Existing Large Solid Fuel Boilers and Process Heaters
Baghouse
COMS for Opacity
w/ Emissions Averaging
Health-Based HCl using Risk Assessment
Part II - FACILITY SPECIFIC TERMS AND CONDITIONS
A.State and Federally Enforceable Permit To Install Facility Specific Terms and Conditions
1.The permittee shall comply with the applicable provisions of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for industrial, commercial, and institutional boilers and process heaters, as promulgated by the United States Environmental Protection Agency under 40 CFR Part 63, Subpart DDDDD. The final rules found in 40 CFR Part 63, Subpart DDDDD establish national emission standards for hazardous air pollutants (NESHAP), work practice standards, and compliance requirements for industrial, commercial, and institutional boilers and process heaters located at a major source of hazardous air pollutants (HAP). The permittee shall comply with the requirements and limits of this NESHAP for the facility’s existing (commenced construction or reconstruction on or before 1/13/03) solid fuel-fired boilers and/or process heaters no later than September 13, 2007, at which time the initial compliance period begins.
[40 CFR 63.6(c)(1)], [40 CFR 63.7485], [40 CFR 63.7490], and [40 CFR 63.7495(b)]
2.The terms in this permit reflect the requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) contained in 40 CFR Part 63, Subpart DDDDD and are meant to help the permittee maintain compliance with this NESHAP. The requirements of this Subpart apply to the facility boilers and process heaters according to their applicable subcategory, as defined in 40 CFR 63.7575.
[40 CFR Part 63, Subpart DDDDD]
B.State Only Enforceable Permit To Install Facility Specific Terms and Conditions
None
Part III - SPECIAL TERMS AND CONDITIONS FOR SPECIFIC EMISSIONS UNIT(S)
A.State and Federally Enforceable Section
I.Applicable Emissions Limitations and/or Control Requirements
Unless demonstrating compliance through emissions averaging (where the average emissions from the facility’s large, existing, solid fuel-fired boilers can be used to meet the Subpart DDDDD limits), the organic hazardous air pollutants (HAP)/HAP surrogate emissions from each of the facility’s large, existing, solid fuel-fired boilers and process heaters shall not exceed the particulate matter (or total selected metals), mercury, and visible emissions limits from 40 CFR Part 63, Subpart DDDDD; and every emission point subject to Subpart DDDDD shall be included in the eligibility demonstration for the health-based alternative limits established for HCl and Cl2 by meeting the requirements of Appendix A to the Subpart.
PM* (or TSM**)0.07 lb per mmBtu of heat input (0.001 lb per mmBtu of heat input)
Hydrogen Chloride (HCl)XX lb per hour
Chlorine (Cl2)XX lb per hour
Mercury (Hg)0.000009 lb per mmBtu of heat input
Visible emissions from the stack shall not exceed 20% opacity as a 6-minute average, except for one 6-minute period per hour of not more than 27 percent.
[40 CFR 63.7500], [40 CFR 63.7507(a)], [40 CFR 63 Subpart DDDDD, Tables 1, 2, 3, and 8], and [40 CFR 63 Subpart DDDDD, Appendix A]
* Particulate matter
**Total Selected Metals, the combination of these metallic HAP: arsenic, beryllium, cadmium, chromium, lead, manganese, nickel, and selenium
2.aThe permittee shall meet the requirements of 40 CFR 63, Subpart DDDDD through the following methods in order to demonstrate compliance with the limits from Table 1 to this Subpart for particulate matter (PM) or total selected metals (TSM), mercury (Hg) and visible emissions for the facility’s existing, large, solid fuel-fired boilers and process heaters; and the limits for hydrogen chloride (HCl) and chlorine (Cl2), established under the health-based alternative as provided under 40 CFR 63.7507 and Appendix A to the Subpart, for all the facility’s boilers and process heaters subject to the Subpart. The permittee shall:
i.conduct an initial compliance demonstration for each of the surrogate HAP pollutants, as required by 40 CFR 63.7510, and within 180 days following the compliance date (to be completed on or before March 13, 2008), to include performance testing and an initial fuel analyses;
ii.maintain continuous compliance with the emission limits in Table 1 for PM or TSM, Hg, and the HCl and Cl2 limits established per Appendix A to the Subpart, as required per 40 CFR 63.7540 and according to Table 8, by monitoring the opacity as measured by the continuous opacity monitoring systems (COMS) on the baghouse stack;
iii.develop and submit a site-specific test plan to document the procedures needed for compliant performance testing as required by 40 CFR 63.7520(a) and meeting the requirements of 40 CFR 63.7(c)(2);
iv.conduct performance tests as required by 40 CFR 7530(a), according to 40 CFR 63.7520, and at the frequency required in 40 CFR 63.7515, using the methods specified in Table 5 for PM/TSM and Hg and the methods in Table 1 of Appendix A for HCl and Cl2, initially on or before 3/13/08;
v.develop and submit a site-specific monitoring and performance evaluation test plan, as required by 40 CFR 63.7505(d), for the COMS required at each emission point from the subject boilers and process heaters;
vi.install, operate, certify, and maintain the COMS as required by 40 CFR 63.7525(b), 40 CFR 63.8, and Performance Specification 1 and maintain continuous compliance with the opacity limit by proper maintenance of the baghouse and operating and maintaining the COMS as required in this permit and according to the approved site-specific monitoring plan;
vii.conduct performance evaluations of each COMS according to the requirements of 40 CFR 63.8, Performance Specification 1, and the approved site-specific performance evaluation test plan;
viii.develop and submit, at least 60 days before the date of the intended compliance demonstration, a site-specific fuel analysis plan, as required by 40 CFR 63.7521(b), to determine the concentrations of chlorine (Cl), Hg, and TSM (if demonstrating compliance with this alternative emissions limit for PM) in the fuel, according to the methods and procedures in Table 6;
ix.collect solid fuel samples and conduct fuel analyses for each type of fuel burned (or to be burned) according to 40 CFR 63.7521 and Table 6, initially in conjunction with the performance test on or before 3/13/08, and at the frequency required in 40 CFR 63.7515(f), i.e., no later than 5 years after the previous fuel analysis for each fuel type;
x.establish, from the fuel analyses, maximum fuel pollutant input levels of chlorine, Hg, and TSM if demonstrating compliance with this alternative emissions limit for PM, in pounds per million Btu, as required in 40 CFR 63.7530(c);
xi.maintain records as required in this permit and per 40 CFR 63.7535, 63.7540, and 63.7555;
xii.develop and implement a written startup, shutdown, and malfunction plan as required by 40 CFR 63.6(e)(3) and 40 CFR 63.7505(e);
xiii.meet the reporting requirements of 40 CFR 7515(g), 63.7545, and 40 CFR 63.7550 and as specified in Tables 9 and 10 to the Subpart; and
xiv.maintain compliance with all the requirements of this permit and Subpart DDDDD.
[40 CFR 63.6(e)(3)], [40 CFR 63.7(c)(2)], [40 CFR 63.8], [40 CFR 63.7(c)(2)], [40 CFR 63.7500(a)], [40 CFR 63.7505], [40 CFR 63.7507], [40 CFR 63.7510], [40 CFR 63.7515], [40 CFR 63.7520], [40 CFR 63.7521], [40 CFR 63.7525(b)], [40 CFR 63.7530(a) and (c)], [40 CFR 63.7535], [40 CFR 63.7540], [40 CFR 63.7545], [40 CFR 63.7550], [40 CFR 63.7555], and [40 CFR 63 Subpart DDDDD, Tables 1, 2, 3, 5, 6, 8, 9, and 10, and Appendix A]
2.bFollowing the initial performance stack test and fuel analyses, conducted on or before March 13, 2008, if the facility has conducted enough fuel analyses and has collected enough data to demonstrate compliance with 40 CFR 7530(d), for a 90th percentile confidence level of the pollutant concentration, and after having established correlating performance stack testing results, the permittee may qualify to demonstrate compliance with the TSM, Hg, HCl emission limitations through fuel analyses, as allowed per 40 CFR 63.7505(c) and according to 40 CFR 63.7530(a) and (d) where the permittee shall:
i.submit a sufficient number of fuel analyses testing results (each report certified by an accredited laboratory) to demonstrate the required 90th percentile confidence level at the appropriate degrees of freedom, for the pollutant(s) for which fuel analyses is proposed to be used as the method of compliance;
ii.determine the 90th percentile confidence level fuel pollutant concentration of the composite samples collected and analyzed for the solid fuel, at the appropriate degrees of freedom to meet this confidence level, as required per 40 CFR 7530(d)(2); and
iii.calculate the emission rate of TSM and/or Hg in pounds per million Btu, as required in 40 CFR 7530(d)(4) or (5), to be less than the applicable limit from Table 1 to the Subpart and this permit; or
iv.calculate the emission rate of HCl as required in 40 CFR 7530(d)(3), in pounds per million Btu and converting HCl and Cl2 to pounds per hour, to be less than the limits established through the health-based alternative in Appendix A to the Subpart.
The permittee may demonstrate compliance with the limits for HCl, Hg, or TSM through fuel analyses if the emission rate(s) calculated using the equations from 40 CFR 63.7530(d) [Equation 8 for the 90th percentile confidence level pollutant concentration, and Equation 9 for the HCl emission rate, or Equation 10 for the TSM emission rate, or Equation 11 for Hg emission rate] is/are less than the applicable emission limit(s) from Table 1 of Part 63, Subpart DDDDD, or for HCl, less than the alternative limit established per Appendix A to the Subpart. The Ohio EPA, Division of Air Pollution Control, Central Office shall determine if the fuel analyses data submitted are sufficient to meet the requirements of the rule and a 90th percentile confidence level. If the calculated emission rate for HCl, Hg, or TSM exceeds the applicable emission limitation using these equations, compliance for the subject pollutant shall again be demonstrated through performance testing according to 40 CFR 63.7520; and the maximum fuel pollutant input levels of chlorine, total selected metals, and mercury shall be established and calculated by using the fuel analyses results in the Equations 5, 6, and/or 7 from 40 CFR 7530(c). When conducting fuel analysis, any chlorine detected shall be assumed to be emitted as Cl2. The performance stack test and fuel analyses shall be conducted at the frequency required per 40 CFR 63.7515 and this permit.
[40 CFR 63.7505(c)], [40 CFR 63.7510(b)], [40 CFR 63.7530(a) and (d)], and [40 CFR 63 Subpart DDDDD, Section 4(a)(1)]
2.cThe permittee shall meet the requirements of the site-specific risk assessment compliance demonstration contained in Appendix A to 40 CFR Part 63, Subpart DDDDD, Section 7, for the facility’s subject boilers and process heaters, which provides the methodology and criteria for demonstrating that the facility boilers and process heaters are eligible for the alternative HCl emission limit, established through the risk assessment determination by estimating long-term inhalation exposures from the boiler and process heater operations at worst-case conditions. The risk analysis shall meet the requirements of Sections 4, 5, 7, 8, 9, and 12 of Appendix A to the Subpart. All the facility boilers and process heaters that emit HCl or Cl2 shall be included in the health-based risk assessment for emissions of HCl. Each existing, large, solid fuel-fired boiler and process heater (and/or the average of the boilers’ emissions, if approved for emission averaging) shall meet the requirements of 40 CFR Part 63, Subpart DDDDD and the emission limits contained in Table 1 to the Subpart for PM or TSM, and Hg; all emission points from the subject boilers and process heaters shall meet the operating limit for opacity from Tables 2 and 3; and all of the facility’s boilers and process heaters (or the existing, large, solid fuel boilers’ average emissions, if approved for emission averaging) shall meet the HCl/Cl2 limits, established by demonstrating eligibility for the health-based compliance alternative in Appendix A to the Subpart.
[40 CFR 63.7507] and [40 CFR 63, Subpart DDDDD, Appendix A, Sections 1 through 3]
2.dThe permittee shall conduct emissions testing for PM or TSM, Hg, and both HCl and Cl2 at all emission points from the subject boilers and process heaters, at the frequency required in 40 CFR 63.7515 (unless approved for demonstrating compliance through fuel analysis as required in this permit). The HCl/Cl2 emissions shall be determined using Section 4 of Appendix A to the Subpart and the calculations for Ei,s (the maximum hourly emission rate for HCl and Cl2) which is based on the 3-run average emissions from the stack performance test.
[40 CFR 63.7507], [40 CFR 63.7510(a)], [40 CFR 63.7520], and [40 CFR 63, Subpart DDDDD, Appendix A, Section 4]
2.eThe facility’s health-based risk assessment of HCl emissions has demonstrated that the maximum Hazard Index (HI) values for HCl and CL2 are not greater than 1.0, at locations where people live or congregate at the closest proximity to the facility.
[40 CFR 63, Subpart DDDDD, Appendix A, Sections 5 and 7]
2.fIn order to remain eligible for the health-based compliance alternative, the parameters that defined the subject boilers and process heaters in the risk assessment demonstration for the HCl health-based compliance alternative shall be maintained and shall be federally enforceable. These parameters include:
i.fuel type: solid fuel;
ii.maximum heat input of each boiler and process heater, i.e., mmBtu/hr of each boiler and process heater;
iii.emission rate: the maximum hourly emission rate, calculated as E,i,s in this permit, and performance stack testing results shall not exceed XX lbs HCl/hr or XX lb Cl2/hr;
iv.stack height: at least XX meters;
v.stack exit velocity: no less than XX meters/second;
vi.distance from stack to nearest residence: no closer than XX meters;
vii.the maximum chlorine content of the solid fuel, determined from the fuel analyses conducted between the issuance of the Permit to Install and the Title V permits, shall be made federally enforceable in the Title V.
If these federally enforceable limitations cannot be maintained, the boilers and process heaters shall become subject to the HCl emission limit and operating limit(s) in Subpart DDDDD until or unless a revised risk assessment reestablishes the facility's eligibility and alternative limits.
[40 CFR 63, Subpart DDDDD, Appendix A, Section 8(d)]
2.gThe eligibility demonstration for the health-based compliance alternative for HCl was submitted to the U.S. EPA's Risk and Exposure Assessment Group at Research Triangle Park in September 2006, as is required by the rule.
[40 CFR 63, Subpart DDDDD, Appendix A, Section 9(a)]
2.hA revised eligibility demonstration shall be submitted to both the Central Office and the appropriate District Office or local air agency of the Ohio EPA Division of Air Pollution Control, prior to making any change that would affected the boilers’/process heaters’ eligibility for the health-based compliance alternative, by proposing changes in a way that could result in increased HAP emissions or increased risk from exposure to emissions. These parameters include those federally enforceable parameters listed above. The permit shall be revised to incorporate any change. If the boilers and process heaters are no longer eligible for the health-based compliance alternative, then compliance with the applicable emission limit, operating limits, and compliance requirements in Subpart DDDDD shall be met prior to making the process change and revising the permit. If the update of the eligibility demonstration is being made to account for an action that is outside of the facility’s control (e.g., change in a reference value), and that change causes the boilers and process heaters to no longer be able to meet the criteria for the health-based compliance alternative, the permittee shall comply with the HCl emission limit, operating limits, and compliance requirements in Subpart DDDDD within 3 years.
The revised eligibility demonstration shall be reviewed by the Division of Air Pollution Control, Central Office to verify that the demonstration meets the requirements of Appendix A to this Subpart and is technically sound (i.e., the site-specific assessment is technically valid). If there are any deficiencies in the eligibility demonstration submitted, the facility shall not be eligible for the health-based compliance alternatives until the Ohio EPA Division of Air Pollution Control, Central Office verifies that the deficiencies are corrected.
[40 CFR 63, Subpart DDDDD, Appendix A, Section 11]
2.iCompliance with the emission limits and operating limits contained in this permit shall be maintained at all times except during periods of startup, shutdown, and malfunction, and as specified in Subpart DDDDD. The Director of the Ohio EPA or his/her representative shall determine compliance with the applicable emission limits, opacity limit, and/or operational restrictions through review and evaluation of required records of operational and maintenance procedures, monitoring data, COMS performance evaluations, performance testing results, fuel analyses results, supporting calculations and emissions data, and any other applicable records required in this permit.
[40 CFR 63.6(f)(1) and (2)], [40 CFR 63.6(h)(1) and part of (2)], and [40 CFR 63.7505(a)]
2.jThe permittee shall develop and implement a written startup, shutdown, and malfunction plan (SSMP) by the compliance date of Subpart DDDDD and according to the provisions found in 40 CFR 63.6(e)(3), as follows:
i.The written startup, shutdown, and malfunction plan (SSMP) shall describe, in detail, procedures for operating and maintaining the boilers and process heaters during periods of startup, shutdown, and malfunction.
ii.The plan shall document detailed procedures of corrective action for the malfunction of the boilers and/or process heaters, the baghouse, and the COMS, used to comply with the requirements of this permit and Subpart DDDDD.
iii.The SSMP does not need to address any scenario that would not cause the emissions unit(s) to exceed an applicable emission limitation in Subpart DDDDD.
iv.The SSMP shall be written for the following purpose:
(a)to ensure that, at all times, each emissions unit, including the associated air pollution control equipment and monitoring equipment, is maintained in a manner consistent with safety and good air pollution control practices for minimizing emissions;
(b)to ensure that operators are prepared to correct malfunctions as soon as practicable after their occurrence, in order to minimize excess emissions of hazardous air pollutants;
(c)to reduce the reporting burden associated with periods of startup, shutdown, and malfunction; and