The following table summarizes the actual emissions from Perdue based on its Annual Emission Certification Reports:

Transcription

1

2 BACKGROUND Owner/Operator and Facility Information: Perdue Agribusiness LLC (Perdue) Zion Church Road Complex 6906 Zion Church Road Salisbury, Maryland Wicomico County, Maryland Air Quality Region VI Major Business Activities and Associated SIC/NAICS: Grain receiving, drying, cleaning, and storage SIC No Production of animal feeds SIC No Soybean preparation and soybean oil extraction using hexane SIC No Vegetable oil refining SIC No Types of Equipment: Equipment at the facility includes grain silos, vertical grain dryers, grain scalpers, cracking and dehulling equipment, hammermills, flaking rolls, meal dryers, solvent recovery equipment (e.g., evaporators, condensers), pellet mills, grain handling equipment, boilers, and emergency generators. Types of Raw Materials and Final Products Manufactured: Raw materials include corn, soybeans, and other grains and oilseeds, and crude vegetable oils. Products include feed for poultry houses, refined soybean oil and other vegetable oils. The following table summarizes the actual emissions from Perdue based on its Annual Emission Certification Reports: Table 1: Actual Emissions Year NO x (TPY) SO x (TPY) PM 10 (TPY) CO (TPY) VOC (TPY) Total HAP (TPY) < < Page 1 of 81

3 The major source thresholds for triggering Title V permitting requirements in Wicomico County are 50 tons per year for VOC, 100 tons for NOx, and 100 tons per year for any other criteria pollutants and 10 tons for a single HAP or 25 tons per year for total HAP. Since the actual VOC, HAP, and PM 10 and potential NOx emissions from the facility are greater than the major source thresholds for each pollutant, Perdue is required to obtain a Title V Part 70 Operating Permit under COMAR Perdue s current Title V Part 70 Operating Permit was issued on August 1, 2010 and expires on June 30, The renewal Title V Operating Permit will be issued to replace the current permit. The facility s Title V Part 70 Operating Permit renewal application was received by the Department on July 2, An administrative completeness review was conducted and the application was deemed administratively complete. An administrative completeness letter was sent on July 16, 2014 granting Perdue an application shield. GREENHOUSE GAS (GHG) EMISSIONS Perdue emits the following greenhouse gases (GHG) related to Clean Air Act requirements: carbon dioxide, methane, and nitrous oxide. These GHG originate from fuel burning equipment at Perdue. The facility has not triggered Prevention of Significant Deterioration (PSD) requirements for GHG emissions; therefore, there are no applicable GHG Clean Air Act requirements. While there may be no applicable requirements as a result of PSD, emission certification reports for the years 2011, 2012, and 2013 showed that Perdue is a minor source of GHG (major source threshold = 100,000 tpy CO 2 e). The Permittee shall quantify facility wide GHG emissions and report them in accordance with Section 3 of the Part 70 permit. The following table summarizes the actual emissions from Perdue based on its Annual Emission Certification Reports: Table 2: Greenhouse Gases Emissions Summary GHG Conversion factor 2011 tpy CO 2 e 2012 tpy CO 2 e 2013 tpy CO 2 e Carbon dioxide CO ,128 45,445 37,352 Methane CH Nitrous Oxide N 2 O Total GHG CO 2eq 42,379 46,015 37,580 Page 2 of 81

4 EMISSION UNIT IDENTIFICATION Perdue has identified the following emission units as being subject to Title V permitting requirements and having applicable requirements. Table 3: Emission Unit Identification Emissions Unit Number MDE/ARMA Registration Number Emissions Unit Name and Description Page 3 of 81 Date of Installation MAIN BOILER ROOM BR HP ( MMBtu/hr) Cleaver Brooks boiler 09/2008 (NSPS) fired with interruptible natural gas, No. 2 fuel oil and/or No. 6 fuel oil; Permittee No. 800A BR HP ( MMBtu/hr) Cleaver Brooks boiler 09/2008 (NSPS) fired with interruptible natural gas, No. 2 fuel oil and/or No. 6 fuel oil; Permittee No. 800B BR HP ( MMBtu/hr) Cleaver Brooks boiler 09/2008 (NSPS) fired with interruptible natural gas, No. 2 fuel oil and/or No. 6 fuel oil; Permittee No. 800C BR HP ( MMBtu/hr) Cleaver Brooks boiler 07/2015 (NSPS) fired with interruptible natural gas, No. 2 fuel oil and/or No. 6 fuel oil; Permittee No. 800D VEGETABLE OIL REFINERY OR HP (29 MMBtu/hr) Cleaver Brooks boiler fired 09/1985 with natural gas, No. 2 fuel oil, and/or No. 6 fuel oil OR Clay Transfer Silo controlled by a MAC 03/1985 Environmental Bag Filter OR Clay Storage Silo controlled by a MAC 09/1985 Environmental Bag Filter OR DeSmet Crude Vegetable Oil Deodorizing Unit 06/2011 OR Newpoint NUK 5.85 MMBtu/hr, high-pressure 06/2011 steam generator (HPSG) fired with natural gas or propane HATCHERIES HAT MMBtu/hr Laars hot water heater fired with 2006 natural gas, located at the facility s Hatchery No. 3 SOYBEAN PROCESSING PLANT SP Two (2) Cantrell Double Series Shakers, 11 01/1987 tons/hr each, (Cracking and Dehulling, Primary Tables 5 & 6), controlled by a MAC Environmental Baghouse SP Two (2) Cantrell Double Series Shakers, 11 01/1987 tons/hr each, (Cracking and Dehulling, Primary Tables 3 & 4), controlled by a MAC Environmental Baghouse

5 Emissions Unit Number MDE/ARMA Registration Number Emissions Unit Name and Description Date of Installation SP Two (2) Cantrell Double Series Shakers, 11 tons/hr each, (Cracking and Dehulling, Primary Tables 1 & 2), controlled by a MAC Environmental Baghouse SP Two (2) Champion/Roskamp Meal Grinders (20 X 44 Magnum Model Hammermills), and two (2) Sifters (60 X 30 Gyrosifters), 31.5 tons/hr input each, controlled by a MAC Environmental SP-5 (NSPS) Baghouse Rotex Model 536 Whole Bean Cleaner (Scalper), 89 tons/hr, and Storage Tanks controlled by a MAC Environmental Baghouse SP Six (6) Roskamp Flaking Rolls, 14.5 tons/hr each, controlled by a MAC Environmental High Efficiency Cyclone Collector SP Two (2) Fluidized Bed Separators for aspiration of Secondary Table, 15 tons/hr each, controlled by a MAC Environmental baghouse SP Two (2) Champion/Roskamp 20 X 40 Magnum Model Hammermill Hull Grinders controlled by a MAC Environmental baghouse SP French Industries Soybean Meal Dryer/Cooler, 67 tons/hr, controlled by three (3) Kice CK-90 cyclones (subject to CAM) SP-16 (MACT) Soybean Oil Extraction Process, controlled by condensers, and a French Oil Machinery Company mineral oil scrubber (final vent) SP Meal/Hull Loadout Area controlled by a Pneumafil baghouse (subject to CAM) SP Four (4) Roskamp P X 52 (two pair high) Cracking Mills controlled by a MAC Environmental 96 MWP baghouse SP Raw Dry Soybean Conveyances Controlled by one (1) Kice Baghouse. Page 4 of 81 01/ / / / / / / / / / /1987 baghouse installed 2015 FEEDMILL EQUIPMENT FM Bulk Ingredient Rail Dump Pit, 70 tons/hr, 01/1972 uncontrolled FM Bulk Ingredient Truck Dump Pit, 70 tons/hr, 01/1972 uncontrolled, small liquid loading only FM Champion HM44-48 Hammermill, 60 tons/hr, 05/2007 controlled by an Alanca Environmental 264LS baghouse FM Champion HM44-48 Hammermill, 60 tons/hr, 05/2007

6 Emissions Unit Number MDE/ARMA Registration Number Emissions Unit Name and Description Page 5 of 81 Date of Installation controlled by an Alanca Environmental 264LS baghouse (unconfined source) FM Three (3) Finished Feed Storage Silos, no controls 01/1964 FM DL Methionine Storage Tank controlled by an 01/1964 Alanca Environmental baghouse (subject to CAM) FM Pellet Mill Line No. 1 with three (3) Aircon 12/2005 cyclones, 70 tons/hr input FM Pellet Mill Line No. 2 with three (3) Aircon 01/1964 cyclones, 30 tons/hr input FM Pellet Mill Line No. 3 with two (2) MAC 01/1964 Environmental High Efficiency Cyclones, 20 tons/hr input FM Finished Feed Loadout, 70 tons/hr input, animal fat 01/1964 used as dust suppressant (unconfined source) FM Ingredient Mixer and Material Handling Equipment 01/1964 controlled by a MAC Environmental baghouse (subject to CAM) FM Ingredient Storage Bins/Silo controlled by bin vent 01/1964 filters FM Salt Storage Silo controlled by bin vent filters 01/1964 FM Meal Storage Silo controlled by bin vent filters 01/1964 GRAIN RECEIVING GS tons/hr Zimmerman Column Grain Dryer, fired 01/1975 with propane and/or natural gas, equipped with GS-2 (NSPS) GS-3 (NSPS) GS-4 (NSPS) GS-5 (NSPS) GS-6 (NSPS) GS-7 (NSPS) screens Two (2) Shanzer Column Grain Dryers (Nos. 4 & 5), tons/hr each, each fired with propane and/or natural gas, equipped with screens Marot Grain Cleaning Scalper for Dryers 4 & 5, controlled by a MAC Environmental 14MW-252 baghouse (BH-1) (subject to CAM) Two (2) Shanzer Column Grain Dryers (Nos. 2 & 3), tons/hr each, each fired with propane and/or natural gas, equipped with screens Marot Grain Cleaning Scalper for Dryers 2 & 3, controlled by a MAC Environmental 14MW-252 baghouse (BH-1) (subject to CAM) Two (2) Shanzer Column Grain Dryers (Nos. 6 & 7), tons/hr each, each fired with propane and/or natural gas, equipped with screens Marot Grain Cleaning Scalper for Dryers 6 & 7, controlled by a MAC Environmental 14MW-212 baghouse (BH-2) (subject to CAM) GS Grain Receiving Truck Pit No. 3 controlled by a MAC Environmental 14 MW-252 baghouse (BH-1) 08/1965 reconstructed 08/ / /1965 reconstructed 08/ / /1965 reconstructed 08/ /

7 Emissions Unit Number MDE/ARMA Registration Number Emissions Unit Name and Description (subject to CAM) Date of Installation GS Grain Receiving Truck Pit No. 4 controlled by a MAC Environmental 14 MW-252 baghouse (BH-1) (subject to CAM) GS Grain Receiving Truck Pit No. 2 controlled by a MAC Environmental 14 MW-212 baghouse (BH-2) (subject to CAM) GS Grain Receiving Truck Pit No. 1 controlled by a MAC Environmental 14 MW-212 baghouse (BH-2) (subject to CAM) GS-12 (NSPS) Grain Handling System comprising Bucket Elevators and Covered Belts with an Oil Spray System 01/1982 GS Grain Load Out Chute by Truck Dump Pit Nos. 1 08/1965 and 2 GS Grain Load Out Chute by Truck Dump Pit Nos. 3 08/1981 (NSPS) and 4 GS Grain Load Out Chute from Grain Tank No. 7 01/1995 (NSPS) GS-16 (NSPS) Grain Load Out Rail Chute 01/1995 INTERNAL COMBUSTION ENGINES (EMERGENCY GENERATORS) EG HP Emergency Generator fired with No. 2 fuel oil EG HP Emergency Generator fired with No. 2 fuel oil EG kW Portable Emergency Generator fired with No. 2 fuel oil EG kW 2007 Model Year KATOLIGHT (Model (NSPS) D600FRY4T2) diesel powered Emergency Generator (provides emergency power to facility s Main Boiler Room) APPLICABILITY OF FEDERAL REGULATIONS 06/ /1993 (rebuilt injectors in 2012) /2009 NSR Applicability None of Perdue s operations are subject to NSR approval. However, to preclude applicability of non-attainment NSR requirements, collective NOx emissions from four boilers in the Main Boiler Room (Emission Units BR-1, BR-2, BR-3, and BR-4) Page 6 of 81

8 are subject to a synthetic minor emissions limit of tons of NOx in all periods of 12 consecutive months. BR-2 was removed from the facility in 2015, so the limit now applies to BR-1, BR-3, and BR-4 only. PSD Applicability None of Perdue s operations are subject to PSD approval. NSPS Applicability 40 CFR 60, Subpart Dc (NSPS for Small Industrial-Commercial-Institutional Boilers) applies to each of the four boilers in the Main Boiler Room with a maximum rated heat input of 10 MMBtu/hr or greater and constructed, modified, or reconstructed after June 9, CFR 60, Subpart DD (NSPS for Grain Elevators) applies to the facility s column dryers and grain handling equipment constructed, modified, or reconstructed after August 3, CFR 60, Subpart IIII (NSPS for Stationary CI RICE) applies to the emergency generator installed in NESHAP/MACT Applicability Perdue is a major source of HAP emissions subject to the following NESHAP requirements for major sources: 40 CFR 63, Subpart GGGG (NESHAP for Solvent Extraction for Vegetable Oil Production) applies to the facility s soybean oil extraction processes. 40 CFR 63, Subpart ZZZZ (NESHAP for Stationary Reciprocating RICE) applies to all of the facility s emergency generators. 40 CFR 63, Subpart DDDDD (NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters at Major Sources) applies to the facility s boilers. CAM APPLICABILITY Compliance Assurance Monitoring (CAM), as specified in 40 CFR, Part 64, applies to any emission unit at a Title V major source that meets all of the following criteria: (1) The emission unit is subject to a federally enforceable emission limit or standard for a regulated pollutant; Page 7 of 81

9 (2) The emission unit uses a control device to achieve compliance with any such emission limitation or standard; and (3) The emission unit has the potential to emit pre-control device emissions of the applicable regulated air pollutant that are equal to or greater than 100 percent of the amount, in tons per year required for a source to be classified as a major source and must not otherwise be exempt from CAM. Compliance Assurance Monitoring (CAM) requirements, as promulgated under 40 CFR 64, apply to each of the following particulate air pollution control devices: 3 Kice cyclones associated with emissions unit SP-13, which is a 67 tons-perhour soybean meal dryer/cooler; 1 Pneumafil baghouse associated with emissions unit SP-18, which is a soybean meal/hull loadout area; 1 Alanca Environmental baghouse associated with emissions unit FM-8, which is a DL Methionine storage tank; 1 MAC Environmental baghouse associated with emissions unit FM-13, which comprises feed mill ingredient mixing and materials handling equipment; 1 MAC Environmental baghouse (BH-1) associated with emissions units GS-3 (a Marot grain cleaning scalper for dryers 4 & 5), GS-5 (a Marot grain cleaning scalper for dryers 2 & 3), GS-8 (grain receiving truck pit no. 3) and GS-9 (grain receiving truck pit no. 4). 1 MAC Environmental baghouse (BH-2) associated with emissions units GS-7 (a Marot grain cleaning scalper for dryers 6 & 7), GS-10 (grain receiving truck pit no. 2) and GS-11 (grain receiving truck pit no. 1). CAM requirements do not apply to HAP/VOC control devices associated with the facility's soybean oil extraction plant (SOEP) because the SOEP is subject to the major-source NESHAP rule promulgated under 40 CFR 63, Subpart GGGG for "Solvent Extraction for Vegetable Oil Production". Page 8 of 81

10 CHANGES SINCE THE ISSUANCE OF THE LAST PERMIT The following changes have occurred at the facility since the issuance of the last Title V Part 70 Operating Permit: Permit to Construct No issued on May 19, 2010 for modifications and upgrades to the facility s existing hexane recovery system associated with the SOEP. Permit to Construct No issued on December 15, 2010 for the installation of a temporary boiler. This boiler has been removed from the facility. Permit to Construct No and issued on June 21, 2011 for the installation of one (1) De Smet crude vegetable oil deodorizing unit and one (1) Newpoint NUK high-pressure steam generator (HPSG) with a rated heat input capacity of 5.85 MMBtu/hr to replace existing equipment. Permit to Construct No issued on February 15, 2013 for the installation of one (1) new desolventizing toaster to replace an existing unit in the SOEP. Permit to Construct Nos and issued in May 2015 for the installation of one (1) new natural gas fired (No. 2 or No. 6 fuel oil as back up) boiler (BR-5) in the Main Boiler Room and the installation of one (1) baghouse to control emissions from Raw Dry Soybean Conveyances (SP-20) in the Soybean Processing Plant. This boiler replaces BR-2 ( ) which has been removed from the facility. All boilers associated with the Research Farms (Emission Units RF-1 through RF-6, ARMA Registration Nos through ) have been removed from the facility. The boiler associated with the Vegetable Oil Refinery (Emission Unit OR-2, ARMA Registration No ) has been removed from the facility. Page 9 of 81

11 AN OVERVIEW OF THE PART 70 PERMIT The Fact Sheet is an informational document. If there are any discrepancies between the Fact Sheet and the Part 70 permit, the Part 70 permit is the enforceable document. Section I of the Part 70 Permit contains a brief description of the facility and an inventory list of the emissions units for which applicable requirements are identified in Section IV of the permit. Section II of the Part 70 Permit contains the general requirements that relate to administrative permit actions. This section includes the procedures for renewing, amending, reopening, and transferring permits, the relationship to permits to construct and approvals, and the general duty to provide information and to comply with all applicable requirements. Section III of the Part 70 Permit contains the general requirements for testing, record keeping and reporting; and requirements that affect the facility as a whole, such as open burning, air pollution episodes, particulate matter from construction and demolition activities, asbestos provisions, ozone depleting substance provisions, general conformity, and acid rain permit. This section includes the requirement to report excess emissions and deviations, to submit an annual emissions certification report and an annual compliance certification report, and results of sampling and testing. Section IV of the Part 70 Permit identifies the emissions standards, emissions limitations, operational limitations, and work practices applicable to each emissions unit located at the facility. For each standard, limitation, and work practice, the permit identifies the basis upon which the Permittee will demonstrate compliance. The basis will include testing, monitoring, record keeping, and reporting requirements. The demonstration may include one or more of these methods. Section V of the Part 70 Permit contains a list of insignificant activities. These activities emit very small quantities of regulated air pollutants and do not require a permit to construct or registration with the Department. For insignificant activities that are subject to a requirement under the Clean Air Act, the requirement is listed under the activity. Section VI of the Part 70 Permit contains State-only enforceable requirements. Section VI identifies requirements that are not based on the Clean Air Act, but solely on Maryland air pollution regulations. These requirements generally relate to the prevention of nuisances and implementation of Maryland's Air Toxics Program. Page 10 of 81

12 REGULATORY REVIEW/TECHNICAL REVIEW/COMPLIANCE METHODOLOGY Table IV 1 (General Provisions for Section IV) 1.0 General Provisions Within Plant Specific Requirements: This table provides generally applicable provisions with regard to requirements for observations for visible emissions, preparation of operations and maintenance plans, preparation of best management practice plans for unconfined sources, stack testing, record keeping and reporting. Provisions included in this table will be referenced in succeeding tables in this section when such provisions are applicable. Provisions in this table may also be superseded or modified by requirements in succeeding tables in this section. INDEX: 1.1 Observations For Visible Emissions 1.2 Operations and Maintenance Plans 1.3 Best Management Practices Plans For Unconfined Sources 1.4 Performance Test Protocols 1.5 Record Keeping and Reporting 1.1 Observations For Visible Emissions: Unless otherwise provided in the specific requirements for an affected emissions unit or emissions point, whenever the Permittee is required to perform an observation for visible emissions the following shall apply: (A) Each required observation of an emissions point shall be performed when the affected source of emissions is in operation. If the affected source of emissions does not operate within the period during which an observation would otherwise be required, the Permittee shall not be required to make an observation of the emissions point for that period. (B) If the Permittee is required to observe an emissions point that is common to more than one source of emissions, the Permittee shall make the required observation when at least one of the sources of emissions is in operation. If none of the affected sources of emissions operate within the period during which an observation would otherwise be required, the Permittee shall not be required to make an observation of the emissions point for that period. Page 11 of 81

13 Table IV 1 (General Provisions for Section IV) (C) Observations shall be performed during daylight hours unless the Permittee obtains from the Department written approval to conduct observations of properly lighted emissions points during non-daylight hours. (D) Excepting observations for visible emissions from exhaust stacks on fuel burning equipment, each required observation for visible emissions shall endure for at least one (1) minute unless a longer duration is specified in the Part 70 operating permit condition that requires the observation. Required observations for visible emissions from exhaust stacks on fuel burning equipment (e.g., boilers, thermal oil heaters) shall be performed in accordance with Method 9 and shall endure for at least 18 minutes unless a different duration is specified in the Part 70 permit condition that requires the observation. (E) The Permittee shall make a written or printable electronic record of each required observation for visible emissions, and each such record shall include identification of the observer, the date of the observation, the time at the start of the observation, the time at the end of the observation if the observation endures for more than 1 minute, and an account of the observer s findings during performance of the observation. [Authority: COMAR C] 1.2 Operations and Maintenance Plans: Unless otherwise provided in the specific requirements for an emissions unit or plant, whenever the Permittee is required to develop and implement an operations and maintenance (O&M) plan, the plan shall include at minimum: (A) Information that is sufficient to demonstrate that air emissions from each affected emissions unit can be expected to comply with all applicable standards and limits during periods of normal operation. Examples of types of information that could be included to support the required demonstrations would be design criteria, vendor specifications and performance guarantees, approved computer modeling studies, and results of testing programs in which approved test methods and procedures were utilized; Page 12 of 81

14 Table IV 1 (General Provisions for Section IV) (B) Procedures that provide for proper operation and maintenance (including preventive maintenance) of all affected emissions units and air pollution control equipment associated with the source; (C) Provisions for periodic monitoring of operating parameters and emissions as necessary to determine that affected emissions units and air pollution control equipment are functioning properly; (D) Provisions for periodic inspections, to be conducted at least as frequently as once per month, to determine whether responsible persons are complying with the provisions and procedures included in the required O&M plan; (E) Descriptions of procedures to be followed and corrective actions to be taken when inspections or monitoring information indicate that an emissions unit or pollution control device is not functioning properly; and (F) Provisions for developing written or printable electronic records that show whether prescribed operating, maintenance and monitoring procedures are consistently followed, and whether timely and appropriate corrective actions are taken when malfunctions occur. [Authority: COMAR C] 1.3 Best Management Practices Plans For Unconfined Sources: Unless otherwise provided in the specific requirements for an emissions unit, whenever the Permittee is required to develop and implement a best management practices (BMP) plan for control of particulate emissions from an unconfined source, such plan shall identify all reasonable precautions to be implemented to prevent particulate matter from becoming airborne. Such reasonable precautions shall include: (1) Housekeeping measures to minimize excess dust, including (a) using either an industrial vacuum system or manual sweeping to reduce the amount of dust; (b) at least once per month, removing dust from walls, ledges, and equipment using low pressure air or other means, and then sweeping or vacuuming the area; and (c) keeping exterior doors in the immediate affected areas shut except during normal ingress and Page 13 of 81

15 Table IV 1 (General Provisions for Section IV) egress, as practicable. (2) Maintaining and operating all process equipment in accordance with manufacturer's specifications and in a manner to minimize dust creation. (3) Storing raw materials in closed containers, as practicable. (4) Keeping mixers covered when mixing is occurring except when materials are added to the mixer. (5) For bulk loading processes where materials are loaded into trucks or railcars, lessen fugitive emissions by reducing the distance between the loadout spout and the vehicle being loaded by using a device of any kind at the bulk loadout spout that minimizes the distance to the vehicle being loaded, or using any other means to minimize the distance between the loadout spout and the vehicle being loaded. The BMP plan shall include provisions for periodic inspections, to be conducted at least once per month, to determine whether reasonable precautions identified in the plan are consistently employed. [Authority: COMAR C, COMAR C(1), and COMAR C] 1.4 Performance Test Protocols: (A) Unless otherwise provided in the specific requirements for an emissions unit or emissions point, when the Permittee is required to perform stack testing the Permittee shall submit to the Department for approval a stack test protocol that includes: (1) the purpose of the stack testing; (2) a testing schedule that provides the projected dates and times of testing; (3) an account of all test methods and procedures to be employed during the testing program; (4) for the emissions source or sources to be tested, an account of the operating conditions that will be extant during the testing program; Page 14 of 81

16 Table IV 1 (General Provisions for Section IV) (5) for fuel burning sources, identification of the types of fuels that will be burned during the testing periods; and (6) identification of operating data that will be collected during the testing periods. (B) The required stack test protocol shall be submitted at least 30 days prior to performance of any testing, and testing shall not be conducted before the Department provides approval of the protocol. (C) Results of all required stack tests shall be submitted to the Department in writing within 60 days of completion of the testing. [Authority: COMAR G] 1.5 Record Keeping and Reporting Requirements: (A) Unless otherwise provided in the specific requirements for an emissions unit or emissions point, the Permittee shall maintain at the facility for at least five (5) years, and shall make available to the Department upon request, all records that the Permittee is required by this Part 70 operating permit to establish. (B) Records required by this Part 70 operating permit shall be maintained in a format that is acceptable to the Department. A format adopted by the Permittee shall be considered acceptable until the Department provides the Permittee with written notice otherwise. (C) Unless otherwise specified in this Part 70 operating permit required records shall be maintained either in writing or in a printable electronic form. [Authority: COMAR C] Table IV 2 (Main Boiler Room) Emission Units BR-1, BR-3, BR-4 and BR-5 BR-1: 800-HP ( MMBtu/hr) Cleaver Brooks boiler fired with interruptible natural gas, No. 2 fuel oil and/or No. 6 fuel oil; Permittee No. 800A, installed in 2008, ARMA Registration No , subject to 40 CFR 60, Subpart Dc. Page 15 of 81

17 BR-3: 800-HP ( MMBtu/hr) Cleaver Brooks boiler fired with interruptible natural gas, No. 2 fuel oil and/or No. 6 fuel oil; Permittee No. 800B, installed in 2008, ARMA Registration No , subject to 40 CFR 60, Subpart Dc. BR-4: 800-HP ( MMBtu/hr) Cleaver Brooks boiler fired with interruptible natural gas, No. 2 fuel oil and/or No. 6 fuel oil; Permittee No. 800C, installed in 2008, ARMA Registration No , subject to 40 CFR 60, Subpart Dc. BR-5: 800-HP ( MMBtu/hr) Cleaver Brooks boiler fired with interruptible natural gas, No. 2 fuel oil and/or No. 6 fuel oil; Permittee No. 800D, installed in 2015, ARMA Registration No , subject to 40 CFR 60, Subpart Dc. Permitting History: None of the emissions units have undergone reconstruction or modification since initial construction. To preclude applicability of non-attainment NSR requirements, collective NO x emissions from BR-1, BR-3, and BR-4 are subject to a synthetic minor emissions limit of tons NO x in all periods of 12 consecutive months. The limit may in the future be adjusted for demand growth if the company submits to the Department an approvable demonstration that justifies such an adjustment. All of the emissions units are subject to 40 CFR 60, Subpart Dc (NSPS for Small Industrial-Commercial-Institutional Steam Generating Units). Each of the emissions units is subject to 40 CFR 63, Subpart DDDDD (NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters operated at facilities that are major sources of HAP). The final NESHAP rule was promulgated on January 31, Existing boilers (boilers constructed June 4, 2010 or earlier) must comply with the NESHAP no later than January 31, 2016, BR-5, a new boiler, must comply with the NESHAP upon startup. None of the emissions units are subject to Compliance Assurance Monitoring (CAM) requirements because none are equipped with an air pollution control device. Page 16 of 81

18 Applicable Standards and Limits: A. General Requirements Emissions units BR-1, BR-3, BR-4 and BR-5 shall burn only natural gas except during periods of gas curtailment or gas supply interruptions of any duration as defined in 40 CFR No. 2 and/or No. 6 fuel oil may be burned only during periods of gas curtailment or gas supply interruptions or for periodic testing of liquid fuel, maintenance, or operator training, not to exceed a combined total of 48 hours during any calendar year. [Authority: 40 CFR ] Compliance Demonstration and Rationale for Record Keeping and Reporting Requirements Only All four (4) boilers are considered natural gas boilers with respect to the boiler NESHAP, 40 CFR 63, Subpart DDDDD. To comply with the requirement the Permittee shall: maintain a copy of the interruptible natural gas service contract that the Permittee is required by the Part 70 operating permit to maintain with a utility company under the jurisdiction of the Maryland Public Service Commission; maintain records of all periods during which the Permittee's natural gas service was interrupted or curtailed; and maintain records of all fuels burned in the boilers during periods when natural gas was available, and records of all fuels burned in the boilers when natural gas service was interrupted or curtailed. The applicable requirement limits the types of fuels that may be burned and when the fuels may be burned in the emissions units. Records of utility contracts, periods of when natural gas was interrupted or curtailed, and fuel usage are sufficient to demonstrate compliance. The records must also be made available to the Department upon request for compliance review. B. Visible Emissions Limitations B1. The Permittee shall limit the opacity of exhaust gases to not more than 20 percent. Page 17 of 81

19 Exceptions: The opacity standard stated in this condition does not apply to emissions during load changing, soot blowing, start-up, or adjustments or occasional cleaning of control equipment if: (a) The visible emissions are not greater than 40 percent opacity; and (b) The visible emissions do not occur for more than 6 consecutive minutes in any sixty minute period. [Authority: COMAR A(1) and COMAR A(3)] B2. Except during periods of start up, shut down, or malfunction, when the Permittee is burning fuel oil in a boiler the Permittee shall operate the unit so that the opacity of any exhaust gases does not exceed 20 percent on a 6- minute average, except for one (1) 6-minute period per hour of not more than 27 percent. [Authority: 40 CFR 60.43c(c) and (d)] Compliance Demonstration For each of emissions units BR-1, BR-3, BR-4 and BR-5, the Permittee shall establish in writing, revise as necessary and implement an operations and maintenance (O&M) plan developed and implemented in accordance with Section 1.2 of Table IV-1 of this Part 70 operating permit. [Authority: COMAR C] The Permittee shall submit to the Department for approval a written sitespecific monitoring plan that includes procedures and criteria for establishing and monitoring specific parameters for the boilers indicative of compliance with the opacity standard. For testing performed as part of this site-specific monitoring plan, the Department may require as an alternative to the notification and reporting requirements specified in 40 CFR 60.8 and that the Permittee submit any deviations with the excess emissions report required under 40 CFR 60.48c(c). [Authority: 40 CFR 60.47c(f)(3)] Such site-specific monitoring plan may be included in the required O&M plan. Subpart Dc was amended in 2009, 2011, and 2012 to require a continuous opacity monitoring system (COMS) for oil-fired boilers rated at 30 MMBtu/hr or greater. In lieu of a COMS, for boilers that only burn oil containing no more than 0.5 weight percent sulfur, the Permittee may operate under an approved site-specific monitoring plan as specified 40 CFR 60.47c(f)(3). [Note: The site-specific monitoring plan requirement in 40 CFR 60.47c(f)(3) was originally listed in 40 CFR 60.47c(g) in the 2009 and 2011 amendments. In the 2009 and 2011 amendments, 40 CFR 60.47c(a) clearly states that sources operating under an approved site-specific monitoring plan allowed in 40 CFR 60.47c(g) meet the compliance demonstration requirements for Page 18 of 81

20 opacity in lieu of using a COMS or conducting prescribed periodic observations in 40 CFR 60.47c(a). When the requirement was moved to 40 CFR 60.47c(f)(3) in the 2012 amendments, 40 CFR 60.47c(a) was not amended to continue to exclude sources operating under an approved site-specific monitoring plan from prescribed periodic observations. As this appears to be a clerical error in the 2012 amendments, the requirement to conduct prescribed periodic observations under 40 CFR 60.47c(a) is not included in the permit. Rationale for Periodic Monitoring Strategy All of the boilers burn natural gas as a primary fuel with distillate or residual oil as a back up fuel only when natural gas is unavailable. All of the boilers are required to be operated and maintained in accordance with an O&M plan. Properly operated and maintained boilers will rarely cause visible emissions when burning natural gas or No. 2 fuel oil. The Permittee operates the boilers under an approved sitespecific monitoring plan specifically allowed by 40 CFR 60, Subpart Dc when burning oil for units not equipped with a COMS. No additional periodic monitoring is required. C. Control of Particulate C1. The Permittee shall not cause or permit particulate matter caused by the combustion of residual oil to be discharged into the atmosphere in excess of the amounts shown in Figure 2 of COMAR [Authority: COMAR A(2)] C2. Installations that burn oil with a sulfur content that does not exceed 0.5 percent by weight are not subject to the particulate emissions limit established in 40 CFR 60, Subpart Dc. [Authority: 40 CFR 60.43c(e)(4)] Compliance Demonstration and Rationale for Periodic Monitoring Strategy The Permittee is not required to conduct specific periodic monitoring to demonstrate compliance with the particulate emissions standard because compliance can be demonstrated through the use of emissions factors and permit limits. The maximum allowable sulfur content for any No. 6 fuel oil burned in emissions units BR-1, BR-3, BR-4 and BR-5 is not more than 0.5 percent by weight, and the AP-42 emissions factor for particulate from combustion of no. 6 fuel oil with a sulfur content of 0.5 weight percent is approximately 7.8 pounds of particulate per 1,000 gallons of No. 6 fuel oil burned. Assuming a heating value of 147,000 Btu/gal for No. 6 fuel oil, the AP-42 emissions factor converts to about Page 19 of 81

21 0.05 pounds particulate per million Btu heat input. For each of emissions units, the regulatory standard is about pounds per million Btu heat input. The maximum emissions rate predicted by the AP-42 emissions factor is appreciably less than that allowed by the standard. D. Control of Sulfur Oxides D1. The Permittee shall not burn, sell, or make available for sale any distillate fuel oil with a sulfur content in excess of 0.3 percent by weight. [Authority: COMAR A(1)(c)] Compliance with this requirement also provides compliance with the emissions standard for sulfur dioxide (SO 2 ) established under 40 CFR 60.42c for the boilers when the boilers are burning distillate fuel oil. Specifically, 40 CFR 60.42c(d) establishes that compliance with the SO 2 standard for affected units may be demonstrated by use of fuel oil with a sulfur content that does not exceed 0.5 percent by weight. D2. Unless the Permittee obtains from the Department written authorization otherwise, the Permittee shall limit the 30-day rolling average sulfur content of any No. 6 fuel oil burned in the boilers to not more than 0.5 percent by weight. Compliance with this requirement also provides compliance with the emissions standard for sulfur dioxide established under 40 CFR 60.42c for the boilers. Specifically, 40 CFR 60.42c(d) and (g) establish that compliance with the standard for affected units shall be demonstrated by use of fuel oil with a sulfur content that does not exceed 0.5 percent by weight on a 30-day rolling average basis. Compliance with requirement D2 of this Section also provides compliance with COMAR A(1)(b), which prohibits burning or selling any residual fuel oil with a sulfur content in excess of 2.0 percent by weight. D3. The fuel oil sulfur limits imposed by this Part 70 permit apply at all times, including periods of startup, shutdown and malfunction. [Authority: 40 CFR 60.42(i); and Permit to Construct Nos , , and issued as one document 09/12/2008] Compliance Demonstration For any No. 2 fuel oil fired in the boilers, the performance test to determine compliance status with regard to the applicable SO 2 standard shall consist of the certification from the fuel supplier, as described in 40 CFR 60.48c(f)(1). [Authority: 40 CFR 60.44c(h)] For any No. 6 fuel oil fired in the boilers, the initial performance test to determine compliance status with regard to the applicable SO 2 standard shall Page 20 of 81

22 consist of sampling and analyzing the oil in the initial tank of oil to be fired in the NSPS boilers to demonstrate that the oil contains not more than 0.5 weight percent sulfur. Thereafter, the Permittee shall sample the oil in the fuel tank after each new shipment of oil is received, as described under 40 CFR 60.46c(d)(2), which establishes that oil samples may be collected from the fuel tank for each boiler after the fuel tank is filled and before any oil is combusted. The Permittee shall analyze the oil sample to determine the sulfur content of the oil. If a partially empty fuel tank is refilled, a new sample and analysis of the fuel in the tank would be required upon filling. Results of the fuel analysis taken after each new shipment of oil is received shall be used as the daily value when calculating the 30-day rolling average until the next shipment is received. If the fuel analysis shows that the sulfur content in the fuel tank is greater than 0.5 weight percent sulfur, the Permittee shall ensure that the sulfur content of subsequent oil shipments is low enough to cause the 30-day rolling average sulfur content to be 0.5 weight percent sulfur or less. [Authority: 40 CFR 60.44c(g) and 60.46c(d)(2)] Rationale for Periodic Monitoring Strategy 40 CFR 60, Subpart Dc requires fuel supplier certification for No. 2 fuel oil and oil sampling for No. 6 fuel oil to demonstrate compliance with the applicable sulfur content standard. Certifications and sampling of sulfur content are sufficient to demonstrate compliance with the applicable sulfur content limits. E. Control of Nitrogen Oxides E1. To preclude applicability of federal non-attainment NSR requirements the Permittee shall limit the combined total emissions of nitrogen oxides (NO x ) from emissions units BR-1, BR-3 and BR-4 to not more than tons in all periods of 12 consecutive months unless the Permittee demonstrates to the satisfaction of the Department that a different NSR applicability threshold is appropriate. If and when such demonstration is approved by the Department the more appropriate NSR applicability threshold shall become the enforceable NO x emissions limit in this Part 70 permit. [Authority: Permits to Construct Nos , , and issued as one document 09/12/2008] Compliance Demonstration Page 21 of 81

23 Within 30 days of the end of each calendar month the Permittee is required to determine for the month, and for the most recent period of 12 consecutive months, the combined total emissions of NO x from emissions units BR-1, BR-3 and BR-4. If for any period of 12 consecutive months such combined total emissions of NO x exceeds the NSR applicability threshold specified pursuant to condition E1 of Section 2.1 of Table IV-2 of the Part 70 permit, the Permittee is required to provide written notification of the emissions to the Department within 15 days of determination. The Permittee is required to conduct stack tests for NO x on each of the emissions units and to base determinations of monthly and 12-monthly NO x emissions on the most recent stack test results. The Permittee is also required to maintain records of all required determinations of NO x emissions, including all methods of calculations, all data used and all assumptions made. Rationale for Periodic Monitoring Strategy Monthly determinations of emissions of NO x and periodic stack testing to confirm the bases for the determinations are sufficient monitoring strategies to demonstrate compliance with the applicable NO x emissions limit. E2. For each of emissions units BR-1, BR-3, BR-4 and BR-5, each of which is a fuel burning unit with a rated heat input capacity less than 100 million Btu per hour, the Permittee is required to: submit to the Department an identification of the emissions unit, the rated heat input capacity of the emissions unit, and the type of fuel burned in the emissions unit. This notification is necessary only if the required information differs from that included in the application for renewal of the Permittee's Part 70 permit. [Authority: COMAR E(1)] perform a combustion analysis on the emissions unit at least once per year and optimize combustion based on the analysis. [Authority: COMAR E(2)] once every 3 years, require each operator of the emissions units to attend training programs on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors. [Authority: COMAR E(4)] Page 22 of 81

24 Compliance Demonstration and Rationale for Periodic Monitoring Strategy The Permittee is required to maintain for at least 5 years, and to make available to the Department upon request, records of all combustion analyses and of required training program attendance. COMAR outlines the methods for demonstrating compliance with the requirements. No additional monitoring is required. F. Control of HAP F1. The Permittee shall operate BR-1, BR-3, and BR-4 such that the concentration of carbon monoxide (CO) in the exhaust gases from each unit does not exceed 400 parts per million by volume (ppmv) when the volume is adjusted to 3 percent oxygen on a dry basis. [Authority: Permit to Construct Nos , , and issued as one document 09/12/2008] Compliance Demonstration and Rationale for Periodic Monitoring Strategy To demonstrate compliance with the applicable CO emissions standard, the Permittee shall conduct performance tests to determine CO emissions from the boilers. The performance tests will verify that CO emissions meet the applicable CO emissions standard for the boilers. F2. No later than January 31, 2016 for BR-1, BR-3, and BR-4 and upon startup for BR-5, the Permittee shall comply with the work practice requirements of 40 CFR 63, Subpart DDDDD. [Authority: 40 CFR (b)] Compliance Demonstration and Rationale for Periodic Monitoring Strategy To comply with the requirements of 40 CFR 63, Subpart DDDDD for boilers greater than 10 MMBtu/hr that burn natural gas (and fuel oil only as a back up during gas curtailment or supply interruption), the Permittee must conduct a one-time energy assessment for the existing boilers, BR-1, BR-3, and BR-4, and initial and subsequent tune-ups of all boilers (existing and new). The Permittee must conduct the assessment and tune-ups using the procedures prescribed in Subpart DDDDD and submit initial and subsequent annual reports. The Permittee must also keep records of when gas supply is curtailed or interrupted and when alternative fuels are used. Subpart DDDDD outlines all of the specific initial and continuous compliance demonstration requirements for the assessment and tune-ups. No additional periodic monitoring is required. Page 23 of 81

25 Table IV 3 (Other Fuel Burning Equipment) Emissions Units OR-1, OR-9, and HAT-1 OR-1: 700-horsepower (29-MMBtu/hr) Cleaver Brooks boiler fired with natural gas, with No. 2 and/or no. 6 fuel oil as back up, installed in 1985, located at the facility's Vegetable Oil Refinery, ARMA Registration No OR-9: Newpoint NUK 5.85 MMBtu/hr, high-pressure steam generator (HPSG) fired with natural gas or propane, installed in 2011, located at the facility s Vegetable Oil Refinery, ARMA Registration No HAT-1: 1.99-MMBtu/hr Laars hot water heater fired with natural gas, installed in 2006, located at the facility s Hatchery No. 3, ARMA Registration No Permitting History: None of the emissions units have undergone reconstruction or modification since initial construction. None of the emissions units are subject to nonattainment NSR requirements, PSD requirements, or to a synthetic minor limit. None of the emissions units are subject to 40 CFR 60, Subpart Dc (NSPS for Small Industrial-Commercial-Institutional Steam Generating Units). Each unit was installed before the June 9, 1989 applicability date of the subpart or is less than the 10 MMBtu/hr applicability threshold of the subpart. OR-1 and OR-9 are subject to 40 CFR 63, Subpart DDDDD (NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters operated at facilities that are major sources of HAP). The final NESHAP rule was promulgated on January 31, Existing boilers (boilers constructed June 4, 2010 or earlier) must comply with the NESHAP no later than January 31, HAT-1 is a hot water heater and is exempt from Subpart DDDDD. None of the emissions units are subject to Compliance Assurance Monitoring (CAM) requirements because none are equipped with an air pollution control device. Page 24 of 81

26 Applicable Standards and Limits: A. General Requirements A1. Emissions unit OR-1 shall burn only natural gas except during periods of gas curtailment or gas supply interruptions of any duration as defined in 40 CFR No. 2 and/or No. 6 fuel oil may be burned only during periods of gas curtailment or gas supply interruptions or for periodic testing of liquid fuel, maintenance, or operator training, not to exceed a combined total of 48 hours during any calendar year. [Authority: 40 CFR ] A2. Emissions units OR-9 and HAT-1 shall burn only natural gas or propane unless the Permittee obtains an approval from the Department to burn alternate fuels. [Authority: COMAR A] Compliance Demonstration and Rationale for Record Keeping and Reporting Requirements Only To demonstrate compliance with the fuel use limits, the Permittee shall: maintain a copy of the interruptible natural gas service contract for emissions unit OR-1 that the Permittee is required by the Part 70 operating permit to maintain with a utility company under the jurisdiction of the Maryland Public Service Commission; maintain records of all periods during which the Permittee's natural gas service was interrupted or curtailed; and maintain records of all fuels burned in emissions unit OR-1 during periods when natural gas was available, and records of all fuels burned in emissions unit OR-1 when natural gas service was interrupted or curtailed. The applicable requirement limits the types of fuels that may be burned and when the fuels may be burned in the emissions units. OR-9 and HAT-1 are equipped to burn natural gas or propane only. Records of utility contracts, periods of when natural gas was interrupted or curtailed, and fuel usage are sufficient to demonstrate compliance. The records must also be made available to the Department upon request for compliance review. Page 25 of 81