272
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EXECUTIVE SUMMARY
1.0 INTRODUCTION
On November 30, 1978, Domtar Industries, Inc. forwarded to the
U.S. Environmental Protection Agency (U.S. EPA), Region III, an appli-
cation for a permit under the Prevention of Significant Deterioration
(PSD) requirements of the Clean Air Act. Additional information was
submited by Domtar in correspondence dated May 7, 1980, October 10,
1980, November 17, 1980, and January 29, 1981.
Briefly, Domtar Industries, Inc. proposes to expand the lime pro-
duction capacity at its Beliefonte Lime Plant in Centre County, Penn-
sylvania. The proposed project includes the rehabilitation of the No.
1 coal-fired rotary kiln at this plant to produce quick lime. In
mid-1979, U.S. EPA determined that this reactivation is a major modi-
fication requiring a PSD permit.
On August 7, 1980 (45 CFR 52676), U.S. EPA finalized the new PSD
regulations. However, Section 52.21(i)(9) and Section 52.21(i)(10)
state that a source submitting a complete application prior to
August 7, 1980 are not subject to some of the new requirements, but
instead, are subject to the "old PSD requirements" (June 19, 1978
rules). Domtar Industries, Inc. was determined to be substantially
complete prior to that date and was therefore reviewed in accordance
with the "old PSD requirements" for "Control Technology Review and Air
Quality Monitoring." Potential emissions from Domtar Industries'
proposed modification are given in Table 1.
As shown in Table 1, emissions of sulfur dioxide, nitrogen oxide,
and carbon monoxide exceed the 50 tons/year (TPY), 1000 Ibs/day, or
100 Ibs/hr criteria of Section 52.21(g) of the June 19, 1978 PSD regu-
lations. Therefore, these pollutants are subject to BACT review,
while particulates are subject to NSPS and Pennsylvania rules only.
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. Table 1. POTENTIAL EMISSIONS*
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TSP
S02
cox
Annual
(TPY)
16.2
101.1
134.7
89.8
Daily
(Ibs/day)
88.6
551.2
738.0
492.0
Hourly
(Ibs/hr)
3.69
23.09
30.75
20.50
Consistent with the August 7, 1980 promulgation, and are based on the
limitations recommended as permit conditions.
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2.0 BEST AVAILABLE CONTROL TECHNOLOGY
2.1 PARTICULATES
Although not administratively required by the PSD regulations,
Domtar Industries will be installing baghouses to control particulate
emissions. This is BACT for lime kilns.
2.2 SULFUR DIOXIDE
To control sulfur dioxide emissions, a two-fold approach is proposed.
First, the sulfur content of the coal used to fire the kilns will be
limited to 1.96 percent sulfur and secondly, 90 percent of the sulfur
dioxide will be removed by the baghouse. To insure this level of sulfur
dioxide emission in the baghouse by the "lime dust" interacting with the
SOp in the exhaust gas, design operational parameters of the baghouse
will be monitored and maintained. This is BACT for S02-
2.3 NITROGEN OXIDES AND CARBON MONOXIDE
At the present time, no add-on technology or process modifications
exist to reduce NO and CO emissions. BACT for these pollutants is
/\
simply the proper design and operation of the kiln. BACT for NO
^
and CO is proposed by Domtar Industries.
2.4 BACT EMISSION LIMITS
Emission limits which reflect BACT are:
o 0.18 Ibs particulate/ton limestone feed
o 1.13 Ibs S02/ton limestone feed
o 1.50 Ibs NO /ton limestone feed
J\
o 1.00 Ibs CO/ton limestone feed
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3.0 MONITORING AND OTHER REQUIREMENTS
The NSPS and Pennsylvania rules require substantial monitoring and
reporting requirements for this proposed kiln. Section 60.343(a)
describes the requirements and equipment specifications for the con-
tinuous monitoring of opacity. Section 60.343(e) contains the specific
reporting requirements on malfunctions, excess emissions, etc. These
specific requirements are in addition to the general NSPS requirements
contained in Sections 60.7 through 60.11.
Additionally, the following recommendations are made:
o Daily coal samples will be taken and analyzed for sulfur
content and combined to demonstrate that the weekly-weighted
sulfur percentage of the coal does not exceed 1.96 percent.
o Simultaneous compliance tests should be required for S0£
(U.S. EPA Method 8) both upstream and downstream of the bag-
house to demonstrate 90 percent removal efficiency. This test
should be redone whenever a cumulative 50 percent of the bags
have been replaced.
o The compliance tests described above should establish the
operating procedures associated with 90 percent S02 removal
efficiency. The pressure drop and cleaning cycles (or equiva-
lent measurable operating parameters) associated with this
level of control should be monitored.
o A preventive maintenance program should be established for the
baghouse and maintenance procedures be established to minimize
fugitive emissions. Such a program (applicable to Kiln Nos. 2
and 3 at this Belefonte facility) is described in Section 3 of
a Consent Decree dated October 3, 1979 between Domtar Indus-
tries, Inc. and the Commonwealth of Pennsylvania. A copy is
included in Appendix B.
Lastly, the demonstration for the attainment of the NAAQS and
preservation of the increments require that the existing Kiln Nos. 2
and 3 not exceed the following emission limitations:
o 0.18 Ibs particulate/ton limestone feed
o 1.36 Ibs S02/ton limestone feed
o 1.50 Ibs NO /ton limestone feed
o 1.00 Ibs CO/ton limestone feed
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4.0 EFFECTS ON VISIBILITY, SOIL, AND VEGETATION
The effects of other impacts resulting from Domtar Industries,
Inc.'s proposed lime kiln are not adequately addressed in the appli-
cation. However, the proposed construction does not change the lime
producing capability which had previously existed at this facility.
The reactivation will have better controls than previously existed and
the emission limitations and monitoring requirements will insure non-
degradation of the controls not only of the new re-construction, but
also of the additional existing kilns. These facts together with the
present industrialization of the local area do not present any signi-
ficant impact provided all air quality standards are met.
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5.0 AIR QUALITY IMPACTS
Briefly, the applicant's consultant, Dames and Moore, Inc. used
two U.S. EPA computer dispersion models, VALLEY and ISC, to show that
neither the NAAQS nor the PSD increments will be violated. The VALLEY
model was appropriate for the rough terrain locale where Domtar's
Bellefonte facility is located. The mode was appropriately used to
demonstrate attainment of all air quality standards. The ISC model
was employed to demonstrate that Kiln No. 1's physical dimensions
would not interact with the exhaust gases from other existing stacks
at this facility so as to cause excessive off-property ground level
concentrations resulting from downwash. The stack for Kiln No. 1 was
demonstrated to be of good engineering practice design using the
formulas in U.S. EPA's proposed "Tall Stack" policy.
Finally, the nearest Class I area to Domtar, Inc.'s facility is
the Shenandoah National Park in Virginia, located over 200 km away.
There are no significant impacts on the area from the Domtar facility.
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EVALUATION OF THE PREVENTION OF SIGNIFICANT
DETERIORATION APPLICATION FOR THE PROPOSED
LIME PLANT OF DOMTAR INDUSTRIES, INCORPORATED,
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NO. 1 ROTARY LIME KILN AT THE
fT OF DOMTAR INDUSTRIES, INCOR
LOCATED IN BELLEFONTE, CENTRE COUNTY, PENNSYLVANIA
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1.0 INTRODUCTION
On November 30, 1978, Domtar Industries, Incorporated forwarded to
the U.S. Environmental Protection Agency (U.S. EPA), Region III, an
application for a permit under the Prevention of Significant Deteriora-
tion (PSD) requirements of the Clean Air Act. Additional information
was submitted on May 7, 1980, October 10, 1980, November 17, 1980, and
January 29, 1981. The application, however, was determined to be
complete prior to August 7, 1980. Briefly, Domtar Industries, Inc.
proposed to expand the lime production capacity at its Bellefonte Lime
Plant in Centre County, Pennsylvania. The proposed project includes
the rehabilitation of No. 1 coal-fired rotary lime kiln. In mid-1979,
U.S. EPA determined that this proposed reconstruction is a major modi-
fication requiring a PSD permit.
On August 7, 1980 (45 FR 52676), U.S. EPA finalized the new PSD
regulations. Section 52.21(i)(9) and Section 52.21(i)(10) state that
sources submitting a complete application prior to August 7, 1980 are
not subject to paragraph (j) relating to control technology review and
paragraph (m) relating to air quality monitoring effective August 7,
1980. Instead, such sources (including this application by Domtar
Industries are subject to the requirements of 40 CFR 52.21(j) (Control
Technology Review) and 40 CFR 52.21(n) (Air Quality Monitoring) as in
effect on June 19, 1978. For Domtar Industries, a pre-construction
air quality monitoring program is not required. However, Domtar
Industries is required to install BACT to "each applicable pollutant
unless the increase in allowable emissions of that pollutant from the
source...would be less than 50 tons/year (TPY), 1000 Ibs/day, or 100
Ibs/hr, whichever is most restrictive." No offsetting emissions are
considered. These allowable emissions are listed in Table 1. This
table shows that Domtar Industries is subject to BACT review for SOo,
NOX, and CO.
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Table 1. ALLOWABLE EMISSIONS*
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limitations recommended as permit conditions.
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TSP
SO?
NOX
CO
Annual
(TRY)
16.2
101.1
134.7
89.8
Daily
(Ibs/day)
88.6
551.2
738.0
492.0
Hourly
(Ibs/hr)
3.69
23.09
30.75
20.50
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2.0 ANALYSIS OF EMISSIONS
The calculations of the potential emissions from the Domtar Indus-
tries, Inc. facility is based on the following design information from
their application:
Kiln Nos. Rotary
Parameter No. 1 2 & 3 Drier
Limestone Input (ton/hr) 20.5 39.5
Quicklime Yield (ton/hr) 10.4 20.0 14.05
Fuel Type Pulverized bituminous coal
Btu Content 12,940 12,940 12,940
Fuel Ratio (MBtu/ton quicklime) 7.5 8.5
Fuel Consumption (ton/hr) 3.0 6.6 0.16
Fuel Sulfur Content (percent) 1.96 1.96 1.96
Ash Content (percent) 10.0 10.0 10.0
Annual Operation Hours 7600 6600 6600
The additional assumptions used were the manufacturer's guarantee of
0.01 grains/SCFM maximum emissions from the baghouse, 90 percent con-
trol efficiency of S09 and AP-42 emission factors for NO and CO.
u. A
Because of the approximate flow rates of the baghouse, the slightly
higher proposed emission limit of 0.18 Ibs particulate/ton of lime-
stone feed was used in the final calculations. Detailed calculations
which can be found in Appendix A are summarized in Table 2.
It should be noted that the total annual emissions exceeds those
listed in the application in that 8760 hours of operation are assumed
since no limitation in operations is proposed. The totals listed by
Domtar Industries integrate anticipated annual operating hours.
Finally, fugitive emissions associated with vehicular traffic and
mass handling operations have not been quantified. However, opera-
tional practices to minimize these emissions have been the subject of
a consent order with the State of Pennsylvania. Continuation of these
practices will be incorporated into the proposed permit conditions.
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Table 2. POTENTIAL EMISSIONS
Source/Pollutant
No. 1 Kiln
Particulate
so2
NOX
CO
No. 2 Kiln, No. 3 Kiln, Drier
Particulate
so2
NOX
CO
Total Facility
Particulate
so2
NOX
CO
Annual
(TPY)
16.2
101.1
134.7
89.8
31.1
228.6
259.5
173.0
47.3
329.7
394.2
272.8
Daily
(Ibs/day)
88.6
551.2
738.0
492.0
170.6
1252.3
1422.0
948.0
259.2
1803.5
2160.0
1440.0
Hourly
(Ibs/hr)
3.69
23.09
30.75
20.50
7.11
52.18
59.25
39.58
10.80
75.27
90.00
60.00
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3.0 BEST AVAILABLE CONTROL TECHNOLOGY
3.1 PARTICULATES
Since Domtar Industries, Inc.'s PSD application was determined to
be complete prior to August 7, 1980, the requirements to install BACT
for particulates are not applicable. However, Domtar is proposing to
install an adequately designed baghouse for the control of particu-
lates. This proposed control system is BACT and will exceed the NSPS
for lime calcining of 0.30 Ibs particulates/ton of limestone feed.
The manufacturer's guarantee of 0.01 gr/SCFM equates to 0.16 Ibs
particulate/ton limestone feed. However, since there is normal via-
bility in the exhaust gas flowrate, Domtar's proposed emission rate of
0.18 Ibs particulate/ton limestone feed will be accepted and incor-
porated into the PSD permit (if issued).
3.2 SULFUR DIOXIDE
Domtar proposes to control sulfur dioxide emissions by the com-
bined implementation of two factors. First, the sulfur content of the
coal to be used in firing the proposed kiln will be medium sulfur coal
with a maximum sulfur content (on a weekly weighted average basis) of
1.96 percent sulfur. The second factor of SOp control was Domtar1s
choice of a baghouse as the particulate control device. The limestone
dust in the exhaust gas stream will interact with the SO,, in the gas
stream and it will be removed as a particulate. The S02 control
efficiency is dependent on the amount of time the limestone and S02
have to interact. Domtar's proposed baghouse and operational proce-
dures (i.e., primarily shown in the pressure drop across the fabric)
will allow sufficient residence time to achieve a minimum control
efficiency of 90 percent for S02- This is BACT for S02.
3.3 NITROGEN OXIDES AND CARBON MONOXIDE
At the present time, there exists no controls other than the proper
design and operation of a rotary lime kiln for the minimization of
NO and CO emissions. Domtar has proposed this and has an economic
A
incentive to insure that this BACT for NO and CO is implemented.
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3.4 BACT EMISSION LIMITS
The BACT emission limits for the proposed No. 1 rotary lime kiln
are:
o 0.18 Ibs particulate/ton limestone feed
o 1.13 Ibs S02/ton limestone feed
o 1.50 Ibs NO /ton limestone feed
A
o 1.00 Ibs CO/ton limestone feed
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4.0 MONITORING AND EMISSION LIMITATION RECOMMENDATIONS
4.1 NO. 1 ROTARY LIME KILN
To ensure the continued maintenance of BACT and level of emissions
as proposed, the following emission limitations are recommended:
o Opacity not to exceed 10 percent
o 0.18 Ibs particulate/ton limestone feed
o 1.13 Ibs SOp/ton limestone feed
o 1.50 Ibs NO /ton limestone feed
/\
o 1.00 Ibs CO/ton limestone feed
The NSPS and Pennsylvania rules require substantial monitoring and
reporting requirements for this proposed kiln. Section 60.343(a)
describes the requirements and equipment specifications for the con-
tinuous monitoring of opacity. Section 60.343(e) contains the speci-
fic reporting requirements on malfunctions, excess emissions, etc.
These specific requirements are in addition to the general NSPS re-
quirements contained in Section 60.7 through 60.11.
Additionally, the following recommendations are made:
o Daily coal samples will be taken and analyzed for sulfur
content and combined to demonstrate that the weekly-weighted
percent of sulfur of the coal does not exceed 1.96 percent.
o Simultaneous compliance tests should be required for S02
(U.S. EPA Method 8) both upstream and downstream of the bag-
house to demonstrate 90 percent removal efficiency. This test
should be redone whenever a cumulative 50 percent of the bags
have been replaced.
o The compliance tests described above should establish the
operating procedures associated with 90 percent S02 removal
efficiency. The pressure drop and cleaning cycles (or equi-
valent measurable operating parameters) associated with this
level of control should be monitored.
o Preventive maintenance should be established both for the
baghouse and for the process operations to minimize fugitive
emissions. Such a program (applicable to Kiln Nos. 2 and 3 at
this Belefonte facility) is described in Section 3 of a Consent
Decree dated October 3, 1979 between Domtar Industries, Inc.
and the Commonwealth of Pennsylvania. A copy is included in
Appendix B.
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Lastly, the demonstration for the attainment of the NAAQS and
preservation of the increments require that the existing Kiln Nos. 2
and 3 not exceed the following emission limitations:
o 0.18 Ibs particulate/ton limestone feed
o 1.36 Ibs S02/ton limestone feed (based on 1.96
percent sulfur coal and 90 percent control efficiency)
o 1.50 Ibs NO /ton limestone feed
J\
o 1.00 Ibs CO/ton limestone feed
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5.0 DISPERSION MODELING PARAMETERS
Fugitive emissions are not quantified in the application. However,
their impacts are localized, generally impact within plant property,
and consequently, do not impact the final conclusions of the analysis.
The input parameters for a Gaussian dispersion model using the emis-
sion limitations recommended are:
o Stack Parameters
o Stack height
o Stack diameter
o Stack gas exit
velocity
o Stack gas exit
temperature
o EMISSION RATES
o Particulates
o S02
o NOX
o CO
Kiln No. 1
45.7 m
(150 ft)
1.07 m
(3.5 ft)
19.11 m/sec
(62.7 ft/sec)
505.37°K
(450°F)
3.69 Ibs/hr
(0.47 g/sec)
23.09 Ibs/hr
(2.91 g/sec)
30.75 Ibs/hr
(3.88 g/sec)
20.50 Ibs/hr
(2.59 g/sec)
Kiln No. 2
18.9 m
(62 ft)
0.76 m
(2.5 ft)
6.05 m/sec
(19.8 ft/sec)
449.82°K
(350°F)
3.55 Ib/hr
(0.45 g/sec)
26.09 Ibs/hr
(3.29 g/sec)
29.62 Ibs/hr
(3.74 g/sec)
19.75 Ibs/hr
(2.49 g/sec)
Kiln No. 3
18.9 m
(62 ft)
3.42 m
(11.2 ft)
1.5 m/sec
(4.92 ft/sec)
449.82°K
(350°F)
3.55 Ibs/hr
(0.45 g/sec)
26.09 Ibs/hr
(3.29 g/sec)
29.62 Ibs/hr
(3.74 g/sec)
19.75 Ibs/hr
(2.49 g/sec)
The above parameters are reflective of both long and short term
averaging time periods and were the ones used (with insignificant
differences) in the modeling analyses.
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6.0 AIR QUALITY IMPACTS
Consistent with the determination that the Domtar Industries PSD
application was substantially complete prior to August 7, 1980, air
quality impact analysis is limited to SOp, NO , and CO. Addition-
ally, quantitative techniques to estimate impacts of CO in complex
terrain are not available at present and will not be addressed further.
To address the air quality impacts of S09 and NO , Dames and
Cm, f*t
Moore, Domtar's consultant, used the VALLEY computer dispersion model.
This model is part of U.S. EPA's UNAMAP series of models and despite
its limitations, is the recommended approach for the terrain in the
vicinity of the Bellefonte, Pennsylvania Lime Plant. Dames and Moore's
analysis used the "screening scenario" in addition to 15 other combi-
nations of meteorological data, a sufficiently dense receptor grid
system and maximum hourly emission rates for both Domtar's sources and
other sources in the impact region. These input assumptions are con-
sistent with U.S. EPA's modeling guidelines.
The results of this analysis, as seen in Table 3, show that all
the applicable standards and increments are maintained.
Two other air quality related demonstrations were made. First,
using the formula from U.S. EPA's proposed "Tall Stack" policy, Kiln
No. 1's stack was shown to be of good engineering practice design.
Secondly, Dames and Moore used U.S. EPA's ISC model to show that no
excessive off-site ground level concentrations would result from
building induced downward caused by the interation of Kiln No. 1's
building and the stacks serving Kiln Nos. 2 and 3.
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Pollutant
S02
S02
S02
N02
Averaging
Period
annual
24-hour
3-hour
annual
Predicted Air Quality
Concentrations
All Sources PSD Sources
34.1
178.9
715.6
39.4
3.41
60.1
240.5
NAAQS
80
365
1300
100
Class III
PSD
Increment
20
91
512
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Table 3. AIR QUALITY IMPACTS
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7.0 EFFECTS ON VISIBILITY, SOIL, AND VEGETATION
The effects of other impacts resulting from Domtar Industries,
Inc.'s proposed lime kiln are not adequately addressed in the appli-
cation. However, the proposed construction does not change the lime
producing capability which had previously existed at this facility.
The reactivation will have better controls than previously existed and
the emission limitations and monitoring requirements will insure non-
degradation of the controls not only of the new re-construction, but
also of the additional existing kilns. The facts together with the
present industrialization of the local area do not present any signi-
ficant impact provided all air quality standards are met.
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8.0 DETERMINATION OF THE AREA OF SIGNIFICANT IMPACT
The assessment of increment consumption must include all sources
which have been constructed since the baseline date. In order to
enable future sources to more easily obtain information on previously
approved PSD sources which could potentially interact with the appli-
cant's proposed source, Region III is preparing a data file to assist
in identifying potentially interacting sources which have (or are in
the process of obtaining) approved PSD permits. This report provides
the needed data on the maximum distance from which a proposed source
need not be considered as potentially interacting with the Domtar Lime
Kiln located in Centre County, at Bellefonte, Pennsylvania.
8.1 METHODOLOGY
In order to assess the area of impact, the screening procedures as
described in the U.S. EPA "Guidelines on Air Quality Modeling" were
followed. Briefly, the PTMAX model of the UNAMAP package, together
with time correction factors (Ref: D.B. Turner, Workbook on Atmos-
pheric Dispersion Estimates) were used to determine a radius of signi-
ficant impact for this PSD source. The significant impact area is
defined as that area where ambient air pollutant concentrations equal
or exceed the following levels:
AVERAGING TIME
Pollutant
so2
TSP
N02
CO
Annual
1 ug/m
1 ug/m
1 ug/m
24-Hour
5 ug/m
5 ug/m3
_-
8-Hour
__
0.5 ug/m
3-Hour
25 ug/m3
--
1-Hour
__
2 ug/m3
The boundary of the area of significant impact shall extend up to a
maximum of 50 kilometers from the source.
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While these proposed models may not be appropriate for quantifying
impact in complex terrain, they will be used since, for determining a
radius of impact, they are conservative. Since the Region III data
base will be used for identification of potential interacting sources
rather than quantification of the impact, the conservative radius
resulting from the assumption of flat terrain is desirable.
8.2 DISPERSION MODELING PARAMETERS
The input parameters for a Gaussian dispersion model for Domtar's
Bellefonte Lime Kiln using the recommended emission limits are listed
in Section 5.0.
8.3 SIGNIFICANT IMPACT AREA
The significant impact area is presented in the following table:
Pollutant No. 1 Kiln Nos. 1. 2, & 3 Kilns
TSP 0.55 km 0.8 km
S02 2.66 km 50.0 km
NOV 13.82 km 50.0 km
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CO 2.06 km 50.0 km
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APPENDIX A
CALCULATION OF POTENTIAL EMISSIONS
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APPENDIX A
CALCULATION OF POTENTIAL EMISSIONS
Based on the information submitted by Domtar Industries, Inc., the
following data are used to calculate the emissions from the Domtar
Lime Plant.
Kiln
No. 1
Kiln Nos.
2 & 3
Rotary
Drier
20.5 39.5
10.4 20.0 14.05
Pulverized bituminous coal
12,940
7.5
3.0
1.96
10.0
7600
12,940
8.5
6.6
1.96
10.0
6600
12,940
0.16
1.96
10.0
6600
Parameter
Limestone Input (ton/hr)
Quicklime Yield (ton/hr)
Fuel Type
Btu Content
Fuel Ratio (MBtu/ton quicklime)
Fuel Consumption (ton/hr)
Fuel Sulfur Content (percent)
Ash Content (percent)
Annual Operation Hours
POTENTIAL EMISSIONS FROM NO. 1 KILN
PARTICIPATE
Potential TSP emissions from the No. 1 kiln are calculated based
on the baghouse supplier's warranty of 0.01 grains per SCFM maximum
emissions to the atmosphere and approximately 70,000 ACFM at 500°F.
PE = 0-01 x 70,000 x 60 x (460 + 70) = 3 31 ibs/nr
7000 x (460 + 500)
The emission limitation for the No. 1 kiln is:
3.31 Ibs/hr = 0>16 lbs/ton of Iimest0ne feed
20.5 tons/hr
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Based on Domtar's PSD application, the proposed allowable particulate
emissions are 0.18 Ibs/ton of limestone feed. The hourly Particulate
emission rate from the No. 1 kiln is:
0.18 Ibs/ton x 20.5 tons/hr = 3.69 Ibs/hr
The daily Particulate emission rate is:
3.31 Ibs/hr x 24 hrs/day = 88.56 Ibs/day
The annual Particulate emission rate is calculated based on 8760 hours
of operation rather than the 7600 hours listed in the application
since no limitation on the hours of operation is proposed. The annual
emissions are:
3.69 Ibs/hr x 8760 hrs/ yr x 1 ton = 16.16 tons/yr
2000 Ibs
Domtar's Bellefonte lime plant No. 1 kiln will be in full compliance
with the applicable NSPS emission limitation of 0.30 Ibs particu-
late/ ton of limestone feed.
SULFUR
High purity limestone having less than 0.01 percent sulfur content is
fed to the kiln, so the hourly sulfur content in the limestone is:
20.5 tons/hr x 0.01 percent x 2000 Ibs/ton = 4.1 Ibs/hr
The product having an average sulfur content of 0.03, the hourly
sulfur content in the quicklime is:
10.4 tons/hr x 0.03 percent x 2000 Ibs/ton =6.24 Ibs/hr
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The hourly coal usage is 3 tons, the maximum sulfur content in the coal
is 1.96 percent by weight, the hourly sulfur content in the coal is:
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3 tons/hr x 1.96 percent x 2000 Ibs/hton = 117.6 Ibs/hr
The total sulfur which is emitted from the calcination process is:
117.6 Ibs/ton + 4.1 Ibs/hr - 6.24 Ibs/hr = 115.46 Ibs/hr
Converting the sulfur to sulfur dioxide, the S02 emission rate is:
1115.46 Ibs/hr x = 230.92 Ibs/hr
32
Assuming the baghouse has a minimum 90 percent sulfur dioxide removal
efficiency, the hourly sulfur dioxide emission rate emitted from the
baghouse is:
230.92 Ibs/hr x (1 - 0.9) = 23.09 Ibs/hr
The daily S0? emission rate is:
23.09 Ibs/hr x 24 hrs/day = 554.21 Ibs/day
The annual SOp emission rate is:
123.09 Ibs/hr x 8760 hrs/yr x l ton = 101.13 tons/yr
2000 Ibs
The proposed allowable emission limitation for sulfur dioxide is:
23.09 Ibs/hr =
20.5 tons/hr
1. = L13 1bs/ton of iimestone feed
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NITROGEN OXIDE
AP-42, Emission Factor = 1.5 Ibs/ton of limestone feed
The potential hourly, daily and annual emission
as follows:
Hourly NO emission rate is:
X
1.5 Ibs/ton x 20.5 tons/hr = 30.75 Ibs/hr
Daily NO emission rate is:
A
30.75 Ibs/hr x 24 hrs/day = 738.0 Ibs/day
Annual NO emission rate is:
x
?fl 7^ Ihc/hr v A7fiD hr~/\/r y - 1 ?d
ju , / D lub/iir A o/ou iir b/yr A ~^ XOH.
2000 Ibs
There is no control device for nitrogen oxide.
oxide is proper design and operation of the kiln
device exists, the allowable emission limit will
AP-42 emission factor; i.e., 1.5 Ibs NO/ton of
X
CARBON MONOXIDE
rates are calculated
69 tons/yr
The BACT for nitrogen
. Since no control
be the same as the
limestone feed.
AP-42 Emission Factor = 1 Ib/ton of limestone feed
The potential hourly, daily, and annual emission
as follows:
Hourly CO emission rate is:
1 Ibs/ton x 20.5 tons/hr = 20.5 Ibs/hr
rates are calculated
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Daily CO emission rate is:
20.5 Ibs/hr x 24 hrs/day = 492 Ibs/day
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Annual CO emission rate is:
1 ton
2000 Ibs
There is no control device for carbon monoxide. The allowable
_ emission limit will be the same as the AP-42 emission factor; i.e.,
I 1.0 Ibs CO/ton limestone feed.
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POTENTIAL EMISSIONS FROM NOS. 2 & 3 KILNS
PARTICULATE
Potential TSP emissions from the Nos. 2 & 3 kilns were calculated
_ based on the baghouse supplier's warranty of 0.01 grains per SCFM
maximum emission to the atmosphere and approximately 142,000 ACFM at
500°F.
PE = 0.01 x 142,000 x 60 x (460 + 70) = 6 72 lbs/}
7000 x (460 + 500)
The emissions from the Nos. 2 & 3 kilns are:
6.72 Ibs/hr = Q>17 lbs/ton of iimest0ne feed
39.5 tons/hr
The TSP emissions emitted from the Nos. 2 & 3 kilns will satisfy the
proposed allowable 0.18 Ibs/ton of limestone feed.
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The hourly TSP emission rates are:
0.18 Ibs/hr x 39.
5 tons/hr = 7.11 Ibs/hr
The daily TSP emission rates are:
7.11 Ibs/hr x 24
hrs/day = 170.64 Ibs/day
The annual TSP emission rates are calculated based on 8760 hours of
operation since no limitation on hours of operation is proposed. The
annual emission rate
7.11 Ibs/hr x 876
SULFUR DIOXIDE
If the sulfur content
is:
n hr~/\/r v - ?1 1 d tnn"/vr
u riib/yr x 01.1*+ Luiib/jM
2000 Ibs
in the limestone fed to the kiln is 0.01 per-
cent, the hourly sulfur content in the limestone is:
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39.5 tons/hr x 0.
01 percent x 2000 Ibs/ton =7.9 Ibs/hr
The product has an average sulfur content of 0.03 percent. The total
hourly sulfur content
20 tons/hr x 0.03
The hourly coal usage
in the product is:
percent x 2000 Ibs/ton = 12 Ibs/hr
for Nos. 2 & 3 kilns are 6.6 tons.
The maximum sulfur content in coal is 1.96 percent.
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The hourly sulfur in
6.76 tons/hr x 1.
The hourly sulfur emi
264.99 Ibs/hr + 7
the coal is:
96 percent x 2000 Ibs/ton = 264.99 Ibs/hr
ssions emitted from Nos. 2 & 3 kilns are:
.9 Ibs/hr - 12 Ibs/hr = 260.89 Ibs/hr
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Converting the sulfur to sulfur dioxide, the S02 emission rate is:
fid
260.89 Ibs/hr x = 521.78 Ibs/hr
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Assuming the baghouse has a minimum 90 percent SO^ removal effi-
ciency, the hourly sulfur dioxide emission rate is:
521.78 Ibs/hr x (1 - 0.9) = 52.18 Ibs/hr
H The daily SOp emission rate is:
* 52.18 Ibs/hr x 24 hrs/day = 1252.32 Ibs/day
The annual S02 emission rate is calculated based on 8760 hours of
_ operation:
" 52.18 Ibs/hr x 8760 hrs/yr x 2000 Ibs/ton = 228.55 tons/yr
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152.18 Ibs/hr = L36 1b$ so /ton of limestone feed
39.5 tons/hr ^
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Note: Since the gases from the rotary drier are combined with those
I of Kilns 2 & 3, the coal burned in the drier was added to the total
coal consumed in these kilns.
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NITROGEN OXIDE
AP-42 Emission Factor =1.5 Ibs/ton of limestone feed.
I The potential hourly, daily, and annual emission rates are calculated
below; the annual emission rate is based on 8760 hours of operation.
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The SOp emissions from the Nos. 2 & 3 kilns are:
52.18 Ibs/hr
39.5 tons/hr
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Hourly NO emission rate is:
Daily NO emission rate is:
/\
Annual NO emission rate is:
/\
^H
1.5 Ibs/ton x 39.5 tons/hr = 59.25 Ibs/hr
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59.25 Ibs/hr x 24 hrs/day = 1422 Ibs/day
59.25 Ibs/hr x 8760 hrs/yr x 2000 Ibs/ton = 259.52 tons/yr
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. CARBON MONOXIDE
AP-42 Emission Factor = 1.0 Ibs/ton of limestone feed.
| The potential hourly, daily, and annual emission rates are calculated
below; the annual emission rate is based on 8760 annual hours of
I operation.
Hourly CO emission rate is:
1.0 Ibs/ton x 39.5 tons/hr = 39.5 Ibs/hr
Daily CO emission rate is:
I 39.5 Ibs/day x 24 hrs/day = 948 Ibs/day
Annual CO emission rate is:
39.5 Ibs/hr x 8760 hrs/yr x 2000 Ibs/ton = 173.01 tons/yr
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APPENDIX B
CONSENT DECREE AND AGREEMENT
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IN THE COMMONWEALTH COURT OF PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA
v. : No.fo^C.D. 1979
DOMTAR INDUSTRIES INC.
CONSENT DECREE AND AGREEMENT
AND NOW, this day of , 1979, it appearing to the
Court that Plaintiff, Commonwealth of Pennsylvania, through its Depart-
ment of Environmental Resources (hereinafter "Department"), and Domcar Indi
tries Inc. (hereinafter ''Domtar"), in disposition of the litigation, conser
and agree to the following Findings of Fact and the entry of this Decree
prior to Judgment and without further hearing, and it further appearing
to the Court that implementation of the compliance plan contained in this
Decree will achieve compliance with the applicable rules and regulations
| of the Department as expeditiously as practicable, the Court hereby finds:
_ A. Domtar owns and operates a lime manufacturing facility located
In Benner Township, Centre County (hereinafter "Dellefonte Plant");
I D. The Deportment alleges that during the course of the operation
of the Bellefonte Plant, certain equipment, operations_and processes,
I including but not limited to, material handling, truck and rail car loading
I roadways, crushers, and air pollution control device malfunctions and
...
other inadequacies, have caused violations of the Air Pollution Control
I Act', the Act of January 8, 1960, P.L. 2119, as amended, 35 P.S. 4001 et seq.
(hereinafter "Act");
* C. The Department further alleges that the violations of law de-
scribed in Paragraph B above consist of fugitive air contaminant emissions
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violations, contrnry to $§123.1 and 123.2 of the Department's Rules nnd
I Regulations, 25 I'a. Coda $$123.1 and 123.2, ;md violations of tlic visible
emission standards contrnry to $123./'I of die Department's Ruler nnd
I Regulations (hereinafter "Rules"), 25 Pa. Code §123.41;
D. The Department further alleges that the kiln baghouse at the
HoJlefonto Plant has produced nnd continues to produce fugitive emission
. violations contrnry to §123.1, of the Department's Rules, 25 Pa. Code
_ §123.1; and that these violations occur on a frequent and continual basis;
* E. The Department further alleges that the air contaminant emissions
from the kiln bafihouse mentioned in Paragraph D, above, also constitute vio-
lations of the opacity standr.rd as set forth in §123.41 of the Department's
I Rules, 25 Pa. Code §123.41;
F. The Department further alleges that fugitive air contaminant
emissions from the truck and rail car loadouts at the Bellcfontc Plant arc
frequently in violation of §123.1, of the Department's Rules, 25 Pa. Code
§123.1;
C. The Department further alleges that the roadways in and around
the Gcllefonte Plant arc in violation of the fugitive participate matter
standards because Domtar did not take all reasonable actions to prevent
particulatc matter from becoming airborne; nnd that this inaction and the
_ subsequent fugitive particulate matter emission has produced violations of
.. §123.1 of the Department's Rules, 25 Pa. Code §123.1;
II. The. Department further alleges that fugitive air contaminants
from the stone: crusher ;it the Bcllcfontc plant have been in violation of
I §123.1 of the Department's Rules, 25 Pa. Code §123.1;
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I. Domtar ncilhcr admits nor denies the allegations contained in
Paragraphs B through II above, buc for purposes of this Consent Decree
and Agreement only docs not contest them. Domtflr has recognized that n
comprehensive program of preventive maintenance mid pollution control
\
must be implemented at the Bellefonte Plant and intends to take action
in the following areas:
1. Control of fugitive dust from plant roadways.
2. Maintenance and surveillance of process particulatc matter
collect ton equipment nnd throughout die plant.
3. Repair and rehabilitation of dust collection system for Nos.
2 and 3 Rotary Kilns.
J. Domtar intends as a result of thin program, to bring particulatc
matter emissions, fugitive emissions, and emission opacities at the Belle-
fonte Plant into compliance with the Act and the Rules of the Department
on or before September 1, 1979-
K. The Department contends that ea.ch violation alleged in Paragraphs
D through 1! constitutes unlawful conduct in violation of $8 of the Air
Pollution Control Act, supra, 35 P.S. §4008, and could subjecc Domtar to
criminal penalties of not more than five thousand dollars ($5,000) per day
per violation, and civil penalties of not more than ten thousand dollars
($10,000) per day per violation, as provided by 5§9 and 9.1 of the Air
Pollution Control Act, 35 P.S. §§4009 and 4009.1;
L. The parties ik-sirc to .-wold further lit Ig.-ition concerning the
aforesaid violations.
Based on the foregoing, it is hereby ORDERED, ADJUDGED AND DECKED THAT:
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1. Tlily Court has jurisdiction over the subject matter pursuant to
JJO(b) of the Act, 35 P.S. $4010(b), and 5761 of the Jmllcifll Code 42 Pfl.
C.S. $761.
2. Repair and Rehabilitation by Domtar of the Dust Collcr.tion System
for No. 2 and 3 Rotary Kilns.
a. The ten cylindrical tanks shall be replaced and brought into
service by September 1, 1979.
Tluse tanks shall have testable stacks.
1). Six Structural Compartments
i. The doors on the six (6) structural compartments shall
he replaced so that these doors can be kept closed.
ii. Interior and exterior walls (corrugated asbestos) shall
be repaired .';o that kiln garter can be exhausted only through the
j»roper exhaust vents.
iii. The area above the interior compartment walls shall
be .separated into at least three approximately equal chambers,
the walls of which will extend to the roof monitors.
iv. Items b.i. through b.iii. shall be completed by Septem-
ber 1, 1979.
c. After the date of this Consent Decree the supply of air to
the kiln baghou.sc shall be maintained and kept in working order so
that the kiln baghouso has a supply of air at the pressure required
to properly operate the baghouse and to comply with the provisions of
the Act and the Rules. Domtar will provide the Department with a
sinfoment of the physical arrangement and operating parameters of
the air system on or before September 1, 1979.
d. Upun completion of the activities and obligations described
in Paragraphs 2.a. through c. Domtar sh.ll make regular and frequent
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inspect ions lo detect any bag or structural lcnk« In the kiln bag-
house. Domtnr shall attempt to repair such leaks Immediately.
c. If, after the provisions contained in Paragraphs 2.a.
through d. have been instituted, DER determines in writing that fugi-
\
tive emissions from the facility are not in compliance with the Act
and the Rules of die Department, Domtar will subn.it to DER for ap-
proval, within 20 days of receipt of notice of such determination,
a plan which details the measures Domtar will take to bring the
plant into compliance wit Is the Act and the Rules of the Department
and a schedule for Die implementation of the measures. Domtar agrees
to implement the measures within the Limes specified in the plan,
if approved by DER. In tl:c event that said plan is not approved by
DER, then notwithstanding any other provisions of this Consent Decree
and Agreement, DER shall have the right to bring any enforcement action
against Domtar, civil or criminal, necessary to obtain compliance
witli the Act nnd any applicable Regulations.
3. General Plant Procedures for Maintenance and Surveillance.
a. Domtar sh.-ill, on or before execution of this agreement, desig-
nate n person (referred to hereafter in this Decree and Agreement as
the Environmental Control Supervisor "ECS") at the Bcllefonte Plnnt,
whose function shall be daily surveillance of the Dellefonte Plant's
rondw.-iys , process equipment, and emissions control equipment.
b. The- EC.S shall report directly to the plnnt manager. Th«. plant
manager or his designce shall be responsible for the institution of
measures to correct any outage, malfunction, equipment breakdown, or
fugitive dust emission in the manner herein set forth nnd shall be
responsible for reporting to the Department any control equipment
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,-' ouingcs or malfunctions, fugitive emissions, and any process
equipment malfunctions resulting in visible emissions, and for the
preparation and maintenance of all records or notices required by
this agreement.
_ c. Domtar shall instruct its employees thnt it shall be the
responsibility of cnch employee to notify his superior, and each
. superior to notify plant management, of any observed process or
control equipment outage or malfunctions, or any fugitive nir con-
taminant emissions. When used in this Consent Decree and Agreement,
the term malfunction shall mern "sudden and unavoidable failures of
control or process equipment, or processes that do not operate in
a normal or usual manner". Failures that are caused entirely or
in part by poor maintenance, careless operation, or any preventable
condition shall not be considered malfunctions. "Preventable" as
used in this definition means any condition as to which the Depart-
ment has given prior notice to Domtar in writing either by correspon-
| dcnce or by entry into the log referred to in subpnragraph c below.
m d. Domcnr's ECS shall make routine inspection tours of the
Bollcfonte Plant before 10:00 a.m. and after 2:QO_p.m. on regular
working days and once a day on Sundays and statutory holidays and
shall specifically inspect the following areas.
.. i. AJ1 jxirticulatc matter collection installations;
including hoods, Joadout spouts, duct work, screw conveyors,
bnghouses and bucket elevators.
| A. All PnrLiculate matter collection installations
_ and devices shall be examined to ensure that they are
operating correctly and efficiently.
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D. The kiln baghousc pressure shall be recorded at
least twice daily and such recording shall be nvailnblc
for inspection.
C. Immediate action shall be initiated by Domtar to
I correct fugitive air contaminant emissions discovered durir
these inspection tours.
| ii. All plant roadways and plant yard areas.
_ iii. All building roofs for particulatc accumulations po-
tentially responsible for any fugitive air contaminant emissions
iv. Malfunctions resulting in air contaminant emissions,
and any fugitive emissions discovered as a result of the above
inspection procedure shall be recorded in a log book and signed
by the ECS, reported to the plant manager, and reported to the
Department of Environmental Resources office in Lcwistown, PA
as discovered or if the discovery is made after 4:00 p.m. and
_ before 8:00 a.m., not later than the next regular working day.
v. If a malfunction or fugitive air contaminant emission
is not corrected by the next day's inspection, then it shall be
recorded again in the log book, reported again to the plant
| manager, and reported again to the Department, as described In
H paragraph iv. above, if there has been any significant change in
the amount of the fugitive emissions, or if any previously-given
estimate for time of repair is changed.
e. A daily log of the plant inspection tours will be maintained
|V
at the plant Lo record:
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i. Sources of all visible fugitive nir contaminant
emissions and their apparent cnusc;
ii. Date and time of discovery of such visible fugitive oi
contaminant emissions;
iii. Comments on degree of visibility of specific source
emissions and general comments regarding overall appearance of
I . emissions from plant site and comments identifying locations of
observat ion;
iv. General comments on weather conditions including pre-
cipitation, temperature, and wind speed and direction.
f. Roadways Maintenance.
I i. Domtar shall institute a program for regularly-scheduli
_ treatment of its roadways and yard for fugitive dust, which
shall occur on a frequency of at least once every month between
April 15 and November 1 of each year. If, after the provisions
contained in this paragraph have been instituted, DER determines
in writing that fugitive emissions from the Bcllefonte Plant
roadways and ynrds do not comply with the Act and the Rules of
the Department, Domtar shall submit to DER for approval, within
15 days of receipt of notice of such determination, a plan and
program to bring fugitive emissions from roadways and yards into
I'
compliance with the Act and the Rules of the Department, and a
schedule for the implementation of the measures. Domtar agrees
to implement the measures within the times specified In the plan,
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If approved by DKR. In the event that s.ild plan is not upprovcd
b> DF.R, then notwithstanding any other provisions of this Consent
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Decree and Agreement, DER shall have the right to bring any en-
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forccmort action against Domtar, cJvil or criminal, necessary
to obtain compliance with tlic Act /uul any applicable RcgulnCioi
ii. Domtar shall keep a log which records the utilizatior
of maintenance and dust control procedures for roadways and the
plant yard.
g. Maintenance Procedures for Kiln Baghouse.
i. Damaged bags will be capped or tied off as soon as
the bag failure is detected.
I ii. When the total number of bags tied off or capped in
the. bnghouse reaches a maximum of 30 bags, all damaged bags wtl]
be replaced within 36 hours. For the purposes of this section,
Uomtar may maintain production levels at any desirable level, so
long as air contaminant emissions and fugitive emissions are
" in compliance vith the Act and Lhc Rules of the Department, and
, so long as the damaged bags arc replaced within 36 hours. Domta
agrees to cease operating the kilns and kiln systems if necessary
| in order to comply with the rccjui rcmnnts of this section.
tm Jii. Domtar shall keep records of baps replaced in each com-
partment. When the rate of bag dctcrioration_ in a compartment
becomes excessive Domtar shall replace all the bags in that com-
partment .
. iv. If, at any time, there nre visible fugitive air contam-
inant emissions and no detectable bag or structual leaks, then
Domtar shall Immediately employ a leak detection procedure, such
|X
as fluorescent powder injection to locate the cause of said
emissions. Domtar shall attempt to repair or eliminate sucJi leaks
immediately.
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4. Settlement
n. In settlement of the alleged violations of the Act nnd tht.
Rules, which occurred before the entry of this Consent Decree and
Agreement, and as are generally described in paragraphs D through II
herein, Domtar shall pay to the Pennsylvania Clc;jn Air Fund the sura
of nine thousand (?9,000.00) dollars. Thf sum shall be due and pay-
able within thirty (30) days from Ihc date this instrument is cnterce
by the Court.
| b. After the dace of this agreement, in the event that Domtar
_ sliould discover and then fail to log an event, incident or malfunctic
as required and described by paragraph 3 herein, Domtar shall pay to
the Pennsylvania Clean Air Fund the sum of five hundred ($500.00)
dollars for each and every day that said event, incident, or malfunct
remains unlogged after the date of occurrence of the said event, in-
cidcnt or malfunction. Any sums due under this subsection shall be
due and payable on the last calendar day of che month following the
I month in which violations, if any, should occur.
_ c. After the date of this agreement, in the event that a mal-
function, as described by paragraph 3 herein, should occur, resulting
in the emission of fugitive air contaminants in violation of the Act
or the Ruler, of the Department, Domtar shall attempt to correct the
| - malfunction as soon as possible. If Domtar has not corrected the
m said malfunction within twenty-four hours from the time the malfunctio
occurod, then Domtar shall pay to the Pennsylvania Clean Air Fund the
sum of three hundred ($300.00) dollars per day for the second, third,
fourth and fifth day, or part thereof, after the-, day of the said mal-
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/ function, In which the malfunction or resulting condition ha.s not
been corrected and continues to permit the emission of fugitive air
contaminants in violation of tlic Act or the Rules. Domtar shall pa)
to the Pennsylvania Clean Air Fund the sum of five hundred ($500.00)
(
_ dollars for each and every day or part thereof, after the fifth day
in which the malfunction or resulting condition has not been correct
and which malfunction or resulting condition continues to permit the
emission of fugitive air contaminants in violation of the Act or the
Rules. Any suns due within this subsection shall be due and payable
on the last calendar, day of the month following the month in which
violations, if any, occur.
I d. After the date of this Agreement, in the event that a repr<
_ scntative of the Department observes a condition which in his or her
opinion constitutes the emission of fugitive air contaminants hy Domt
the Department shall notify Domtar within 24 hours of the time of the
observation. If the Department observes a condition which constitute
| an emission of fugitive air contaminants in violation of the Act and
M the Rules, and fails to give notice to Domtar as provided above, then
no penalties referred to in paragraphs 4.b. through c. shall accrue ui
such notice is given as provided in this subsection.
e. After the date of this Agreement, in the event that Domtar
should fail to meet the requirements within the time period set forth
. in Paragraphs 2 and 3 herein, Domtar shall pay to the Pennsylvania
Clean Air Fund the sum of one thousand ($1,000.00) dollars for each
and every day on which the said requirements remain unfulfilled. Any
_ sums due under this subsection shall l>c due and payable on the last
calendar day of the month following the month in which violations,
if any, should occur.
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f. All payments required herein shall be made payable to the
Pcmnsy 1 van in Glenn Air Fund nnd .should he delivered to Mr. H. F.
Robinson or his successor, Administrntive Officer, Bureau of Air
Quality Control, P. 0. Box 2063, Fulton Nntional Bank Building,
Harrisburg, PA 17120.
5. So long as Domtar meets each and every obligation it assumes
. under this Consent Decree nnd Agreement within the times specified for
m performance, the Department shall not institute administrative, civil,
or criminal actions ag.iinsi Domtar, Its partners, officers, agents, ser-
v.-mts or employees, for violation;; of the Air Pollution Control Act, or
the Department's Regulations as set forth or described in paragraphs D,
I :!, F, C, and H, above.
6. Any payments tendered by Domtar and received by the Department
pursuant to paragraph 4 lie re in shall constitute a settlement of all
claims for civil and criminal penalties under §9 and §9(1) of the Air
Pollution Control Act for the violations set forth in Paragraphs D, E,
~ F, C, and II above; but shall not be construed as a waiver by the Dcpart-
mcnt of its right to take any action against Domtar, civil or criminal,
at law or in equity, after September 1, 1979, to achieve compliance with
£ the Air Pollution Control Act and the Rules and Regulations adopted pursue
_ thereto, and the provisions of this Consent Decree and Agreement.
7. F.ach and every obligation of Domtar under this Consent Decree
and Agreement shall be subject to the following force majcure clause.
Tf Domtar shows that it has been delayed in the jmplc-montation of its obli
gations under the Consent Decree and Agreement by any act of Cod, or by
riot, insu r rrc.t i on , war, pestilence, fire, lightning, earthquake, cyclone,
flood, strikes, work stoppage or slow-down, unusual delays in transportati
delays in equipment deliveries which Domtar is unable to plan for or prc-
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x vciil , til" by any oilier cause;; beyond t.he control of Domtar, its agents,
sr rvanl:: , I'mp ) uyces , .successors and assigns, llicn Dnmlar Khali hi: re-
licved of Its obligations for a period of time equivalent to the period
" of dclny. Oomtar shall be: entitled to the benefits of this paragraph
only if it submits a written report within thirty (30) days of the: oc-
currence of each such event to the Regional Air Pollution Engineer,
which submission shall include all re Kited documontacion, such as third
M party correspondence and a notarized affidavit from a responsible cor-
porate official, sped ly i n^ cacii Oi tr.e excuses and the efforts of Domtar
to perform its obligations on time. Failure by Domtar to comply with
the requirements of this f.nrapraph specifically and in a timely fashion
shall rcnc'cr thi-; paragrapii void and of no effect as to the particular
incident involved.
8. Failure by Domtar to comply with any parnp.raph of this Consent
I Decree and Agreement shall be considered a material violation or breach
_ of the Decree and shall entitle the Department to pursue any anc1. .ill
available remedies and penalties, administrative, criminal, or civil,
in law or in equity.
9. It is agreed by the parties that any chango"sF7 additions or
| amendments to this Consent Decree and Agreement shall be set out in
writing as an amendment, signed by the parties hereto, and sumitted to
the. Court for approval.
I 10. This Consent Decree and Agreement shall not affect any respon-
sibilities imposed upon Domtar by any permit heretofore or hereafter issued
by the Department.
I 11. This Consent Decree does not grant a variance from any requirement
I
of the Air 1'olliition Control Acr, Acr of January 8, I960, P.L. 2119, as
amended, 35 P.S. 4001 ct scq., the Clean Air Act, 42 U.S.C. 1857 et scq. or
-13-
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':'* ^ ( , ~M 91 v
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any regulations promulgated thereunder, nor does it purport to modify any
requirement of Pennsylvania's State Implementation Plan as approved under
§110 of the Clean Air Act. Notice is hereby provided to Domcar that it
may be subject to additional penalties pursuant to §120 of the Federal
Clean Air Act, provided that this notice shall not deny to Doiatar any
defense or exemption to which it may be entitled ar, a matter of law.
I
12. This Consent Decree shall operate as a final order of the Depart-
ment to u-iiic'1; :>(;:..".-r vajvor, j i - r "! ; h l ; of appeal i.'Mch ripjit:; arc nvailn-^
..-.-.ju. L..C ..CL r. :.;-: il ,, .:/.v, .'.L. 17;, as ,ir:;er.deo, 71 P . S . 5510-21.
13. The ConvTuonwcaltii Court retains jurisdiction over this matter.
1
OR DOMTAii C!i)us'iR]rs i::r. FOR T!!io::.v:o;;',.'r..\LTi! or !T,NX:;YLVA:;IA
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| CERF/FiED FROM THE RECORD
I ^
OCT3 197.1
r1
-<-'
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APPENDIX D
B Scott Paper Company - Chester, Pennsylvania
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D-l
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EPA Contract No. 68-02-2536
Work Assignment No. 14
EVALUATION OF THE PREVENTION OF SIGNIFICANT
DETERIORATION APPLICATION FOR THE PROPOSED
INSTALLATION/CONVERSION OF COAL FIRED BOILERS AT THE
POWERHOUSE OF THE SCOTT PAPER COMPANY FACILITY
LOCATED IN CHESTER, PENNSYLVANIA
Robert Blaszczak - Task Manager
Thomas P. Blaszak - Project Manager
December, 1980
Prepared for:
U.S. Environmental Protection Agency
Region III
Air Programs Branch
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Prepared by:
Pacific Environmental Services, Inc.
465 Fullerton Avenue
Elmhurst, Illinois 60126
(312) 530-7272
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EXECUTIVE SUMMARY
1.0 INTRODUCTION
On June 2, 1980, Scott Paper Company forwarded to the U.S. Environ-
mental Protection Agency (U.S. EPA), Region III, an application for a
permit under the Prevention of Significant Deterioration (PSD) require-
ments of the Clean Air Act. Additional information was submitted on
June 16, 1980. Scott Paper Company proposes to convert the powerhouse
located at their Chester, Pennsylvania facility from oil to coal as
its principle fuel. In their application, Scott presents three alter-
native scenarios, only one of which will be implemented. The existing
boilerhouse contains four oil fired units (Boiler Nos. 6, 7, 8, and
9). Under Alternative One, Boiler Nos. 8 and 9 will be converted to
coal firing and Boiler Nos. 6 and 7 will remain as oil fired. Under
Alternative Two, Boiler Nos. 8 and 9 will be converted to coal firing,
a new Boiler No. 10 will be installed, and Boiler Nos. 6 and 7 will be
permanently retired. Under Alternative Three, three new coal fired
boilers would be constructed (Boiler Nos. 10, 11, and 12) and all four
existing boilers (Boiler Nos. 6, 7, 8, and 9) will be permanently
retired.
On August 7, 1980 (45 FR 52676), U.S. EPA finalized the new PSD
regulations. Section 52.21(i)(9) and Section 52.21(1)(10) state that
sources submitting a complete application prior to August 7, 1980 are
not subject to some of the new requirements but instead, are subject
to the old requirements (June 19, 1978 rules). Scott Paper was re-
viewed in accordance with the "old" requirements for "Control Tech-
nology Review and Air Quality Monitoring". Potential emissions from
Scott Paper's proposed construction/modification is given in Table 1.
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Table 1. POTENTIAL EMISSIONS*
HEAT POLLUTANT
ALTERNATIVE
INPUT
TSP
SO?
NOy
CO
HC
Pb
ANNUAL (TPY)
Alternative One
Boiler Nos. 8 & 9
Alternative Two
Boiler Nos. 8 & 9
Boiler No. 10
Alternative Three
Boiler Nos. 10 & 11
Boiler Nos. 12
Alternative One
Boiler Nos. 8 & 9
Alternative Two
Boiler Nos. 8 & 9
Boiler No. 10
Total
Alternative Three
Boiler Nos. 10 & 11
Boiler No. 12
Total
Alternative One
Boiler Nos 8 & 9
Alternative Two
Boiler Nos. 8 & 9
Boiler No. 10
Total
Alternative Three
Boiler Nos. 10 & 11
Boiler No. 12
Total
596
596")
298J
596*)
298J
596
596
298
894
596
298
894
596
596
298
874
5%
298
894
97.5
97.5
97.5
715
715
358
1073
715
358
1073
29.8
29.8
14.9
44.7
29.8
14.9
44.7
878
878
878
10299
10299
5149
15448
10299
5149
15448
429
429
215
644
429
215
644
1170
1170
1170
DAILY
8582
8582
4291
12874
8582
4291
12874
HOURLY
358
358
179
536
358
179
536
78
78
78
(LBS/DAY)
572
572
286
858
572
286
858
(LBS/HR)
23.8
23.8
11.9
35.8
23.8
11.9
35.8
23.4
23.4
23.4
172
172
86
257
172
86
257
7.15
7.15
3.58
10.7
7.15
3.58
10.7
0.98
0.98
0.98
7.16
7.16
3.58
11.2
7.16
3.58
11.2
0.30
0.30
0.15
0.45
0.30
0.15
0.45
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Table 1. POTENTIAL EMISSIONS* (continued)
Fugutive emissions (identical for all three alternatives)**
TSP(TPY)
Coal Unloading 0.62
Transfer to Coal Pile 0.16
Coal Pile Activities
Active Pile 0.94
Dead Storage Pile 0.53
Reclaim Hoppers 1.12
Transfer to Bunkers/Boilers 0.75
Ash Silo ***
Lime Storage 0.0 (totally enclosed operation)
Total 4.12
* Consistent wth the August 7, 1980 promulgation, and are based on the limitations
recommended as permit conditions.
** Annual estimates are based on 156,000 tons/yr.
*** 2.5 Ib/hr maximum; however, due to the poor quality of emission factors, no annual
estimate is given. Equipment specifications/operating parameters are recommended
for BACT.
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2.0 BEST AVAILABLE CONTROL TECHNOLOGY
The BACT discussion that follows is based on the installation of a
298 MBtu/hr. coal fired boiler. This discussion is reflective of all
three alternatives proposed by Scott Paper since all proposed scenarios
consist of constructing/converting various numbers of 298 MBtu/hr coal
fired boilers.
3.1 PARTICIPATES, SULFUR DIOXIDE, AND NITROGEN OXIDES
On June 11, 1979, the U.S. EPA published a final rule on the New
Source Performance Standards (NSPS) for Electric Utility Steam Gener-
ating Units. This standard does not apply to Scott Paper since no
electricity is generated. The applicable NSPS standard is described
at 40 CFR 60.40 which became effective for subject source construction
commencing after August 17, 1971. This applicable NSPS is dated and
does not reflect BACT. The Clean Air Act, as amended, recognized that
fact and required U.S. EPA to undertake studies to update these
standards. A list of these studies completed to date can be found in
Appendix C.
For Scott Paper, the applicable Pennsylvania Regulations for S0£
are more stringent than the NSPS for Electric Utilities and is BACT.
For particulates, the proposed emission limitation of 0.10 Ibs/MBtu is
considered RACT for boilers of Scott Paper's proposed size. The BACT
standard recommended here for non-utility boilers is less stringent
than that required of the utility industry. An emission limitation of
0.05 Ibs SO~/MBtu is recommended to be BACT. For NO control, an
£ A
emission limitation equal to that required of utility boilers is
recommended. BACT for NOV is 0.6 Ibs/MBtu.
A
For S02 control, Scott Paper proposes to use a lime scrubber to
achieve a rolling 30 day average emission limitation of 0.45 Ibs
S02/MBtu. This represents a control efficiency of 80.3 percent,
which is more stringent than the NSPS level of Electric Utility
boilers, which requires a minimum of 70 percent removal efficiency at
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levels less than 0.60 Ibs S02/MBtu (30 day rolling average). Addi-
tionally, Scott Paper is required by the state SIP not to exceed a
daily cap of 0.72 Ibs S02/MBtu and not exceed 0.60 Ibs 502/MBtu
more than twice during any 30 day period. Accounting for the design
restriction that no more than 156,000 tons of coal will be burned
annually, BACT emissions for S02 are 878 TPY, 10,299 Ibs/day (Alter-
native 1) to 15,448 Ibs/day (Alternative 2 or 3), and 429 Ibs/hr
(Alternative 1) to 644 Ibs/hr (Alternative 2 or 3).
For TSP, Scott Paper proposed to use a baghouse to meet the present
NSPS standard of 0.10 Ibs TSP/MBtu. To achieve the BACT emission
limitation of 0.05 Ibs TSP/MBtu, a control efficiency of 99.4 percent
(based on the inlet loading of 2437 Ib/hr per 298 MBtu/hr boiler) is
required. The proposed baghouse can meet this requirement. Accounting
for the design restriction that no more than 156,000 tons of coal will
be burned annually, BACT emissions for TSP are 97.5 TPY, 715 Ibs/day
(Alternative 1) to 1,073 Ibs/day (Alternatives 2 or 3) and 29.8 Ibs/hr
(Alternative 1) to 44.7 Ibs/hr (Alternatives 2 or 3).
For NO control, proper design and operation is proposed by
A
Scott Paper to minimize emissions. This same technique can meet the
recommended BACT emission limit of 0.6 Ibs NO /MBtu. As before,
/\
with the incorporation of the design restriction that the annual coal
consumption not exceed 156,000 tons, BACT emissions for NO are
1,170 TPY, 8,582 Ibs/day (Alternative 1) to 12,874 Ibs/day (Alterna-
tives 2 or 3) and 358 Ibs/hr (Alternative 1) to 536 Ibs/hr (Alterna-
tives 2 or 3).
3.2 HYDROCARBONS, CARBON MONOXIDES, AND LEAD
At the present time, there are no mechanisms to control HC, CO,
and Pb other than the proper design and operation of the boiler. For
economic reasons, Scott Paper will see that this is done (Note: BACT
for HC and Pb are not technically required for this application).
Therefore, the BACT emissions limitations recommended which reflect
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proper operation and design of the proposed boilers are 0.012 Ibs
HC/MBtu, 0.04 Ibs CO/MBtu, and 0.0005 Ibs Pb/MBtu. The design
limitation of 156,000 tons of annual coal burn will restrict annual
emissions. BACT for HC will be 23.4 TRY, 172 Ibs/day (Alternative 1)
to 257 Ibs/day (Alternatives 2 or 3), and 7.15 Ibs/hr (Alternative 1)
to 10.7 Ibs/hr (Alternatives 2 or 3). BACT emissions for CO will be
78 TRY, 572 Ibs/day (Alternative 1) to 858 Ibs/day (Alternatives 2 or
3), and 23.8 Ibs/hr (Alternative 1) to 35.8 Ibs/hr (Alternatives 2 or
3). BACT for Pb will be 0.98 TPY, 7.16 Ibs/day (Alternative 1) to
11.2 Ibs/day (Alternatives 2 or 3), and 0.30 Ibs/hr (Alternative 1) to
0.45 Ibs/hr (Alternatives 2 or 3).
3.3 FUGITIVE PARTICULATE EMISSIONS
Scott Paper proposes various means to control fugitive emissions
from the coal, lime, and ash handling systems. Briefly, these are the
use of surfacants, enclosure with baghouse controls, pneumatic con-
veying of waste products and the conditioning (wetting) of the ash/
waste prior to transfer to the waste haul trucks. These are BACT if
properly designed and operated. An opacity limitation for fugitive
emissions has been recommended to insure this.
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3.0 MONITORING
The NSPS and Pennsylvania rules require substantial monitoring and
reporting requirements for their proposed boiler. Section 60.47a
describes the requirements and equipment specifications for the con-
tinous monitoring of opacity, S02, and NO . Section 60.49a con-
tains the specific reporting requirements on malfunctions, excess
emissions, etc. Additionally, the following reporting recommendations
are made:
o Records should be maintained to establish proper usage of the
wetting/crusting agents in the dust suppression system (i.e.,
dilution/consumption rates, purchase records, etc.).
o The placement/use of sprayers, covers, etc. proposed for the
control of fugitive emissions shall be consistent with that
approved by U.S. EPA.
o Opacity resulting from all transfer points/storage piles should
not exceed five percent.
o Records of ACTUAL coal consumption should be maintained to
verify the design limitation of 156,000 tons of coal burned/yr.
o All records should be maintained and available for inspection
for a period of two years.
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4.0 EFFECTS ON VISIBILITY, SOIL, AND VEGETATION
The effects of other impacts resulting from Scott Paper's proposed
boilers is not addressed in the application. However, the proposed
construction does change the boilerhouse capability presently in exis-
tence. Rather, it upgrades the source and reduces oil dependency.
Hence, no impacts which do not presently exist are expected. The
localized impact of a new coal pile is not considered significant in
an industrial area if all air quality standards are met.
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5.0 AIR QUALITY IMPACTS
Briefly, the applicant's consultant, Enviroplan, Inc., used a
proprietary dispersion model (APES) which is reported to be equivalent
to U.S. EPA's reference model MPTER. The use of this model was
approved by Region III for this application. The analysis has been
found acceptable to U.S. EPA and demonstrates that neither the NAAQS
nor the PSD increments will be violated.
Several comments will aid in clarifying the differences in disper-
sion modeling parameters described in Section 5 and the input para-
meters found in the consultant's report entitled, "Air Quality Analysis
of New or Rebuilt Coal Fired Boilers at the Scott Paper Company
Facility in Chester, Pennsylvania" (with Appendices) dated "Revised
May 28, 1980." First, the final design proposed by Scott Paper
(letter dated June 16, 1980) has a lower stack gas exit temperature
(by 25°F) and a lower stack gas volume flow rate (by 19,000 ACFM)
than was utilized in the dispersion modeling analyses. These changes,
which would affect the air quality impacts, were known to Region III
and were considered during their review. Second, the particulate and
NO emission rates were higher than BACT. Therefore, the air
X
quality impacts discussed in the report will be higher than those
expected using BACT emissions.
The use of good engineering stack height was inadequately addressed
by the applicant but was independently analyzed by Region III and was
determined to be acceptable.
Finally, the nearest Class I area to Scott Paper is the Brigantine
National Wildlife Refuge, located 90 km away. There are no signifi-
cant impacts on this area from Scott Paper.
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EVALUATION OF THE PREVENTION OF SIGNIFICANT
DETERIORATION APPLICATION FOR THE PROPOSED
INSTALLATION/CONVERSION OF COAL FIRED BOILERS AT THE
POWERHOUSE OF THE SCOTT PAPER COMPANY FACILITY
LOCATED IN CHESTER, PENNSYLVANIA
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1.0 INTRODUCTION
On June 2, 1980, Scott Paper Company forwarded to the U.S.
Environmental Protection Agency (U.S. EPA), Region III, an application
for a permit under the Prevention of Significant Deterioration (PSD)
requirements of the Clean Air Act. Additional information was sub-
mitted on June 16, 1980. Scott Paper Company proposes to convert the
powerhouse located at their Chester, Pennsylvania facility from oil to
coal as its principle fuel. In their application, Scott presents
three alternative scenarios, only one of which will be implemented.
The existing boilerhouse contains four oil fired units (Boiler Nos. 6,
7, 8, and 9). Under Alternative One, Boiler Nos. 8 and 9 will be
converted to coal firing and Boiler Nos. 6 and 7 will remain as oil
fired. Under Alternative Two, Boiler Nos. 8 and 9 will be converted
to coal firing, a new Boiler No. 10 will be installed, and Boiler Nos.
6 and 7 will be permanently retired. Under Alternative Three, three
new coal fired boilers would be constructed (Boiler Nos. 10, 11, and
12) and all four existing boilers (Boiler Nos. 6, 7, 8, and 9) will be
permanently retired.
On August 7, 1980 (45 FR 52676), U.S. EPA finalized the new PSD
regulations. Section 52.21(i)(9) and Section 52.21(i)(10) state that
sources submitting a complete application prior to August 7, 1980 are
not subject to paragraph (j) relating to control technology review and
paragraph (m) relating to air quality monitoring effective August 7,
1980. Instead, such sources (including this application by Scott
Paper) are subject to the requirements of 40 CFR 52.21(j) (Control
Technology Review) and 40 CFR 52.21(n) (Air Quality Monitoring) as in
effect on June 19, 1978. For Scott Paper, a pre-construction air
quality monitoring program is not required. However, Scott Paper is
required to install BACT to "each applicable pollutant unless the
increase in allowable emissions of that pollutant from the source...
would be less than 50 TPY, 1000 Ibs/day, or 100 Ibs/hr, whichever is
most restrictive." No offsetting emissions are considered. These
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allowable emissions are listed in Table 1. This table shows that
Scott Paper is subject to BACT review for TSP, S0?, NO , and CO.
L. A
Additionally, a total of 4.12 TRY of participates (controlled) arising
from fugitive sources are subject to BACT as reflected in the recom-
mended equipment and/or performance specifications.
It should be noted that the annual allowable emissions listed in
Table 1 are identical to the potential emissions for applicability
determination in the new finalized regulations. Since the new defini-
tions for applicability apply, Pb must be considered in Scott Paper's
application for all the remaining requirements (mostly administrative)
of PSD, since the Pb emissions are significant. The new regulations
do allow emissions reductions to "offset" potential emissions if the
requirements listed in Section 52.21(b)(3) are met. Scott Paper
(although requested) has not submitted information to determine if the
emissions reductions from the proposed shutdown of various boilers are
creditable. These proposed emissions reductions will be assumed as
"not-creditable" for the purposes of this review; however, permanent
shutdown will be recommended as a condition for approval since the air
quality impact analysis relies upon it.
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ALTERNATIVE
Alternative One
Boiler Nos. 8 & 9
Alternative Two
Boiler Nos. 8 & 9
Boiler No. 10
Alternative Three
Boiler Nos. 10 & 11
Boiler Nos. 12
Alternative One
Boiler Nos. 8 & 9
Alternative Two
Boiler Nos. 8 & 9
Boiler No. 10
Total
Alternative Three
Boiler Nos. 10 & 11
Boiler No. 12
Total
Alternative One
Boiler Nos 8 & 9
Alternative Two
Boiler Nos. 8 & 9
Boiler No. 10
Total
Alternative Three
Boiler Nos. 10 & 11
Boiler No. 12
Total
Table 1. ALLOWABLE EMISSIONS
HEAT
INPUT
596
596
596
POLLUTANT
TSP SO? NOv CO RC
. .... - c. -""-^ '-
ANNUAL (TPY)
Pb
97.5 878 1170 78
97.5 878 1170 78
97.5 878 1170 78
DAILY (LBS/DAY)
715
10299
572
596
298
894
596
298
894
715
358
1073
715
358
1073
10299
5149
15448
10299
5149
15448
572
286
858
572
286
858
429
HOURLY (LBS/HR)
23.8
23.4
23.4
23.4
0.98
0.98
0.98
7.15
596
298
894
596
298
894
429
215
644
429
215
644
23.8
11.9
35.8
23.8
11.9
35.8
7.15
3.58
10.7
7.15
3.58
10.7
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2.0 ANALYSIS OF EMISSIONS
The calculations of potential emissions from each of the three
alternative scenarios are based on the AP-42 emissions factors (in-
cluding Supplement 10). Additionally, a limitation of a maximum
annual combustion of 156,000 tons of coal, irrespective of the alter-
native, was used. This limitation is considered part of the design of
the proposed boilers. For short term emissions, design heat input of
the proposed boilers was used. The results are listed in Table 2 and
the calculation details for all six criteria pollutants are presented
in Appendix A.
Fugitive emissions which will be associated with the coal/lime/ash
handling systems are also summarized in Table 2. The calculation of
these emission estimates are included in Appendix B by duplication of
Scott Paper's estimations. However, the emission factors and calcula-
tional estimates were independently verified.
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Table 2. POTENTIAL EMISSIONS*
HEAT POLLUTANT
ALTERNATIVE
Alternative One
Boiler Nos. 8 & 9
Alternative Two
Boiler Nos. 8 & 9
Boiler No. 10
Alternative Three
Boiler Nos. 10 & 11
Boiler Nos. 12
Alternative One
Boiler Nos. 8 & 9
Alternative Two
Boiler Nos. 8 & 9
Boiler No. 10
Total
Alternative Three
Boiler Nos. 10 & 11
Boiler No. 12
Total
Alternative One
Boiler Nos 8 & 9
Alternative Two
Boiler Nos. 8 & 9
Boiler No. 10
Total
Alternative Three
Boiler Nos. 10 & 11
Boiler No. 12
Total
INPUT
596
596"}
298J
596^
298J
^
596
596
298
894
596
298
894
596
596
298
874
596
298
894
TSP
97.5
97.5
97.5
715
715
358
1073
715
358
1073
29.8
29.8
14.9
44.7
29.8
14.9
44.7
Spj,
878
878
878
10299
10299
5149
15448
10299
5149
15448
429
429
215
644
429
215
644
NO*
CO
HC
Pb
ANNUAL (TPY)
1170
1170
1170
DAILY
8582
8582
4291
12874
8582
4291
12874
HOURLY
358
358
179
536
358
179
536
78
78
78
(LBS/DAY)
572
572
286
858
572
286
858
(LBS/HR)
23.8
23.8
11.9
35.8
23.8
11.9
35.8
23.4
23.4
23.4
172
172
86
257
172
86
257
7.15
7.15
3.58
10.7
7.15
3.58
10.7
0.98
0.98
0.98
7.16
7.16
3.58
11.2
7.16
3.58
11.2
0.30
0.30
0.15
0.45
0.30
0.15
0.45
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Table 2. POTENTIAL EMISSIONS* (continued)
Fugutive emissions (identical for all three alternatives)**
TSP(TPY)
Coal Unloading 0.62
Transfer to Coal Pile 0.16
Coal Pile Activities
Active Pile 0.94
Dead Storage Pile 0.53
Reclaim Hoppers 1.12
Transfer to Bunkers/Boilers 0.75
Ash Silo ***
Lime Storage 0.0 (totally enclosed operation;
Total 4.12
* Consistent wth the August 7, 1980 promulgation, and are based on the limitations
recommended as permit conditions. (See Section 4)
** Annual estimates are based on 156,000 tons/yr.
*** 2.5 Ib/hr maximum; however, due to the poor quality of emission factors, no annual
estimate is given. Equipment specifications/operating parameters are recommended
for BACT.
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3.0 BEST AVAILABLE CONTROL TECHNOLOGY
The BACT discussion that follows is based on the installation of a
298 WJtu/hr. coal fired boiler. This discussion is reflective of all
three alternatives proposed by Scott Paper since all proposed scenarios
consist of constructing/converting various numbers of 298 M8tu/hr coal
fired boilers.
3.1 PARTICIPATES, SULFUR DIOXIDE. AND NITROGEN OXIDES
On June 11, 1979, the U.S. EPA published a final rule on the New
Source Performance Standards (NSPS) for Electric Utility Steam Gener-
ating Units. This standard does not apply to Scott Paper since no
electricity is generated. The applicable NSPS standard is described
at 40 CFR 60.40 which became effective for subject source construction
commencing after August 17, 1971. This applicable NSPS is dated and
does not reflect BACT. The Clean Air Act, as amended, recognized that
fact and required U.S. EPA to undertake studies to update these
standards. A list of these studies completed to date can be found in
Appendix C.
For Scott Paper, the applicable Pennsylvania Regulations for SO^
are more stringent than the NSPS for Electric Utilities and is BACT.
For particulates, the proposed emission limitation of 0.10 Ibs/Wtu is
considered RACT for boilers of Scott Paper's proposed size. The BACT
standard recommended here for non-utility boilers is less stringent
than that required of the utility industry. An emission limitation of
0.05 Ibs S02/MBtu is recommended to be BACT. For NOX control, an
emission limitation equal to that required of utility boilers is
recommended. BACT for NOV is 0.6 Ibs/MBtu.
J\
For S02 control, Scott Paper proposes to use a lime scrubber to
achieve a rolling 30 day average emission limitation of 0.45 Ibs
S02/MBtu. This represents a control efficiency of 80.3 percent,
which is more stringent than the NSPS level of Electric Utility
boilers, which requires a minimum of 70 percent removal efficiency at
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levels less than 0.60 Ibs S02/MBtu (30 day rolling average). Addi-
tionally, Scott Paper is required by the state SIP not to exceed a
daily cap of 0.72 Ibs S02/MBtu and not exceed 0.60 Ibs SQ2/Wtu
more than twice during any 30 day period. Accounting for the design
restriction that no more than 156,000 tons of coal will be burned
annually, BACT emissions for S02 are 878 TPY, 10,299 Ibs/day
(Alternative 1) to 15,448 Ibs/day (Alternative 2 or 3), and 429 Ibs/hr
(Alternative 1) to 644 Ibs/hr (Alternative 2 or 3).
For TSP, Scott Paper proposed to use a baghouse to meet the pre-
sent NSPS standard of 0.10 Ibs TSP/MBtu. To achieve the BACT emission
limitation of 0.05 Ibs TSP/MBtu, a control efficiency of 99.4 percent
(based on the inlet loading of 2437 Ib/hr per 298 MBtu/hr boiler) is
required. The proposed baghouse can meet this requirement. Accounting
for the design restriction that no more than 156,000 tons of coal will
be burned annually, BACT emissions for TSP are 97.5 TPY, 715 Ibs/day
(Alternative 1) to 1,073 Ibs/day (Alternatives 2 or 3) and 29.8 Ibs/hr
(Alternative 1) to 44.7 Ibs/hr (Alternatives 2 or 3).
For NO control, proper design and operation is proposed by
/\
Scott Paper to minimize emissions. This same technique can meet the
recommended BACT emission limit of 0.6 Ibs NO /MBtu. As before,
/\
with the incorporation of the design restriction that the annual coal
consumption not exceed 156,000 tons, BACT emissions for NO are
1,170 TPY, 8,582 Ibs/day (Alternative 1) to 12,874 Ibs/day (Alterna-
tives 2 or 3) and 358 Ibs/hr (Alternative 1) to 536 Ibs/hr (Alterna-
tives 2 or 3).
3.2 HYDROCARBONS, CARBON MONOXIDES, AND LEAD
At the present time, there are no mechanisms to control HC, CO,
and Pb other than the proper design and operation of the boiler. For
economic reasons, Scott Paper will see that this is done (Note: BACT
for HC and Pb are not technically required for this application).
Therefore, the BACT emissions limitations recommended which reflect
proper operation and design of the proposed boilers are 0.012 Ibs
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HC/MBtu, 0.04 Ibs CO/MBtu, and 0.0005 Ibs Pb/MBtu. The design limita-
tion of 156,000 tons of annual coal burn will restrict annual emis-
sions. BACT for HC will be 23.4 TRY, 172 Ibs/day (Alternative 1) to
257 Ibs/day (Alternatives 2 or 3), and 7.15 Ibs/hr (Alternative 1) to
10.7 Ibs/hr (Alternatives 2 or 3). BACT emissions for CO will be 78
TRY, 572 Ibs/day (Alternative 1) to 858 Ibs/day (Alternatives 2 or 3),
and 23.8 Ibs/hr (Alternative 1) to 35.8 Ibs/hr (Alternatives 2 or 3).
BACT for Pb will be 0.98 TRY, 7.16 Ibs/day (Alternative 1) to 11.2
Ibs/day (Alternatives 2 or 3), and 0.30 Ibs/hr (Alternative 1) to 0.45
Ibs/hr (Alternatives 2 or 3).
3.3 FUGITIVE PARTICULATE EMISSIONS
Scott Paper proposes various means to control fugitive emissions
from the coal, lime, and ash handling systems. Briefly, these are:
o Dust suppressant sprayed on the coal being unloaded
o Total enclosure of the area of the vibrating feeders connecting
the coal unload track hoppers and the head of the stockout
conveyor and ventilating air (negative pressure in the enclosed
area) discharg-ed through a baghouse
o Enclosure of the stockout conveyor and transfer station and
both simple wet spraying in conjunction with a telescopic chute
at the loadout end of the system
o The active coal pile will be sprayed with a dust suppressant
and additional spraying will occur over areas disturbed by
vehicular movement
o The inactive storage pile will be sprayed with a wetting agent
o Front end loaders move the coal to the reclaim hoppers wtiich
gravity feed the reclaim conveyors
o Enclosed conveyors and transfer areas, including the bunkers
and pulverizers with air evacuation to a baghouse
o Ash conditioning (wetting) of the ash silo discharge
o Enclosed lime handling system
o Spent absorbent and baghouse dust pneumatically conveyed to the
ash silo
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The above system is qualitatively described in the application and
is shown figuratively in the material balance diagram. The system
described describes BACT. However, the following items should be
adequately described/included in the final design to ensure BACT:
o The location of all sprayers to insure adequacy of coverage
o Chemical mixing of wetting agents consistent with manufac-
turer 's recommendati ons
o Frequency/methodology of respraying the active pile as it is
disturbed by vehicular movement
o Frequency of respraying of inactive parts of the coal storage
piles (The use of crusting agents rather than wetting agents
may eliminate/minimize the need to respray)
o The addition of a sprayer at the reclaim hopper to control
emissions as coal is moved to this area
o Adequate sizing of all draft fans and baghouse systems
o Covering of ash haul trucks (or similar system) unless it can
be demonstrated that the moisture added by the ash conditioning
system is sufficient to suppress fugitive emissions for the
entire haul distance to the off-site landfill (surface layer is
of prime importance).
The recommended opacity requirement, preventive maintenance
program, and recordkeeping requirements will insure that these BACT
requirements will be implemented. Additionally, the final design of
the system should be approved and implemented prior to the start of
the coal pile buildup.
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4.0 MONITORING AND EMISSION LIMITATION RECOMMENDATIONS
To ensure the continued maintenance of BACT and level of emission
as proposed, the following emission limitations are recommended:
o Opacity not to exceed 20 percent
o 0.05 Ib Particulate/MBtu heat input
o 0.45 Ib S02/MBtu heat input (30 day rolling average), a
24-hour maximum of 0.72 Ib S02/MBtu, and only two exceedances
of 0.60 Ibs S02/MBtu per 30 day period.
o 0.60 Ib NO /MBtu heat input
/\
o 0.04 Ib CO/MBtu heat input
o 0.01 Ib HC/MBtu heat input
o 0.0005 Ib Pb/MBtu heat input
The NSPS and Pennsylvania rules require substantial monitoring and
reporting requirements for this proposed boiler. Section 60.47a
describes the requirements and equipment specifications for the con-
tinous monitoring of opacity, S02» and NOX. Section 60.49a con-
tains the specific reporting requirements on malfunctions, excess
emissions, etc. Additionally, the following recommendations are made:
o The total annual coal consumption (irrespective of the alterna-
tive chosen) shall not exceed 156,000 tons. This restriction
shall be considered as part of the design of the boiler(s) and
modification of this restriction will require re-review of this
source under the PSD regulations as if it were a proposed new
subject source/modification.
o A preventive maintenance program should be established not only
for the ESP, FGD scrubber, and boiler, but also for the dust
suppression systems.
o Wetting agents and crusting agents should be used at the manu-
facturer's recommended dilution ratios.
o Records should be maintained to establish proper usage of the
wetting/crusting agents in the dust suppression system (i.e.,
dilution/consumption rates, purchase records, etc.).
o The placement/use of sprayers, covers, etc. proposed for the
control of fugitive emissions shall be consistent with that
approved by U.S. EPA.
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o Opacity resulting from all transfer points/storage piles should
not exceed five percent.
o Records of ACTUAL coal consumption should be maintained to
verify the design limitation of 156,000 tons of coal burned/yr.
o All records should be maintained and available for inspection
for a period of two years.
o All ash hauling trucks should be covered.
Lastly, the following recommendations are needed to insure a
timely selection from the three alternatives proposed and insure that
the fugitive emission control systems is BACT:
o Within 90 days of the effective date of the permit, Scott Paper
shall notify U.S. EPA of its final selection of Alternatives 1,
2, or 3 and the permit and application modified as if the
selected alternative was the sole topic of this application.
o If Alternative 2 is selected, existing Boiler Nos. 6 and 7 will
be permanently shut down when Boiler No. 10 becomes operational.
o If Alternative 3 is selected, existing Boiler Nos. 6, 7, 8, and
9 will be permanently shut down when Boiler Nos 10, 11, and 12
become operational. Additionally, if the new boilers become
operational sequentially, at least one of the existing boilers
must be retired as each new boiler becomes operational.
o No later than 180 days prior to the commencement of the coal
pile buildup, Scott Paper shall submit the final design of the
fugitive dust suppression system (including all necessary
procedures/maintenance "manuals") to U.S. EPA for approval.
o Coal pile buildup shall not commence until the fugitive dust
suppression system has been installed and operated consistent
with U.S. EPA's approval.
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5.0 DISPERSION MODELING PARAMETERS
5.1 FUGITIVE EMISSIONS AND OTHER SOURCES
An area source inventory describing the fugitive emission sources
from the new proposed coal/lime/ash handling systems can be developed
from the plot plan and the data presented in Appendix A. However,
except for a qualitative discussion, there is insufficient information
to quantify other area sources in the impact area. The only data
presented on existing sources in the region of impact is the data on
the existing oil fired Boiler Nos. 6, 7, 8, and 9 at the Scott Paper
facility. Dispersion modeling data is presented for three PSD incre-
ment consuming sources. These are Tenneco in New Jersey, Delmarva
Power and Light's Edge Moor Power Plant in Delaware, and Getty in
Delaware. This data is discussed in Section 6.0.
5.2 ALTERNATIVE ONE
Alternative 1 will consist of one stack servicing two boilers
(Nos. 8 and 9). The input parameters for a Gaussian dispersion model
using the emission limitations recommended are:
o STACK PARAMETERS
o Stack height - 180 ft (54.9 m)
o Stack diameter - 8.0 ft (2.44 m)
o Stack gas exit velocity - 54.4 ft/sec (16.6 m/sec)
o Stack gas exit temperature - 275°F (408.2°K)
o SHORT TERM EMISSION RATES
o Particulates - 29.8 Ibs/hr (3.76 g/sec)
o S02 - 429 Ibs/hr (54.10 g/sec)
o N0x - 358 Ibs/hr (45.14 g/sec)
o CO - 23.8 Ibs/hr (3.00 g/sec)
o Pb - 0.32 Ibs/hr (0.04 g/sec)
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o ANNUAL EMISSION RATES
o Particulates 29.8 Ibs/hr (3.76 g/sec)
o S02 - 268.2 Ibs/hr (33.82 g/sec)
o NOX - 358 Ibs/hr (45.14 g/sec)
o CO - 23.8 Ibs/hr (3.00 g/sec)
o Pb - 0.35 Ibs/hr (0.04 g/sec)
As can be seen, the emission rates with one exception, are the
same for both the annual and short term averaging periods. This is
the result of the fact that this reflects maximum operations whenever
the boiler is on. The design limitation of a maximum of 156,000 tons
of coal burn annually is reflected in limiting the operating hours
rather than constant operation at low load levels. The S02 emission
rate differs for the short term and annual inputs, reflecting the
lower 30 rolling average emission limit and the 24 hour maximum emis-
sion limit ceiling. These comments are appropriate for all three
alternatives.
5.3 ALTERNATIVE TWO
Alternative 2 consists of two stacks. The first stack services
Boiler Nos. 8 and 9 and is identical to the single Alternative 1 stack
(see Section 5.2 above). The second stack will serve a single boiler.
The input parameter for a Gaussian dispersion model using the emission
limitations recommended are:
o STACK PARAMETERS
o Stack height - 180 ft (54.9 m)
o Stack diameter - 8.0 ft (2.44 m)
o Stack gas exit velocity - 27.2 ft/sec (8.29 m/sec)
o Stack gas exit temperature - 275°F (408.2°K)
o SHORT TERM EMISSION RATES
o Particulates - 14.9 Ibs/hr (1.88 g/sec)
o S02 - 215 Ibs/hr (22.11 g/sec)
o N0x - 179 Ibs/hr (22.57 g/sec)
o CO - 11.9 Ibs/hr (1.50 g/sec)
o Pb - 0.16 IDS/ hr (0.02 g/sec)
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o ANNUAL EMISSION RATES
o Particulates - 14.9 Ibs/hr (1.88 g/sec)
o S02 - 134 Ibs/hr (16.9 g/sec)
o NOX - 179 Ibs/hr (22.57 g/sec)
o CO - 11.9 Ibs/hr (1.50 g/sec)
o Pb - 0.16 Ibs/hr (0.02 g/sec)
See Section 5.2 for comments on the emission rates which are also
applicable to this Alternative.
5.4 ALTERNATIVE THREE
Alternative 3 consists of the construction of three boilers
serviced by two stacks. The first stack will service Boiler Nos. 10
and 11 and is identical to the stack described in Section 5.2 above.
The second stack services Boiler No. 12 and is identical to the stack
described in Section 5.3 above. The additional comments on the emis-
sion rates discussed in Section 5.2 are applicable to both stacks
described in this Alternative.
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6.0 AIR QUALITY IMPACTS
The air quality impact analysis of this application was done
independently by Region III staff. The results of this analysis are
summarized in a memo dated July 10, 1980 from Mr. William E. Belanger
to Mr. Glenn Hanson through Mr. Lew Felleisen (see Appendix D).
Briefly, the applicant's consultant, Enviroplan, Inc., used a
proprietary dispersion model (APES) which is reported to be equivalent
to U.S. EPA's reference model MPTER. The use of this model was
approved by Region III for this application. The analysis has been
found acceptable to U.S. EPA and demonstrates that neither the NAAQS
nor the PSD increments will be violated.
Several comments will aid in clarifying the differences in disper-
sion modeling parameters described in Section 5 and the input para-
meters found in the consultant's report entitled, "Air Quality
Analysis of New or Rebuilt Coal Fired Boilers at the Scott Paper
Company Facility in Chester, Pennsylvania" (with Appendices) dated
"Revised May 28, 1980." First, the final design proposed by Scott
Paper (letter dated June 16, 1980) has a lower stack gas exit tempera-
ture (by 25°F) and a lower stack gas volume flow rate (by 19,000
ACFM) than was utilized in the dispersion modeling analyses. These
chan-ges, which would affect the air quality impacts, were known to
Region III and were considered during their review. Second, the
particulate emission rate reflecting the recommended BACT level of
0.05 Ibs/MBtu is 50 percent of that used in the analysis. The result
is that the estimated particulate impacts will be approximately 50
percent less (Scott Paper's contribution to the total impact only)
(Similar reductions in NO emissions and impacts occur). Thirdly,
/\
the emissions from the existing scenario of four oil fired boilers as
Scott Paper were negative inputs to the analysis which results in the
fact that the estimated air quality impacts reflect the net effect of
both the shutdown of existing boilers and the startup of the new
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boilers. The recommended requirement of permanent shutdown of these
units reflects this air quality impact analysis but not address the
issue of creditable contemporaneous offsets. Lastly, data for other
PSD increment consuming sources was derived from Federal and state
files and was not evaluated further.
The use of good engineering stack height was inadequately addressed
by the applicant but was independently analyzed by Region III and was
determined to be acceptable.
Finally, the nearest Class I area to Scott Paper is the Brigantine
National Wildlife Refuge, located 90 km away. There are no signifi-
cant impacts on this area from Scott Paper.
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7.0 VISIBILITY, SOIL, AND VEGETATION Iff ACT
The effects of other impacts resulting from Scott Paper's proposed
boilers is not addressed in the application. However, the pn-oposed
construction does change the boilerhouse capability presently in exis-
tence. Rather, it upgrades the source and reduces oil dependency.
Hence, no impacts which do not presently exist are expected. The
localized impact of a new coal pile is not considered significant in
an industrial area if all air quality standards are met.
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8.0 DETERMINATION OF THE AREA OF SIGNIFICANT IMPACT
The assessment of increment consumption must include all sources
which have been constructed since the baseline date. In order to
enable future sources to more easily obtain information on previously
approved PSD sources which could potentially interact with the appli-
cant's proposed source, Region III is preparing a data file to assist
in identifying potentially interacting sources which have (or are in
the process of obtaining) approved PSD permits. This report provides
the needed data on the maximum distance from which a proposed source
need not be considered as potentially interacting with the Scott Paper
Co. Plant located in Delaware County, at Chester, Pennsylvania.
8.1 METHODOLOGY
In order to assess the area of impact, the screening procedures as
described in the U.S. EPA "Guidelines on Air Quality Modeling" were
followed. Briefly, the PTMAX model of the UNAMAP package, together
with time correction factors (Ref: D.B. Turner, Workbook on Atmos-
pheric Dispersion Estimates) was used to determine a radius of signi-
ficant impact for this PSD source. The significant impact area is
defined as that area where ambient air pollutant concentrations equal
or exceed the following levels:
AVERAGING TIME
Pollutant
so2
TSP
N02
CO
Annual
1 ug/m
1 ug/m
1 ug/m
24-Hour
5 ug/m3
5 ug/m3
--
8-Hour
__
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--
0.5 ug/m3
3-Hour
25 ug/m3
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1-Hour
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--
2 ug/m3
The boundary of the area of significant impact shall extend up to a
maximum of 50 kilometers from the source.
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While these proposed models may not be appropriate for quantifying
impact in complext terrain, they will be used since, for determining a
radius of impact, they are conservative. Since the Region III data
base will be used for identification of potential interacting sources
rather than quantification of the impact, the conservative radius
resulting from the assumption of flat terrain is desirable.
8.2 DISPERSION MODELING PARAMETERS
The input parameters for a Gaussian dispersion model for the Scott
Paper Company Plant using the recommended emission limits are listed
in Section 5.0 for the various Alternatives.
8.3 SIGNIFICANT IMPACT AREA
The significant impact area by Alternative and pollutant is pre-
sented in the following table:
ALTERNATIVE NUMBER
POLLUTANT
so2
TSP
N02
CO
GOOD ENGINEERING
ONE TWO
50.0 km 50.0 km
0.98 km 1.27 km
50.0 km 50.0 km
50.0 km 50.0 km
PRACTICE STACK HEIGHT
THREE
50.0 km
1.27 km
50.0 km
50.0 km
8.4
The evaluation of the use of a good engineering practice (GEP)
height was performed in-house by Region III staff (see Appendix D).
The proposed power plant will use a GEP stack.
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I APPENDIX A
BOILER EMISSION CALCULATIONS
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BOILER EMISSIONS
I A.I ALLOWABLE EMISSIONS BASED ON 40 CFR 52.21 AS IN EFFECT ON
JUNE 19, 1980 (without operating restrictions)
I A.1.1 PARTICULATE EMISSIONS
_ -- Based on the emission limit of 0.05 Ibs/MBtu
-- for 298 MBtu/hr:
(0.05 lbs/MBtu)(298 MBtu/hr) = 14.9 Ibs/hr
(14.9 lbs/hr)(24 hrs/day) = 357.6 Ibs/day
(357.6 Ibs/day)(365 days/yr)(ton/2000 Ibs) = 65.3 TRY
-- for 596 MBtu/hr:
A.1.2 SULFUR DIOXIDE EMISSIONS
-- Based on a long-term (30-day rolling average) emission limit of
0.45 Ibs/MBtu for the annual estimate
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- (0.05 lbs/MBtu)(596 MBtu) = 29.8 Ibs/hr
(29.8 Ibs/hr) (24 hrs/day) = 715.2 Ibs/day
(715.2 lbs/day)(365 days/yr)( ton/2000 Ibs) = 130.5 TPY
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_ Based on a short-term emission limit of 0.72 Ibs/MBtu for the
hourly and daily estimates
for 298 MBtu/hr:
I (0.72 lbs/MBtu)(298 MBtu/hr) = 214.56 Ibs/hr
(214.6 Ibs/hr) (24 hrs/day) = 5149 Ibs/day
(0.45 lbs/MBtu)(298 MBtu/hr)(8760 hr/yr)( ton/2000 Ibs) = 587.4 TPY
for 596 MBtu/hr:
1(0.72 lbs/hr)(596 MBtu/hr) = 429.12 Ibs/hr
(429.12 lbs/hr)(24 hrs/day) = 10,299 Ibs/day
(0.45 lbs/MBtu)(596 MBtu/hr)(8760 hr/yr)( ton/2000 Ibs) = 1175 TPY
A. 1.3 NITROGEN OXIDE EMISSIONS
I Based on an emission limitation of 0.6 Ibs/MBtu
- for 298 MBtu/hr:
(0.6 lbs/MBtu)(298 MBtu/hr) = 178.8 Ibs/hr
(178.8 Ibs/hr) (24 hrs/day) = 4291.2 Ibs/day
(4291.2 Ibs/ day) (365 days/yr)( ton/2000 Ibs) =783.1 TPY
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- for 596 MBtu/hr:
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(0.6 lbs/MBtu)(596 MBtu/hr) = 357.6 Ibs/hr
1(357.6 lbs/hr)(24 hrs/day) = 8582.4 Ibs/day
(8582.4 lbs/day)(365 days/yr)(ton/2000 Ibs) = 1566 TRY
I A.1.4 CARBON MONOXIDE EMISSIONS
Based on AP-42 emission factor of 1 Ib/ton coal burned
-- Based on HHV of 12,500 Btu/lb coal (25 MBtu/ton)
Therefore, the calculated emission limit is:
I (1 Ib C0/ton)(ton/25 MBtu) = 0.04 Ib/MBtu
_ for 298 MBtu/hr:
(0.04 lbs/MBtu)(298 MBtu/hr) = 11.92 Ibs/hr
(11.92 lbs/hr)(24 hrs/day) = 286.08 Ibs/day
(286.08 lbs/day)(365 days/yr)(ton/2000 Ibs) = 52.2 TRY
-- for 596 MBtu/hr:
I (0.04 lbs/MBtu)(596 MBtu/hr) = 23.84 Ibs/hr
(23.84 lbs/hr)(24 hrs/day) = 572.16 Ibs/day
_ (572.16 lbs/day)(365 days/yr)(ton/2000 Ibs) = 104.4 TRY
A.1.5 HYDROCARBON EMISSIONS
Based on AP-42 emission factor of 0.3 Ibs/ton coal
-- Based on HHV of 12,500 Btu/lbs coal (25 MBtu/ton)
I Therefore, the calculated emission limit is:
(0.3 Ibs HC/ton)(ton/25 MBtu) = 0.012 Ibs/MBtu
for 298 MBtu/hr:
(0.012 lbs/MBtu)(298 MBtu/hr) = 3.576 Ibs/hr
3.576 lbs/hr)(24 hrs/day) = 85.82 Ibs/day
(85.82 lbs/day)(365 days/yr)(ton/2000 Ibs) = 15.7 TRY
- for 596 MBtu/hr:
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_ (0.012 lbs/MBtu)(596 MBtu/hr) = 7.152 Ibs/hr
(7.152 Ibs/hr)(24 hrs/day) = 171.65 Ibs/day
(171.65 lbs/day)(365 days/yr)(ton/2000 Ibs) = 31.3 TRY
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(156 x 103 tons coal)(25 MBtu/ton) = 3.9 x 106 MBtu
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A.I.6 LEAD EMISSIONS
Based on AP-42 emission factor of 1.6 (L) lbs/103 ton (where L
is lead content in ppm, average of 8.3 ppm assumed)
Based on HHV of 12,500 Btu/lb (25 MBtu/ton)
The calculated emission limit is:
((1.6)(8.3)(10-3)lbs Pb/ton)(ton/25MBtu) = 0.0005312 Ib/MBtu
_ 0.0005 Ibs/MBtu
for 298 MBtu/hr:
0.0005 lbs/MBtu)(298 MBtu/hr) = 0.149 Ibs/hr
0.149 lbs/hr)(24 hrs/day) = 3.576 Ibs/day
(3.576 lbs/day)(365 days/yr)(ton/2000 Ibs) = 0.653 TRY
-- for 5% MBtu/hr:
(0.0005 lbs/MBtu)(596 MBtu/hr) = 0.298 Ibs/hr
(0.298 lbs/hr)(24 hrs/day) = 7.152 Ibs/day
(7.152 Ibs/day)(365 days/yr)(ton/2000 Ibs) = 1.31 TRY
A.2 POTENTIAL EMISSIONS AS PER AUGUST 7, 1980 PROMULGATION
Note: Allowable emissions for 1-hour and 24-hour calculated in A.I
are identical to potential emissions and are incorporated by
Reference.
Annual emissions is restricted by the design limitation that no more
than 156,000 tons of coal will be burned annually (If an enforceable
permit restriction was incorporated into a June 19, 1978 PSD permit,
these listed emissions would become allowable annual emissions).
Based on a HHV of 12,500 Btu/lb (25 MBtu/ton), the design heat input
per year is:
This design limitation is independent of the alternative finally
selected.
A.2.1 PARTICULATE EMISSIONS
~ Based on an emission limit of 0.05 Ibs/MBtu
(0.05 lbs/MBtu)(3.9 x 106 MBtu/yr)(ton/2000 Ibs) = 97.5 TRY
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A.2.2 SULFUR DIOXIDE EMISSIONS
Based on am emission limit of 0.45 Ibs/MBtu
I (0.45 lbs/MBtu)(3.9 x 106 MBtu/yr)(ton/2000 Ibs) « 877.5 TPY
I A.2.3 NITROGEN OXIDE EMISSIONS
Based on an emission limit of 0.6 Ibs/MBtu
I (0.6 "Ibs/MBtu)(3.9 x 106 MBtu/yr)(ton/2000 Ibs) = 1170 TPY
I A.2.4 CARBON MONOXIDE EMISSIONS
~ Based on am emission limit of 0.04 Ibs/MBtu
* (0.04 lbs/MBtu)(3.9 x 106 MBtu/yr)(ton/2000 Ibs) = 78 TPY
I A.2.5 HYDROCARBON EMISSIONS
-- Based on an emission limit of 0.012 Ibs/MBtu
(0.012 1bs/MBtu)(3.9 x 106 MBtu/yr)(ton/2000 Ibs) = 23.4 TPY
A.2.6 LEAD EMISSIONS
Based on an emission limit of 0.0005 Ibs/MBtu
(0.0005 lbs/MBtu)(3.9 x 106 MBtu/yr)(ton/2000 Ibs) = 0.98 TPY
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APPENDIX B
FUGITIVE EMISSIONS ESTIMATES
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7. FUGITIVE DUST EMISSIONS
The primary sources of fugitive emissions from operation of the new
equipment are crushing, grinding, material handling and transfer
operations, wind erosion of the storage pile and the unloading of
the ash from the ash silos.
Dealing first with the coal handling system, the following is taken
from the EPA publication: "Technical Guidance for Control of
Industrial Process Fugitive Particulate Emissions", EPA-450/3-77-010,
March 1977.
Rail Car Unload
The coal is delivered to the plant by rail car; bottom dump cars
discharge coal into a double track hopper. The track"hopper
discharges to vibrating feeders which load coal onto the stockout
conveyor; with the stockout conveyor sized for 175 tph, uncontrolled
emissions of 0.4 Ib./ton will result in an uncontrolled emission of
70 Ib./hr. (62,400 Ib./yr.) when unloading.
To minimize emissions, the coal is sprayed with a dust suppressant,
and the track hoppers, enclosed space around the feeders and the
head end of the conveyor are ventilated through a baghouse for a 98%
effective removal rate of 0.02 Ib./ton or 1.4 Ib./hr. 0.62 (tons/yr.)
Stockout
The stockout conveyor has two flights, with the transfer tower
between flights arranged for the future addition of a crusher. The
discharge of the second flight is equipped with a telescopic chute
to minimize dusting as the coal drops from the conveyor to the pile.
The uncontrolled emission factor for stockout is 0.056 Ib./ton and
based on a 175 tph conveying rate, the emission is 9.8 Ib./hr.
(8,736 Ib./yr.). Controlled by wet suppression (85% effective) and
the effect of the telescopic chute (75% effective) the fugitive
emission rate is reduced to 0.365 Ib./hr. (0.16 tons/yr.).
Coal Pile
The coal storage pile contains 17,750 tons when stacked to a height
of 30 feet. Approximately half (dead storage) the pile is compacted
and another coat of dust suppressant is applied. A bulldozer or
front end loader is required to move coal from the remainder of the
pile (live storage) to the reclaim hoppers and to dress the pile.
The dust aroused by the vehicle traffic creates dusting at a rate
of 0.120 Ib./ton of coal stored or 18,778 Ib./yr. controlled by
chemical wetting agents (90% effective) reduces dusting to 0.94
tons/yr.
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Wind erosion on the 30 day storage pile is reduced, by spraying a
cheinical wetting agent or foam (95% effective), from 10,608 Ib./yr.
uncontrolled to 0.53 tons/yr. after control.
Reclaim Hoppers
Two reclaim hoppers are provided. The reclaim hoppers empty into
vibrating feeders which load coal onto the load out conveyors. The
uncontrolled emission resulting from loading coal from the above
operation is 21.5 lb./hr. (11,232 Ib./yr.). Control by gravity feed
onto the reclaim conveyor (80% effective) the emission is reduced to
4.3 lb./hr. (1.12 tons/yr.).
Coal Conveying and Transfer
Coal conveying and transfer including bunker storage, pulverizing,
transfer points and enclosed conveyors emits uncontrolled fugitive
dust, based on a conveying rate of 300 tph, at 288 lb./hr. (149,760
Ib./yr.).
Enclosed conveyors and transfer points exhausted to a baghouse (99%
effective) reduces the fugitive emission to 2.88 lb./hr. (0.75
tons/yr.).
Ash Silo Discharge
The single major source of fugitive dust emission from the ash
handling system is the ash silo discharge. The discharge of ash
from each silo to a transfer truck produces 0.4 to 5 Ib./ton of
ash discharged (estimated figure) resulting in an emission of 10
to 125 lb./hr. In order to reduce these emissions, an ash
conditioning system (dustless unloader) wets the ash and unloads
it from the silo resulting in a 98% dust reduction of 0.2 to 2.5
lb./hr.
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APPENDIX C
REFERENCES
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REFERENCES
Archer, T., P. Bakski and I.J. Weisenberg, "Review of Individual Tech-
nology Assessment Reports (ITAR) for Industrial Boiler Applications,"
Argonne National Laboratory, Technical Memo ANL/EES-TM-76, U.S.
Department of Energy Contract No. W-31-109-Eng-38, January 1980.
Buroff, J., et. al., "Technology Assessment Report for Industrial
Boiler Applications: Coal Cleaning and Low Sulfur Coal," Versar, Inc.
and Teknekron, Inc., EPA Contract No. 68-02-2199, Task 12, Draft, July
1979.
Comley, E.A., et. al., "Technology Assessment Report for Industrial
Boiler Applications: Oil Cleaning," Catalytic, Inc., EPA Contract
68-02-2604, Task 2, Draft, July 1979.
Devitt, T., P. Spaite and L. Gibbs, "Background Study in Support of
New Source Performance Standards for Industrial Boilers," PEDCo
Environmental, Inc., EPA Contract No. 68-02-2603, March 1979.
Devitt, T., P. Spaite and L. Gibbs, "Population and Characteristics of
Industrial/Commercial Boilers in the U.S.," PEDCo Environmental Inc.,
Cincinnati, Ohio, U.S. Environmental Protection Agency, Report No. EPA
600/7-79-178a, August 1979.
Dickerman, J.C. and K.L. Johnson, "Technology Assessment Report for
Industrial Boiler Applications: Flue Gas Desulfurization," Radian
Corp., EPA Contract No. 68-02-2608, Draft, July 1979.
Ehrenfeld, J.R., R.H. Berstein, K. Carr, J.C. Goldish, R.G. Orner and
J. Parks, "Systematic Study of Air Pollution from Intermediate-Size
Fossil-Fuel Combustion Equipment," CPA 22-69-85, Walden Research
Corporation, Cambridge, Massachusetts, 1971.
"Guidelines for Presentation of Cost Data for the Second Seminar on
Desulfurization of Fuels and Combustion Cases," U.S. EPA Office of
Research and Development, RD-681, November 10-17, 1975.
Hamel, B.B. and H.L. Brown, "Total Energy, Steam Use and Boiler Pro-
file for the Industrial Manufacturing Sector," (SIC 20-39), Report for
DOE under Contract E (11-1) 2862, Drexel University, Philadelphia,
Pennsylvania, January 1980.
Jones, G. and K. Johnson, "Technology Assessment Report for Industrial
Boiler applications: Nox Flue Gas Treatment," Radian Corp., EPA
Contract No. 68-02-2608, Task 45, Draft, June 1979.
Kenkley, M.L. and R.B. Neveril, "Capital and Operating Costs of
Selected Air Pollution Control Systems," Gard Inc., U.S. Environmental
Protection Agency, Report No. EPA-450/3-76-014, May 1976.
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Lim, K.J., R.J. Milligan and Lips, H.I., "Technology Assessment Report
for Industrial Boiler Applications: NOX Combustion Modification,"
Acurex Corp., EPA Contract No. 68-02-3101, December 1979.
Locklin, D.W., H.S. Krause, A.A. Putman, E.L. Kropp, W.T. Reid and
M.A. Duffy, "Design Trends and Operating Problems in Combustion Modi-
fication of Industrial Boilers," Battelle-Columbus Laboratories,
Columbus, Ohio, U.S. Environmental Protection Agency, Report No. EPA
600/2-75-067, March 1974.
"New Source Performance Standards for Industrial Boilers, Volume II,
Review of Industry Operating Practices", Pacific Environmental Ser-
vices, Inc., Argonne National Laboratory Contract No. 31-109-38-5630,
September 1980.
"The Population and Characteristics of Industrial/Commercial Boilers,"
U.S. Environmental Protection Agency, Report No. EPA-600/7-79-178a.
Putman, A.A., E.L. Kropp and R.E. Barrett, "Evaluation of National
Boiler Inventory," Battelle-Columbus Laboratories, Columbus, Ohio,
U.S. Environmental Protection Agency, Report No. EPA 650/2-74-032,
October 1975.
"Review of Individual Technology Assessment Reports and Background
Information Document for Proposed Standards for Fossil Fuel Fired
Industrial Boilers," Pacific Environmental Services, Inc., Argonne
National Laboratory Contract No. 31-109-38-5630, September 1980.
Roeck, D.R. and R.D. Dennis, "Technology Assessment Report for Indus-
trial Boiler Applications: Particulate Control," GCA/Technology
Division, EPA Contract No. 68-02-2607, Draft, June 1979.
Streets, D.G. and T.A. Speciner, "Issues Relating to New Source
Performance Standards for Industrial Steam Generators," Argonne
National Laboratory, Technical Memo ANL/EES-TM-54, June 1979.
"Technology Assessment Report for Industrial Applications: Oil
Cleaning," U.S. Environmental Protection Agency, Report No.
EPA-600/7-79-178b.
"Technology Assessment report for Industrial Applications: Coal
Cleaning and Low Sulfur," U.S. Environmental Protection Agency, Report
No. EPA-600/7-79-178C.
"Technology Assessment Report for Industrial Applications: Synthetic
Fuels," U.S. Environmental Protection Agency, Report No. EPA-600/7-
79-178d.
"Technology Assessment for Industrial Boiler Applications: Fluidized-
Bed Combustion," U.S. Environmental Protection Agency, Report No.
EPA-600/7-79-178e.
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"Technology Assessment for Industrial Boiler Applications: NOv Com-
bustion Modifications," U.S. Environmental Protection Agency, Report
No. EPA-600/7-79-178f.
"Technology Assessment for Industrial Boiler Applications: NOX Flue
Gas Treatment," U.S. Environmental Protection Agency, Report No.
EPA-600/7-79-178g.
"Technology Assessment for Industrial Boiler Applications: Particu-
late Collections," U.S. Environmental Protection Agency, Report No.
EPA-600/7-79-178h.
"Technology Assessment for Industrial Boiler Applications: Flue Gas
Desulfurization," U.S. Environmental Protection Agency, Report No.
EPA-600/7-79-1781.
Thomas, W.C., "Technology Assessment Report for Industrial Boiler
Applications: Synthetic Fuels," Radian Corp., EPA Contract No.
68-02-2608, Task 49, Draft, June 1979.
U.S. Department of Energy, "Industrial Cogeneration Optimization
Program" DOE/CS/05310-01, Prepared by Westinghouse Electric Corpora-
tion and Gibbs and Hill, Inc., January 1980.
U.S. Environmental Protection Agency, "Industrial Fuel Choice Analysis
Model: Primary Model Documentation" Prepared by Energy and Environ-
mental Analysis, Inc., Arlington, Virginia, June, 1980.
U.S. Environmental Protection Agency, "National Air Pollution Control
Techniques Advisory Committee, Minutes of Meeting July 9 and 10,
1980," July 30, 1980.
Young, C.W., J.M. Robinson and C.B. Thunem, "Technology Assessment
Report for Industrial Boiler Applications: Fluidized Bed Combustion,"
GCA/Technology Division, EPA Contract No. 68-02-2693, November 1979.
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I APPENDIX D
REGION III MEMO REGARDING SCOTT PAPER CO.'S
AIR QUALITY IMPACT ANALYSIS
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I Glenn Hanson, Chief
WA, PA, DE Section (3ASL2)
THRU: V&ew Felleisen, Chief
I Air Analysis & Energy Section (3AHL3)
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Scott raper Modeling Analysis JUl.-10.T9QO
Villiaa K. Belanger, P.E.
Air Analysis & Energy Section (3AH13)
Fer your reqneat, I have reviewed tho oodeling analysis perforncd by
Enviroplan for Scott Paper's proposed switch to coal at thio Chester, PA
plant. While I do not agree vith several things that have been done in
the analysis, there is anple car gin of safety eo that no threat is posed
to either the attainment of 1JAAQS or to the PSD increment. I have
perfomed several calculations with taore conservative background assuap-
tions and find no problems.
The modeling used here is essentially EPA's ?IPTER program vhich ia a
tmlti-source version of CHSTER. Enhanced dispersion duo to entrainrveht
has been added to the codel. This is not a standard EPA nodel, but has
been approved by Larry 2udney in his dealings vith the Cosroany in the
pre-applicetion conferences. Five years of data have been used in
Eodelins. Ky only concerns involve the receptor locations, the back-
grounds used and the CE? ctack height.
Tho. receptor locations have been set in rin^s using ring distances
determined by a nodified P1MAX. Tlie oodificationa riake it consistent
with the coslal. This is the generally-used practice in setting rin-g
distances, aud is acceptable.
i
The choice of background values is strange. Enviroplan has averaged the
Eecond-hifch values at all the local stations for short- terra backgrounds
and has averaged nany ctations for long-tera values. There has been no
attempt to account for the spatial variability of background. It also
results in lower backgrounds than vould be obtained froa the closest
tu>nitors. I have tharefore extracted local backgrounds froa the report,
and vhen added ^o,the modeled concentrations, there is still an adequate
c.?urgin of c-ifety before the UAAQS are exceeded. There is E.O effect on
the PSD increments.
Tinnlly, CEP stack height ia discussed on Page 2-23. The building
height is sivan SB 70 feet, and the lateral dimensions of the poiler-
hou&c are given as 55' x 30'. Since the CEP fornula is H + 1.5L, one
RECEIVED .
DC, VA, MO SECTION .
SEP 10190)
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_ 2 ~
oo...:...3 a rusiilt. oi o.iiy 113 £V_c ;->r t'.:o individual boilcrhouse, not
the 130 feet vhlch 1« used In nodcling. Fortunately, the Scott paper
portion of the report given a plot plan on Page 1-10 (figure 1-3). It
is obvious froa this plan that the neu boilcrhouae for Tnit 10 vould be
adjacent to that for Units 8 and 9f yielding a width of about 90 feet as
Viewed froa the stack. This yields a T-EP height of 175 feet, which is
not significantly different fron the 180 feet used. Only Option 1,
vhich docs not involve new boilers or a new stack, vould possibly have a
lover CEP heipht. This (frco the drevinj;) vould be on the order of 160
feet, and there is the possibility that tha stack is grand fathered.
Since the enissioria change ia lower under this option, there should
utill be ho air quality problem. I vould, however, want to advise Enviroplan
that detailed GZP calculations would normally be required including site
drawings. It is only fortuitons in this case that their client provided
a drawing which allowed estinates to be nade.
In sunaary, I believs that the low aodeled concentrations froa the plant
give sufficient safety laargin to allow ua to accept the nodeling results.
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APPENDIX E
Pfizer, Inc. - Easton, Pennsylvania
E-l
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LOS ANGELES. C/
PACIFIC CHICAGO, ILt
ENVIRONMENTAL RESEARCH TRIANGLE PARK. N(
SERVICES, INC. WASHINGTON D(
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July 14, 1980
Mr. Robert J. Blaszczak
Air Programs Branch
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Blaszczak:
PES has reviewed the PSD permit application received by Region III from
Pfizer, Inc. for a new oil-fired boiler to be located at their Eastern,
Pennsylvania facility. PES has completed its initial, cursory review and
has found that the requirements for a PSD permit are applicable to this
proposed construction. However, we have also found the application to
be incomplete.
The PSD regulations require that sources not identified by the 28 named
source categories which have a potential to emit more than 250 tons per
year (TPY) are required to obtain a permit. The potential SO? emissions
(using 1.5%S) are 504 TPY.
Since contemporaneous reductions in emissions are proposed by the perma-
nent shutdown of the International Boiler Works (IBW) Boiler, the applica-
bility review was also performed with respect to the proposed PSD regula-
tions of September 5, 1979 and the partial stay of regulations published
in February 5, 1980. The 1979 S(>2 actual emission for the IBW Boiler was
16.6 TPY and, therefore, does not alter the applicability determination.
However, the proposed regulations do indicate that Pfizer's proposed new
boiler will emit TSP and NOX in significant amounts. Therefore, the final-
ization of the proposed regulations may require PSD review for an additional
two pollutants.
The initial review has also found the application to be incomplete. The
following items must be further clarified:
I* The Edgemoar Boiler will be retained as an operational unit.
In the various parts of the application, it is described as
being mothballed, a standby unit, and operational but only
I when the proposed boiler is off-line. Please clarify the
status of this unit, the intent to maintain the state oper-
ating permits and its future operating schedule.
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MIDWEST OPERATIONS 465 Fullerton Ave Elmhurst, ILL 60126 (312) 530-7272
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- Mr. Robert J. Blaszczak Page 2 July 14, 1980
t BACT is required for all PSD sources. The proposed use of
|1.5%S fuel oil has not been demonstrated to be BACT. The
unit is technologically feasible to use 1.0%S fuel oil
or better.
| The description of the proposed unit's impacts on visibility,
soils, and vegetation is inadequate. This requirement of
I the PSD permit is separate from the maintenance of incre-
ments and standards demonstration. The meeting of the
increment does not necessarily satisfy this impact assessment.
I Should there be any questions, please call.
Since/ely^
|v
Utomas . .
Assistant Director
_ Midwest Operations Division
' TPB/jlf/453
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LOS ANGELES. C/
CHICAGO. ILI
ENVIRONMENTAL RESEARCH TRIANGLE PARK. N(
SERVICES, !NC. WASHINGTON 0<
October 27, 1980
Mr. Robert Blaszczak
Air Programs Branch
U.S. Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Blaszczak:
Pacific Environmental Services, Inc. (PES) has completed its initial
review of the permit application for the Prevention of Significant
Deterioration for the proposed expansion of the Phillip Morris Inc.
Park 500 facility. This review has found the application incomplete.
Table 1 enumerates the application deficiencies. These deficiencies
result from a closer examination of the supporting documentation and
do not adequately substantiate the summary statements presented by
Phillip Morris, Inc. in their June, 1980 report entitled "Evalution of
the Air Quality Impact of a Proposed Expansion of the Park 500 Facility
of Phillip Morris, Inc." It should be noted that the response to the
deficiencies listed in Table 1 does not preclude the need for addi-
tional clarification which may arise in evaluating the applicant's
response.
The evaluation was performed under EPA Contract No. 68-02-2536, Task
14. Should there be any questions, please call.
Thomas P. tfraszal
Assistant Directc _
Midwest Operations Division
TPB/cs/453
Attachments
MIDWEST OPERATIONS 465 Futterton Ave Elmhurst ILL 60126 (312) 530-7272
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Table 1. APPLICATION DEFICIENCIES
Comment Reference
Number Page No.
13 The Plot Plan and elevation shows the
existing stacks serving boilers No. 1 and
No. 2 have heights of 140 feet and 185
feet, respectively. Adjacent and nearby
buildings have heights of 112.5 feet,
which can cause excessive ground level
concentrations due to downwash. This
potential situation is not discussed in
the application.
16, 17 The total pollutant estimates presented
are based on 100 percent coal usage,
despite the statements of 80/20 coal/oil
ratio. For example, for S02 and the
fuel specifications listed, a total of
2242 tons per year (TPY) would be emitted
assuming the 80/20 ratio. This is an
increase of 90 TPY over 100 percent coal
firing. Clarification is needed.
16, 17 The use of high sulfur oil (2.4 % S, No.
6), medium sulfur coal (1.2% S) and emis-
sion limits of 0.1 Ibs particulates/MBtu
and 0.7 Ibs NO^/MBtu may not reflect
BACT for an industrial boiler of this
size (especially in light of the signifi-
cant use of fuel oil). No discussion of
BACT is presented nor referenced in the
application.
16, 17 Estimates of non-criteria pollutants are
not presented nor discussed in the appli-
cation.
The PSD regulations at 52.21 (o) require
an "Additional Impact Analysis" relating
to impairment to visibility, soils and
vegetation resulting from the source
and/or associated growth, and air quality,
resulting from growth associated with the
source. No such discussion is included
in the application.
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Table 1. APPLICATION DEFICIENCIES (continued)
Comment Reference
Number Page No.
6 25 The statement "Boiler stack height re-
quired to prevent downwash was determined
to be 250 feet..." supports the concern
addressed in Comment 1 above.
7 25 The conclusions discuss the maintenance
of the NAAQS and PSD increments at the
SAPCD monitoring site in Hopewell and at
the site of maximum impact of Park 500
before and after expansion. Neither of
the conclusions nor the 'remaining report
discuss the maintenance of the NAAQS and
PSD increments in the remaining area of
the region of impact of the proposed
source. Conversely, no discussion is
presented to support the implied conclu-
sion that these two receptor sites are
the v/orst case situation.
8 27 The use of the urban option in CRSTER
utilizes urban mixing heights but does
not change the use of Pasquill-Gifford
(Turner) dispersion coefficients. In an
urban setting, as assumed by the appli-
cant, the McElroy-Pooler dispersion
coefficients are more appropriate. Sub-
stantiation of the dispersion model
selected (i.e., CRSTER with urban mixing
heights) is warranted.
9 29 The methodology for obtaining the area
source contribution for $03 (i.e.,
background) was to subtract the modeled
impact from point sources from the mea-
sured air quality annual value at the
SAPCD Hopewell site. As presented in the
report, three concerns are evident.
First, impacts from the point sources
were representative of short term emis-
sions (this is inferred in presentation.
See Comment 10.) and as such, would over-
estimate annual impacts. Second, the
calculation is made as if the modeled
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Table 1. APPLICATION DEFICIENCIES (continued)
Comment Reference
Number Page No.
impact was without bounds. Dispersion
modeling estimates are considered accur-
ate to a factor of two. Thirdly, the
ratio of area (background) to point
source contributions at a receptor was
considered a constant for all averaging
time periods. The assumptions made in
this approach for estimating background
must be supported and documented.
10 42, 43, 44 Except for the Park 500 sources, raw data
to calculate/verify the SOj? emission
rates is not presented (emission data for
particulates is also not presented).
Although worst case emission rates are
inferred, verification of the S02 emis-
sion rates for the Park 500 Boilers 2 and
3 show some inconsistencies, which are:
Boiler No 3's emission rate is based
on 100 percent coal. Since firing of
No. 6 fuel oil up to 20 percent of the
year is proposed, emissions based on
2.51 Ibs S02/MBtu for oil rather
than 2.07 IBs S02/MBtu should be
used as the "worst short term" case.
Boiler No. 2 can use No. 6 fuel oil as
noted above. Additionally, in the 100
percent coal example, nominal rather
than minimum heating value of the coal
was used, resulting in a 13 percent
lower emission rate for S02-
Raw data of the emissions inventory should
be presented for independent verification
of the modeling input data. Also, the
methodology used by Phillip Morris in
deriving the modeling input should be
described (Example calculations would
also be helpful).
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Table 1. APPLICATION DEFICIENCIES (continued)
Comment Reference
Number Page No.
11 Nitrogen oxides are emitted by the pro-
I posed source in significant amounts. The
maintenance of the NAAQS for NOX is
neither demonstrated nor discussed in the
application.
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APPENDIX G
The Multitrade Group - Martinsville, Virginia
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^jl^&t PACIFIC
irfwj^ EN VI RON M ENTAL
VjaC^gr SERVICES, INC.
December 17, 1980
Mr. Robert Blaszczak
Air Programs Branch
U.S. Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
LOS ANGE
CHIC
RESEARCH TRIANGLE F
WASHING
Dear Mr. Blaszczak:
Pacific Environmental Services, Inc. (PES) has completed its initial
review of the permit application for the Prevention of Significant
Deterioration for the proposed coal /wood fired steam boilers of the
Multitrade Group. This review has found the application to be incom-
plete. Table 1 enumerates the application's deficiencies. It should
be noted that the response to the noted deficiencies listed in Table 1
does not preclude the need for additional clarification which may
arise in evaluating the applicant's response.
This completeness evaluation was performed under U.S
68-02-2536, Task Order No. 14. Should there be any
ral 1
Sincerely yoyxs-p A
^-^^Thomas P. Blaszak/
Project Manager
Midwest Operations Division
TPB/cs/453
Enclosure
MIDWEST OPERATIONS 465 Fullerton Ave Elmhurst, ILL 60126
. EPA Contract No.
questions, please
(312) 530-7272
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Table 1. MULTITRADE GROUP PSD APPLICATION
DEFICIENCIES/COMMENTS
Comment
Number
1 The application is for two coal/wood fired spreader stoker
boilers with total capacity of 225 MBtu/hr controlled by
two multieye Tones in series. Better design information is
needed, including the size of the individual units, whether
the particulate control device is common to both boilers
or individual devices for each, gas flow rates, particu-
late size distribution in the gas stream, etc.
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2 The multicyclones have a claimed 94 percent removal effi-
Iciency. Design curves of particle size versus efficiency
and particulate size distributions (for all proposed wood/
coal ratios) are needed to verify this efficiency.
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3 The emission limit for TSP in the state permit reflects 89
percent control efficiency rather than the 94 percent
control efficiency proposed in the application. At 94
percent control efficiency, the emission limit would be
0.12 Ibs. Particulate/MBtu.
4. The AP-42 emission factor for NOX for coal is incorrect;
1.5 Ibs. N0x/ton was used rather than 15 Ibs N0x/ton.
The correction of this error results in an emission limit
of 0.40 Ibs. NOx/MBtu.
5. All emission limits in the state permit represent a wood/
coal ratio of 50/50 (on a heat input basis). The applica-
tion states that this ratio is a minimum, and that higher
ratios would be fired. Table 2 shows that at higher wood/
coal ratios, non-compliance with the CO and HC emission
limits would result.
6. The quality of the design coal is very good. The use of a
poorer quality coal can be offset by increased wood usage
to meet TSP, $03, and NOX emission limits. However,
non-compliance with the CO and HC emission limits would be
further aggravated (see Comment 5).
7. The hourly annual fuel use figures (SCAPCD form 7-Section
E-2-Page 2) do not reflect a wood/coal ratio of 50/50.
The ratios of wood/coal (on a Btu basis) are 41.7/58.3 for
the hourly usage rates and 25.1/74.9 on an annual basis.
Both ratios are less than the permit requirement of a
50/50 minimum ratio.
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Table 1. MULTITRADE GROUP PSD APPLICATION
DEFICIENCIES/COMMENTS (Continued)
Comment
Number
8. Only five criteria pollutants are discussed in the appli-
cation. The criteria pollutant Lead and all non-criteria
pollutants must be addressed.
9. The coal/wood/ash handling systems, their fugitive emis-
sions, and their associated controls are not addressed in
the application.
10. Multigrade Group intends to sell steam to its neighbors in
the industrial park and as such, used the actual emissions
from its planned customers to "offset" the proposed new
bolers. For emissions to be considered a "creditable
contemporaneous offset," demonstration must be made to
show that the conditions listed in Section 52.21(b)(3) are
satisfied.
11. Offsets described in the application reflect no emissions
from the Multitrade customers. The quantity of emissions
increasing or decreasing is dependent on the customer
mix. For example, Table 3 shows that if Bassett-Walker
Knitting supplies its own steam (which is permitted in the
state permit) and Multitrade supplies only four of the
remaining facilities (excluding Frith Warehouse) a net
increase in emissions occurs for all five criteria pollu-
tants discussed. This increase would occur even if Multi-
trade limited its boilers to 91 MBtu/hr which is the total
design rating of these four customers.
12. BACT is not discussed for any pollutant except particu-
lates. For particulates, undocumented references and an
opinion by the applicant is an insufficient BACT demon-
stration. Previous BACT evaluations resulting in 99+
percent particulate control efficiency for wood/coal
boilers of Multitrade's proposed size have been made
(ref: Compilation of BACT/LAER Determinations. EPA-450/
2-79-003, May 1979).
13. The only Air Quality impact analysis performed was the
PTMAX model with the results compared to the de Minimis
values found in Section 52.21(i)(8). These values are for
exempting a source from conducting pre-application air
quality monitoring studies. They do not per se exempt a
source from performing an air quality impact analysis.
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DEFICIENCIES/COMMENTS (Continued)
Comment
Number
Dispersion modeling analyses must address all criteria
pollutants for all averaging times. EPA "Guidelines on
Air Quality Modeling" should serve as a guide for the
development and implementation of an acceptable air
quality impact analysis.
14. The proposed use of a good engineering stack (GEP) height
is not addressed.
15. The requirements of Section 52.21(o), Additional Impact
Analysis, have not been addressed in the application.
16. The impact (or lack thereof) of the proposed source on
Class I areas has not be discussed.
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Table 1. MULTITRADE GROUP PSD APPLICATION
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Table 2. COMPARISON OF EMISSION LIMITS
AT VARIOUS WOOD/COAL RATIOS
POLLUTANT
PERMIT EMISSION
LIMIT
(Ibs/MBtu)
ACTUAL EMISSION LIMIT (Ibs/MBtu)
FOR WOOD/COAL RATIO
TSP*
so2
NOV
X
CO
HC
0.22
0.80
0.40**
0.12***
0.11
100/0
0.03
0.15
0.23
0.20
0.20
0/100
0.20
1.41
0.56
0.04
0.02
50/50
0.12
0.78
0.40
0.12
0.11
75/25
0.07
0.40
0.31
0.16
0.16
* 94% control efficiency assumed
** Permit lists 0.27 Ibs NOx/MBtu. 0.40 Ibs. NOx/MBtu is based
on correcting the erroneous AP-42 emission factor used in the
application.
*** Equivalent to permit listing of 26.67 Ibs CO/hr
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Table 3. EMISSIONS CHANGE WITHOUT BASSETT WALKER KNITTING*
Heat Input Pollutant Emissions (TPY)
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PSD Significance Level 25 40 40 100 40
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*Emissions reflect
I 94% control efficiency for Participates (PT)
Corrected emission limit of 0.40 Ibs NOx/MBtu
-- S02» CO, and HC emission limits as per state permit
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Company
American Furniture
Martinex Fabrics
Southeast Container
Division
Continental Can
Total
Multitrade limited to 91
Net Change (+, increase)
Multitrade at design of
225 MBtu/hr
Net Change (+, increase)
(MBtu/hr)
27.10
6.25
46.00
12.55
91.
MBtu/hr
PT
2.12
0.03
0.25
0.22
2.62
47.8
+45.2
118.3
+115.7
SO?
7.36
0.45
1.26
1.13
11.2
318.9
+307.7
788.4
+772.2
NOY
A
7.50
0.35
3.70
3.26
14.8
156.6
+141.8
387.3
+372.5
CO
28.40
0.08
0.49
0.43
29.4
46.9
+17.5
116.0
+86.6
HC
31.94
0.02
0.07
0.08
32.1
43.6
+11.4
107.7
+75.6
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APPENDIX H
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_ E.I. DuPont de Nemours and Company, Inc.
Waynesboro, Virginia
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I OS ANGELL'S CA
CHICAGO III
TniAtJGLt PARK NC
WASHINGTON DC
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PACIFIC ENVIRONMENTAL SERVICES. INC.
March 27, 1981
Mr. Robert Blaszczak
Air Programs Branch
U.S. Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Blaszczak:
Under Task Order No. 14 of EPA Contract No. 68-02-2536, Pacific
Environmental Services, Inc. (PES) was requested to make a PSD
applicability determination on the proposed modification of the E.I.
duPont de Nemours and Company synthetic fiber production facility at
Waynesboro, Virginia. DuPont contends that PSD does not apply since
there will be no signficant net increase in emissions. Briefly, DuPont
states that the Acetate production shutdown in May, 1977 and the asso-
ciated power generation fuel comsumption and emission reductions are
both contemporaneous and creditable with the proposed increase(s) and
hence, there will be no significant net increase in emissions.
PES has reviewed the materials received on March 4, 1981 and has
determined first, that there are insufficient materials to indepen-
dently verify "no significant net increase," and second, that it is
probable that not all increases have been properly accounted for.
Discussed below are specific items which must be clarified/resolved
before a definitive PSD applicability determination can be made:
(1) In general, there is insufficient information to independently
verify the pollutant calculations. For example, DuPont has
presented data to show that there was a decrease in fuel con-
sumption at the powerhouse due to the Acetate shutdown in May,
1977. This reduction in tons of coal and gallons of fuel oil is
reportedly equivalent to a reduction of 1383.3 TPY S02, etc.
However, DuPont did not provide the percent sulfur, percent ash,
control device efficiency, method of calculation, etc. to verify
these quantifications of emissions (this missing information is
not limited to boilerhouse calculations).
(2) To be creditable, Section 52.21(3)(vi)(b) requires that the re-
ductions be Federally enforceable on and after May, 1982 (the
proposed start of actual construction of the Dowtherm). In their
November 20, 1980 letter, DuPont stated that proposed permit
MIDWEST OPERATIONS 465 Fullerton Ave. Elmhurst, ILL 60126 (312) 530-7272
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Mr. Robert Blaszczak March 27, 1981
U.S. Environmental Protection Agency Page 2
conditions would be available for the Philadelphia meeting (held
November 25, 1980). These were not available for review. Of
prime importance is the fact that the "offsets" are principally
derived from reduced fuel consumption at the boilerhouse. This
would require permit conditions which not only restrict the fuel
quality (i.e., percent sulfur, etc.), but also the fuel quantity
(i.e., tons of coal, etc.) on a fuel-type basis.
(3) Section 52.21(3)(vi)(a) simply states that reductions are credit-
able only to the extent that they exceed the previous actual-
allowable emissions. At DuPont, the baghouse started operation
in October, 1977. The reduction in particulate emissions from
the pre-May, 1977 levels is not clearly shown to be beyond the
actual allowable emissions for May, 1977.
(4) Section 52.24(3)(iv) states that particulate and sulfur dioxide
emissions occurring before the baseline date are creditable only
if they are "required to be considered in calculating the amount
of maximum allowable increases remaining available." Since the
Acetate shutdown occurred before the baseline date (September 25,
1979 for particulate and not yet triggered for sulfur dioxide),
this shutdown must be interpreted as the beginning of the modifi-
cation of the source. A clarification that this interpretation
is correct is needed from U.S. EPA. If this interpretation is
correct, then the significant reduction in fuel consumption from
the boilerhouse is part of the modification of the source and is
creditable. On the other hand, if this interpretation is incor-
rect, then the reductions from the boilerhouse are not creditable
and a conclusion can be reached that DuPont is subject to PSD
review, since the construction of the new emission units (i.e.,
Dowtherm and Lycra Permasep expansion) will result in a net
significant increase in emissions.
(5) Assuming that the assumption in (4) above is correct, then all
changes in emissions from the boilerhouse must be included in the
summation. At a minimum, the following changes are indicated in
the materials examined and have not been adequately described:
(a) The Nylon Plant and Permasep began construction in 1974, but
did not become fully operational until 1978. If this was
caused by construction, then the boilerhouse emissions re-
lated to these operations would be added to the May, 1977
base emissions. However, if operation during May, 1977 at
less than capacity was due to market demand, then any in-
creases from the processes themselves and the associated
boilerhouse emissions must be included with the increase
calculation.
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Mr. Robert Blaszczak March 27, 1981
U.S. Environmental Protection Agency Page 3
(b) The future operations of the boilerhouse will employ a coal/
oil fuel ratio of 94/6 (on a Btu basis). However, the fuel
use for the period May to December, 1977 indicates a coal/oil
ratio of 87.5/12.5 (on a Btu basis using 150,000 Btu/gal oil
and 12,520 Btu/lb coal). This increase in coal usage and
the increased emissions must be included in the increase
calculation. The actual Btu/gal and Btu/lb figures should
be obtained and utilized in final calculations.
(c) Boilerhouse fuel consumption is also dependent upon demand
by other processes at this source. The change caused by
these other processes, if any, is not discussed in the
application. It is noted that permit conditions on the
boilerhouse may make this point moot.
I anticipate discussing these items with you next week and potentially
with DuPont in the near future.
Sincere^y~}yours,
lomas
Project Manager
TPB/cas/453
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APPENDIX I
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_ Big Mountain Coal, Inc. (a subsidiary of Armco, Inc.)
I Prenter, West Virginia
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LOS ANGELES CA
CHICAGO. ILL
RESEARCH TRIANGLE PARK. NC
WASHINGTON DC
PACIFIC ENVIRONMENTAL SERVICES. INC.
July 30, 1981
Mr. Robert Blaszczak
Air Programs Branch
U.S. EPA, Region III
Sixth and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Blaszczak:
PES has reviewed the proposed Big Mountain Coal, Inc.'s (a subsidiary of
Armco, Inc.) new coal mining complex to be located near Prenter, West Virginia.
The proposed mining complex will include a coal preparation plant but will
not have a thermal dryer. Therefore, a Prevention of Significant Deterioration
(PSD) permit will be required only if potential emissions of any pollutant
will exceed 250 tons per year (TPY). The following discussion of particulate
emissions (the pollutant emitted in greatest quantity) demonstrates that
potential emissions are below 250 TPY. Therefore, we recommend that a
determination be made for the proposed mining complex that a PSD review is
not applicable.
The PES review commenced by independently verifying the particulate emissions
estimates made by the applicant. The 94 TPY particulate potential emissions
is correct in utilizing the following three design constraints:
1) Plant operation is limited to 5 days per week and 24 hours
per day (220 days per year, 5,280 hours per year).
2) The run of mine (R.O.M.) coal to be processed is 3,800,000
tons coal per year.
3) The clean coal produced is 2,000,000 tons coal per year.
4) The coal crusher has a capacity of 100 tons per hour.
As a check on applicability, emission calculations were made without design
constraints (i.e., based on the physical sizing of the equipment). The
design conditions described above influence the sizing of the equipment at
the proposed facility and affect the quantification of pollutant emissions
of the various operations. More specifically: (parenthesized numbers refer
to Attachment D of the submittal)
o 800 tons per hour raw coal (R.O.M.) feed to the preparation
plant was based on the availability of 3.8 million tons per
year raw coal feed. This datum was used to calculate emissions
from R.O.M. coal storage files (#1), R.O.M. coal transfer (#2),
and R.O.M. coal screening (#3).
MIDWEST OPERATIONS 465 Fullerton Ave. Elmhurst, ILL 60126 (312) 530-7272
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Mr. Robert Blaszczak Page 2 July 30, 1981
o Emissions from R.O.M. coal crushing (#4) operations were
based on a crushing rate of 100 TPH and a 220 day (5,280
hours) operating schedule.
o Clean coal transfer (#6), clean coal storage (#7), and
railcar loading (#8) emissions calculations were based on
a 2,000,000 TPY clean coal capacity, 220 days per year
(5,280 hours), and the 90% plant availability resulting
in a 421 ton per hour clean coal production rate.
Therefore, calculations were made using the physical size of the prepara-
tion plant. More specifically, the following data were used:
o 8,760 hours of operation (24 hours/day for 365 days)
o R.O.M. coal process rate is 800 tons per hour
o Clean coal production rate is 421 tons per hour
o Coal crushing rate is 100 tons per hour
Attachment 1 details these calculations. The total of 171 TPY particulate
emissions is still well below the applicability criteria of 250 TPY for
this plant.
This evaluation was prepared under U.S. EPA Contract No. 68-02-2536,
Work Assignment No. 14. Should there be any questions, please call.
Sincerely,
-:--=7^
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ATTACHMENT 1
POTENTIAL EMISSIONS BASED ON EQUIPMENT SIZE
* 1. R.O.M. coal storage piles
a. Wind erosion emissions =
0.0013 ^ x (800 TPH x 8,760 hrs) = 9,110 Ib/yr or 4.6 TPY
b. "Working the piles" emissions =
I 0.029 Ibs x (800 TPH x 8,760 hrs)(1.00-0.50) = 101,616 Ib/yr
or 50.8 TPY
2. R.O.M. coal transfer-mine to screening tower (4 transfer points)
I Emissions = 0.00025 Ib/ton x (800 TPH x 8,760 hrs)(4)(1.00-0.70)
- 2,102.4 Ib/yr or 1.1 TPY
3. R.O.M. coal screening
I Emissions = 0.10 Ib/ton x (800 TPH x 8.760 hrs)(1.00-0.70) =
210,240 Ib/yr or 105.1 TPY
4. R.O.M. coal crushing
I Emissions = 0.006 Ib/ton x (100 TPH x 8,760 hrs)(1.00-0.70) =
15,768 Ib/yr or 7.9 TPY
5. Coal cleaning
| Emissions = negligible
I 6. Clean coal transferfrom preparation plant to railcar loading
surge bins and transfer points.
Emissions = 0.00025 Ib/ton x (421 TPH x 8,760 hrs)(1.00-0.70) =
2,212.8 Ib/yr or 1.1 TPY
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7. Clean coal storage
Emissions = negligible
8. Railcar loading
Emissions = 0.0004 Ib/ton x (421 TPH x 8,760 hrs)(1.00-0.70) =
442.6 Ib/yr or 0.22 TRY
SUMMARIES
From Attachment D of Submittal
l.a.
l.b.
2.
3.
4.
5.
6.
7.
8.
From Above
4.6 tons/yr
50.8
1.1
105.1
7.9
0.0
1.1
0.0
0.2
Total 170.8 tons/yr
365 day/yr (8,760 hrs)
plant operation
l.a. 2.5 tons/yr
l.b. 27.6
2. 0.6
3. 57.0
4. 4.8
5. 0.0
6. 0.6
7. 0.0
8.
0.1
Total 93.2 tons/yr
220 day/yr (5,280 hrs)
plant operation
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I APPENDIX J
IA.E. Staley Manufacturing Company
Morrisville, Pennsylvania
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**af!*i a\
of cusrsffi* \^
\\ '°01 ^°r-irs CA
Jf/ RESEARCH TRIANGLE PARK NO
WASHINGTON DC
PACIFIC ENVIRONMENTAL SERVICES. INC.
July 6, 1981
Mr. Robert Blaszczak
Air Programs Branch
U.S. Environmental Protection Agency
Region III
Sixth and Walnut Streets
1
Philadelphia, Pennsylvania 19106
Dear Mr. Blaszczak:
I PES has completed its initial BACT and "other impacts" review of the
PSD application for
the proposed coal-fired boiler to be installed at
the A.E. Staley Manufacturing Company in Morrisville, Pennsylvania.
As a result of this
review, it has been determined that additional
information and/or commentary is needed from the applicant.
Additionally, we have provided an initial BACT recommendation for
particulate and SOo which differs from that suggested by the appli-
cant. These recommendations and a brief justification for these
recommendations are
provided. Since the applicant did not provide
support for his recommendations, no comparisonss to the applicant's
concepts could be made. These specific BACT comments are provided at
this time since it may be opportune for the applicant to supplement or
modify his application concerning BACT.
This evaluation was performed under U.S. EPA Contract No. 68-02-2536,
1
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Work Assignment No. 14.
Sincerely yours,
r- ^^eSjj^t
Thomas P. Blas^zak
/7
Senior ResearcVScientist
Midwest Operations Division
TPB/cas/453-R
Attachment
MIDWEST OPERATIONS
465 Fullerton Ave. Elmhurst, ILL 60126 (312) 530-7272
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COMMENTS AND INFORMATION NEEDS FOR THE
A.E. STALEY MANUFACTURING COMPANY'S PSD APPLICATION
o The application only addressed five criteria pollutants for the
proposed boiler. Lead, a criteria pollutant, has uncontrolled
emissions of 579.3 TPY (Ref: Supplement 10, AP-42, Compilation of
Air Pollutant Emission Factors). The non-criteria pollutants
Beryllium and Mercury have uncontrolled emissions of 0.113 TPY and
0.0105-0.180 TPY, respectively (Ref: Emission Factors for Trace
Substances). This total uncontrolled emissions exceed PSD signi-
ficant levels and must be addressed.
o BACT for particulates is not supported by the applicant. The pro-
posed emission limit of 0.1 Ibs particulate/MBtu is considered RACT
for boilers of this size. Based on the NSPS background studies and
previous PSD determinations, the recommended level of BACT for large
industrial boilers is 0.05 Ibs particulate/MBtu. The proposed bag-
house control system can achieve the 98.9 percent control efficiency
needed to meet this limit, provided that the system is operated and
maintained properly.
o BACT for S0? is not supported by the applicant. The proposed
emission limit of 1.0 Ibs SOp/MBtu is the SIP requirement only.
The recommended BACT level of 0.60 Ibs S02/MBtu is based on the
materials submitted by the applicant. Briefly, a double-alkali
scrubber of at least 85 percent control efficiency is proposed by
the applicant. Section B.2.2 of the Pennsylvania Permit Applica-
tion provides the boiler's coal specifications of 1.5 percent sulfur
and 12,500 Btu/lb. This equates to 2.28 Ibs S02/MBtu. Assuming
85 percent removal efficiency of the scrubber, an emission limit of
0.342 Ibs S02/MBtu would result. This is more stringent than the
NSPS for the electric utility industry. However, the NSPS for
the electric utility industry should provide some guidance for
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determining BACT. That NSPS requires a minimum control efficiency
of 70 percent and 90 percent control efficiency above 0.60 Ibs
SOp/MBtu. The proposed Staley boiler can achieve an emission
limit of 0.60 Ibs SO^/MBtu operating the scrubber at 74 percent
control efficiency (This should be less expensive than maintaining
the design level of 85 percent). Additionaly, the proposed scrubber
could achieve this same limit burning a coal that is twice as dirty
(with respect to sulfur content).
The recommendation of an emission limitation of 0.60 Ibs S02/MBtu
without a simultaneous percentage reduction requirement:
(1) is achievable with the control equipment proposed by Staley;
(2) recognizes that a non-utility coal user does not enter into
long-term coal contracts and must have flexibility in its
coal source; and
(3) is highly likely to be more economical to operate with the
coal specified in the application, since the design coal
only requires operation at the 74 percent removal effi-
ciency level rather than the greater than 85 percent level
specified (Note: the vendor states that 90 percent is
achievable, but was only asked to guarantee 85.6 percent).
o The fugitive dust controls for the various coal ash and sludge
handling activities are only vaguely described. Control techniques
of air aspiration, chemical wetting and coverings are not described.
Due to the preliminary nature of the design, a better definitiza-
tion may not be possible at present. However, a complete descrip-
tion of these controls should be reviewed as soon as practicable,
and the applicant is requested to provide the time frame for this
review, which would be incorporated into a permit condition.
o The growth analysis does not describe increased operations from the
existing milling facilities (up to design capacity) which may re-
sult. It is noted that the proposed boiler will not replace the
existing boilerhouse. Hence, a substantial increase in boiler
capacity will exist at the facility.
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o The qualitative description of impacts on soils and vegetation is
not satisfied by simply demonstrating that the NAAQS is maintained.
The applicant provides a description of plant sensitivity (to SCL)
and alludes to a search to identify such species. Although the
applicant identifies greenhouses, commercial vegetable growers, and
nurseries in the area of impact, no conclusion on the sensitivity
(hence, impacts) on the species which exist in the area was given.
o The good engineering stack height of 175 feet was adequately demon-
strated and utilized in the air quality impact analyses. The Penn-
sylvania permit application, however, lists a stack height of only
150 feet. The discrepancy must be resolved and the application
amended accordingly.
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APPENDIX K
Consolidated Gas Supply Corporation
Hastings Compresssor Station
Wetzel County, West Virginia
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EPA Contract No. 68-02-2536
Work Assignment No. 14
BACT EVALUATION
OF THE PREVENTION OF SIGNIFICANT
DETERIORATION APPLICATION FOR THE PROPOSED
NATURAL GAS FUELED COMPRESSOR ENGINES AT
CONSOLIDATED GAS SUPPLY CORPORATION'S
HASTINGS COMPRESSOR STATION
LOCATED IN WETZEL COUNTY, WEST VIRGINIA
Robert Blaszczak - Task Manager
Thomas P. Blaszak - Project Manager
August 6, 1981
Prepared for:
U.S. Environmental Protection Agency
Region III
Air Programs Branch
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Prepared by:
Pacific Environmental Services, Inc.
465 Fullerton Avenue
Elmhurst, Illinois 60126
(312) 530-7272
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1.0 INTRODUCTION
On June 8, 1981, Consolidated Gas Supply Corporation (C6SC) for-
warded to the U.S. Environmental Protection Agency (U.S. EPA), Region
III, an application for a permit under the Prevention of Significant
Deterioration (PSD) requirements of the Clean Air Act. Additional
information was submitted on July 31, 1981. CGSC is modernizing its
gas pipeline distribution system in its service area. Part of this
modernization program is the modification of the Hastings Compressor
Station in Wetzel County, West Virginia. This modification will
consist of relocating two existing gas-fired compressors, thereby
expanding the Hastings station. The "new" units are two 16-year old,
1,600 hp Cooper Bessemer GMVH-8 internal combustion reciprocating
engines with associated compressors. The existing Hastings Compressor
Station is a major source due to its NO emissions. The proposed
/\
modification will increase NO emissions by 217.1 tons per year
J\
(TPY). (Note: this potential emissions increase includes a design
constraint limiting the hours of operation of either unit to 5,600
hours per year and was derived using AP-42 emission factors.) No
other pollutant emitted will increase in significant amounts. There-
fore, the proposed modification is subject to PSD review for NO
A
only.
The proposed installation of the two 1600-hp engines which are 16
years old does not reflect a state-of-the-art design with respect to
minimizing NO emissions. Therefore, the evaluation for best avail-
/v
able control equipment must consider the case specific factors of
technological feasibility, energy impacts, economic impacts, and
environmental impacts. Four alternatives to the proposed installation
were examined:
(I) Modification of engine operating parameters;
(2) Hardware modification of the existing engine to meet NOX
emission rates of a new engine;
(3) Exhaust cleanup using a catalytic converter; and
(4) Installation of a new unit.
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Alternatives 1 and 3 are technologically not feasible at the
present time and were not further considered. The other two alterna-
tives would delay the project one year and would result in a loss of
680.6 million cubic feet of gas valued at $2,218,756. This is the
energy equivalent of 4.8 million gallons of oil and is considered
significant.
To further support the recommendation that the applicant's proposal
is BACT, the incremental cost of reduced NO emissions were calcu-
A
lated. The incremental costs under the alternatives examined ranged
from $591/ton to $1119/ton and are considered conservative, since the
analysis was streamlined and did not include legitimate factors such
as interest, inflation, contingencies, etc.
Three permit conditions are recommended to be consistent with the
submitted application and the BACT recommendation:
o NO emissions shall not exceed 4.9 g/sec
A
o The engines will not be operated more than 5600 hours per
calendar year, irrespective of the level of operation during
this time
o NO compliance tests demonstrations should utilize Method 7
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BACT EVALUATION
OF THE PREVENTION OF SIGNIFICANT
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DETERIORATION APPLICATION FOR THE PROPOSED
NATURAL GAS FUELED COMPRESSOR ENGINES AT
CONSOLIDATED GAS SUPPLY CORPORATION'S
HASTINGS COMPRESSOR STATION
LOCATED IN WETZEL COUNTY, WEST VIRGINIA
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1.0 INTRODUCTION
On June 8, 1981, Consolidated Gas Supply Corporation (CGSC) for-
warded to the U.S. Environmental Protection Agency (U.S. EPA), Region
III, an application for a permit under the Prevention of Significant
Deterioration (PSD) requirements of the Clean Air Act. Additional
information was submitted on July 31, 1981. CGSC is modernizing its
gas pipeline distribution system in its service area. Part of this
modernization program is the modification of the Hastings Compressor
Station in Wetzel County, West Virginia. This modification will
consist of relocating two gas-fired compressors, thereby expanding the
Hastings station. The "new" units are two 16-year old, 1,600 hp
Cooper Bessemer GMVH-8 internal combustion reciprocating engines with
associated compressors. The existing Hastings Compressor station is a
major source due to its NO emissions. The proposed modification
A
will increase NO emissions by 217.1 tons per year (TPY). (Note:
/\
this potential emissions increase includes a design constraint limiting
the hours of operation of either unit to 5,600 hours per year.) No
other pollutant emitted will increase in significant amounts. There-
fore, the proposed modification is subject to PSD review for NO
only.
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2.0 CALCULATION OF EMISSIONS
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AP-42 (Table 3.3.2-1) lists an NO emissions factor for recipro
cating engines as 11 gm/hp-hr.
For two 1600 hp engines, the hourly NO emissions are:
}\
I (11 gm/hp-hr) (2) (1600 hp) = 35,200 g/hr
or = 77.53 Ibs/hr
I or = 9.78 g/sec
The annual emissions for 8760 hours of operation would be:
(77.53 Tbs/hr)(8760 hrs/yr) = 339>58 TPY
I 2000 Ibs/ton
I For 5600 hours of operation, the annual emissions are:
|( 560° hrs/yr)(339.58 TPY) = 217.08 TPY
8760 hrs/yr
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I (For annual modeling purposes only, 217.1 TPY equates to 6.25 g/sec)
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3.0 BEST AVAILABLE CONTROL TECHNOLOGY
The installation of the two 1600-hp engines which are 16 years old
does not reflect a state-of-the-art design with respect to minimizing
NO emissions. Therefore, the evaluation for best available control
A
equipment must consider the case specific factors of technological
feasibility, energy impacts, economic impacts, and environmental im-
pacts. Four alternatives to the proposed installation were examined:
(1) Modification of engine operating parameters;
(2) Hardware modification of the existing engine to meet NOX
emission rates of a new engine;
(3) Exhaust cleanup using a catalytic converter; and
(4) Installation of a new unit.
Alternatives 1 and 3 are technologically not feasible at the
present time. The proposed engines were designed to operate in a
narrow range of working parameters. Modification of these working
parameters to reduce NO emissions will seriously affect performance
X
and reliability and hence, is not considered a feasible alternative.
Likewise, the lean burn characteristics of these engines do not meet
the specifications of the available catalytic converters currently on
the market. Vendors also do not anticipate a commercially available
catalytic converter for the proposed engine design in the foreseeable
future.
The remaining two alternatives are technologically feasible, but
both will cause a delay of one year in the completion of the modifica-
tion of the project. One of the prime advantages of the modernization
of the pipeline system is the elimination of the loss of 680.6 million
cubic feet of gas through leakage. This gas (equivalent to 4.8 million
gallons of oil) is valued at $2,218,756 (using the 1982 price of
o
$3.26/10 cu.ft.). This energy impact is considered significant.
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Additionally, a 2.5 percent fuel penalty (over the base case) is
associated with the engine hardware modification (3.4 x 10 cu.ft;
$11,084) and adds to the negative energy impact of this alternative.
From an economic viewpoint, BACT can be assessed by calculating
the incremental cost to achieve incremental reductions in NO emis-
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sions by utilizing the alternative "engines." Table 1 lists the NO
emissions from the various alternatives.
Table 1. N0₯ EMISSIONS
/\
8760 hours of operation 5600 hours of operation
TRY
339.6
101.9
101.9
Difference
(TRY) from
Base Case
228.7
228.7
TRY
217.1
65.1
65.1
Difference
(TRY) from
Base Case
152.0
152.0
Base Case
Hardware Modification
New Units
The costs described below and associated with the alternatives do
not include any escalation factors or interest costs. Installation,
operating and maintenance and other costs are conservatively assumed
as constant or offsetting between scenarios. Capital costs and/or
single one-time costs are spread over the remaining life of the
engines, which is assumed to be 16 years for the existing 16 year old
engines and 35 years for the new units.
The cost per engine of hardware modification is estimated as
$126,000 and 1200 man hours. Assuming $30/manhour, the total hardware
modification is:
(2)($126,000 + (1200)($30)) = $326,000
It should be noted that while the engine manufacturer has a design for
this hardware modification, it has never been done.
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The 1981 purchase price of a single new engine is $1,122,000. In
addition, a loss is incurred with the depreciated value of the existing
engines currently valued at $271,000. Assuming conservatively that 50
percent of this amount can be recovered through sale/salvage of these
units, the total cost is:
(2)($1,122,000)(50% of $271,000) = $2,525,000
The total cost for the alternatives is given in Table 2.
The incremental cost for reducing NO emissions is shown in
A
Table 3. The incremental costs, though conservatively incomplete, are
high. Additionally, the applicant, though proposing to limit opera-
tions to 5600 hours, would not do so if either of the alternatives
were considered. In this case, the annual NO emissions reduction
A
would only be 115.2 TPY and the incremental costs would be higher.
The proposed installation (i.e., relocating the two existing 16
year old engines) is recommended as BACT, considering the energy loss
that would result from the one year delay needed to implement the
above described alternatives and, in addition, the high incremental
cost of further NO reductions.
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Table 2. "TOTAL COSTS"
Hardware
Modification
Loss of gas caused
by one year delay
Increased fuel
consumption
Hardware/Purchase
Costs
$2,218,756/16 yrs
$16,300 (8760 hrs of operation)
$11,084 (5600 hrs of operation)
$326,000/16 yrs
$175,347/yr (8760 hrs of operation)
$170,131/yr (5600 hrs of operation)
Table 3. INCREMENTAL COST
New
Units
$2,218,756/35 yrs
$2,515,000/35 yrs
$135,250/yr
8760 hours of operation
5600 hours of operation
Incremental
NOX
Reduction
TPY
Hardware
Modification 228.7
New Units 228.7
Annual
Cost
$/yr
175,347
135,250
Incremental
Incremental NOX Annual Incremental
Cost Reduction Cost Cost
$/ton TPY $/yr $/ton
767
591
152.0
152.0
170,131
135,250
1,119
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4.0 RECOMMENDED PERMIT CONDITIONS
I The following PSD permit conditions are recommended to insure
consistency with the BACT evaluations.
o NO emissions shall not exceed 4.9 g/sec
o The engines will not be operated more than 5600 hours per
calendar year, irrespective of the level of operation during
this time
o NO compliance tests demonstrations should utilize Method 7
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5.0 DISPERSION MODELING PARAMETERS
The input parameters for an annual Gaussian dispersion model using
the recommended permit conditions are, for each category:
I o Stack Height - 41 ft (12.51 m)
o Stack Diameter - 20 in (0.51 m)
I o Stack Gas Exit Velocity - 81 ft/sec (24.9 m/sec)
o Stack Gas Exit Temperature - 247°F (660.9°K)
o NOX Emission Rate - 24.8 Ibs/hr (3.13 g/sec)
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APPENDIX L
_ Northeast Maryland Waste Disposal Authority
Baltimore, Maryland
BACT Evaluation
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EPA Contract No. 68-02-2536
Work Assignment No. 14
EVALUATION OF BEST AVAILABLE CONTROL TECHNOLOGY (BACT)
FOR THE PROPOSED SOUTHWEST RESOURCE RECOVERY FACILITY
PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICATION
SUBMITTED BY THE NORTHEAST MARYLAND WASTE DISPOSAL AUTHORITY
IN BALTIMORE CITY, MARYLAND
Robert Blaszczak - Task Manager
Thomas P. Blaszak - Project Manager
July 30, 1981
Prepared for:
U.S. Environmental Protection Agency
Region III
Air Programs Branch
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Prepared by:
Pacific Environmental Services, Inc.
465 Fullerton Avenue
Elmhurst, Illinois 60126
(312) 530-7272
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EXECUTIVE SUMMARY
1.0 INTRODUCTION
On July 7, 1981, the Northeast Maryland Waste Disposal Authority
submitted to the U.S. Environmental Protection Agency (U.S. EPA),
Region III, an application for a permit for a proposed waste disposal
facility under the Prevention of Significant Deterioration (PSD) Regu-
lations as promulgated on August 7, 1980 (45 FR 52676). Additional
material was submitted on July 20, 1981. The Northeast Maryland Waste
Disposal Authority proposes to construct a municipal waste disposal
facility in Baltimore City, Maryland, to be known as the Southwest
Resource Recovery Facility. This proposed facility will consist of
three water wall incinerators with a total design capacity of 2010
tons of refuse per day. Energy recovery from the incinerator gener-
ated steam will result from electricity produced by a 50-MW turbine or
by the direct sale of steam for heating. Ferrous residue and other
saleable materials will be recovered from the incinerated refuse.
Finally, in conjunction with the proposed new construction, the
existing pyrolisis plant located at the proposed site will be per-
manently shut down and razed.
The proposed source requires a PSD permit covering S02» CO,
NO and Fluorides. Lead will be emitted in significant quantities
A
from the new units. However, actual lead emissions from the pyrolisis
plant will "offset" the new emissions such that no "net emissions
increase" for lead will result. Berrylium and mercury emissions do
not exceed the significant amount levels which trigger PSD review.
Particulates and volatile organic compounds (VOC) emissions are sub-
ject to the State of Maryland New Source Review program under the Part
D SIP rather than PSD review since the area is non-attainment for
particulates and ozone. No other pollutants are emitted by the
facility. The potential emissions and PSD applicability criteria
levels are listed in Table 1.
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Table 1. POTENTIAL EMISSIONS FROM THE PROPOSED FACILITY
POTENTIAL SIGNIFICANT
EMISSIONS LEVEL
POLLUTANT (TPY) (TPY)
Particulates Area is Non-Attainment.
VOC Area is Non-Attainment.
S02 1259 40
CO 406 100
NOX 1001 40
Pb (Existing Plant) 2.97 No Net increase
(Proposed Plant) 2.0
Fl 15.7 3
Be 2.64 x KT6 4 x 10'4
Hg 0.01 0.1
Asbestos
Vinyl Chlorides
Hydrogen Sulfide Zero Emissions
Sulfuric Acid Mist
Total Reduced Sulfur Compounds
Reduced Sulfur Compounds
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The PSD subject pollutants emitted result principally from
incineration of the refuse. Additional though substantially smaller
quantities of PSD subject pollutants will result from the No. 2
distillate fuel that will be used for start-up of the incinerators.
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2.0 BEST AVAILABLE CONTROL TECHNOLOGY
2.1 SULFUR DIOXIDE AND FLUORIDES
The emissions of S0? and Fl result principally from the quality
of the input refuse. Maintenance of the quality of the refuse to be
processed, in order to insure that industrial refuse (and its poten-
tial to have higher sulfur and fluoride content) will not become an
acceptable waste for the facility, is the only control that is possible
for this type of process. The Northeast Maryland Waste Disposal
Authority has developed an acceptable criteria for defining acceptable
waste to insure the quality of the input refuse.
2.2 CARBON MONOXIDE AND NITROGEN OXIDE
CO and NO are products of the incineration process. The only
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practical control, hence BACT, for these pollutants at the present
time is the proper design and operation of the incinerator. The
authority has an incentive to insure the proper design and operation
is performed, since total incineration of the refuse as well as maxi-
mum heat generated for energy recovery will result.
2.3 LEAD
Although Pb is not subject to PSD, BACT will be employed. Pb is a
particulate and is controlled only by the particulate control device
employed by the facility. The utilization of a high efficiency ESP is
BACT. In addition, this control device for total particulate emis-
sions must be reviewed by the State of Maryland for LAER as part of
the state's new source review under the Part D SIP. LAER cannot be
less stringent than BACT under any circumstances.
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3.0 RECOMMENDATIONS FOR PERMIT CONDITIONS
To insure that BACT will be installed and continuously maintained,
the following permit cconditions are recommended:
o The criteria for acceptable refuse must remain as stated in the
application (see Appendix B). An approvable procedure to
insure this should be developed and implemented.
o The permanent shutdown and razing of the Pyrolisis Plant has
provided offsets for lead emissions and are not creditable for
any future application.
o The sulfur content of the No. 2 distillate fuel oil should not
exceed 0.3 percent sulfur
o The annual fuel consumption at the facility shall not exceed
180,000 gallons.
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EVALUATION OF BEST AVAILABLE CONTROL TECHNOLOGY (BACT)
FOR THE PROPOSED SOUTHWEST RESOURCE RECOVERY FACILITY
PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICATION
SUBMITTED BY THE NORTHEAST MARYLAND WASTE DISPOSAL AUTHORITY
IN BALTIMORE CITY, MARYLAND
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1.0 INTRODUCTION
On July 7, 1981, the Northeast Maryland Waste Disposal Authority
submitted to the U.S. Environmental Protection Agency (U.S. EPA),
Region III, an application for a permit for a proposed waste disposal
facility under the Prevention of Significant Deterioration (PSD) Regu-
lations as promulgated on August 7, 1980 (45 FR 52676). Additional
material was submitted on July 20, 1981. The Northeast Maryland Waste
Disposal Authority proposes to construct a municipal waste disposal
facility in Baltimore City, Maryland, to be known as the Southwest
Resource Recovery Facility. This proposed facility will consist of
three water wall incinerators with a total design capacity of 2010
tons of refuse per day. Energy recovery from the incinerator gener-
ated steam will result from electricity produced by a 50-MW turbine or
by the direct sale of steam for heating. Ferrous residue and other
saleable materials will be recovered from the incinerated refuse.
Finally, in conjunction with the proposed new construction, the
existing pyrolisis plant located at the proposed site will be per-
manently shut down and razed.
The proposed source requires a PSD permit covering SOp, CO,
NO , and Fluorides. Lead will be emitted in significant quantities
/\
from the new units. However, actual lead emissions from the pyrolisis
plant will "offset" the new emissions such that no "net emissions
increase" for lead will result. Berrylium and mercury emissions do
not exceed the significant amount levels which trigger PSD review.
Particulates and volatile organic compounds (VOC) emissions are sub-
ject to the State of Maryland New Source Review program under the Part
D SIP rather than PSD review since the area is non-attainment for
particulates and ozone. No other pollutants are emitted by the
facility. The potential emissions are listed in Table 1.
The PSD subject pollutants emitted result principally from
incineration of the refuse. Additional though substantially smaller
quantities of PSD subject pollutants will result from the No. 2
distillate fuel that will be used for start-up of the incinerators.
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Table 1. POTENTIAL EMISSIONS FROM THE PROPOSED FACILITY
POTENTIAL SIGNIFICANT
EMISSIONS LEVEL
POLLUTANT (TPY) (TPY)
Parti culates Area is Non-Attainment.
VOC Area is Non-Attainment.
S02 1259 40
CO 406 100
NOX 1001 40
Pb (Existing Plant) 2.97 No Net increase
(Proposed Plant) 2.0
Fl 15.7 3
Be 2.64 x 10~6 4 x 10~4
Hg 0.01 0.1
Asbestos
Vinyl Chlorides
Hydrogen Sulfide Zero Emissions
Sulfuric Acid Mist
Total Reduced Sulfur Compounds
Reduced Sulfur Compounds
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2.0 ANALYSIS OF EMISSIONS AND PSD APPLICABILITY
The three water wall incinerators proposed for the facility have a
total daily throughput capacity of 2010 tons of refuse. However, on
an operating basis, a nominal average throughput of 1720 tons of
refuse per day is planned. At this nominal daily rate, 627,800 tons
of refuse will be processed in one year, assuming 365 days of opera-
tion. A complete description of the entire resource recovery process
is adequately described on pages 11-16 through 11-29 of the applica-
tion. PSD subject pollutants will only be emitted by the incinerators
themselves and only that portion of the facility will be discussed
here.
2.1 SULFUR DIOXIDE EMISSIONS
Sulfur dioxide emissions result from the oxidation of sulfur con-
tained in the refuse input into the incinerators. Characterization
studies of the municipal waste found in the literature indicate an
average content of 0.1 percent by weight is present in municipal
waste. Based on this assumption of 0.1 percent sulfur in the refuse
and 2010 tons of refuse per day, 335 Ibs S02/hr will be emitted.
The annual SO^ emissions of 1255.6 TPY are based on 365 days of
operation at the nominal rate of 1720 tons refuse per day processed.
Additional SO^ emissions will result from the combustion of a
maximum of 180,000 gallons of No. 2 distillate fuel oil that will be
used for start-up of the incinerators and the preheating of the ESP's
to insure that they will effectively control particulates at the start
of refuse incineration. Assuming a maximum of 0.3 percent sulfur in
the fuel oil, 3.83 tons S02 will be emitted per year. These two
sources of S02 result in a total of 1259 TPY. This assumption of
180,000 gallons burned is conservative in that the entire on-site
storage capacity will be consumed each year. Maximum hourly start-up
fuel consumption rate will not exceed 10 gal/hr. Actual annual fuel
consumption will be dependent on the final incinerator design and
future actual maintenance and operation schedules.
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2.2 CARBON MONOXIDE
Carbon monoxide emissions are estimated from stack tests pre-
viously performed on similar water wall incinerators. These tests
show a measured CO concentration of 100 ppm when operating at 69 per-
cent excess air. Operation at 75 percent excess air should reduce
this concentration; hence, these emission estimates will be slightly
conservative. At 100 ppm and the design airflow of 243,898 dscf/min
associated with 27.9 tons/hour of refuse (2010 tons/24 hours) results
in maximum hourly emissions of 108.11 Ibs CO/hr. At the nominal daily
rate of 1720 tons refuse/day, the annual CO emissions are 405.21 TPY.
The additional CO resulting from the combustion of the start-up fuel
oil (based on AP-42 emission factors and the conservative annual usage
of 180,000 gal) is 0.45 TPY for total annual CO emissions of 406 TPY.
2.3 NITROGEN OXIDE
Nitrogen oxide emissions are also based on the same stack test
measurements for which CO emissions estimates are made. At 73 percent
excess air, NO concentrations of 150 ppm have been measured. Con-
y\
servatively assuming all NO is emitted as NOp, 266.42 Ibs NO^/hr
will be emitted at nameplate capacity. At the nominal refuse feed
rate of 1720 tons/day, 998.6 TPY N02 will be emitted. The combus-
tion of the start-up fuel oil (using AP-42 emission factors and the
conservative annual fuel usage rate noted above) will add another 2 TPY
of NO emissions for an annual total of 1001 tons NO .
A X
2.4 LEAD
Lead emissions (similar to SO^ emissions) result from the
presence of this element in the input refuse. The only historical
test data available for the Baltimore area indicates that in nearby
Montgomery and Howard counties, an average of 162 ppm of lead exists
in the municipal refuse of this area. This would result in 0.33
tons/day of lead available for emission to the atmosphere.
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Lead emissions from water wall incinerators are not known to have
been directly measured. Emission measurements from coal combustion
which indicate that one-third of the lead remains in the bottom ash is
used by the applicant in his calculations. This assumption is reason-
able and has been utilized consistently in the application. As a
result, should future information alter this assumption, the quantifi-
cation of the lead emissions would change. Using the applicant's
assumption, 18.15 Ibs/hr of lead would be emitted in the absence of a
control device.
A second assumption derived from the coal combustion studies is
the particulate size distribution in the effluent gas stream. Lead as
a pollutant is a particulate rather than a gas. Additionally, it is a
fine particulate (less than 5 urn). The size distribution from the
coal combustion studies indicate that over 75 percent of the particu-
late emissions are less than 2 urn in size. ESP's are less efficient
in this small particle size range. AP-42 indicates that for a 99
percent efficient ESP, only a 97 percent efficiency can be expected
for partial!ates in the 0-5 urn range; therefore, potential lead emis-
sions would be 0.54 Ibs/hr. At the nominal refuse rate of 1720
tons/day, 2.01 TPY lead would be emitted.
The applicant utilizes a similar argument to calculate Pb emis-
sions from the pyrolsis plant. However, the scrubber associated with
the existing plant had a particulate control efficiency of approxi-
mately 89 percent. For the 0-5 urn size range, this corresponded to 63
percent control efficiency. Using the substantially lower 75,162 tons
of refuse actually processed in the base year and assuming the same
bottom ash retention percentage of 33 percent, the annual lead emis-
sions were 2.97 TPY. Since these emissions exceed the lead emissions
of the proposed new facility, no net increase will result and hence,
lead is not subject to PSD review.
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2.5 FLUORIDES
Fluoride emissions are the result of this pollutant's content in
the input refuse. Testing of fluorides has been done prior to the
scrubber at the existing pyrolisis plant. An emission factor of
0.05 Ibs fluoride/ton refuse developed from these tests. It is reason-
able to apply this same emission factor to the proposed facility.
Therefore, fluoride emissions will be 4.19 Ibs/hr at nameplate design
and 15.7 TRY at nominal input rates.
2.6 BERYLLIUM AND MERCURY
Similar to the fluoride emission calculations, the existing
pyrolisis plant was tested for Beryllium and Mercury prior to the
scrubber. Emission factors of 1.4 x 10 Ibs beryllium/ton refuse
and 4 x 10 Ibs mercury/ton refuse were developed from these tests.
Beryllium is a particulate and the 99.4 percent control efficiency of
the control device is assumed. The resulting annual emissions of
2.64 x 10 ton beryl!iurn/yr and 0.01 ton mercury/yr are below the
significant levels which trigger PSD review.
2.7 SUMMARY
The complete description of these emission calculations has been
verified for accuracy and is reproduced from the application in
Appendix A. These emission totals and the significant emission levels
which trigger PSD review are listed in Table 1. The conclusion drawn
from this table is that the resource recovery facility is subject to
PSD review for four pollutants: S09, CO, NO , and Fluoride.
L /\
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3.0 BEST AVAILABLE CONTROL TECHNOLOGY
3.1 SULFUR DIOXIDE AND FLUORIDES
The emissions of S02 and Fl result principally from the quality
of the input refuse. The maintenance of the quality of the refuse to
be processed to insure that industrial refuse (and its potential to
have higher sulfur and fluoride content) will not become an acceptable
waste at the facility is the only control that is possible for this
type of process. The only possible alternative for SOp control
would be an add-on scrubber. However, the use of scrubbers for parti-
culate control is not considered BACT for particulates because it
cannot achieve equivalent particulate control efficiencies to the ESP
proposed (see below). Therefore, scrubbers for SO^ control (at
least at the concentrations which are expected with this project, is
not considered viable.
The Northeast Maryland Waste Disposal Authority has developed a
criteria for acceptable waste to insure the quality of the input
refuse. A copy of this criteria is included in Appendix B. The
consistency of refuse to the criteria and the implementation of a
program to insure that it is followed is BACT for SO,, and Fl.
3.2 CARBON MONOXIDE AND NITROGEN OXIDE
CO and NO are products of the incineration process. The only
A
practical control for these pollutants at the present time is the
proper design and operation of the incinerator. The authority has an
incentive to insure the proper design and operation is performed, and
hence, BACT is employed since total incineration of the refuse as well
as maximum heat generated for energy recovery will result.
3.3 LEAD
Although Pb is not subject to PSD, BACT will be employed. Pb is a
particulate and is controlled only by the particulte control device
employed by the facility. Although some uncertainty was raised
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3.0 BEST AVAILABLE CONTROL TECHNOLOGY
3.1 SULFUR DIOXIDE AND FLUORIDES
The emissions of S02 and Fl result principally from the quality
of the input refuse. The maintenance of the quality of the refuse to
be processed to insure that industrial refuse (and its potential to
have higher sulfur and fluoride content) will not become an acceptable
waste at the facility is the only control that is possible for this
type of process. The only possible alternative for SO,, control
would be an add-on scrubber. However, the use of scrubbers for parti-
culate control is not considered BACT for particulates because it
cannot achieve equivalent particulate control efficiencies to the ESP
proposed (see below). Therefore, scrubbers for S0? control (at
least at the concentrations which are expected with this project, is
not considered viable.
The Northeast Maryland Waste Disposal Authority has developed a
criteria for acceptable waste to insure the quality of the input
refuse. A copy of this criteria is included in Appendix B. The
consistency of refuse to the criteria and the implementation of a
program to insure that it is followed is BACT for SO,, and Fl.
3.2 CARBON MONOXIDE AND NITROGEN OXIDE
CO and NO are products of the incineration process. The only
/^
practical control for these pollutants at the present time is the
proper design and operation of the incinerator. The authority has an
incentive to insure the proper design and operation is performed, and
hence, BACT is employed since total incineration of the refuse as well
as maximum heat generated for energy recovery will result.
3.3 LEAD
Although Pb is not subject to PSD, BACT will be employed. Pb is a
particulate and is controlled only by the particulte control device
employed by the facility. Although some uncertainty was raised
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concerning the quantification of Pb emissions in the previous section
(although the assumptions are deemed reasonable), this uncertainty is
not significant since the utilization of a high efficiency ESP is
BACT. The particulate control device must also be reviewed by the
State of Maryland for LAER as part of the state's new source review
under the Part D SIP. LAER cannot be less stringent than BACT under
any circumstances.
4.0 RECOMMENDATIONS FOR PERMIT CONDITIONS
To insure that BACT will be installed and continuously maintained,
the following permit conditions are recommended:
o The criteria for acceptable refuse must remain as stated in the
application (see Appendix B). An approvable and enforceable
procedure to insure this should be developed and implemented.
o The permanent shutdown and razing of the Pyrolisis Plant has
provided offsets for lead emissions and are not creditable for
any future application.
o The sulfur content of the No. 2 distillate fuel oil should not
exceed 0.3 percent sulfur
o The annual fuel consumption at the facility shall not exceed
180,000 gallons.
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5.0 DISPERSION MODELING PARAMETERS
The input parameters for a Guassian dispersion model for the PSD
subject pollutants are:
o STACK PARAMETERS
o Stack Height: 315 ft (96.0 m)
o Stack Diameter: 3 flues at 7 ft (3.70 m equivalent diameter)
o Stack Gas Exit Velocity: 66.95 f/sec (20.4 m/sec)
o Stack Gas Exit Temperature: 400°F (477.4°K)
o SHORT-TERM EMISSION RATES
o S02: 335 Ibs/hr (42.24 g/sec)
o CO: 108.11 Ibs/hr (13.63 g/sec)
o N0x: 266.42 Ibs/hr (33.60 g/sec)
o Fl: 4.19 Ibs/hr (0.53 g/sec)
o ANNUAL EMISSION RATES
o S02: 286.7 Ibs/hr (36.15 g/sec)
o CO: 92.5 Ibs/hr (11.67 g/sec)
o N0x: 228.0 Ibs/hr (28.75 g/sec)
o Fl: 3.59 Ibs/hr (0.45 g/sec)
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I APPENDIX A
EMISSION CALCULATIONS
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Sulfur Dioxide
In estimating sulfur dioxide emissions from the proposed
plant, we conservatively assumed that all sulfur in the incoming
refuse will be emitted as SC>2 The plant is being designed for
a refuse sulfur content of 0.1%. Thus, maximum daily emissions
will be:
2010 ton x 0.001 ton S x 2 ton SO? _ 4,02 ton/day.
day ton refuse ton S
Since the plant will operate 24 hours per day, maximum
hourly emissions will be:
4.02 ton x 1 day x 2000 Ib = 335.00 Ib/hr.
day 24 hr ton
The plant has been designed to operate at a_rate of 1720
ton/day of refuse, 365 days/year. Thus, annual S02 emissions
from burning refuse will be:
1720 ton x 365 days x 0.001 ton S x 2 ton SO7 _ 1255.60 ton/yr.
day year ton refuse ton S
The fuel oil used for startups is estimated to have a sulfur
content of 0.3%. Using the sulfur dioxide emission factor for
firing distillate fuel oil, i.e., 142 (S) lb/103 gal (where S =
% sulfur = 0.3%), we calculate annual emissions from firing fuel
oil to be:
180,000 gal x 142 (0.3) Ib x 1 ton = 3 83 ton/yr
yr 1000 gal 2000 Ib
Total annual SO2 emissions from firing both fuels will
therefore be:
(1255.60 + 3.83) ton/yr = 1259.43 ton/yr.
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Carbon Monoxide
In estimating carbon monoxide emissions from the proposed
plant, we examined stack test data to find a set of operating
conditions similar to those in the proposed plant. Measured CO
concentration at the Nashville, Tennessee, water wall incinerator*,
operating at 69% excess air, was 100 ppm.
Excess air is one of the primary methods for minimizing car-
bon monoxide emissions. Since the proposed plant will operate
at 75% excess air, it is anticipated that a lower carbon monoxide
concentration will result from the proposed plant than was mea-
sured at Nashville. However, to be conservative, we will assume
a carbon monoxide concentration of 100 ppm for the proposed
plant. Maximum hourly emissions are thus estimated to be:
243,898 dscf x 60 min x 100 dscf CO x 1 Ib mole x 28 Ib CO -
min hr l,000,000dscf 379 dscf Ib mole
= 108.11 Ib/hr.
Maximum hourly emissions are based on a maximum charge rate
and airflow of 2010 ton/day of refuse and 243,898 dscf/min, res-
pectively. Air flow required for burning 1 ton of refuse at 75%
excess air is 174,733 dscf/ton (as previously determined for par-
ticulates). Annual CO emissions are therefore calculated as
follows:
174,733 dscf x 627,800 ton x 100 dscf CO x 1 Ib mole
ton yr 1,000,000 dscf 379 dscf
28 lb x 3- ton = 405.21 ton/yr.
Ib mole 2000 lb
* Bozeka, C.G. 1975. Nashville incinerator performance tests.
Babcock and Wilcox Company, North Canton, Ohio.
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Reference B-2, Table 1.3-1, indicates that CO emissions for
distillate fuel oil firing will be 5 lb/10^ gal. Thus, annual CO
emissions from firing distillate fuel oil during start-ups will be
180,000 gal x _5 Ib x 1 ton =0.45 ton/yr.
yr 103 gal 2000 Ib
Total annual emissions will therefore be:
(405.21 + 0.45) ton/yr = 405.66 ton/yr.
Nitrogen Oxides
In estimating nitrogen oxide emissions from the proposed
plant, we examined stack test data to find a set of operating
conditions similar to those for the proposed plant. Measured
NOX concentration at the Nashville, Tennessee, water wall
incinerator, operating at 73% excess air, was 150 ppm. (Test
data for carbon monoxide were not taken for those operating
conditions.) Since the proposed plant will operate under essen-
tially the same conditions, we assumed nitrogen oxide stack
concentrations to be 150 ppm, emitted as NO2. Maximum hourly
emissions are thus estimated to be:
243,898 dscf x 60 min x 150 dscf NO2 x 1 Ib mole x 46 Ib _
min hr 1,000,000 dscf 379 dscf Ib mole
= 266.42 Ib/hr.
As was previously determined for the particulate emission
calculations, 174,733 dscf are required to burn 1 ton of refuse
at 75% excess air. Annual NOX emissions from burning refuse
can be calculated as follows, based on a refuse charge rate of
1720 ton/day, 365 days/year, and assuming a NO2 stack gas concen-
tration of 150 ppm:
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1174,733 dsc£ x 1720 ton x 365 days x 150 dscf x 1 lb mole x
ton day yr 1,000,000 dscf 379 dscf
M f
x 46 lb x * ton = 998.56 ton/yr.
Ib mole 2000 lb
I Reference B-2, Table 1.3-1, indicates that NOX emissions for
distillate fuel oil firing will be 22 lb/103 gal. Thus, annual
NOX emissions from firing distillate oil during startups will be:
1180,000 gal x 22 lb x 1 ton = i.98 ton/yr.
yr 103 gal 2000 lb
Total annual NOX emissions will therefore be:
(998.56 + 1.98) ton/yr = 1000.54 ton/yr.
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_ Lead
In 1977, the Bureau of Mines analyzed municipal refuse
I samples from various sections of the United States (Ref. B-4).
Table 5, page 12, lists lead levels for Montgomery County and
Howard County, areas close to Baltimore. Results were as follows;
Montgomery: 158 pg/g or 158 ppm
I Howard ; 165
Average: 162 ppm '
The total lead input in the maximum refuse charge of 2010
tons per day is therefore estimated to be:
2010 ton/day x 162 = 0.33 ton/day.
_ 1,000,000
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Studies on the behavior of lead during coal combustion are
summarized in Ref. B-5 (pages 338-344). These studies indicate
that approximately 2/3 of the lead present in the coal is released
to fly ash, while 1/3 remains with the bottom ash. In the absence
of data for the behavior of lead during combustion of municipal
refuse, we will assume that it is apportioned as with coal, i.e.,
2/3 of the initial lead present will accumulate on and be emitted
with fly ash. Uncontrolled hourly lead emissions will therefore be;
0.33 ton/day x 1 day x 20°0 lb x 0.66 = 18.15 Ib/hr
24 hr ton
The studies cited in Ref. B-5 also indicate that over 75%
of the lead emissions are associated with particles less than
2 pm in size. Therefore, we will conservatively assume that
all the lead present in fly ash from the proposed plant will ad-
here to 2- pin particles. Therefore, whatever efficiency the pre
cipitators achieve for 2-micron particles will be the efficiency
of the lead removal.
According to Ref. B-2, Table A-2, an efficiency of 99% can
be expected in the particle size range of 0-5 microns for a
control device with an efficiency of 99.5%. For a 99%-ef f icient
control device, an efficiency of 97% can be expected in the par-
ticle size range of 0-5 microns. As a conservative estimate, we
will assume that the proposed 99 .4%-ef f icient precipitator
performs at 97% on the 2-micron particles.
Hourly lead emissions would thus be:
18.15 Ib/hr x (1.00 - 0.97) = 0.54 Ib/hr.
Annual lead emissions will be based on charging 1720 tons
per day of refuse for 365 days/yr. Total annual lead input at
this rate will be:
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Sines the precipitators are estimated to be 97.0% efficient
in removing lead, annual lead emissions will be:
365 days 162 ton lead
1720 ton/day x x ; - 101.70 ton/yr lead input,
year 10° ton refuse
However, since 33% of the lead will stay with the bottom ash and
I 66% will stay with the fly ash, annual uncontrolled lead emis-
sions will be:
101.70 ton/yr x 0.66 = 67.12 ton/yr.
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62.75 ton/yr x (1.00 - 0.97) = 2.01 ton/yr.
There will be no lead emissions from firing distillate fuel
oil -during startups.
Beryllium
Based on the TRW tests conducted on the pyrolysis scrubber
inlet, uncontrolled beryllium emissions were 1.4 x 10~6 Ib/tqn
of refuse charged. Since the refuse processed at the pyrolysis
plant and the proposed plant are similar, we will consider the
I TRW results representative.
| Hourly uncontrolled beryllium emissions will be:
I 1.4 x 10~6 Ib/ton x 2010 ton/day x 1 day/24 hr = 0.0001 Ib/hr,
I Reference B-6, page 804, indicates that beryllium will melt
at a temperature of 2400° F. Since the grate temperature wil'l
form at all times. Some of the beryllium is expected to stay
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not exceed 2000° F, the input beryllium will remain in solid
form at all times. Some of the beryllium is expected to sta
with the bottom ash, while the remainder is emitted with the fly
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ash. However, to be conservative, we will assume that all the
input beryllium will be emitted dispersed uniformly throughout
the fly ash. Therefore, the control efficiency of the precipita-
tor for fly ash will also apply to beryllium, i.e., 99.4%. Maxi-
mum hourly controlled beryllium emissions will therefore be:
0.0001 Ib/hr x (1.0 - 0.994) = 6 x 10~7 Ib/hr.
Annual emissions will be:
1720 ton/day x 1.4 x 10~6 Ib/ton x 365 days/yr x
x (1.00 - 0.994) x 1 ton/2000 Ib = 2.64 x 10~6 ton/yr.
There will be no beryllium emissions from firing distillate
fuel oil during startups.
Mercury
Based on the TRW tests of the pyrolysis kiln, uncontrolled
mercury emissions were 4 x 10~^ Ib/ton. Since the mercury was
sampled as a vapor, and the proposed plant precipitator will not
control vapors, uncontrolled and controlled emissions will be
the same. Maximum hourly emissions are thus:
4 x 10~5 Ib/ton x 2010 ton/day x 1 day/24 hr =
= 3.35 x 10~3 Ib/hr.
Annual emissions will be:
1720 ton/day x 365 days/yr x 4 x *0"5 lb x * ton/2000 Ib =
= 0.01 ton/yr.
There will be no mercury emissions from firing distillate
fuel oil during startups.
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Fluorides
Gaseous Fluorides
Gaseous fluorides were sampled by TRW at the scrubber
inlet of the pyrolysis plant for a processing rate of
30.6 ton/hr of refuse. An inlet concentration of 5.2 ppra
of HF was measured in an air volume of 98,951 dscf/min.
An emission factor can thus be developed as follows for
gaseous fluorides from the pyrolysis plant:
98,951 dscf x 60 min x 5.2 dscf HF
hr 1,000,000 dscf air
x 1 Ib mole x
379 dscf
20
Ib mole 30. 6 ton
ib/ton
Since the proposed plant will be handling the same kind
of refuse, the same emissions factor should be appro-
priate .
Maximum hourly uncontrolled gaseous fluoride emissions for
the proposed plant will thus be:
0.05 Ib/ton x 2010 ton/day x 1 day/24 hr = 4.19 Ib/hr.
The electrostatic precipitators will not reduce gaseous
fluoride emissions. Thus, maximum hourly uncontrolled
gaseous fluoride emissions will equal total hourly fluoride
emissions, i.e., 4.19 Ib/hr.
Annual emissions are based on charging 1720 ton/day of
refuse for 365 days/yr. Annual gaseous fluoride emissions
are thus:
1720 ton x 365 days x 0.05 Ib x 1 ton _ 15.70 ton/yr.
day year ton 2000 Ibs
Particulate Fluorides
On occasion, as noted in Ref. B-7, page 221, particulate
fluorides were also observed at the scrubber outlet of
the pyrolysis plant. Measurements indicated 136 ppm
of particulate fluorides, based on total particulate
weight.
We will assume the same concentration of particulate
fluoride emissions from the proposed plant. Thus, hourly
particulate fluorides will be:
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25.09 Ib/hr x 136 lb fluoride _ negligible.
1,000,000 Ib particulates
Annual particulate emissions from burning refuse will be
94.03 tons per year. Annual particulate fluoride emissions
will therefore be:
94.03 ton x 136 ton particulate fluoride = o.Ol ton/yr.
M yr 1,000,000 ton particulates
Total fluoride emissions will therefore be:
(15.70 + 0.01) ton/yr = 15.71 ton/yr.
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There will be no fluoride emissions from firing distillate
I fuel oil during start-ups.
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I APPENDIX B
ACCEPTABLE WASTE CRITERIA
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Excerpt From Operations Contract Between
Northeast Maryland Waste Disposal Authority and
Wheelabrator-Frye Regarding Acceptable Wastes
"Acceptable Waste" means all that household garbage, trash,
rubbish, refuse and offal that is now normally collected and/or
disposed of in the corporate boundaries of the Subdivisions.
Such Acceptable Waste may include but is not limited to, such
oversize household items as beds, mattresses, sofas, refriger-
ators, and washing machines. Oversized items may be delivered
separately. It may also include leaves, twigs, grass and plant
cuttings. Tree trunk sections and branches will be accepted
provided that they are no more than six (6) feet long and one (1)
foot in diameter. Acceptable Waste may also include items of
discarded tangible personal property such as bicycles, baby
carriages, or automobile or small vehicle tires to the extent
that air emission criteria are not violated. Acceptable Waste
may also include such types of commercial and industrial waste
as is now normally collected and/or disposed of in the corporate
boundaries of the Subdivisions except for Unacceptable Waste.
If any governmental agency or unit having appropriate jurisdiction
shall determine that any chemicals or other substances which are
not included, as of the date of this Contract, within this
definition of Acceptable Waste because they are considered harmful
or of a toxic nature or dangerous, are not harmful, toxic or
dangerous, the Authority and the Contractor may mutually agree
that such chemicals or other substances shall be Acceptable Waste
for the purposes of this Contract.
"Unacceptable Waste" means explosives, pathological and bio-
logical waste, hazardous chemicals and radioactive materials,
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oil sludges, cesspool or other human waste, human and animal re-
mains, motor vehicles, automotive engines, transmissions, rear
ends, springs, fenders or major parts of motor vehicles, trailers,
agricultural equipment, marine vessels, or similar items, farm and
other large machinery, liquid wastes, nonburnable construction
material and/or demolition debris, hazardous refuse of any kind,
such as cleaning fluids, crank case oils, cutting oils, paints,
acids, caustics, poisons, drugs or other materials that would
be likely to pose a threat to health or safety or which may
cause damage to or adversely affect the operation of the Facility.
If any governmental agency or unit having appropriate jurisdic-
tion shall determine that certain chemicals or other substances
which are not, as of the date of this Agreement, considered
harmful or of a toxic nature or dangerous, are harmful, toxic
or dangerous, the Authority and the Contractor shall agree that
such chemicals or other substances shall be Unacceptable Waste.
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I APPENDIX M
Northeast Maryland Waste Disposal Authority
Baltimore, Maryland
Electrostatic Precipitator Evaluation
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M-l
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This report was prepared under EPA Contract
Number 68-02-2536
Work Assignment Number 14
EVALUATION OF THE ELECTROSTATIC PRECIPITATOR
SYSTEM FOR THE PROPOSED RESOURCE RECOVERY
FACILITY OF THE NORTHEAST MARYLAND DISPOSAL
AUTHORITY LOCATED IN BALTIMORE, MD
Robert Blaszcz-ak - EPA Project Officer
Thomas Blaszak - PES Project Manager
May 1982
Prepared for
Air Programs Branch
U.S. Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Prepared by
Pacific Environmental Services, Inc.
1905 Chapel Hill Road
Durham, North Carolina 27707
(919) 493-3536
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TABLE OF CONTENTS
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Page
| SUMMARY .......................... iii
1.0 INTRODUCTION ..................... 1
12.0 EVALUATION OF PROPOSED ELECTROSTATIC PRECIPITATOR
SYSTEM ....................... 2
_ 2.1 Review of Section IV. Emission Control
Technology .................. 2
2.2 Impacts of Variations in Gas Flow Parameters . . 6
12.3 Experience with ESP Operation at Existing Resource
Recovery Units ............ .... 9
2.4 Recommendations ................. 14
| Appendix A: Calculations of Refuse Composition from the
Flue gas Analysis ............. A-l
I Appendix B: Evaluation of Electrostatic Precipitator
Design Specifications ........... B-l
Appendix C: Calculations for Estimating Effects of
Increase in Combustion Air Flow Rates . . . C-l
Appendix D: A Brief Description of the Operating Resource
Recovery Units ............... D-l
Appendix E: Persons Familiar with the Operating Resource
Recovery Facilities ............ E-l
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LIST OF TABLES
Title Page
2-1. Proposed ESP Specifications 3
2-2. Calculated Specific Collection Plate Area (SCA)
Based on Existing ESP Installations on Water-wall
Incinerator Units 5
2-3. Sensitivity of Proposed ESP Design to Changes in
Incinerator Characteristics 8
2-4. Available Data on Electrostatic Precipitator
Design at Existing Incinerator Units 10
2-5. Available Participate Emission Test Data for the
Existing Resource Recovery Units 11
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SUMMARY
An evaluation of the proposed electrostatic precipitator (ESP)
system and its comparison with the operating ESPs at existing resource
recovery units indicate that the proposed system has been designed
adequately for the amount of particulate and volume flow rate indicated.
2
The proposed ESP system will contain 806 ft of collection plate area
per 1,000 acfm of flue gas, and should perform at 99.4 percent efficiency
required to reduce the flue gas particulate concentration from 2.5 gr/dscf
at 12 percent C02 to 0.015 gr/dscf at 12 percent COp. The calculated
maximum collection plate area to achieve the same efficiency based on
2
the ESP design at existing facilities is less than 600 ft /I,000 acfm
flue gas. The proposed system can be expected to perform with reliability
under design conditions as each of the three ESP devices includes excess
collection plate area and is designed for a low velocity gas flow. The
ESPs will be down for 2 months each year because of the scheduled shutdown
of their associated incinerators. This annual outage will provide
opportunity for a better than average preventive maintenance program.
Characteristics of the refuse to be burned in the proposed facility
are not clearly defined in the application. Significant departures from
the design refuse characteristics may cause changes in flue gas composition
and affect the ESP performance. Variations in ash content of refuse or
flyash dropout rate in boilers will proportionally increase the particulate
concentrations at ESP inlet and outlet. For example a 20 percent increase
in refuse ash content or an additional 20 percent sweep of total flyash
into flue gas (i.e. about 36 percent less flyash dropout in boilers)
will increase the ESP inlet concentration by 20 percent from 2.5 gr/dscf
at 12 percent C02 to 3.0 gr/dscf at 12 percent COp, thus requiring an
overall particulate efficiency of 99.5 percent to achieve the design
outlet loading of 0.015 gr/dscf.
In the evaluation of the ESP system, it was assumed that the acidity
of refuse to be burned in the proposed plant is known and taken into
consideration in the ESP design. Therefore no efforts were made to
collect information on the possible corrosion effects of refuse on the
proposed ESP system.
Ill
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The experience at existing resource recovery facilities indicate
that the problems of ESPs are mainly due to the refuse characteristics
and plant specific factors. Strict regulation of the quality of the
input refuse and an effective preventive maintenance program are essential
for optimum performance of an ESP for resource recovery units.
iv
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1.0 INTRODUCTION
This document presents an evaluation of the electrostatic precipitator
system (ESP) for the proposed incinerator facility of the Northeast
Maryland Disposal Authority. This evaluation has resulted from a detailed
review of Chapter IV of the "Southwest Resource Recovery Facility Permit
Application" prepared by Martin Marietta Corporation, available information
on many existing incinerator ESP systems, and conversations with various
personnel associated with the incinerator ESP operation.
The main objective of the evaluation was to determine adequacy of
proposed ESP system to meet the required emission limit of 0.015 gr/dscf
and reasonableness of its design effectiveness.
In addition to the evaluation of the ESP system equipment design,
an attempt has been made to review the factors considered in the design
of the incinerator/ESP system and other factors which were not considered
but may provide a better evaluation of the system.
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1
2.0 EVALUATION OF PROPOSED ELECTROSTATIC PRECIPITATOR SYSTEM
2.1 Review of Section IV. Emission Control Technology of the Permit
Application
Each of the three electrostatic precipitators (ESPs) is designed to
treat a gas volume flow rate of 154,474 acfm at 400°F. The ESP system
guarantee of 99.4 percent efficiency and outlet particulate concentration
of 0.015 gr/dscf corrected to 12 percent C02 is based on the treatment
of flue gas containing 67.5 Ib/min (48.6 tons/day) of particulate. The
amount of particulate in the flue gas is based on a refuse ash content
of 17.45 percent. 78.4 percent of the total ash is bottom ash and the
remaining 21.6 percent is flyash. Thirty-six percent of total flyash
was assumed to dropout in the boilers (see Appendix A, p. A-5). An
analysis which relates the gas volume flow rate and its composition to
the refuse characteristics, indicates that the gas volume flow rate of
154,474 acfm at 400°F will be generated by a maximum refuse burn rate of
712 tons/day at 100 percent excess combustion air. (This analysis does
not account for the carbon content of the auxiliary fuel and assumes
that 100 percent combustion takes place.) A detailed analysis of gas
volume flow rate to estimate refuse characteristics is provided in
Appendix A.
The ESP specifications given on page IV-6 of the permit application
and reproduced as Table 2-1 indicate that each ESP consists of four
fields with three to be active at any give time and 124,500 ft2 of total
collection plate area. This plate area equates to an active specific
collection plate area (SCA) of 604 ft2/ 1,000 acfm and a total SCA of
806 ft2/!,000 acfm at the design gas flow rate of 154,474 acfm per ESP.
It also equates to an active SCA of 706 ft2/!,000 acfm and total SCA of
942 ft2/l,000 acfm at the nominal flow rate of 132,200 acfm per ESP.
Gas velocity in the ESP varies from 1.93 ft/second at the nominal flow
rate to 2.25 ft/second at the design flow rate. An analysis of the ESP
design specifications is provided in Appendix B.
Experience with ESPs indicate that successful performance of an ESP
depends upon a proper design of ESP device and its operation and
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Table 2-1. REPRODUCTION OF ESP
SPECIFICATIONS
_ FROM THE PERMIT APPLICATION
1
Table IV-1. Precipitator specifications
precipitator}
Gas volumetric flow rate
Operating temperature
Effective collection plate area
Residence time
Compartments
_ Number of electrical sections
I Electrical length per plate
Wire diameter
jj Wires per section
Wire length per section
1 Type of electrodes ISODYNE, FIELDS 1 &
STAR, FIELDS 3 & 4
Wire-to-plate spacing
Wire-to-wire spacing
1 Particle resistivity
Applied voltage, each section
Total current in electrical section
1
1
1
1
1
1
(applicable for each
154,474 acfm
400° F
373,500 ft2
17 seconds
1
4
12.5 ft
1/16 in. x 3/16 in.
545
30 ft
2)
> (see Figure IV-1)
)
5.5 in.
11 in.
108 - 10l° ohm-cm
50,000 volts
1700 milliamperes
per transformer
rectifier set
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maintenance. In general, efficiency of an ESP is proportional to specific
collection plate area (SCA) and electrical power input to it. Optimum
power input to an ESP is achieved by proper sectional ization of ESP with
independent power supply to each section. In addition, gas velocity in
the precipitator below a maximum value is necessary to avoid particulate
re-entrainment. Review of available data on ESP design at existing
resource recovery units indicate that the proposed ESP is designed
conservatively. In comparison with the existing systems the proposed
system contains more than adequate collection plate area and power
supply. The existing ESP systems were designed for efficiencies of
93 to 98.5 percent and included SCA of 120 to 320 ft2/!,000 acfm.
Table 2.2 presents the existing ESP design data and calculated SCA
values for achieving 99.4 percent efficiency. The data indicate a
maximum calculated SCA of 550 ft2/!,000 acfm is needed to achieve
99.4 percent.
Plant specific factors such as refuse characteristics, method of
combustion air and plant location influence the design (e.g. material of
construction), operation and maintenance of an ESP system. Refuse with
higher acidity, when burned in an incinerator system located in an area
of high moisture content, may become a source of corrosion. (High
moisture content air, if leaked into the ESP system may produce corrosion
in the presence of chlorine and S02 in the flue gas). An improper ratio
of under-fire to over-fire combustion air may cause air stratification
in the system and aid corrosion. People familiar with the existing
pyrolysis plant and the Pulaski incinerator plant, both located in
Baltimore City, expressed the opinion that the refuse fed to these
plants may be highly acidic. Analysis of the ash from the pyrolysis
plant in the past has indicated a pH value as low as 1.2, and the analysis
of ash from the Pulaski incinerator plant indicated a pH value of as low
as 3.O.* Information on the potential affect of acidic refuse and
moisture content of the air on the proposed ESP design and operation
were not presented in the application. An assumption has been made that
*Telephone conversation between Vishnu Katari, PES, and Bill Tollman, Koppers
Company, Baltimore City, MD on January 21, 1982.
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the refuse that was input into the pyrolysis plant will be representative
of the input refuse of the proposed incinerator. Therefore, in the
evaluation of the proposed ESP system, it was assumed that the acidity
of the refuse is known and has been adequately considered in the ESP
design. No further efforts were made to collect and analyze data on the
corrosion effects of refuse on the proposed ESP system.
2.2 Impacts of Variations in Gas Flow Parameters
Gas parameters such as volume flow rate and particulate concentration
from a resource recovery unit vary over a range depending upon the
refuse composition, combustion air and boiler efficiency. Particulate
control systems are usually designed to handle gas flow rates generated
under worst possible conditions. As indicated earlier the proposed ESP
system is designed to treat 463,422 acfm of flue gas at 400°F produced
from burning a maximum refuse rate of 2,136 tons/day in three incinerators.
The design combustion air is 100 percent excess air. The system is
designed for a low velocity of 2.25 ft/sec and includes 25 percent
redundant plate area. It is not known if the excess air would be
restricted to below 100 percent either by limiting fan capacity or by
another technique. However an increase in excess air potentially as
high as 130 percent will have no effect on the particulate removal
capability of the ESP system if the amount of particulate entering the
ESP system remains at the design rate 67.5 Ib/min. As shown in Appendix C,
increasing the combustion air to 130 percent excess air from the design
excess air of 100 percent will increase the total volume flow rate by
only 12 percent. The actual flue gas particulate concentration will be
lowered if the total particulate rate entering the ESP remains at design
rate. However, the particulate concentration in terms of grains per dry
standard cubic feet corrected to 12 percent C0« will remain unaffected
by the changes in excess air. Therefore the only change that will
result from an increase in excess air to 130 percent with no change in
the input particulate rate will be the increase in gas velocity from
2.25 ft/sec to 2.46 ft/sec.
The problem associated with the increase in excess air over the
design excess air will be that the ratio of flyash-in-flue gas to
flyash-dropout in the boilers may not remain constant. The ESP system
design is based on a ratio of 1.8 to 1. But any increase in this ratio
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due to the increased gas velocity in the incinerator system from increased
excess air may proportionally increase the ESP inlet participate concentration.
For example, an additional 20 percent sweep of flyash into flue gas will
change the ratio of flyash-in-flue gas to flyash-dropout in the boiler
to a ratio of 3.4 to 1.0. The inlet particulate concentration will be
increased by 20 percent over the design concentration from the 2.5 gr/dscf
at 12 percent CO^ to 3.0 gr/dscf at 12 percent (XL. thus requiring an
overall particulate removal efficiency of 99.5 percent to achieve the
design outlet loading of 0.015 gr/dscf.
The following changes in refuse composition will affect the performance
of the ESP system. Any changes in refuse ash content or total flyash or
flue gas flyash content at ESP inlet* will cause proportional changes in
the ESP inlet and outlet particulate concentrations. A periodic increase
in the amount of refuse (if it is possible to burn in the incinerator
system) will require proportionally higher amount of combustion air and
generate proportionally higher volume flow rate of flue gas. Limited
higher volume flow rates of flue gas can be treated in the proposed ESP
system. If necessary all four fields in the ESP may be activated (which
will result in increased power consumption). However if the supply of
combustion air is limited, an increase in the refuse feed rate will
result in incomplete combustion and higher combustible material in flue
gas. When high amounts of rubber containing material or extremely high
chlorine content material are present in the refuse, problems such as
particulate material sticking to the ESP internal parts or corrosion of
ducts and ESP, will result. These problems will necessitate frequent
and extreme maintenance and will lower the system reliability.
A deterioration of boiler efficiency will also result from increased
flue gas temperature and therefore increased volume flow rate. As
discussed earlier, certain amounts of excess flue gas can be treated in
the ESP without problems. (However if the drop in boiler efficiency is
significant both the boiler and ESP will be shutdown). Table 2-3 summarizes
the impacts of variations in incinerator characteristics.
*Design dropout of flyash in boilers is 36 percent of total flyash.
e.g. A 50 percent less dropout in boilers will increase amount of
particulate loading to the ESP by 28 percent.
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2.3 Experience^_witji jSP Operations at Existing Resource Recovery Units
Currently four waterwall resource recovery incinerator facilities
are known to be in operation. They are located in the City of Braintree,
Massachusetts; City of Harrisburg, Pennsylvania; City of Nashville,
Tennessee; and City of Saugus, Massachusetts. A brief description of
these facilities is included in Appendix D. In addition to these units,
a small incinerator unit with two boilers is in operation in the City of
Salem, Virginia. An another waterwall resource recovery unit which is
located in the City of Chicago operated for several years in 1970s. The
unit has not operated for at least the last three years. Its operation
was discontinued in favor of landfill ing the refuse. The physical unit
itself, currently, serves as a transfer point for refuse from the point
of origin to the landfill facility. Table 2-4 presents available
information on ESP design at 19 existing incinerator units. The listed
units include both waterwall incinerators and refractory lined incinerators.
The data indicate that the existing ESP systems were designed for removal
efficiencies of 93 to 98.5 percent and have specific collection plate
areas (SCA) of 120 to 320 ft2/!,000 acfm.
All the currently existing waterwall incinerator facilities including
the emission control systems have been plagued with operating problems
in the past. The problems varied in nature and seemed to have originated
due to the refuse characteristics, the circumstances surrounding the
unit, and the control system design limitations. Table 2-5 presents the
latest particulate emission compliance test data available for the
resource recovery units. Some of the test data were obtained by or in
the presense of EPA personnel. The remaining test data were obtained by
the incinerator operator or the ESP manufacturer. Table 2-5 also presents
the ESP design data for the purpose of a comparison between the design
and the actual performance. The data included in the table are volume
flow rates, ESP specific collection plate area, and particulate concentration.
When available the emission test data for both the ESP inlet and outlet
are presented. As explained earlier, the City of Chicago Northwest
incinerator is not in operation. The City of Salem, Virginia, incinerator
has no control system. The City of Braintree, Massachusetts, and the
City of Harrisburg, Pennsylvania, incinerators are having problems and
have been in and out of compliance. Of the two remaining incinerators
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Table 2-4. AVAILABLE DATA ON ELECTROSTATIC PRECIPITATOR DESIGN
AT EXISTING INCINERATOR UNITS
Incinerator3'
1. City of Baltimore, MD
2. City of Braintree, MAC
3. City of Chicago, ILC
4. City of Harrisburg, PAC
5. City of Honolulu, HI
6. City of Lexington, KY
7. City of Montreal, Canada0
8. City of New York, Brooklyn, NY
9. City of New York, Southshore, NV
10. City of New York,
Hamilton Avenue, NY
11. City of Philadelphia, PA
12. Dade County, Miami, FL
13. Gross Point, MI
14. Hempstead, Love Island, NY
15. Nashville Thermal Incinerator,
TNC
16. Quebec City, P.Q.C, Canada
17. Resco Facility, City of
Saugus, MA^
18. Town of Huntington, Long
Island, NY
19. Washington, D.C.
Design Performance
Instal-
lation,
Year
1975
1970
1971
1970
1970
1970
1981
1976
97.5
95
1972
Effi-
ciency,
%
93
96.9
95
95
95
95
95
95
98.1
95.6
96.5
95
94.5
98.5
209
95
SCA, ft2/
1,000
acfn
126
154
162
149
145
177
331
316
0.292
203
Particulate loading,
gr/scf
Inlet
1.6
1.87
0.13
1.87
1.87
0.7d
1.41d
2.14
7.08
0.05
0.0146
1.87
Outlet
0.086
0.05
0.2
0.0138
0.0875
0.093
0.093
0.0346d
0.01d
0.093
0.015
0.107
0.2
Refractory lined units except when indicated otherwise.
Refractory lined units are equipped with evaporative cooling/electrostatic
precipitor system.
cWaterwall unit.
Grains per actual cubic feet (gr/acf).
10
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Table 2-5. AVAILABLE PARTICIPATE EMISSION TEST DATA FOR THE
EXISTING RESOURCE RECOVERY UNITS3 (Concluded)
the tests were conducted in the stack, i.e., at the outlet of ESP
except when indicated.
Tests were conducted at 160 percent of design refuse burning capacity.
Only one of the two boilers were operated.
Currently not in operation.
ESP inlet and outlet tests were conducted simultaneously. Only first
three tests at inlet and outlet were conducted by EPA.
eOnly one of the two units (Unit No. 1) was tested.
Total volume flow for two ESP units.
90nly the tests conducted on 9/22/76 were observed by EPA.
hTests on 9/22/76 were conducted on Unit 1, and the tests on 8/26/77
were conducted on Unit 2.
The ESP system is guaranteed for an outlet particulate loading of
0.015 gr/dscf at 12 percent C02<
^Obtained by testing the fine-tuned ESP system.
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(City of Saugus, Massachusettes, and City of Nashville, Tennessee,
thermal incinerators) only the City of Nashville incinerator is designed
for a stringent ESP outlet participate loading of 0.015 gr/dscf at
12 percent C02. However, as indicated by the test data, the ESP outlet
particulate concentration at this facility exceeded the design under
normal operating conditions. But the same ESP after a fine tuning
performed at a level exceeding the design.
The experience at existing resource recovery facilities indicates
that the problems with ESPs are mainly due to the refuse characteristics
and plant specific factors. All of the existing facilities experienced
outages due to corrosion problems. Other problems which contributed to
unscheduled outages of ESPs included pluggage of gas distribution plates,
collection plates, and hoppers. No one seems to have a firm indication
of causes of corrosion, but chlorine and moisture content of refuse and
uneven distribution of combustion air in the system are recognized as
contributing factors to corrosion. Suggestions made by personnel experienced
with the resource recovery units are that a strict regulation of refuse
and its composition, the development of an efficient preventive maintenance
program and adherence to this program are a necessity for operating an
ESP at its optimum removal efficiency.
Another suggestion was that cross-connection of ESPs at the inlet,
and a spare ESP would be helpful to a facility experiencing severe
outage problems and requiring frequent maintenance. However, the fact
that the cross-connection of ESPs at the inlet increases capital and
operating costs of the system and the fact that it possibly causes
velocity irregularities in the ESP system thus affecting its removal
efficiency, are also recognized. The cross-connection of ESPs at inlet
is unnecessary if the refuse to be burned contains negligible amounts of
corrosion elements.
The following preventive maintenance program had proved to be very
successful for City of Chicago, Northwest incinerator*. Each of the
four units was brought down twice a year on a rotating basis. Usually
Conversation with John Ellis, who was responsible for the ESP system at
this facility when it was in operation. February 10, 1982.
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each unit was brought down only for a day or two for a complete internal
inspection during the first shutdown. As a rule, during this inspection,
the items which need maintenance or replacement were noted and arrangements
were made to correct deficiencies. When the unit was reentered for the
second time (after 60 days for the main scheduled shutdown for 15 to
30 days) the items which were noted in the first inspection were corrected.
In addition, the entire unit was once again thoroughly checked. t
2.4 Recommendations
The availability and reliability of an ESP system for a resource
recovery unit depend upon many factors, especially refuse characteristics
and proper maintenance. Detailed information on refuse characteristics
for the proposed facility and any suggested maintenance program by the
ESP manufacturer are not provided in the application. As indicated
earlier the ESP system has been designed adequately to meet the required
outlet concentration of 0.015 gr/dscf based on the design inlet loading.
Reliability of its performance will depend upon variations in system
actual parameters and operation. The following recommendations for
additional information are made for improving the evaluation of the
proposed ESP system.
o Obtain the following information from Wheelebrator-Frye, the
manufacturer of the proposed ESP system and the systems at
two of the currently operating resource recovery facilities,
namely the City of Saugus, and City of Braintree incinerators
in Massachusetts:
- The possibilities of combustion air exceeding the
design value is 100 percent excess air, frequency of
occurrance, and the relation between the increase in
combustion air and the ratio of flyash-in-boiler to
flyash-in-flue gas.
- Meantime to repair, meantime to failure, a list of
equipment failures, causes of failures, and actions that
were taken to prevent similar failures at the existing
installations.
- Possibility of providing performance guarantee correction
curves for variation in operating parameters such as gas
flow, ash loading, and temperature. Also possibility of
providing example calculations to determine the performance
guarantee if one or more parameters vary.
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- Electrical power consumption rate guarantees.
- Possibility of over 15 percent total participate at ESP
inlet being less than 10 m in size and the resulting
particle size effect on the ESP performance. Test data
obtained at Nashville Thermal Incinerator, Tennessee,
indicated that an average of 40 percent (between 26 and
56 percent) of the ESP inlet particulate were less than 10
microns in size and that an average of 21 percent (range
between 18 and 40 percent) of the ESP inlet particulates
were less than 5 micron*.
Consult Region X which is presently evaluating involved with
a proposed resource recovery facility in the City of Portland,
Oregon. This facility has many similarities with the proposed
facility in Baltimore City, Maryland. The refuse burning
capacity and ESP design parameters for both facilities were
the same. However, the ESP design specifications for the
proposed City of Portland, Oregon, facility have been changed
to include five fields in place of the original four.
9
Obtain more data on analysis of refuse to be burned. The
permit application for the proposed unit did not discuss the
chlorine content of the refuse. Also, it is believed that
the ash content of the flue gas from the current pyrolysis
plant was strongly acidic (to a level of 1.2 pH value).
Consult the personnel listed in Appendix E for information on
the existing or proposed resource recovery units.**
*Reference 10 in Application.
**According to National Solid Waste Management, seven resource recovery
units are proposed to be built. They are to be located in Anadoga
County, NY, Westchester County, NY, Bronx, NY, Oyster Bay, NY,
Tampa, FL, Lawrence, MA, and Baltimore, MD.
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APPENDIX A: CALCULATIONS OF REFUSE COMPOSITION FROM THE FLUE6AS ANALYSIS
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CALCULATIONS OF REFUSE COMPOSITION FROM THE FLUE GAS ANALYSIS
Analysis of Flue Gas
Flue gas volume flow rate - 463,418 acfm at 400°F (given)
= 463,418 acfm x USS = 285,595 scfm at 70°F
= 285,595 scfm * 386.7 scf/mole = 738.54 moles/min
Molar composition of
flue gas:
Gas
component
co2
so2
°2
N2
H20
Total
Vol ume
composition,
% volume
7.95
0.01
9.08
68.33
14.63
100.00
aFrom page B-3, Appendix B. In: Southwest
Facility Permit Application.
Obtained by multiplying volume composition
volume flow rate of 738.54 moles/min.
Total b
molar volume,
moles/min
58.71
0.07
67.06
504.64
108.05
738.54
Resource Recovery
with total molar
Specific gravity of flue gas
7.95 x 44.011 + 0.01 x 64 + 9.08 x 32 + 68.33 x 28.2 + 14.63 x 18.016
100 x 29
= 0.98
Density of flue gas at std. conditions = (Sp. gravity) (Density of air)
= 0.98 x 0.075 = 0.0732 lb/ft3
Total mass of flue gas
= (Density) (Volume flow rate)
= 0.0732 lb/ft3 x 285,595 ft3/min
= 20,914 Ib/min.
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Total oxygen (0^) content of flue gas
= 02 present in C02, S02, 02 and H20
= (58.71 + 0.07 + 67.06 + 0.5 x 108.05) moles/min
=179.87 moles/min
Calculation of Combustion Air
Total dry combustion air
= (Moles of nitrogen in flue gas) * (moles of nitrogen per mole of air)
I = 504.64 moles of N,, * 0.791 mole N2/mole of air
= 637.98 moles/min (assuming that all the nitrogen in the flue
I gas came with air i.e., there was no nitrogen in the refuse
and auxiliary fuel)
= 637.98 moles/min x 29 Ib/mole = 18,500 Ib/min
Water contained in combustion air
I = (Moles of combustion air) x (air humidity)
« 637.98 moles/min x (0.013 Ib water per Ib of air at 80°F and
60% humidity) x 29 Ib air/18.016 Ib water
= 13.35 moles of water
| Total wet combustion air
_ = (Moles of dry combustion air) + (Moles of water)
= 637.98 + 13.35 = 651.33 moles/min
= (1 + 0.013) (18,500 Ib/min) = 18,741 Ib/min
Total oxygen present in combustion air
I = Total oxygen + oxygen in water
m = [(0.209 moles of 09/mole of air) x 637.98 moles/min of air] +
(0.5 x 13.35 molesV H20)
= 140.01 moles/min
Available oxygen in combustion air
= (0.209 moles of 02/mole of air) x 637.98 moles/min
= 133.34 moles of 02 per min
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Composition of Refuse
Oxygen (09) content of the waste
L.
= Moles of 02 in flue gas - Moles of 0,, in combustion air
= 179.87 - 140.01 = 39.86 moles/min
Combined hydrogen content of the waste (in the form of water)
= 2 x 39.86 moles of 02 = 79.72 moles/min (assuming that all
the oxygen in the waste is present as water. Therefore, 2
moles of hydrogen exist for each mole of oxygen.)
Uncombined hydrogen content of the waste
= Water content of flue gas - combined hydrogen of waste -
water content of air
= 108.05 - 79.72 - 13.35 = 14.98 moles/min
Water formed due to oxidation of uncombined hydrogen in the waste
= 1 mole of H2 + 0.5 mole of 0,, 1 mole of H^O
= 14.98 moles of H0/min
c.
Theoretical amount of oxygen for total combustion of refuse
= Moles of 00 in C00, S00, and water formed from refuse
2 2 2
= 58.71 + 0.07 + 0.5 x 14.98 = 66.27 moles/min (assumption is
that no CO is formed)
Excess air used, percent
= / Total 02 - Theoretical OA Assumption is that no
1 Theoretical 02 f uuu; CO is present in the
x ' flue gas
_ / 133. 33 - 66.27\x (\w\\ - IQI o __rccnt
or from flue gas analysis
9.08 %
(0.209 Ib mole 09\
1 v fip "\'\°L i npt
0.791 Ib mole N2 )x '66% " 9'UKX
= 101.2 percent
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M Ratio of total flue gas to combustion air
= (Total flue gas) * [(N~ present in the flue gas) * (% N9 in combustion
- air)] 2 2
= 100 * (68.33% 4 0.791)
= 115.76^ 116 percent
The Calculated Incinerator Burning Rate (on an ash-free basis)
I = (Total mass of flue gas) - (Total amount of wet air introduced)
- (Amount of fuel)
1= 20,914 Ib/min flue gas - 18,741 Ib/min wet air
- (30 gallons of fuel per hour x 8.5 Ib/gal * 60 min/hour)
= 2,168.75 Ib/min of ash-free waste burned
= 65 tons/hr
I The incinerator burning rate = 61 tons/h (given in the report)
Refuse characteristics: Ultimate Analysis
Carbon, 58.71 moles/min. x 12 Ib/mole = 704.52 Ib/min (32 wt% of total)
Sulfur, 0.07 moles/min. x 64 Ib/mole = 4.48 Ib/min (2 wtX of total)
Oxygen, 39.86 moles/min. x 32 Ib/mole = 1,275.52 Ib/min (59 wt% of total)
| Hydrogen, (79.72 + 14.98) x 2
= 189.40 Ib/min (9 wt% of total)
Total = 2,173.92 Ib/min (100 wt% of total)
I Total ash content of refuse (as given in Application)
= Bottom ash + flyash from boilers + flyash from ESPs + flyash
« in flue gas
= 275.1 + 27.0 + 48.3 + 0.3 = 350.7 tons/day
I = (350.7 * 2,010) = 17.45 percent of design refuse flyash content
Flyash content
| = 27.0 + 48.3 + 0.3 = 75.6 tons/day
. = 75.6 * 2,010 = 3.76 percent of design refuse
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Bottom ash content
= 275.1 tons/day
I = 275.1 * 2,010 = 13.7 percent of design refuse
Noncombustible content of refuse
= (Bulky noncombustibles) + (Bottom ash + Ferrous material) +
(Flyash from boilers) + (Flyash from ESPs) + (Flyash in flue gas)
I = 43.7 + 425.1 + 27.0 + 48.3 + 0.3 = 544.4 tons/day
= (544.4 * 2,010) = 27 percent of design refuse input
Amount of flue gas generated per unit of refuse
= 285,595 scfm * [2,010 t/d * (24 h x 60 min/d)]
= 204,600 scf per ton of total refuse burned
I = 204,600 scf/ton * 2,000 Ib/ton = 102.3 ft3/lb of refuse
- = 285,595 scfm * [2,010 t/d x 0.73 * (24 h x 60 min/d)]
= 280,300 ft3 per ton of combustible refuse
I = 140 ft3/lb of combustible refuse
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_ APPENDIX B: EVALUATION OF ELECTROSTATIC PRECIPITATOR DESIGN SPECIFICATIONS
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Evaluation Electrostatic Precipitator (ESP) Design Specifications
Design Specifications (from page IV-6 of the report)
Number of ESPs
Number of fields/ESP
Number of fields active at a time
Effective plate area, total for all ESPs, ft2
Gas flow rate/ESP, acfm
Electrical length per plate, ft
Wire length per section, ft
Wire-to-plate spacing, in
Wire-to-wire spacing, in
Residence time, seconds
Calculation of ESP dimensions and velocity
ESP plate area per field, ft2
= Total plate area 4 (No. of ESPs x No. of fields/ESP)
= 373,500 * (3 x 4)
Single plate dimensions, length, ft
height, ft
Single plate area, ft2
(12.5 ft long x 31.125 ft high x 2 sides)
Total number of plates/field
= Plate area/Field * Plate area/Plate
= 31,125 ft2 * 778.125
Number of ducts = Number of plates
ESP width, ft
= Number of ducts x duct spacing
= 40 x (11 in * 12 in/ft)
ESP cross-sectional area, ft2
= 31.125 ft heights x 36.7 width
*Wire length per section is 30 ft. But, the standard plate
31.125 ft for Wheel ebrator-Fry ESPs.
B-2
3
4
3
373,500
154,474
12.5
30
5.5
11.0
17.0
31,125
12.5
31.125*
778.125
40
40
38.7
1,142.3
size is
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ESP dimensions:
Length, ft = 50
Height, ft = 31.125
Width, ft = 36.7
Calculation of gas velocity and ESP specific collection
at design flow rate
Velocity, ft/min (ft/sec)
plate area (SCA)
= (Gas volume flow rate acfm) * (cross-sectional area, ft2)
= 154,474 acfm * 1,142.3 ft2
Residence time, sec
= (ESP length for 3 active fields, ft) * (velocity
= 12.5 ft x 3 f 2.25 ft/sec
Effective SCA, ft2/!, 000 acfm
= (Number of active fields x total plate area per
f (Total gas flow rate, acfm * 1,000)
= 3 x 31,125 ft2 * (154,474 acfm * 1,000)
Total available SCA, ft2/!, 000 acfm
135.2
(2.25)
, ft/sec)
16.7
field, ft2/field)
604
= (Total number of fields x total plate area per field, ft2/field)
* Total gas flow rate, acfm f 1,000)
= 4 x 31,125 ft2 4 (154,474 acfm * 1,000)
Calculation of gas velocity, residence time and SCA for
qas flow rate
Nominal gas flow rate, acfm
(85.6 percent of design flow rate)
= 85.6% x 154,474 acfm
Gas velocity, ft/min (ft/sec)
= 132,200 acfm * 1,142 ft2 cross-sectional area
Residence time, sec
806
nominal
132,200
116
(1.93)
= 12.5 ft x 3 Precipitator length * 1.98 ft/sec, velocity 19
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Effective SCA, ft2/!,000 acfm
= 3 active fields x 31,125 ft2 total plate area per field *
(132,200 acfm * 1,000) 706
Total available SCA ft2/!,000 acfm
1= 4 fields, total x 31,125 ft2 total plate area per field
* (132,200 acfm * 1,000) 942
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B-4
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APPENDIX C: CALCULATIONS FOR ESTIMATING EFFECTS OF INCREASE
IN COMBUSTION AIR FLOW RATES
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Effect of Increase in Combustion Air Flow rate over Design Combustion
Air at 101.2 percent Excess
Design excess combustion air = 101.2 percent
Excess combustion air at a given time = z percent
Increase in excess air over the design excess air = (z - 101.2)/100
Increase in total volume of flue gas
- (L-i - )x (Theoretical air) * (Total design flue gas volume)
\ 100 /
From Appendix B
Theoretical 02 required = 66.27 moles/mi n
I Total design volume flow rate
= 463,418 acfm at 400°F
285,595 scfm at 70°F
738.54 moles/min
_
Increase in total molar volume of flue gas
(66'27 moles/min ° * °'209 moles mole of
_ * (738.54 moles/min of flue gas)
' = 0.429 (Z "IQQ ' 1 moles/mole of design volume
I Total molar volume flow rate
= (moles of design volume flow) x 1 + 0.429 fz "
= (moles/mole of design volume flow) x (0.566 + 0.429z%) - Equation 1
Increase in water content of flue gas
,on/z - 101. 2\ /nnnJbJuA / 29 l
.429^ - IM-jx^0'013lF7fFJx ^ 16.016
« 0.009 x (Z ioO°lt2) moles/mo1e of design volume
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Total water content of flue gas
= (H90 content of design volume) + (Increase in water)
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= 14.63% H20 (from Appendix B) + 0.009 (Z 100"''^ ) (10°)
= 13.72% + 0.009z percent of design volume
= (13.72% + 0.009z percent of design volume) * (Total molar volume per
mole of design volume)
= (13.72% + 0.009z) water contact * (0.566 + 0.429z%) moles/mole
of design volume - Equation 2
Increase or decrease in amount of C0? due to increase in combustion
air is 0 since no change in carbon content of the input refuse.
Therefore, the COp content of the flue gas after an increase in combustion
air
I
= C0 content of design volume * volume flow rate at z% excess air
= C02 content (from Appendix B) * (0.566 + 0.429z%) moles/mole of
design volume
= 7.95% C02 * 0.566 = 0.429z% C02 content of flue gas - Equation 3
Particulate concentration of flue gas, gr/scf
= (Design particulate at inlet flue gas, X. Ib/min + Additional
particulate in flue gas due to increase in excess air, X~
Ib/min) x 7,000 gr/lb * (flue gas molar volume/design mofar
volume x design volume flow rate, acfm)
Design particulate at inlet flue gas
= 48.66 tons/day (from the application)
| = 67.6 Ib/min
Flue gas molar volume = (0.566 + 0.429 x z%) moles/mole design from Equation 1
Design volume flow rate = 285,595 scfm at 70°F
Particulate concentration of flue gas, gr/scf
= (67.6 + X2) Ib/min x 7,000 gr/lb * (0.566 + 0.429 x z%) (285,595) scfm
| 7,000 (67.5 + X2)
285,595 (0.566 + 0.429 z%) 9r/scf
I = (67.6 + X2) * 40.8 (0.566 + 0.429z«), gr/scf - Equation 4
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= [(67.6 + X2) * 40.8 (0.566 + 0.429z%)] gr/scf + (1-water content
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_ Participate concentration of flue gas, gr/dscf
of flue gas)
Water content of flue gas
= (13.72% + 0.009z) * (0.566 + 0.429z%) from Equation 2
Particulate concentration of flue gas, gr/dscf
I = (67.6 + X2) * 40.8 (0.566 + 0.429z%) * [1 - (13.72% + 0.009z) <
(0.566 + 0.429z%)] - Equation 5
Particulate concentration, gr/dscf at 12% COp
I = (Particulate concentration, gr/dscf) x (12% C02) * [CO,, content of
flue gas * (1 - water content of flue gas)]
COp content of flue gas
= 7.95% C02 * (0.566 + 0.429z%) from Equation 3.
Particulate concentration, gr/dscf at 12% CO
/ 67.6 + X2 \ / l
| 140.8(0.566 + 0.429z%) ) I ~ 13.72% + ort
\ \ 0.566 + 0.42
Iv 1?* rn /7.95% CO, * 0.566 + 0.429z%
A \.LTo LU/J T I 1 o TOW . n nno-»
009T
429z%
2 I i 13.72% + 0.
1 "
0.566 + 0.429z%
2 \ / 12% CO,
II 67.6 + X
= / £ I / \.
\^40.8 (0.566 + 0.429z«)j (7.95it
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67'5 + X= 2.5 + ^2_ gr/dscf at 12% C02
27 27
- Equation 6
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Example calculation for combustion air at 130 percent
z = 130
Total molar volume fl
= 0.566 + 0.429
ow rate at z = 130
(130%) moles/mole of design flow, from Equation 1
= 1.1237 moles/mole
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Water content of flue
gas
= 13.72 + 0.009 x 130 4 (0.56 + 0.429 x 130%) from Equation 2
= 13.25%
C02 content of flue gas
= 7.95% 4 [0.566
= 7.07%
+ 0.429 (130%)]
Particulate concentration in flue gas, with no increase in amount
of particulate from design value
= (67.5 + X2) 4
(40.8 x 1.1237) from Equation 4
where X? = 0 (because of no change in amount of particulate from
design)
= 1.47 gr/scf
= 1.47 4 (1 - 13
.25%) = 1.69 gr/dscf from Equation 5
Particulate concentration corrected to 12% C09 in flue gas, with no
increase in amount of
1.69 gr/dscf x
=2.5 gr/dscf at
particulate from design value
12% CO, 1
7.07% C02 4 (1 - 0.1325)
12%/C02 from Equation 6
Particulate concentration in flue gas, with 10 percent increase in
amount of particulate
67.6 x 1.1
27
= 2.75 gr/dscf
where X = 67.5 x
in flue gas
from Equation 6
0.1 Ib/min
C-5
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RESOURCE RECOVERY UNITS
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APPENDIX D
A BRIEF DESCRIPTION OF THE OPERATING
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City of Nashville, Tennessee
The facility consists of two water-wall incinerator units with a
total capacity to burn 720 tons of refuse per day. Each unit is equipped
with an American Air Filter Corporation's (AAF) electrostatic precipitator
(ESP) unit. The two ESPs are cross-connected at the inlet by a damper
system and were intended to handle the flue gas generated in the incinerators
at 84 percent excess air. Each ESP is designed to handle 144,000 acfm
at 480°F and to achieve an outlet particulate loading of 0.015 gr/dscf.
It has four fields with 25 plates of 8 ft wide by 28 ft high in each
field and a total plate area of about 45,000 ft2. It is designed to
maintain a gas velocity between 2.5 and 3.5 ft/sec. Originally only
three of the four fields were intended to be active at a time (one field
being redundant). Currently all fields in each ESP are activated all
the time. When only three of the four fields were used the ESPs experienced
opacity problems. Currently, the facility is in compliance with the
applicable air regulations.
Both corrosion and solid waste have been and still are a problem
for the facility. The facility is located on the river bank. Therefore
an exceptionally high moisture content air is entering the ESP units
through the leaks that developed over a period and clogging up the ESP
hoppers. Heating of the hoppers has been some help. Efforts are being
made to find the air leaks and patch them. (e.g. rubber seals are used
in the doors). Though corrosion has been a continuous problem with
incinerators, its effect on ESP internals to date has been minimal.
The personnel associated with the facility felt that chlorine
content of the refuse in combination with gas stratification in various
parts of the equipment is the main source of corrosion. Proper fuel-to-air
mixture and introduction of under fired and over fired air are very
important.
City of Saugus, Massachusetts
The facility was designed for a maximum capacity of 1,500 tons per
day and is currently processing 1,150 tons per day of municipal solid
waste. It has two waterwall combustion units each of which is equipped
with a two-field ESP unit made by Wheelebrator-Frye, Incorporated. The
main boilers were provided with auxiliary oil burners that have never
been used.
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The incinerators operate at 75 percent excess air. The ESP system
was designed to handle a maximum volume of flue gas generated at 130 percent
excess air.
There were problems with boiler tube corrosion and erosion, grate
wear and particulate emissions. The corrosion was reduced greatly by a
change in metallurgy of the boiler tube and firing technique. Corrosion
was further reduced by the use of mechanical rapping mechanism, rather
than the usual soot blowers. Also in response to corrosion problem,
Resco changed the quantities and methods of adding air to obtain improved
combustion and mixing gases. It adopted better operating procedures
that minimized slagging and resultant increased gas velocities.
Problems with the ESP system were caused by refuse characteristics.
The incinerators were over loaded with rubber material. Particulate
generated from this material caused short circuiting in the ESPs. In
order to solve the problem the rubber material in the refuse is segregated
and input more slowly over a long time period. (About two or three
tires are fed at a time). Resco had to fine tune the incinerator system
in order to eliminate 'black flakes' which were noticed in the ESP
system. The fine tuning process involved changing the configuration of
the furnace and removing oil burners (to increase furnace volune).
Particulate emission stack test conducted by Resco in 1979 and 1980
showed the facility to be in compliance with the state regulation of
0.05 gr/dscf at 12 percent C02.
City of Harrisburg, Pennsylvania
This plant consists of two 360 ton per day waterwall incinerators,
each equipped with an electrostatic precipitator (ESP). The ESP system
was designed by a German manufacturer. Each precipitator is designed to
handle approximately 104,200 acfm at 600°F and to remove 92.4 percent of
inlet particulate loading. Each precipitator comprises 32 gas passages
and two electrical fields in series. Each ESP contains 22,000 ft2 of
plate area 13.2 ft effective height and 26.4 ft effective length.
Design precipitator velocity is 2.79 ft/sec and treatment time is 4.71 sec.
>,,
Only one transformed/rectifier (T-R) set energizes both fields in each
ESP. (The reason for only one T-R set for two fields is that no definite
efficiency requirement was imposed on the ESPs when the unit was installed
in 1972.)
D-3
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Of the all resource recovery units discussed in this report this
facility suffered and still faces with severe problems. Many problems
were experienced because of burning various types refuse including
commercial refuse in the facility which was designed solely for residential
refuse. A serious explosion about 3 years ago required many internal
parts of the incinerators to be changed. Problems exist with boiler
economizer tubes because of excess air and also with ESP tubes and the
conveyor belt. (The facility is currently using 100 percent excess air
where as the recommended excess air is 85 percent). Air infiltration
from screw conveyors is causing solid removal problems in ESP hoppers.
Rappers and heaters for ash disposal are not working properly, therefore
causing condensation and bridging.
The personnel at the facility believe that a strict regulation of
input refuse and a better maintenance program could have prevented many
of the problems that faced in the facility in the past. A preventive
maintenance program directed toward accurate record keeping of the ESP
operating parameters and regular and periodic maintenance schedules is
critical to the optimum performance of ESP. For a unit such as Harrisburg
incinerator which is plagued with frequent maintenance problems, an
excess ESP capacity in the form of spare would be very advantageous.
City of Braintree, Massachusetts
The facility consists of two incinerators each of which is originally
designed for 240 ton/day capacity but modified later to a 384 ton/day
capacity. Current refuse feed rate to each unit amounts to 250 tons/day.
Each incinerator unit is equipped with an ESP device manufacturer^ by
Wheelebrator-Frye, Inc. Each ESP consists of a single field and is
rated at 32,000 acfm at 600°F with a specified particulate collection
efficiency of 93 percent.
In the early years after the installation in 1970, the facility
experienced corrosion problems due to the practice of intermittent
refuse burning. It was operated only during week days. When cooled
down after shutdown during weekends the ESP temperature decreased to
below the acid dew-point. The ESP interior gradually corroded and was
completely replaced in 1976. Currently, the facility is operated around
the clock for 24 hours a day and 7 days a week. The incinerator units
and ESPs are kept hot by burning natural gas in the absence of refuse.
D-4
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APPENDIX E
| PERSONS FAMILIAR WITH THE OPERATING RESOURCE
RECOVERY FACILITIES
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E-2
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I APPENDIX N
_ PSD Permit Status/Checklist
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PSD PERMIT STATUS/CHECKLIST
Source Narce ABEX Corporation
Project Officer Bob Blaszczak
Model er
State/County/City Pennsylvania / Somerset
New Source* X
Modification*
/ Quemahoning Township
Ty&e/Capacity/SIC Foundry (Castinq) / / -3^
Il07 Designation
Attain. /Unclass./Nonattain. / / PM
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
Dmpl . Detr.
PM
6,181.6
44.06
2/22/79 /
S02
NOx
49.1
CO
163.5
HC
34.5
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
NO
X
X
X
X
Prelim'nary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
6/6/79
6/12/79
6/12/79
7/20/79-
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Issues/Cofrrnents -
1. Operating capacity is limited to a maximum steel production rate 39 ton/hr and
260,000 tons per calendar year.
2. Except for CO, projected emissions for all pollutants are less than 50 TPY..
CO is estimated greater than 163 TPY.
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
iraximun uncontrolled and actual are the maximum allowable under the PSD permit.
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PSD PERMIT STATUS/CHECKLIST
Source Name Airco Speer
1
1
1
1
1
1
1
1
1
1
1
1
Pro.iect Officer E. Glenn/J. Sydnor
Modeler A1 Cimorelli
State/County/City Pennsylvania / Elk
New Source*
Modification* X
/ St. Mary's
Type/Capacity /SIC Graphitizing Plant / /
s ' . _,. (Electrode Manufacturing)
5107 Designation 3
Attain. /Uncl ass. /Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
5,512.9
58
3/2/78 /
S02
177.58
58.6
NOX
CO
1,945
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X
X
X
NO
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
3/2/79
3/6/79
3/6/79
5/8/79 '
Issues/Comments -*This does not include potential or actual emissions from the
"special" stack. Information in the files is insufficient to adequately describe this stac
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
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1
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PSD PERMIT STATUS/CHECKLIST
Source Name Allegheny Ludlum Steel Corporation
Project Officer J. Sydnor
Model er
State/County/City Pennsylvania / Allegheny
New Source*
Modification* X
/ Brackenridqe
Type/Capacity/SIC Scrap Remelting Fac. / 245 tons/hr /
Il07 Designation
Attain. /Uncl ass. /Nonattain. / / PM
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
42.05
42.05
11/7/78 /
S02
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
NO
X
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Compl etion
Estimate
Actual
3/13/79
3/16/79
3/16/79
5/10/79
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Issues/Comments - Claimed reduction not addressed in EPA permit.
Modification over significant value for TSP.
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
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1
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1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Allen Products
Project Officer B. Mykijewycz
Model er
State/County/City ppnn<;
vlvam'a / LeHiah
New Source* X
Modification*
/ Allentown
Type/Capacity/SIC Dry Pet Food Plant /Unloadina 4,700 ft3/hr/
Il07 Designation Grinding & blending; 35,000 Ib/hr
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
4,629.7
4.6
4/16/79 / 5/16/79
S02
NOX
CO
HC
Increment Consumed/Remaining %/ 5;
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual .
7/19/79
7/23/79
7/23/79
9/4/79 '
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Issues/Comments -
Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
Iiiwu vuc »uuiie ai uei meu in me o// / uu luiei. Ddi>H-aii-y potential emissions
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
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PSD PERMIT STATUS/CHECKLIST
Source Narce
1
1
1
1
1
1
1
1
1
1
1
1
Project Officer B. Mvki.iewycz
Model er
Sts^e/County/City Pennsylvania / Delaware
New Source*
Modification* X
/ Philadelphia
Tvse/Cspacity/SIC Petroleum Products / 900,000 BBLS / 4612 & 4613
S,^., r, - ^.. Transportation
5107 Designation
Attain. /Unclass./Nonattain. / / 3
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ornpl . Detr.
PM
8/28/79 / 10/16/79
S02
NOx
CO
HC
233.39
67.49
Increr.er.t Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Mr Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Prelininary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
11/7/79
11/15/79
11/15/79
1/18/80
Iss'jes/Conrnents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
.OT uncontrolled and actual are the maximum allowable under the PSD permit.
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PSD PERMIT STATUS/CHECKLIST
Source Name Berks Products
Project Officer J. Sydnor New Source*
Modeler Modification* X
State/County/City Pennsylvania / / Reading
Type/Capacity/SIC Rotary Drum Mix / 250 tons/hr /
s,^-, r, - ... Bituminous Concrete
5107 Designation Plant
Attain. /Unclass./Nonattain. TSP / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ornpl. Detr. 7/13/79 /
PM S02 NOX CO HC
32,721.5
35.99
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
NO
X
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual .
7724/79
7/31/79
7/31/79
9/12/79
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Narr.e Bethlehem Steel Corporation
Project Officer Bob Blaszczak
Kodeler M- Garrison
State/County/City Pennsylvania / Cambria
New Source*
Modification* X
/ Franklin Borough
Type/Capacity/SIC Electric Furnace Melt / 185 tons /
§107 Designation Shop
Attain. /Uncl ass. /Nonattain. CO / / TSP
Date Application Rec ' d/Compl . Detr.
Emissions (T/Y)* PM
Potential 48,400
Actual 48.4
Net Increase
3/29/79 /
S02
46
46
NOx
CO
HC
Increment Consumed/Remaining %/ X
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES s
X
X
X
NO
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
5/25/79
5/26/79
5/26/79
7/3/79 -
I
I
I
I
Issues/Conments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
iraximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name E. J. Breneman
Project Officer Bob Blaszczak
Modeler
State/County/City Pennsylvania /
New Source*
Modification* X
/ Sinking Spring
Type/Capacity/SIC Drum Mix Asphalt Plant/ 300 tons/hr /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr. _
PM
11,210
11.38
3/?/7Q f
S02
NOx
CO
HC
Increment Consumed/Remaining . %/ . %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
NO
X
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Issues/Comments -
Completion
Estimate
Actual
5/9/79
5/18/79
5/18/79
7/16/79
I
I
I
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Burrell Construction and Supply Company
Project Officer B. Mykijewycz
Model er
State/County/City Pennsylvania / Alleqhenv
New Source*
Modification* X
/ New Kens i nqton
Type/Capacity/SIC Construction & Supply / 192,000 Ib/hr /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
Drnpl . Detr.
PM
8,584
11.33
9/11/78 /
S02
28.47
28.47
NOx
CO
HC
Increment Consumed/Remaining %/ #
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
NO
X
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual .
10/18/78
10/23/78
10/23/78
1/11/79'
I
I
I
I
Issues/Comments - Potential and actual file calculations based on 1,500 hrs/hr.
This operating schedule is not mentioned in permit. Calculations on this checklist
are based on 8.760 hrs/yr.
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
fraximun uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
I
I
I
I
I
I
PSD PERMIT STATUS/CHECKLIST
Source Name Enplay Cement Manufacturing
1
1
1
1
1
1
1
1
1
1
1
1
Project Officer E. Vollberq
Modeler Alan Cimorelli
State/County/City Pennsylvania / Northampton
New Source*
Modification* X
/ Nazareth
Type/Capacity /SIC Portland Cement Manuf. / 2,190,000 TPY /
s ' based on rol ler mi 1 1
5107 Designation rated capacity
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
2,190,000
438
1/25/77 /
S02
12,189
2,437.9
I_ NOx
CO
HC
Increment Consumed/Remaining %/ 2
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X
NO
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
2/21/78
2/24/78
2/24/78
8/4/78 '
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically .potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name GAF Corporation - Chemical Group
Pro.iect Officer D. L. Arnold
Model er
State/County/City Pennsylvania / Adams
Type/Capacity/SIC Stone
New Source*
Modification* x
/ Charmian
Processing / 120 TPH / 3281
§107 Designation
Attain. /Unclass./Nonattain. PM / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
19,977
38
38
6/19/79 / 11/7/79
S02
NOX
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
11/27/79
12/10/79
12/21/79
12/21/79
2/29/80
I
I
I
I
Issues/Corrments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
niuT) uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name GAP Corporation
Project Officer Vernon Butler
Modeler
State/County/City Pennsylvania / Adams
New Source*
Modification* X
/ Charmian
Type/Capacity /SICTruck Loading Station / 40 tons/hr /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ornpl . Detr.
PM
1,536
?.3
sent on 7/31/78 /
S02
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
8/23/78
8/29/78
8/29/78
1/2/79
I Issues/Comments -
I
I
I
I
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
PSD PERMIT STATUS/CHECKLIST
Source Name General Battery Company
Project Officer Ben Mykijewycz
Modeler
State/County/City Pennsylvania
/ Berks
New Source*
Modification* X
/ Laurel dale Borough
Type/Capacity/SIC 2nd lead reverberatory / 70 tons/day ijmi- ted to/
s'n . .. turnace7200 hrs/yr operation
5107 Designation J v
Attain./Unclass./Nonattain. S09 / / TSP
Date Application Rec'd/Compl. Detr.
Emissions (T/Y)*
Potential
Actual
Net Increase
PM
3,931
5
S02
2,139
333
NOx
CO
HC
Increment Consumed/Remaining
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
,1/31/79
2/5/79
2/5/79
.5/25/79 '
Issues/Conrnents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
rraximiro uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Highway Materials, Inc.
Pro.iect Officer Eileen Glen New Source*
Modeler
Modification* X
State/County/City Pennsylvania / Chester / Malvern
Type/Capacity/SIC Asphalt plant / 125 TRY /
§107 Designation
Attain. /Uncl ass. /Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
4.9
10/27/78 /
S02
1.5
NOX
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
[ NO
X
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
1/19/79
1/23/79
1/23/79
3/16/79'
I
I
I
I
I
Issues/Comments -
* Since these sources v/ere reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
rraximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
PSD PERMIT STATUS/CHECKLIST
Source Name Herbert R. Imbt, Inc.
Project Officer Edward Vollberg
Modeler
State/County/City Pennsylvania
/
/ 300 TPH
Type/Capacity/SIC Asphalt Plant
§107 Designation
Attain./Unclass./Nonattain.
Date Application Rec'd/Compl. Detr. 4/17/78
New Source* X
Modification*
/ Stroudsburq
/
limited to 1800 hr/yr
J
/
Emissions (T/Y)*
Potential
Actual
Net Increase
PM
26,100
10.7
S02
20.7
NOX
CO
HC
Increment Consumed/Remaining
%/
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
9/1/78
9/8/78
9/8/78
10/1/78-
Issues/Consents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Source Name Inmetco
PSD PERMIT STATUS/CHECKLIST
Proiect Officer V. Butler
Model er
State/County/City Pennsylvania / Lawrence
New Source* X
Modification*
/ Ell wood City
Tvoe/Capacity/SIC waste metal reclaimatio/i 41,000 TRY /
§107 Designation
Attain. /Unclass./Nonattain. / / PM HC
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
4,225
38.3
8/9/78 /
S02
NOX
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
7/6/79
8/3/79
8/3/79
10/2/79'
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Narce Tntprnatinnal Minprals and Chemical Corporation
Project Officer Bob Blaszczak
Model er
State/County/City Pennsylvania / Lehigh
New Source*
Modification* X
/South Whitehall Township
Ty&e/Cspacity/SIC Formaldehyde plant / 135 MM Ib/yr /
Il07 Designation
Attain, /u'ncl ass. /Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
.Net Increase
ompl . Detr.
PM
3/21/79 /
S02
NOx
CO
256
17.5
HC
946
46.1
Increment Consumed/Remaining %/ «£
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual .
7/19/79
8/2/79
8/2/79
9/12/79-
I
I
I
I
Issues/Coiitsents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
irc'jm uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Millcreek Townshio Asphalt Plant
Project Officer Bob Blaszczak
Modeler
State/County/City Pennsylvania / Erie
New Source* X
Modification*
/ Millcreek Township
Type/Capacity /SIC Drum mix asphalt plant/ 40 Ib/hr /
§107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
Drop! . Detr.
PM
9.75
0.2
2/29/79 /
S02
NOx
CO
HC
Increment Consumed/Remaining %/ 2
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Pvegister Notice
Completion
Estimate
Actual
3/13/79
3/19/79
3/19/79
5/14/79'
I
I
I
I
Issues/Comments -
* Since these sources v/ere reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Narce Mnlyrnrp Tnr (Union Oil)
Project Officer D. L. Arnold
Modeler
State/County/City Pennsylvania / Washington
New Source*
Modification* X
/ Washington
Type/Capacity/SIC Molybdenum Roaster / 13,000 TPY / 3313
Il07 Designation
AttEiin./unclass./Nonattain. PM. SO,, / /
Date Application Rec'd/Compl. Detr.
Emissions (T/Y)* PM
Potential 7,825
Actual 36.9
Net Increase
8/15/79 / 11/19/79
S02
24,730
366
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual .
12/17/79
1/21/80
1/24/80
1/24/80
3/21/80
I
I
I
I
Issues/Corrrnents - These figures are based on 24 hrs/day; 7 days/wk; 52 wks/yr.
Molycorp has different operating schedules. Schedule limitations are not specified
in the permit.
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
raximun? uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Philadelphia Gas Work
Project Officer Vernon Butler
Modeler
State/County/City Pennsylvania / Philadelphia
New Source*
Modification* X
/ Philadelphia
Type/Capacity/SIC Synthetic natural gas/ /
Il07 Designation
Attain. /Unclass./Nonattain. S09 / TSP N09 / Ow & CO
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
12.6
5/16/78 /
S02
135.0
NOx
133.0
CO
31.5
HC
674.49
91.3
Increment Consumed/Remaining %/ 5;
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
3/6/79
3/9/79
3/9/79
5/15/79 '
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
PSD PERMIT STATUS/CHECKLIST
Source Name Smith Kline Company
Project Officer G. Fekete
Modeler
State/County/City Pennsylvania
/ Montgomery
New Source*
Modification* X
/ Upper Marion
Type/Cspacity/SIC Pharmaceutical plant
Il07 Designation
Att=in./unclass./Nonattain.
Date Application Rec'd/Compl. Detr. 6/17/79
/ 600 MT/yr
/ 2833
Emissions (T/Y)*
Potential
Actual
Net Increase
PM | S02
1,536
50
236.8
50
NOX
41.35
27.3
CO
9.4
6.2
HC
1.88
1.24
Incrar^rst Consumed/Remaining
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
12/18/79
12/21/79
12/21/79
1/25/80
Issues/Conr.ents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
raxiiTOT uncontrolled and actual ere the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Source Name Stackpole
PSD PERMIT STATUS/CHECKLIST .
Carbon Company
Project Officer Ben Mykijewycz
Model er
State/County/City Pennsylvania / McKena
Type/Capacity/SIC Rotary
New Source*
Modification* X
/ Kane
Calcining Tubes/ /
5107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
473.04
4.73
/ 3/16/79
SO 2
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soil s/Vegetation/Visibil ity
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
5/23/79
5/31/79
5/31/79
7/20/79'
I
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
PSD PERMIT STATUS/CHECKLIST
Source Name Sun Petroleum Products
Project Officer
Modeler
V. Butler
State/County/City
Type/Capacity/SIC
§107 Designation
Pennsylvania
New Source*
Modification* x
/ Marcus Hooks
Wax tree solvent
63.4 x 10 Btu/hr
recovery unit (heater)
8760 hrs/yr
Attain./line!ass./Nonattain. /_
Date Application Rec'd/Compl. Detr. 12/18/78
Emissions (T/Y)*
Potential
Actual
Net Increase
PM
21
3.5
S02
246
59
NOX
117
45
CO 1
9.7
9.7
HC
1.9
1.9
Incrernent Consumed/Remaining
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soil s/Vegetation/Vi sibil ity
Class I Area Impact
YES
X
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual .
1/19/79
1/25/79
1/25/79
3/20/79 '
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Tonolli Corporation
Proiect Officer Ben Mykijewycz
Model er
State/County/City Pennsylvania / Carbon
Type/Ca pa city/SIC Solder
New Source*
Modification* X
/ Nesquenoning
production / 1.7 ton/hr /
§107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
/ 12/26/78
S02
NOx
CO
HC
Increment Consumed/Remaining %/ X
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soil s/Vegetation/Visibil ity
Class I Area Impact
YES
X
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual .
1/17/79
1/24/79
1/24/79
3/26/79'
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximuni uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Source Narr.e Transco
PSD PERMIT STATUS/CHECKLIST
Proiect Officer J. Sydnor
Model er
New Source* x
Modification*
State/County/City Pennsylvania / Delaware /Chester Township
Ty^/Capacity/SIC Naphtha qasification / Convert 56,000 barrels/ 0
s of Naphtha to N.G. Z4b MM ft1*
5107 Designation
Attain. /unclass./Nonattain. Class II TSP/SO,/ /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
124
124
5/21/76 applic. dated / 6/29/76 submitted informati
S02
710
710
NOx
CO
HC
Increr.snt Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
1/18/78
1/15/78
1/15/78
4/13/78-
I
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
net the "source" as defined in the 8/7/80 rules. Basically potential emissions are
rexinusn uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name llnitpri Rpfining rnmpany
Project Officer V. Butler
Model er
State/County/City Pennsylvania / Warren
New Source*
Modification* X
/ Warren
Type/Capacity/SIC Petroleum refinery / 25,000 bbl/day /
$,«-, rx j.- fluid catalytic cracking unit
§107 Designation J 3
Attain. /Uncl ass. /Nonattain. / /
Uate Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
Drop! . Detr.
PM
7/14/78 /
S02
4,010
none
NOx
CO
HC
Increment Consumed/Remaininq %/ %
Project Milestones
BAC7
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soil s/Vegetation/Visibil i ty
Class I Area Impact
YES
X
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
10/17/79
10/23/79
10/23/79
1/25/80
I
I
I
I
Issues/Comments - Reductions from other units at Refinery result in a net decrease
in emissions. These were assumed creditable for baseline not being triggered
this source.
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
Ti uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Niir.e U.S. Dent, of Interior/Bureau of Mines Research Center
Project Officer Bob Blaszczak
Model er
State/County/City pPnp«;
Type/Capacity/SIC Keeler
vlwania /
New Source*
Modification* X
/ South Park
Boiler No. 1 / 65.5 x 106 Btu/hr /
§107 Designation
Attain./Unclass./Nonattain. / / PM, CO, HC, SO,
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ornpl . Detr. <
PM
1,160
11.6
after 5/18/79 memo requesting PSD application
S02
469
469
NOX
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
for PM
for S00
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
*
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
3/7/79
3/12/79
3/12/79
5/14/79-
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name U.S. Steel
Battery 1
Project Officer B. Mykijewycz
Model er
State/County/City Pennsylvania
Type/Capaclty/SIC 13, 14,
3, 14, 15r ?0
/ Alleahenv
New Source*
Modification* X
/ Clairton
15, 20 : Coke / / 3-03-003-06
§107 Designation batteries
Attain. /Unclass./Nonattain. TSP, NO.,, CO / / S0«
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
827.9
Increment Consumed/Remaining
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soil s/Vegetation/Visibil ity
Class I Area Impact
7/10/78 /
S02 NOX
209
CO
HC
*/ *
YES NO
Preliminary Determination 8/17/73 for No. 20
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
9/20/78
9/26/78
9/26/78
8/1/79
Issues/Conraents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name U. S. Steel Company
Proiect Officer V. Butler
Model er
State/County/City Pennsylvania /
New Source*
Modification* X
/ Duquesne
Typ3/O pa city /SIC Iron desulfurization / 250 tons/hr /
s .' n . ... 6,000 tons/day
si 07 Designation
Attain. /Uncl ass. /Nonattain. / / TSP
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl. Detr. / 9/29/78
PM S02 NOx
2,925
21
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
YES NO
X
X
X
X
Soils/Veqetation/Visibility x
Class I Area Impact
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
5/7/79
5/14/79
5/14/79
7/6/79 '
Issues/Consents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
raxinuzn uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Wilkes-Barre Steam Heat Authority
Proiect Officer D. L. Arnold
Model er
State/County/City Pennsylvania / Luzeme
New Source* X
Modification*
/Wilkes-Barre
Type/Capacity/SIC Culm Boiler / 100,000 Ib/hr steam /
S,"rt, - 4.. 137.4 MBtu/hr
5107 Designation
Attain. /Unclass./Nonattain. so~. CO. NOo / / PM, Ov
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
c.
ompl . Detr.
PM
79,574
43.8
9/10/79 / 10/10/79
S02
581
581
NOx
166
166
CO
24
24
HC
7
7
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X
X
NO
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Issues/Comments -
Completion
Estimate
Actual
4/28/80
5/6/80
5/6/80
7/1/80
I
I
I
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 3/7/80 rules. Basically potential emissions are
imiCT uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Windsor Service, Inc.
Proiect Officer Bob Blaszczak
Modeler
State/County/City Pennsylvania / Lebanon
Type/Capacity/SIC Asphal
New Source*
Modification* X
/ North Lebanon Township
t Batch / 185 tons/hr / 2951
Il07 Designation
Attain. /Unclass./Nonattain. TSP, S09, NOY, CO / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
52,560
34.6
/ ?/?3/7Q
S02
236
236
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
3/13/79
3/21/79
3/21/79
5/7/79 '
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
niaximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Zarlenao Bros.. Inc.
Project Officer D. L.
Model er
Arnold
State/County/City Pennsylvania / Lawrence
Type/Capacity/SIC Asphal
New Source*
Modification* X
/ Hillsville
t Plant / 110 TPH / 2951
Il07 Designation
Attain. /Unclass./Nonattain. S0? / / PM
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
4Q,qnn
19.7
/
S02
13.4
12.4
NOX
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
11/21/79
12/1/79
12/1/79
1/21/80.
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Delaware Reclamation Project
Project Officer J- Sydnor/B. Mykijewycz
Modeler M. Garrison
State/County/City Delaware / New Castle
New Source* x
Modification*
/ Wilmington
Typs/Cepacity/SIC Resource Recov. Plant / 260, 000 TPY-^KSg!^1 /
§107 Designation 91'250 TPY-Sewage Sludge
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
511,505
102.1
3/20/79 /
S02
387.2
37.70
NOx
225.4
30.78
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
1/10/80
1/18/80
1/18/80
3/14/80 >
I
I
I
I
I
Issues/Cofirr.ents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
naximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Delmarva Power & Light
Project Officer G. Rapier New Source* x
Modeler
Modification*
State/County/City Delaware / Susser / Millsboro
Type/Capacity/SIC Coal Fired Steam / 400 Megawatt /
s . JL. Generating Power Plant
§107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
Dmpl . Detr.
PM
400
3/26/76 /
S02
10395
9500
NOX
6129
5600
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Compl etion
Estimate
Actual
8/9/76
8/9/76
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Narce Armco Steel Co.
Project Officer Edward
Modeler
A. Vollberg
State/County/City Maryland /
New Source*
Modification* x
/ Baltimore
Type/Capacity /SIC Electric Arc Furnace /50 ton / 3312
Il07 Designation
Attain. /Unclass./Nonattain. / / TSP
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
1223.6
28.09
/
S02
NOx
CO
HC
Increment Consumed/Remaining %/ 2
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
NO
X
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
7/20/79
7/30/79
7/30/79
12/12/79-
I
I
I
I
Issues/Comments - The new furnace will replace two existing furnaces (Nos. 3 and 5)
and will idle the existing furnace (No. 6) - standby.
* Since these sources v/ere reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
reximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Arundel Corp.
Project Officer E. VoTlberg New Source* X
Model er
Modification*
State/County/City Maryland / Harford / Baltimore
Type/Capacity/SIC Stone
Crushing / 1,000,000 TPY /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
amp! . Detr.
PM
1068.45
40.03
8/14/78 /
S02
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
NO
X
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
9/11/78
9/18/78
9/18/78
11/28/78'
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
JTiaximurn uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Nant-e Bethlehem Steel Sparrows Point
Project Officer Ed Vollmer
Modeler Al Cimorelli
State/County/City Maryland /
New Source*
Modification* x
/ Baltimore
Tyja/Capacity/SIC Coke Oven Battery / 951.700TPY /
Il07 Designation
Attain./'Unclass./.Nonattain. / /
Date Application Rec'd/Compl. Detr. 10/10/78 / 3/30/79
Emissions (T/Y)* PM S02 NOx
Potential 538.7 113.88
Actual 538.7** 113.88**
Net Increase
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones YES NO
BACT X
LAER/Offsets X
Air Quality Monitoring x
Air Quality Impact X
Soils/Vegetation/Visibility X
Class I Area Impact X
Prelinin'ry Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
6/11/79
6/13/79
6/13/79
8/6/79 -
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
rexir.LjTj uncontrolled and actual are the maximum allowable under the PSD permit.
'* From tables supplied by the source.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Campbell -Grove Division
Project Officer Ben Mykijewycz New Source*
Modeler Modification* x (relocatior
State/County/City Maryland / Carroll / Medford Quarry
Type/Capacity/SIC Stone Crushing Plant / 400,000 TPY /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/Compl. Detr.
Emissions (T/Y)* PM
Potential 225.2
Actual 4
Net Increase
/ 7/4/79
S02
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soil s/Vegetation/Vi sibil ity
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
. Actual
6/19/79
6/25/79
6/25/79
8/10/79 -
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
I
I
PSD PERMIT STATUS/CHECKLIST
Source Narne
1
1
1
1
1
1
1
1
1
1
1
1
Proiect Officer E. Vollberq
Modeler M. Garrison
State/County/City Maryland /
New Source*
Modification^
/ Cumberland
Type/Capacity /SIC Acetate Fibers(boiler) / 481,800 TRY /
5107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential **
Actual **
I\=t Increase
ompl . Detr.
PM
8094.2
40.5
7/27/73 / 9/5/78
S02
1025.4
307.6
NOX
404
CO
54
HC
27
Increment Consumed/Remaining %/ %
Project Milestones
BAC7
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X
X
X
NO
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
10/12/78
1/17/79
1/23/79
1/23/79
4/3/79 -
Issues/Comments -
I
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
rcximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Craig Blacktop & Pavinq
Project Officer E. Vollberg
Model er
State/County/City Maryland / Washington
New Source* X
Modification*
/ Hagerstown
Tvoe/Capacity/SIC Asphalt Batch Plant / 75, 000 TPY / 2951
§107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/Compl. Uetr.
Emissions (T/Y)* PM
Potential 3.29
Actual
Net Increase
3/27/78 /
S02
4.94
NOx
2.76
CO
0.57
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
NO
X
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
8/29/78
9/6/78
9/6/78
11/8/78 -
I
I
Issues/Comments - Installation will have a baghouse
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Narr.e Eastalco Aluminum Co,
Project Officer James
Model er
Sydnor
New Source*
Modification* X
State/County/City Maryland / Frederick /
Type/Capacity/SIC Aluminum / /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
744.6
11/10/77 /
S02
4278.3**
NOx
CO
HC
Increment Consumed/Remaining %/ X
Project Milestones
BAC7
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X
NO
PM.SO.
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Issues/Comments -
Completion
Estimate
Actual
12/14/77
12/17/77
12/17/77
2/15/78
I
I
I
I
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
raximum uncontrolled and actual are the maximum allowable under the PSD permit.
** No. 3 only
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
PSD PERMIT STATUS/CHECKLIST
Source Name Firestone Plastic Co.
Project Officer
Modeler
Edward Vollberg
Maryland
Boiler
/ 81.9 MBtu/hr
State/County/City
Type/Capacity/SIC
Il07 Designation
Attain./Unclass./Nonattain. /_
Date Application Rec'd/Compl. Uetr. 9/1/78
New Source*
Modification* X
/ Perryville
Emissions (T/Y)*
Potential
Actual
Net Increase
PM
117.32
117.32
S02
746
746
NOx
CO
HC
Increment Consumed/Remaining
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
. Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
1/17/79
1/24/79
1/24/79
7/3/79 -
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
rraximurn uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Flintkote Co. (Campbell Grove)
Project Officer E. Vollberg
Kodel er
State/County/City Maryland / Carroll
Type/Capacity/SIC stone
New Source* X
Modification*
/ Medford
Crusher / 1,150,000 Ib/hr /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
244
2.23
1/9/78 /
S02
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
NO
X
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
9/1/78
9/6/78
9/6/78
10/31/78'
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
iraximurn uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Francis O'Dav Co. Inc.
Project Officer E. Vollberq
Modeler
State/County/City Maryland /
New Source* X
Modification*
/ Rockville
Type/Capacity/SIC Asphalt Batch /100,OOOTPY / 2951
5107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec ' d/Compl . Detr.
Emissions (T/Y)* PM
Potential 3942°
Actual 17-59**
Net Increase
/ 11/7/78
S02
NOx
CO
HC
Increment Consumed/Remaining %/ 2
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
2/2/79
2/24/79
2/24/79
5/14/79
I
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
** Based on 99.8% baghouse efficiency.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Marvland Material Tnr.
Proiect Officer Edward
Modeler
Vollbera
New Source*
Modification* X
State/Countv/City Maryland / Cecil /
Type/Cspacity/SIC Stone
crushing / 900,000 TPY /
§107 Designation
Attain./Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
4197
95.6
2/12/79 /
S02
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
8/3/79
8/8/79
8/8/79 '
10/4/79 -
I
I
I
I
Issues/Coiiraents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
rraximurn uncontrolled and actual are the maximum allowable under the PSD permit.
I
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I
I
PSD PERMIT STATUS/CHECKLIST
Source Name Hettiki Coal Co.
1
1
1
1
1
1
1
1
1
1
1
1
Project Officer Edward Vollberg
Model er
New Source* X
Modification*
State/County/City Maryland / Garrptt / rwr Pflrk
Type/Capacity/SIC Coal Prep. Facilitv / 600 TPY max. /
Il07 Designation
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Narce Miller Asphalt Product
Proiect Officer Ben Mykijewycz
Modeler
State/County/City Maryland / Carroll
Type/Capacity/SIC Asphal
New Source*
Modification* X (relocatio
/
t Plant / 180 ton/day /
s . (shown on stack test report;
§107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl. Detr. 1/15/79 /
PM SO 2 NOx
4522
2.95
CO
HC
Incra.-ent Consumed/Remaining %/ X
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
YES NO
X
X
X
X
Soils/Vegetation/Visibility X
Class I Area Impact
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
Issues/Conrnents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
rraxim.um uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name PPG Industries
Project Officer G. Fekete
Modeler
State/County/City Maryland /
New Source*
Modification* X
/ Cumberland
Type/Capacity/SIC Glass Melting Furnace / 72,927 TRY /
5107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
48.2
7/6/79 /
SO 2
32.9
NOx
416-876
CO
14.5
HC
3.1
Increment Consumed/Remaining %/ 2
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X
NO
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Pxegister Notice
Completion
Estimate
Actual
9/7/79
9/17/79
9/17/79
11/7/79 '
I
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
PSD PERMIT STATUS/CHECKLIST
Source Narr.e Pulaski Highway Solid Waste Reduction Center, City of Baltimore
Project Officer Edward Vollberg New Source*
Modeler Modification* X
State/County/City Maryland / / Baltimore
Type/Capacity/SIC Solid Waste Incinerator/ 300 ton/day MSW /
Il07 Designation
Attain./Unclass./Nonattain. / /
Dste Application Rec'd/Compl. Detr. _____
/ 9/5/78
Emissions (T/Y)*
Potential
Actual
Net Increase
PM
3285
81.6
S02
274
154
NOX
328.5
11.4
CO
3832
127
HC
164
5.5
Incre.-ent Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
4/10/79
4/17/79
4/17/79
1/25/80 -
Issues/Comments -
* Since these sources v/ere reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
rraxiraurn uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Source Name Sykesville
PSD PERMIT STATUS/CHECKLIST .
Construction Co.
Project Officer Edward Vollberg New Source* X
Modeler
Modification*
State/County/City Maryland / Carroll / Woodbine
Type/Capacity/SIC Asphalt Plant / / 2951
5107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
720
21.6
5/9/78 /
S02
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
.
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
2/1/79
2/7/79
2/7/79
4/3/79 -
I
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Anheuser-Busch
Project Officer G. Fekete
Model er
New Source*
Modification* X
State/County/City Virginia / / wiTHamsburq
Type/Capacity /SIC Standby steam boiler / 98 MBtu/hr /
§107 Designation
Attain./Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
67.89
11/5/79 /
S02
459.9
NOX
709
CO
11.8
HC
59.1
Increment Consumed/Remaining %/ 2
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
3/13/80
3/19/80
3/19/80 '
6/16/80'
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
rraxirnun uncontrolled and actual are the maximum allowable under the PSD permit.
I
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1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Burlington Industries, Inc.
Proiect Officer E- Glenn
Model er
New Source*
Modification* x
State/County/City Virginia / Charlotte /
Type/Capacity/SIC Carpet
, yarn, & woven / fino TPY /
§107 Designation terry manufacturing 36.6 MBtu/hr spreader stoker boiler
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
* Potential
* Actual
Net Increase
ompl . Detr.
PM
485
43.2
10/27/78 / 2/22/79
SO?
202.6
NOx
80
80
CO
11
HC
5
Increment Consumed/Remaining %/ 2
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soil s/Vegetation/Visibil ity
Class I Area Impact
YES
X
NO
X
X
X
X
x
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Issues/Comments - These
operating schedule
Completion
Estimate
Actual
3/7/79
3/15/79
3/15/79
5/14/79'
figures based on 24 hrs/day, 6 days/wk, 50 wks/yr. This
is not mentioned in the permit.
I
I
I
* Since these sources v/ere reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Coal Industry Services r.nmpany, Tnr
Project Officer G. Fekete
Modeler
State/County/City Virginia / Tazewell
New Source* x
Modification*
/ Poundina Mill
Type/Capacity/SIC Rotary Aggregate Dryer/ 249,600 TPY /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
Dmpl . Detr.
PM
56,250
11.25
4/19/79 / 5/8/79
S02
45.99
NOX
14.02
CO
3.17
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
NO
X
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Compl etion
Estimate
Actual
10/22/79
10/27/79
10/27/79
12/6/79-
I
I
I
I
Issues/Comments -
* Since these sources were reviev/ed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
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1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Clinch-field Coal Company
Project Officer J. Sydnor
Modeler Mark Garrison
New Source* X
Modification*
State/County/City Virginia / / Dante
Type/Capacity/SIC Coal
Prep. Plant / *500 TPY /
§107 Designation
Attain. /unclass./N'onattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
420,480
67.27
8/7/78 /
SO 2
428
192.6
NOx
259.2
CO
14.4
HC
Increment Consumed/Remaining %/ 2
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soil s/Veqetation/Visibil Ity
Class I Area Impact
YES
X
NO
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
3/22/79
3/28/79
3/28/79
7/9/79 '
I
I
Issues/Comments - Operating schedule limits plant operations to 16 hrs/day.
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
raxi'mum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
I
I
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I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
PSD PERMIT STATUS/CHECKLIST
Source Name Continental Forest Industrips :
Project Officer E. Glenn
Modeler Alan CimoreTH
State/County/City Virginia
New Source*
Modification* x
/ Hooewel 1
Type/Capacity/SIC Kraft Pulp Mill
Il07 Designation
Attain./Unclass./Nonattain.
Date Application Rec'd/Compl. Detr.
/ 1.715MBtu/hr
/ 2631
8/30/78
Emissions (T/Y)*
Potential
Actual
Net Increase
PM
569.4
S02
6,859,1
NOx
1,795.8
1,795.8
CO
HC
Increment Consumed/Remaining
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X
X
X
NO
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
**Modification
Federal Register Notice
Completion
Estimate
Actual
5/30/78
9/29/78
10/4/78
10/4/78
12/6/78*
5/2/79
Issues/Comments - *By means of letter from CFI
**Modification to previously issued permit of 12/6/78
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
uncontrolled and actual are the maximum allowable under the PSD permit.
I
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1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Georgia Pacific Company
Pro.iect Officer E. Glenn
Model er
1 State/County/City Virginia / .
New Source*
Modification* X
/ Jarratt
TvDe/Caoacity/SIC Boiler / 101.7 MBtu/hr /
1
1
1
1
1
1
1
1
1
1
§107 Designation
Attain. /Unclass./Nonattain. Class II / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
1.532
108
9/28/78 /
S02
673
673
NOx
?fil.54
261.54
CO
.ess than 50
.ess than 50
HC
Less than 50
Less than 50
Increment Consumed/Remaining %/ 2
Project Milestones
BAC7
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X (S0?
NO
X
only, max. i
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Compl etion
Estimate
ipact 32 yg/
Actual
n 24/hr ave
11/27/78
12/4/78
12/4/78
2/6/79 -
I
I
I
I
I
-ag<
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
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I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
PSD PERMIT STATUS/CHECKLIST
Source Narr.e Greer Lime Company
Project Officer J
Model er
State/County/City
Type/Capacity/SIC
. Sydnor
Virginia
Lime plant
/
/ Kiln: 30 T/Hr
New Source* X
Modification*
/ Saltv-illp
/ 3274
5107 Designation
Attain./'Unclass./Nonattain.
Hydrator: 5 T/Hr
Crushing: 15 T/Hr
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
14.6
6/20/77 /
SO 2
409
40.3
NOX
CO
HC
Incrersnt Consumed/Remaining %/ %
Projsct Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soil s/Vegetation/Visibil ity
Class I Area Impact
YES
X
X
X
NO
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
2/10/78
2/12/78
2/12/78
6/28/78'
Issues/Consents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
ir/jni uncontrolled and actual are the maximum allowable under the PSD permit.
I
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1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Hampton Roads Energy Co.
Project Officer E. Glenn
Modeler
State/County/City Virginia /
New Source* X
Modification*
/ Portsmouth
Type/Capacity/SIC Refinery & marine term./ 186,000 bbl/day /
§107 Designation
Attain. /Unclass./Nonattain. / / HC
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
777
6/28/78 /
S02
4,754.4
NOx
2,553.6
CO
453.fi
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Sons/Vegetation/Visibility
Class I Area Impact
YES
X
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
10/16/79
10/20/79
10/20/79
1/25/80
2/11/80
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
jraxirnum uncontrolled and actual are the maximum allowable under the PSD permit.
I
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1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Narr.e Locher Brick Works, Inc.
Project Officer E. Glenn
Modeler
State/County/City Viroinia / Amherst
Type/Capacity/SIC bri'ck
New Source* X
Modification*
/ Amherst
plant / 70,000 TPY /
§107 Designation
Attain. /linclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
411
17.6
2/22/79 /
S02
42
22.7
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual .
3/7/79
3/12/79
3/12/79
5/10/79'
I
I
I
I
Issues/Conraents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
naximurn uncontrolled and actual are the maximum allowable under the PSD permit.
I
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1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Lone Star Industries
Proiect Officer Ben Myki jewycz New Source* X
Model er
Modification*
State/County/City Virginia /Chesterfield
/ Norford
Tvoe/Capacity/SIC stone crushing / 1,000,000 TPY / 1423
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
424
21.2
2/9/79 /
S02
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X
X
X
NO
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
5/11/79
5/18/79
5/18/79
7/3/79
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
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1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Natr.e Lonq Star Lafarqe, Inc. Chesapeake Cement plant
Project Officer J. Sydnor
Modeler
State/County/City Virginia /
New Source* X
Modification*
/ Norfolk
Tvce/Capacity/SIC Cement Plant / 33>000 TPY /
Il07 Designation
Attain. /'Uncl ass. /Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
10,700
10.7
9/16/76 /
S02
134.34
134.34
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
3/23/77
3/28/77
3/28/77
6/10/77-
I
I
I
I
Issues/CotTments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
rraxinizn uncontrolled and actual are the maximum allowable under the PSD permit.
I
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1
1
1
1
1
1
1
1
1
1
1
1
1
1
Source Name Lynchburg
PSD PERMIT STATUS/CHECKLIST
Foundry
Project Officer E. Glenn
Model er
State/Countv/Citv Virginia /
Type/Capacity/SIC boil
New Source*
Modification* X
/ Lynchburg
er / 111 - 3.5 TPH /
s .., . .. "" 112 - J.b IPH; 11J - 3.b IHH;
§107 Designation 114 _ 2.5 rpH; 115 - 13.0 TPH
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
Drop! . Detr.
PM
fi «4Q
?n 5
2/22/79 /
SO 2
NOx
CO
HC
Increment Consumed/Remaining %/ 2
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
5/23/79
5/31/79
5/31/79
7/3/79 '
I
I
I
I
Issues/Conrnents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
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1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name M.A. Layman & Son
Project Officer Eileen
Modeler
State/County/City VA
Type/Capacity/SIC Asphal
Glen New Source*
Modification* X
/ / Harrisonburg
t plant / 240 TPH /
§107 Designation 200,000 TRY
Attain. /'Uncl ass. /Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ampl . Detr.
PM
5508
3.72
5/16/79 /
SO 2
74.9
74.9
NOx
14.32
14.32
CO
1.19
1.19
HC
0.24
0.24
Increr.ent Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soi 1 s/Vegetat ion/Vi s ibi 1 i ty
Class I Area Impact
YES
X
NO
X
X
X
X
X
Prelininary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
5/23/79
5/30/79
5/30/79
7/16/79
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
uncontrolled and actual are the maximum allowable under the PSD permit.
I
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1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Marvin V Templet.nn & Sons. Inc.
Proiect Officer Eileen Glen
Model er
State/County/City VA /
Type/Capacity/SIC Asphal
New Source*
Modification* X
/ Lynchburg
t plant / 160 TPH / 2951
Il07 Designation
Attain. /Unclass./Nonattain. TSP / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
0.6
/ 2/16/79
S02
NOX
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual .
3/14/79
3/29/79
3/20/79
5/7/79 -
I
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
fr-aximurn uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Masonite Co.
Project Officer Eileen Glen
Model er
State/County/City VA /
New Source*
Modification* X
/ Stuart
Type/Capacity/SIC Particle board mfg. / /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec ' d/Compl . Detr.
Emissions (T/Y)* PM
Potential 25788
Actual 24.7
Net Increase
2/22/79 /
S02
NOX
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
5/16/79
5/22/79
5/22/79
7/16/79-
I
I
I
I
I
Issues/Comments -
Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Natr.e Nifty Paving Co.
Proiect Officer Eileen Glen
Modeler
State/County/City VA /
New Source*
Modification* X
/ Coeburn
Tvue/Cepacity/SIC Asphalt plant / 15,000 TPY /
Il07 Designation 90>000 TPH
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/Compl . Detr. 6/10/78 /
Emissions (T/Y)* PH S02 NOx
Potential 337
Actual 0.51
Net Increase
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones YES NO
BACT X
LAER/Offsets x
Air Quality Monitoring X
Air Quality Impact X
Soils/Vegetation/Visibility x
Class I Area Impact X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
9/11/78
10/4/78
10/4/78
11/2/78-
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
rraximun uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Source Narce Pencil eton
PSD PERMIT STATUS/CHECKLIST
Construction Co.
Project Officer George Fekete
Model er
State/County/City VA
/ Wvthe
New Source*
Modification* X
/ Wytheville
Tyte/Ccpacity/SIC Asphalt concrete plant/ 300 TPH, 100,000 TRY /
llC'7 Designation
Attain. /'Unclass./Nonattain. / /
Date Application Rec'd/Compl. Detr.
L-nissions (T/Y)*
Potential
Actual
Net Increase
PM
3375
3.4
7/16/79 /
SO 2
4.3
4.3
NOx '
CO
HC
Ir.crer.rnt Consumed/Remaining %/ %
Project Milestones
B.-.CT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Pxegister Notice
Completion
Estimate
Actual .
10/11/79
10/27/79
10/27/79
1/02/80'
I
I
I
I
I
Issues/Connents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
n2xi-.izij uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Radford Army Ammunition Plant
Project Officer George Fekete
Model er
State/County/City
VA / Montqomery/Pulaski
New Source*
Modification* X
/ Radford
Type/Capacity/SIC Ammunition plant / 12,000 TPY /
Il07 Designation
Attain. /urtclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
373
3.93
3/9/79 /
S02
NOx
CO
HC
1905.7
1905.7
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Sons/Vegetation/Visibility
Class I Area Impact
YES
X
X
NO
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
1/24/80
1/30/80
1/30/80
3/27/80
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
iraximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Norfolk and Western Railroad Co.
Project Officer Ben Mykijewycz
Model er
State/County/City VA
TvDe/Capacity/SIC Boiler
New Source*
Modification* x
/ / Roanoke
/ 82.6 x 106 .MBtu/hr /
S _, n . _ Total 24/.8 x IUU MBtu/hr
§107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
26799
64.1
9/25/79 /
SO 2
764
764
NOx
201
201
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetat ion/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
x
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
5/13/80
5/20/80
5/20/80
7/14/80
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Roanoke Electric Steel Corp.
Project Officer George Fekete
Modeler
State/County/City VA_
/
New Source*
Modification* X
/ Roanoke
Tvoe/Capacity/SIC Elprtnv Arc furnace /200,000 TRY /
§107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
1922
42.3
/
S02
NOx
18
CO
3145
3145
HC
Incrament Consumed/Remaining %/ 2
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X
NO
X
. X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
.Estimate
Actual
12/18/79
12/31/79
12/31/79
3/27/79
I Issues/Comments -
I
I
I
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Southeastern Public Service Authority of Virginia
Project Officer Georqe
Model er
State/County/City
Fekete
VA /
New Source* X
Modification*
/ Portsmouth
Type/Ccpacity/SIC Resource Recovery planl/ 50 T/HR /
Il07 Designation
Attain. /'Unclass./Nonattain. TSP S00 / / Ox
Date Application Rec'd/C
E-nissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr. 8/4/79 /
PM S02 NOx
48.7 2072 975
CO
7133
HC
63.1
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
YES NO
X
X
X
X
Soils/Vegetation/Visibility X
Class I Area Impact
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
4/25/79
5/01/79
5/01/79
7/31/79
Issues/Corrr.ents -
* Since these sources v/ere reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
raxirnun uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name W & W Pavina Company
Project Officer Eileen Glen
Model er
State/County/City VA
/
New Source*
Modification* x
/ Clearbrook (Leesburq)
Type/Capacity/SIC Asphalt batching / 120 T/hr / 2951
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
4050
5.4
12/14/78 /
S02
25.1
12.9
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual .
2/28/79
3/05/79
3/05/79
5/07/79 -
I
I
I
I
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
niaximurn uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Badger Coal Co., Grand Badger No. 1 Plant
Project Officer Joanne McKernan
Model er
State/County/City W. VA /
New Source* x
Modification*
/ Saqo
Type/Capacity/SIC Coal Preparation with / /
5lfl_ . Thermal Dryer
§107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec ' d/Compl . Detr. 8/28/78 /
Emissions (T/Y)* PM S02 NOx
Potential
Actual 121.8 388.9
Net Increase
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones YES NO
BACT X
LAER/Offsets X
Air Quality Monitoring X
Air Quality Impact X
Soils/Vegetation/Visibility X
Class I Area Impact X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
10/6/78
10/13/78 '
10/13/78
1/5/79 '
Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name E-E- Moore Paving, Inc.
Proiect Officer Bob Blaszczak
Modeler
State/County/City W.VA / Putnam
New Source* X
Modification*
/ Nitro
Tyse/Capacity/SIC Hot Mix Asphalt Plant / 120 ton/hr /
§107 Designation
Attiin./unclass./Nonattain. / /
Date Application Rec ' d/Compl . Detr. 3/5/79 /
Emissions (T/Y)* PM S02 NOX
Potential 17520
Actual 25.4
Jiet Increase
CO
HC
Increment Consumed/Remaining %/ 2
Project Milestones YES HO
BACT X
LAER/Offsets X
Air Quality Monitoring X
Air Quality Impact X
Soils/Vegetation/Visibility X
Class I Area Impact X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
4/6/79
4/11/79
4/11/79
6/6/79-
Issues/Conrnents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
raxing uncontrolled and actual are the maximum allowable under the PSD permit.
-------
I
I
I
I
I
I
PSD PERMIT STATUS/CHECKLIST
Source Name Elkay Mining Do. Rum Creek Coal Preparation Plant
1
1
1
1
1
1
1
1
1
1
1
Project Officer Joanne McKernan
Model er
State/County/City W.
VA /
New Source* X
Modification*
/ Lyburn
Type/Capacity/SIC Coal Preparation Plant/ 635 TPH /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
25286
151.72
8/7/78 /
S02
485
266
NOx
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X
NO
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
3/22/79
3/28/79
3/28/79
7/10/79-
Issues/Comments -
Calculation based on 5760 hrs/yr
PM removal efficiency 99.4
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
I
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Narr.e Inland Creek Coal Company Northern Division
Project Officer Joanne McKernan
Modeler
State/County/City W.VA
Type/Cs pa city/SIC Thermal coal dryer
/ Upshur
New Source*
Modification* x
/ Craigsville
/ 287 TPH /
§107 Designation
Attain. /Uncl ass. /Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
31218
68.68
Increment Consumed/Remaining 80% PM
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetat ion/Visibility
Class I Area Impact
4/4/78 /
S02 NOX
61363
135
CO
HC
, 64% of S02 %/ ' ' *
YES NO
X
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
9/1/78
9/16/78
9/16/78
11/8/78
Issues/Conrr.ents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
-------
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Island Creek Coal Company Pond Fork Plant
Project Officer James Sydnor
Model er
State/County/City W.VA / Boone
New Source* X
Modification*
/ Bob White
Type/Capacity/SIC Thermal coal drver / 185 TPH /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
Dmpl . Detr.
PM
19.1
11/9/77 /
S02
27.7
NOx
CO
HC.
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Issues/Comments -
Completion
Estimate
Actual .
5/25/78
6/8/78
6/8/78
8/11/78
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I
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
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1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Narr.e Morgantown Asphalt Co.
Project Officer Vernon
Model er
State/County/City VA
Tyse/Cspacity/SIC Asphal
Butler
/ Monpnqalia
New Source* x
Modification*
/ Morgantown
t olant / 366 TPH /
Il07 Designation
Attiin./Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
13176
10.9
8/24/79 /
S02
1.66
1.66
NOX
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X
X
X
NO
X
Prelininary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal P*egister Notice
Completion
Estimate
Actual
10/11/79
10/19/79
10/19/79
1/25/80
Issues/Conrnents -
I
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* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
ng uncontrolled and actual are the maximum allowable under the PSD permit.
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1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Name Morqantown Energy Research Center
Proiect Officer Eileen
Model er
Glen New Source*
Modification* x
State/County/City W.VA / Mononqalia
/ Morgantown
TvDe/Capacity/SIC Atmospheric Fluidi zed / 98.3 MBtu/hr /
5 ' _ . , . Bed Component Test & Integration Unit
5107 Designation (Boiler)
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
11913
14.5
8/8/78 /
SO 2
284.7
174.1
NOx
131
80.3
CO
17.5
10.4
HC
4.38
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
X
X
NO
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Compl etion
Estimate
Actual
7/16/79
7/23/79
7/23/79
9/20/79
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Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
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1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST
Source Narr.e S & S Asphalt Corporation
Proiect Officer Vernon
Model er
State/County/City W.VA
Type/Capacity/SIC Asphal
Butler
/ Berkeley
New Source*
Modification* x
/ Martin-sburg
t batch plant / 151 TPH /
I 107 Designation
Attain. /Uncl ass. /Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
5137
1.02
6/19/79 /
S02
NOx
CO
HC
!ncrar,ent Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Veqetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Prelininary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual .
8/24/79
9/1/79
9/1/79
11/2/79 '
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Issues/Conrcents -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
raximun uncontrolled and actual are the maximum allowable under the PSD permit.
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1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Superior Sand and Asphalt
Project Officer Vernon Butler
Modeler
State/County/City W.
Type/Capacity/SIC Asphal
VA / Monongalia
New Source* x
Modification*
/ Morgantown
t hot mix plant / 250 TPH /
Il07 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
1874
4.3
5/23/78 /
S02
9.5
9.5
NOx
CO
HC
Increment Consumed/Remaining %/ 2
i
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
9/22/78
10/3/78
10/3/78
1/2/79-
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Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
maximum uncontrolled and actual are the maximum allowable under the PSD permit.
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1
PSD PERMIT STATUS/CHECKLIST
Source Name West Virginia Paving Co.
Project Officer Ben Mykijewycz
1
1
1
1
1
1
1
1
1
1
1
Model er
State/County/City W.VA.
New Source* x
Modification*
/ / Dunban
Type/Capacity/SIC Hot mix asphalt plant / 400 TPH /
§107 Designation
Attain. /Unclass./Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompi . Detr.
PM
12960
12.5
/ 1/23/79
S02
NOx
CO
HC
Increment Consumed/Remaining %/ 2
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soils/Vegetation/Visibility
Class I Area Impact
YES
X
NO
X
X
X
X
X
Preliminary Determination
Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
2/13/79
2/22/79
2/22/79
4/11/79
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I
I
I
Issues/Comments -
* Since these sources v/ere reviewed prior to 8/7/80, data is for the emission units
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
raximurn uncontrolled and actual are the maximum allowable under the PSD permit.
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1
1
1
1
1
1
1
1
1
1
1
1
1
PSD PERMIT STATUS/CHECKLIST .
Source Name Westmoreland Coal Triangle - Has! am Plant
Project Officer Ben Mykijewycz
Modeler
State/County/City W.
VA / Raleigh
New Source* x
Modification*
/ Eccles
Type/Capacity/SIC Thermal coal dryer / /
§107 Designation
Attain. /Uncl ass. /Nonattain. / /
Date Application Rec'd/C
Emissions (T/Y)*
Potential
Actual
Net Increase
ompl . Detr.
PM
78.4
12/20/77 /
SO 2
136
NOX
CO
HC
Increment Consumed/Remaining %/ %
Project Milestones
BACT
LAER/Offsets
Air Quality Monitoring
Air Quality Impact
Soil s/Vegetation/Vi sibil ity
Class I Area Impact
YES
X
X
X
NO
X
X
X
Preliminary Determination
L Public Notice
Notice to Public Officials
Final Permit
Federal Register Notice
Completion
Estimate
Actual
8/30/78
9/6/78
9/6/78
11/8/78-
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Issues/Comments -
* Since these sources were reviewed prior to 8/7/80, data is for the emission units,
not the "source" as defined in the 8/7/80 rules. Basically potential emissions are
raximun uncontrolled and actual are the maximum allowable under the PSD permit.
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I APPENDIX 0
Determination of Significant Impact Radii for PSD Sources
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0-1
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I EPA Contract No. 68-02-2536
Work Assignment No. 14
I
DETERMINATION OF THE RADIUS OF SIGNIFICANT IMPACT
FOR PSD SOURCES WITHIN U.S. EPA REGION III
I
Robert Blaszczak - Project Officer
Thomas Blaszak - Project Manager
Louis Skibicki - Principal Investigator
I
December, 1980
I
wm Prepared For:
Air Programs Branch
U.S. Environmental Protection Agency
Region III
* Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
I
Pacific Environmental Services, Inc.
465 Fullerton Avenue
Elmhurst, Illinois 60126
(312) 530-7272
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1.0 INTRODUCTION
The U.S. EPA Prevention of Significant Air Quality Deterioration
(PSD) Regulations (40 CFR, part 52.21) as amended in the Federal
Register on August 7, 1980 (45 FR 52676) requires that subject sources
must demonstrate that PSD increments (where established) must not be
exceeded.
The assessment of increment consumption must include all sources
which have been constructed since the baseline date. Region III per-
sonnel are constructing a data file and related software to enable
future PSD subject sources to easily obtain information on previously
approved PSD sources which could potentially interact with an appli-
cant's proposed source. Pacific Environmental Services, Inc. (PES)
has been contracted by Region III to assist in this assignment by
providing the needed input data for this file. PES has examined
Region III files in order to develop the information needed for this
data base regarding previously processed PSD permits.
Briefly, the impact of a source on air quality decreases with
distance from the source itself. This distance is dependent on the
magnitude of the pollutants emitted and the manner in which they are
emitted into the atmosphere. Recognizing that the air quality impacts
never reach zero, a level of significant impact has been established
and the radial distance from the source at which the air quality impact
is reduced to this level was determined. The radius of impact defines
the area of impact of the source and is the datum needed for the
Region III data base.
Through discussion with Region III personnel, the following method-
ology and format for presentation of these data was finalized. This
impact assessment includes the radius of significant impact for each
PSD source reviewed (Table 3-1) and a listing of all input parameters
used in this analysis (Table 3-2).
1-1
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2.0 METHODOLOGY
In order to effectively and efficiently accomplish this task, a
methodology has been devised, in conjunction with Region III input.
This methodology is described below.
In this methodology, the screening procedures, as described in the
U.S. EPA "Guidelines on Air Quality Models" (EPA-450/2-78-027) were
followed. Briefly, the PT-series of models in the UNAMAP package,
together with the time correction factors (Ref: D.B. Turner, Workbook
on Atmospheric Dispersion Estimates) were used to determine a radius
of significant impact for each PSD source. The significant impact
area is defined as that area where ambient air pollutant concentra-
tions equal or exceed the following levels:
Pollutant
so2
TSP
N02
CO
Annual
1 ug/m3
1 ug/m
1 ug/m
Table 2-1.
24-Hour
5 ug/m
5 ug/m
AVERAGING TIME
8-Hour 3-Hour
25 ug/m3
0.5 ug/m3
1-Hour
2 ug/m3
The boundary of the area of significant impact extends up to a maximum
of 50 kilometers from the source, the extreme limitation of applica-
bility of Gaussian dispersion models.
The basic methodology was most applicable to single stack sources
where the ground level impacts were reduced to the significance impact
levels using the internally generated meteorological parameters
(Note: Multiple identical stacks can be equated to a single stack
source since this model is incapable of stack separation.). This
approach, which coincides with the approved methodology without
variation, is described as Scenario 1 below. In some cases, however,
the air quality impacts did not reduce to significant impact levels
2-1
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under this scenario. In those instances, described in detail as
Scenario 2, the PTDIS model was used to determine the air quality
impacts at larger distances from the source. Since the meteorology
used was identical to that internally generated by PTMAX, this
procedure is consistent with the agreed methodology.
Under the third scenario, sources having multiple different stacks
were analyzed using the PTMTP model. Since the total ground level
impact is the sum of the contributions of each stack, this model was
used for this summation, since the meteorology was limited to that
generated by PTMAX, this variation is consistent with the agreed
methodology.
The following is a step-by-step explanation of these scenarios and
how they were used to quantify the radius of significant impact.
2.1 SCENARIO 1 - PTMAX
Input
fa) Meteorological data (internally generated data were used)
(b) Source parameters
Output
(a) Maximum one-hour concentrations
(b) Associated distances
The following is the procedure used to definitize the radius of
significant impact for scenario 1. First, the one-hour concentrations
(direct output of the model) were multiplied by the applicable time
correction factors for each pollutant and respective averaging times.
These values were then evaluated with respect to the respective signi-
ficant impact levels listed in Table 2-1. The radius of significant
impact (pollutant specific) was then ascertained. This radius was
calculated to be the greatest distance at which the air quality impact
equalled the significant impact level. In most cases, a linear extra-
polation of two adjacent concentrations/distances, one being above and
one being below significant impact levels was necessary.
2-2
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2.2 SCENARIO 2 - PTDIS
(a) Distances (beginning with the distances predicted by PTMAX
and extending out to 50 km)
(b) Source parameters (identical to PTMAX)
(c) Meteorological (identical to PTMAX)
Output
(a) Distance (user specified)
(b) Associated one-hour concentrations
In some instances, PTMAX did not provide sufficient information to
determine the radius of significant impact due to the fact that maxi-
mum concentrations sometimes exceeded significant levels at the
greatest distance analyzed. For these cases, PTDIS was run. As in
PTMAX, the one-hour concentrations were multiplied by the applicable
time correction factors for each pollutant and respective averaging
times. Again, these values were evaluated with respect to the respec-
tive significant impact levels listed in Table 2-1. The radius of
impact was then calculated to be the greatest distance at which the
air quality impact equalled the significance levels.
2.3 SCENARIO 3 - PTMTP
Input
(a) Source parameters (per stack)
(b) Receptors (a series of downwind receptors up to 50 km - a
denser spacing nearer the source was utilized)
(c) Meteorological data (identical to PTMAX but constant wind
direction to downwind receptors)
Output
(a) One-hour concentrations
(b) Associated receptors (i.e., downwind distances)
As previously mentioned, scenario 3 deals with multiple stack
sources. Receptor concentrations (downwind distances) must sum
partial contributions from all stacks under the same meteorological
2-3
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conditions. PTMTP is equipped to handle just such conditions. Once
PTMTP was run, the one-hour concentrations (output) were subjected to
the same analyses as PTMAX output concentrations. They were multi-
plied by the applicable time correction factors for each pollutant and
respective averaging times, and these values were evaluated in regard
to the respective significant impact levels listed in Table 2-1. From
this point on, the procedure is identical to PTDIS.
2-4
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3.0 RESULTS
The radius of significant impact for all the previously processed
PSD permits is presented in Table 3-1. These were determined using
the previously described methodology. The Table 3-1 Notes adequately
clarify any missing datum. Table 3-2 lists the source parameters used
as input to the PT-series of models.
3-1
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1
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Table 3-1. SIGNIFICANT IMPACT
1
1
1
|
1
1
1
1
'
1
1
1
1
FACILITY
DELAWARE
Delaware Reclamation Project
Delmarva Power and Light
MARYLAND
Armco Steel Co.
Arundel Corporation
Bethlehem Steel, Sparrows Plant
Campbell - Grove Division
Celanese Fibers Co.
Craig Blacktop & Paving Co.
Eastalco Aluminum Co.
Firestone Plastic Co.
Flintkote Co.
Francis O'Day Company, Inc.
Maryland Materials, Inc.
Mettiki Coal Co.
COORDINATES
NORTH/ EAST
(km)
4270.0
479.2
4351.7
364.7
4340.0
373.0
4340.0
373.0
4385.2
327.3
4391.0
692.2
4392.8
264.7
4356.1
290.3
4379.1
407.3
4385.2
327.3
4325.4
316.4
4348.7
420.5
4365.0
290.3
3-2
SIGNIFICANT IMPACT RADIUS
TSP S02 NOX
(km) (km) (km)
(A)
NOT BUILT
3.1
FUGITIVE EMISSIONS ONLY
(A) (A)
*0.2
1.4 34.4
* 0.5 * 0.5 * 0.5
(6%) (10%) (6%)
50.0 50.0
(B) 50.0
2.3
11.7
39.7
1.4 50.0
CO
(km)
(A)
* 0.5
(12%)
w
__
__
vr
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Table 3-1.
FACILITY
Miller Asphalt Product
PPG Industries
Pulaski Highway Solid Waste
Reduction Center
(City of Baltimore)
Sykesville Construction Co.
PENNSYLVANIA
Abex Corporation
Airco-Speer
Allegheny-Ludlum Steel Corp.
Allen Products
Arco Pipe Line Co.
Berks Products
Bethlehem Steel Corp.
(Johnstown Plant)
Breneman, E.J.
Burrell Construction & Supply Co.
Coplay Cement Manufacturers
GAP Corp. - Chemical Group
SIGNIFICANT
COORDINATES
(North/East)
4367.0
333.0
4351.0
365.9
4383.0
329.0
4451.0
675.5
4589.5
705.4
4495.2
606.5
4467.0
679.0
4498.0
375.0
4496.0
601.0
4509.2
473.0
4402.0
288.7
3-3
IMPACT (Continued)
TSP S02 NO*
13.3
*0.8 *0.8 50.0
(78%) (54%)
*0.7 *0.7 *0.7
12.4
29.9 50.0
*1.0 50.0
(29%)
18.2
(C)
ONLY HC EMISSIONS
15.2
(A) (A)
(C)
16.4 9.1
4.3 50.0
18.2
CO
__
2.2
*0.7
-.
50.0
50.0
(A)
__
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Table 3-1.
FACILITY
General Battery Co.
Highway Material Inc.
Herbert Imbt Inc.
Inmetco
International Minerals
& Chemical Corp.
Mi 11 creek Township Asphalt Plant
Molycorp, Inc.
Philadelphia Gas Works
Smith-Kline Co.
Stackpole Carbon Co.
Sun Petroleum Products
Tonolli Corp.
Transco
United Refining Co.
U.S. Dept. of Interior
(Bureau of Mines)
U.S. Steel Battery 13, 14, 15, 20
SIGNIFICANT
COORDINATES
(North/East)
4470.0
420.0
4437.0
467.0
4530.7
477.3
4523.0
561.0
....
4658.0
578.0
4418.7
483.0
4700.0
751.5
4589.0
705.0
4408.8
464.3
4522.2
425.9
4410.0
465.0
4633.8
652.7
4465.0
588.0
4461.0
596.0
3-4
IMPACT (Continued)
TSP S0_2 NOx
*0.4 23.8
(35%)
8.3 11.0
13.8 29.8
10.3
.. .._ __
4.4
1.6 50.0
*1.0 50.0 50.0
(54%)
23.4 41.7 (B)
3.8
2.2 2.2 *0.7
(70%)
6.8 12.6
21.0 50.0
NET DECREASE
(A) (A)
50.0 16.3
CO
«...
(C)
__
--
50.0
(B)
*0.7
(8%)
__
.* _
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Table 3-1.
FACILITY
U.S. Steel (Duquesne)
Wilkes-Barre Steam Heat Authority
Windsor Services, Inc.
Zarlengo Bro. Inc.
VIRGINIA
Anheuser-Busch
Burlington Industries, Inc.
Clinchfield Coal Co.
Coal Industry Services Co, Inc.
Continental Forest Industries
Georgia Pacific Co.
Greer Lime Co.
Hampton Roads Energy Company
Locher Brick Works Inc.
Lone Star Industries
Long Star LaFarge Inc.
SIGNIFICANT
COORDINATES
(North/East)
4469.5
598.4
_ ^
4469.0
378.0
4102.6
682.2
4093.0
384.0
4130.5
299.0
4077.4
278.5
4081.0
431.0
4079.0
382.0
4162.0
671.0
4136.6
277.8
4136.6
277.8
3-5
IMPACT (Continued)
TSP S02 NOx
2.2
*0.5 47.2 29.5
(72%)
10.4 21.7
6.5
13.5 30.9 50.0
(A) (A) (A)
8.2 16.2 32.4
3.7 10.3 5.6
50.0 50.0 50.0
15.2 39.7 50.0
1.7 4.0
50.0 50.0 50.0
20.1 1.2
FUGITIVE EMISSIONS ONLY
PRE-1977
CO
«*.
38.5
31.6
4.5
__
50.0
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Table 3-1.
FACILITY
Lynchburg Foundry
M.A. Layman and Son
Marvin Tempi eton & Sons Inc.
Masonite Co.
Nifty Paving Co.
Norfolk & Western Railroad Co.
Pendleton Construction Co.
Radford Army Ammunition Plant
Roanoke Electric Steel Corp.
Southeastern Public Services
Authority of Virginia
W & W Paving Co.
WEST VIRGINIA
Badger Coal Co.
E.E. Moore Paving Inc.
Elkay Mining Co.
Inland Creek Coal Co.
(Northern Plant)
SIGNIFICANT
COORDINATES
(North/East)
4141.3
665.4
4257.0
687.0
4125.4
655.6
4055.0
566.0
4089.5
369.5
__
4115.0
540.7
4126.0
595.0
4078.0
384.5
4349.0
750.5
4307.0
567.0
4253.0
427.0
4185.5
420.2
4307.0
517.5
3-6
IMPACT (Continued)
TSP SQ2 NO*
18.0
5.2
*1.0
(70%)
(D)
6.4
*0.5 29.2 50.0
(98%)
6.2 0.7
NO NET INCREASE
*1.3
(5%)
1.2 50.0 50.0
6.3 27.8
14.4 22.9
(A)
25.9 16.9 50.0
(D) (D)
CO
__
_ _
__
50.0
50.0
«
__
_..
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1
Table 3-1. SIGNIFICANT
COORDINATES
FACILITY (North/East)
Island Creek Coal Co. 4201.0
(Pond Fork Plant) 436.5
Morgantown Asphalt Co.
Morgantown Energy Research Center 4387.0
590.0
S & S Asphalt Co.
Superior Sand and Asphalt Co. 4388.0
591.0
W. Virginia Paving Co. 4247.0
435.0
Westmoreland Coal 4181.5
(Triangle-Haslam Plant) 476.5
3-7
IMPACT (Continued)
TSP SO?
15.0 28.9
4.0 0.5
*0.6 21.0
(41%)
*0.3 6.6
(96%)
17.6 25.8
14.0
9.4 15.8
NOY CO
11.7
-------
I
I
I
TABLE 3-1 NOTES
I Facility Name In alphabetical order, as it appears on
PSD permit application
I UTM Coordinates As found in the permit application
Radius of Significant Distance to significant concentration
Impact (km) levels in km.
(*) *y/(x%) means significant level not
reached. Concentration is x percent of
the significant impact level at y
distance.
Information not available or not
applicable
(A) No stack parameters given.
(B) Only one emission rate given for
multiple stack source.
(C) No stack height given.
|(D) No stack temperature and/or volume flow
rate given.
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APPENDIX P
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I
Reassessment of the Significant Impact Radius for the
Firestone Plastic Company
Perryville, Maryland
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IB i
PACIFIC
I
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^^ ^S /ffl\\
eofip vkjy
ENVIRONMENTAL SERVICES. INC.
April 22, 1982
Mr. Robert Blaszczak
Air Programs Branch
U.S. EPA, Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Blaszczak:
LOS ANGLLES
RtSCARCH TWANGLC PA«K
WASHINGTON
Pursuant to our telephone conversations, the radius of signifi-
cant impact for the Firestone Plastic Company located in Perryville,
Maryland was reexamined. Originally
, all three boilers at this
facility were modeled to determine the raeHus of significant impact.
In the reanalysis, only boiler No. 3
was modeled using its design fuel oi
the SIP emission limitation of 2.0%
emission parameters were modeled:
Emission Rate (g/sec) = 21.90
was modeled. This boiler
1 burn rate of 553 gal/hr and
sulfur fuel oil. The following
(so2)
Physical Stack Height (m) = 15.90
I
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1
1
1
Stack Gas Temp (°K) = 437.00
Ambient Air Temperature (°K) =
Volume Flow (m3/sec) = 11.10
The radius of significant impact for
293.0
sulfur dioxide is 50.0 Km.
This work^was completed under U.S. EPA Contract No. 68-02-2536,
Work Ass/fgflment No. 14.
^^^/
ynamas P. Blasz^k
5/oject Manager
TPB/jlf/453
MIDWEST OPERATIONS 465 Fullerton Ave. Elmhurst. ILL 60126 (312) 530-7272
ILL
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TECHNICAL REPORT DATA
.'/Vi/ii .'<. jc/ IniZr.ictiuits on tl:r n '<.> «, !\ /ore (.v>ni'!'-t;>'£l
; ^=c;u \;. 2.
903/9-82-008a
J TITLE A\CSU3T
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