PERMIT APPLICATION REVIEW SUMMARY

Transcription

1 PERMIT APPLICATION REVIEW SUMMARY New Hampshire Department of Environmental Services Air Resources Division P.O. Box 95, 29 Hazen Drive Concord, NH Phone: Fax: AFS #: Application #: FY : June 25, 2007 Page 1 of 5 APPLICATION & OTHER COMMUNICATION July 26, 2006 October 6, 2006 FACILITY DESCRIPTION Description Application received Administrative completeness letter was sent Sea-3, Inc., located at 190 Shattuck Way in Newington, is a Liquefied Petroleum Gas (LPG) terminal. The terminal consists of two large LPG storage tanks, two boilers and an emergency generator. LPG is brought in by ocean tankers and unloaded into the two storage tanks. The storage tanks are kept at a low pressure and at -40 o F. Both the storage tanks are low pressure vessels (2 psig). These storage tanks do not release VOCs into the atmosphere. When a cargo of LPG is pumped into a tank, the vapors at the top of the tank are extracted and delivered to the marine vessel unloading the cargo in order to maintain pressure in the vessel s tank. Each tank is also equipped with an emergency pressure relief valve which is designed to relieve the tank pressure before it reaches the design limitation of the tank 1. Using heated water from the boilers, the LPG is heated from -40 o F to 40 o F prior to loading into a day tank. The heating is necessary to warm the product up beyond the brittle fracture point of mild steel. LPG is then transferred from the day tank to the tanker trucks on demand. Sea-3 operates a flare to combust LPG from the storage tanks or the facility, during periods of emergencies, maintenance and terminal loading. PERMITTING HITORY Facility permit FP-S-0159 was issued on October 15, This permit expired on October 31, This permit covered 2 boilers, 2 storage tanks and the flare. Sea-3 submitted the operating permit renewal application in a timely manner. Hence the operation of the above mentioned devices are covered under application shield. PROJECT DESCRIPTION The objective of this project is to renew the operating permit for all devices at the facility. Emission Unit ID Device Identification EU01 Boiler #1 Cleaver Brooks CB L EU02 Boiler #2 Cleaver Brooks LE L EU03 Emergency Generator John Deere 6125AF001 Not available Emission Unit Identification Manufacturer Model Number Serial Number Installation Maximum Design Capacity and Fuel Type(s) MMBtu/hr Natural gas - equivalent to 32,843 scf/hr LPG - equivalent to gal/hr 24.5 MMBtu/hr LPG - equivalent to gal/hr 2.4 MMBtu/hr diesel/#2 fuel oil - equivalent to 17.4 gal/hr EU04 LPG Storage Tank #1 3 n/a 1975 Tank fill capacity - 16,800,000 gallons EU05 LPG Storage Tank #2 3 n/a 1996 Tank fill capacity - 6,720,000 gallons EU06 Flare Smoke-ban Manufacturing, Inc Design capacity - 74,000 scf/hr of propane 1 When the tank pressure reaches 1.78 psig, the flare starts operating automatically. This flare is tested on a weekly basis. 2 The hourly fuel rates presented in this table are set assuming a heating value of 1,020 Btu/scf for natural gas, 94,000 Btu/gal for LPG and 137,000 Btu/gal for diesel fuel. 3 Vertical aboveground storage tank with a fixed roof

2 AFS #: Application #: FY : June 25, 2007 Page 2 of 5 Miscellaneous devices 1. Fire pump (195 hp) - Exempt pursuant to Env-A Freon-22 Compressors - Sea-3 operates a refrigeration system to maintain the LPG in the storage tanks at -40 o F. Sea-3 uses 2 compressors which operate on Freon refrigerant (chlorodifluomethane or CFC-22). Freon-22 is not photo chemically reactive and is not considered to a VOC. It is also not regulated under Title VI of the Clean Air Act. POLLUTION CONTROL EQUIPMENT None EMISSION CALCULATIONS Boiler #1 (33.5 MMBtu/hr - Natural gas/lpg) Pollutant Emission factor Emission rate Potential emissions lb/mmcf (Natural gas) lb/1000 gal (LPG) lb/hr (NG) lb/hr (LPG) TPY PM SO NOx CO VOCs Basis: AP-42 Chapter 1.4 (Natural Gas) & Chapter 1.5 (LPG) SO 2 emission factor for LPG = 0.1S, where S is the sulfur content in gr/100 scf. Sulfur content of LPG = 1.6 gr/100 scf Boiler #2 (24.5 MMBtu/hr - LPG) Pollutant Emission Emission rate factor lb/kgal lb/hr TPY PM SO NOx CO VOCs Basis: AP-42 Chapter 1.5 (LPG) 250 kw Emergency Generator (17.4 gal/hr diesel) Pollutant Emission factor Emission rate lb/kgal lb/hr TPY * PM SO NOx CO VOCs * Based on 500 hours/yr of operation Basis: AP-42 Chapter 3.3

3 AFS #: Application #: FY : June 25, 2007 Page 3 of 5 Permit limits for boilers: LPG = 1,000,000 gal/yr Natural gas = 100 mmcf/yr Permit limit for flare = 150,000 gal/yr of LPG Pollutant Emission factor lb/kgal (LPG) lb/mmcf (Natural gas) Max. allowable LPG in 2 boilers = 10 6 gal/yr Emissions, tpy Max allowable natural gas in Boiler #1= 100 mmcf/yr Max. allowable LPG for flare = 150,000 gal/yr Allowable emissions for Emergency generator tpy Facility-wide potential to emit based on permit limits tpy PM SO NOx CO VOCs Sea-3 is a synthetic minor source. STACK INFORMATION Device Stack height (ft) Exit Diameter (ft) Flow rate (ACFM) Exhaust Temp ( o F) Stack Configuration Boiler # Vertical Boiler # Vertical Flare Vertical (In July 1996 modeling analysis, default values of 20 m/s for velocity and 1273 o K for temperature were assumed for the flare) MODELING Criteria pollutants were modeled in July, Facility is in compliance with NAAQS. Please see modeling memo dated July 24, This analysis included emissions from flare also. The annual limit of 150,000 gal of LPG for the flare was proposed by the facility in The modeling analysis is based on this annual fuel limit for flare. EMISSION TESTING N/A SITE VISITS/INSPECTIONS May 24, 2007 March 8, 2004 Description Site visit was conducted by Padma Baru. Compliance inspection was conducted by Bob White. No major issues were found. ANNUAL EMISSIONS REPORTS/FEES Annual emission reports and fees for the facility are current through Actual emissions for the last 5 years are summarized below: Year PM SO 2 NO 2 CO NMVOC TOTAL (tons) (tons) (tons) (tons) (tons) (tons)

4 AFS #: Application #: FY : June 25, 2007 Page 4 of 5 CHANGES FROM PREVIOUS PERMIT 1. Emergency generator (which was installed in 2006) is added to Table Boiler #2 burns propane only. This is reflected in Table 1 of the new permit. 3. Boiler #1 was modified during 1990 s. This boiler was converted from 750 hp capacity to 800 hp. This was accomplished by changing the combustion air fan size and increasing the fuel-air mixture. This increased the heat input rate from 31.4 MMBtu/hr to 33.5 MMBtu/hr. This is a modification pursuant to 40 CFR and hence Boiler #1 is subject NSPS subpart Dc. Sea-3 has been submitting annual fuel reports to EPA. In the new permit, NSPS annual fuel reporting requirement was added for Boiler #1 also. REVIEW OF REGULATIONS State Regulations Env-A 300, AAQS - Applicable; Facility is in compliance. Env-A 600, Statewide Permit System Env-A (a) - Applicable to boilers & flare Env-A (d) - Applicable to EU03 Env-A (h) - Applicable to storage tanks Env-A (n) - Applicable to the facility [Sea-3 has a potential to emit NOx greater than 50 tpy. In 1995, facility proposed fuel limits to opt out of Title V. Please see application dated 11/22/95] Env-A 700, Permit Fee System - Applicable Env-A 806, Sulfur Content Testing for Fuels - Applicable Env-A 900, Owner/Operator Obligations - Applicable Env-A , VOC RACT for Fixed-roof VOL storage tanks - Not applicable to storage tanks because under normal operating conditions there are no VOC emissions from the tanks. Env-A 1211, NOx RACT - Not applicable because NOx emissions are limited to less than 50 tpy Env-A 1400, Regulated Toxic Air Pollutants - Applicable to Cooling towers; Facility is in compliance Sea-3 operates two conventional forced-draft cooling towers to cool water used in a cooling water system. Biogard 400 is a biocide that is added to the cooling water to control bacteria, fungi and algae growth in the cooling water system. Biogard 400 is essentially a 15% solution of glutaraldehyde (CAS# ) in water, with very small amounts of methanol (CAS # ) present. MacMillan & Donnelly, Inc. did Env-A 1400 compliance demonstration using de minimis method for methanol and adjusted in-stack concentration method for glutaraldehyde. Please see letter dated August 28, 2006 from MacMillan & Donnelly for detailed calculations. Potential emission rates used in calculations: Methanol E-05 lb/hr & 0.68 lbs/yr Glutaraldehyde E-03 lb/hr & lbs/yr Env-A 1600, Fuel Specifications - Applicable Env-A 2000, Fuel Burning Devices - Applicable Federal Regulations NSPS subpart Dc - Applicable for Boilers 1 & 2 NSPS subpart Kb - recordkeeping requirements of Section b are applicable to storage tank #2; Please note that VOC standards of Section b (i.e., requiring the installation of a floating roof and conducting periodic inspections) are not applicable to storage tank #2 because of the high vapor pressure under the storage conditions (LPG is stored at -40 o F. Vapor pressure at this temperature = 3.6 psig, i.e., kpa). Section b is applicable to a storage vessel with a design capacity greater than 151 m 3 (39,890 gal) and storing a VOL that has a maximum true vapor pressure greater than 5.2 kpa but less than 76.6 kpa.

5 AFS #: Application #: FY : June 25, 2007 Page 5 of 5 SUMMARY AND CONCLUSIONS In summary, the operations as applied for will be capable of meeting all regulations and standards for air quality. A state permit to operate has been drafted.