PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK 201 BEASLEY DRIVE, FREDERICK, MD PART 70 PERMIT NO.

Transcription

1

2 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO BACKGROUND Fort Detrick is a Federal military installation located within the city limits of Frederick, Maryland in Frederick County. The military installation is comprised of the following four noncontiguous parcels: Main Post (728 acres); Area B, including the FLAIR Armory (399 acres); Water Treatment Plant (7 acres); and Sewage Treatment Plant (9 acres). Frederick County is located in emission control Area II (in fact Area II is comprised only of Frederick County). Only the Main Post is subject to Part 70 permitting. Fort Detrick houses several medical research laboratories and a worldwide communications area and satellite dishes for satellite tracking. Consequently, the facility s equipment list includes steam generating boilers, space heating boilers, several incinerators, and emergency generators. The SIC code for the facility is The following table summarizes the actual emissions from Fort Detrick based on its Annual Emission Certification Reports: Table 1: Actual Emissions Calendar Year NO x (TPY) SO x (TPY) PM 10 (TPY) CO (TPY) VOC (TPY) Total HAP (TPY) < < < < 2 The major source threshold for triggering Title V permitting requirements in Frederick County is 25 tons per year for VOCs or NOx, 100 tons per year for any other criteria pollutant, 10 tons per year of any single hazardous air pollutant (HAP) or 25 tons per year of any combination of HAPs. Since actual emissions of NOx is greater than the major source thresholds of 25 tons per year, Fort Detrick is required to obtain a Title V Part 70 Operating Permit. The initial Part 70 permit was issued on April 1, A subsequent renewal Part 70 permit was issued on November 1, 2009 covering the period from April 1, 2009 through March 31, The Part 70 permit renewal application for Fort Detrick was received by the Department on June 6, An administrative completeness review was conducted and the application was deemed to be timely and administratively complete. The facility is operating under an application shield. New Construction Since the prior Part 70 permit was issued, Fort Detrick has added one small (1.4 million Btu/hr) gas-fired boiler and four emergency diesel generators. A Permit to Construct was issued on August 12, 2014 to replace two 3.35 million Btu/hr No 2 oil fired boilers with two 3.35 million Btu/hr dual-fired natural gas/no.2 oil fired boilers. A Permit to Construct for the additional control equipment required to bring the two hospital-medical-infectious waste incinerators Page 1 of 108

3 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO (HMIWI) into compliance with the October 6, 2009 Federal emission standards was issued on May 1, The construction was required to be completed and be operational no later than October 6, Two small natural gas fired boilers, A10 and A13, rated at 1.5 and 2.5 million Btu/hr were removed from service during the term of the previous permit. Two small No.2 oil-fired boilers, A6 and A7, rated at 3.35 million Btu/hr were removed in September 2013 and replaced with two boilers also rated 3.35 million Btu/hr but firing both natural gas and No. 2 oil. As of March 31, 2015 two large boilers, A4 and A5 which are rated at 98 million Btu/hr were permanently shut down. Applicable NSPS and MACTs Several of the boilers are subject to Federal New Source Performance Standards (NSPS) under 40 CFR part 60, subpart Dc and the Area Source NESHAP for Industrial, Commercial, and Institutional Boilers 40 CFR part 63, subpart JJJJJJ. There are two large hospital-medicalinfectious waste incinerators (HMIWI) and two small municipal waste combustors at the facility, which were constructed prior to the effective date for the NSPS 40 CFR part 60 subpart Ec and 40 CFR part 60 subpart AAAA. However, the installations are subject to Federal Emission Guidelines (EG) 40 CFR part 60 subpart Ce and the Federal Implementation Plans 40 CFR part 62 subpart HHH for HMIWI and 40 CFR part 62 subpart JJJ for small Municipal Waste Combustion units. The requirements of subpart JJJ have been incorporated into Maryland s Air Quality regulations. Additionally, there are 16 emergency diesel generators subject to either the NSPS 40 CFR part 60 subpart IIII or the NESHAP 40 CFR part 63 subpart ZZZZ. There is a gasoline dispensing facility with two 12,000 gallon underground storage tanks subject to the NESHAP 40 CFR part 63 subpart CCCCCC. Compliance Assurance Monitoring (40 CFR Part 64) The U.S. Army Garrison at Fort Detrick is exempt from CAM plan requirements since no individual installation with an add-on control device is a major source of any regulated pollutant before control. GREENHOUSE GAS (GHG) EMISSIONS Fort Detrick emits the following greenhouse gases (GHGs) related to Clean Air Act requirements: carbon dioxide, methane, and nitrous oxide. These GHGs originate from various processes, i.e., steam heating plants, incinerators, and internal combustion engines contained within the facility premises applicable to Fort Detrick. 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, Fort Detrick is a potential major source of GHG emissions (threshold: 100,000 tpy CO 2 e) for GHGs. The Permittee must quantify facility-wide GHG emissions and report them in accordance with Section 3 of the Part 70 permit. Page 2 of 108

4 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO The following table summarizes the actual emissions from Fort Detrick based on its Annual Emission Certification Reports: Table 2: Greenhouse Gases Emissions Summary GHG Conversion factor 2008 tpy CO 2 e 2009 tpy CO 2 e 2010 tpy CO 2 e 2011 tpy CO 2 e 2012 tpy CO 2 e Carbon dioxide CO ,400 33,400 25,800 28,113 26,900 Methane CH Nitrous Oxide N 2 O Total GHG CO 2eq 44,666 33,594 25,952 28,270 27,054 EMISSION UNIT IDENTIFICATION Fort Detrick has identified the following emission units as being subject to Title V permitting requirements and having applicable requirements: Table 3: Emission Unit Identification MDE Registration Number and and and and Emissions Unit Number A1 and A2 Boiler A1-1 and A2-1 Emissions Unit Name Boiler A8 and A9 Boiler A8-1 and A9-1 Boiler A11 Boiler and A12 A14 and A17 Boiler Boilers Emission Unit Description Two (2) Cleaver Brooks Model DL76E natural gas-fired boilers, each rated at 77 MMBtu/hr, located in Bldg Two (2) Cleaver Brooks Model DL766 natural gas-fired boilers, each rated at 77 MMBtu/hr, located in Bldg Two (2) Burnham Model 4F-450 No.2 fuel oilfired boilers, each rated at 3.35 MMBtu/hr, located in Bldg Two (2) Burnham dual natural gas/no.2 fuel oil-fired boilers, each rated at 3.35 MMBtu/hr, located in Bldg One (1) H.B. Smith Co. Inc. Model 28A-6 natural gas-fired boiler, rated at MMBtu/hr, located in Bldg One (1) Reznor RDF3-280 natural gas-fired boiler, rated at 1.75 MMBtu/hr, located in Bldg Two (2) H.B. Smith Co. Inc. Model 28A-9 natural gas-fired boilers, rated at MMBtu/hr, located in Bldg Date of Installation 06/13/90 11/ /88 and 12/92 09/ /79 12/10/96 6/30/98 Page 3 of 108

5 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO MDE Registration Number Emissions Unit Number Emissions Unit Name Emission Unit Description Date of Installation and and and and A15 A16 Boiler Boiler A20-1 Boiler A21 A23 A24 and A25 A26 and A27 A28 Boiler Boiler Boiler Boiler Boiler B5 and B6 Incinerator B1 and B4 Incinerator One (1) Peerless Model #G-LC-09-WUP natural gas-fired boiler, rated at MMBtu/hr, located in Bldg One (1) H.B. Smith Co. Inc. Model 28A-7 natural gas-fired boiler, rated at MMBtu/hr, located at Bldg One (1) PVI Industries Model 3000P natural gas fired boiler, rated at 2.4 MMBtu/hr located at Bldg One (1) Weil-McLain Model 1088 natural gasfired boiler, rated at MMBtu/hr Bldg One (1) Raypak Model # P-1223 natural gas fired boiler rated at million Btu/hr, located at Bldg Two (2) Bryan Model CLN-270-W natural gas fired boilers rated at 2.7 million Btu/hr, located at Bldg. 693 Two (2) Weil-McLain Mdl 980 natural gas fired boilers rated at 1.23 million Btu/hr, located at Bldgs and 1546 One (1) Fulton Model PHW-1400 natural gasfired boiler rated at 1.4 million Btu/hr, located in Bldg Two (2) hospital, medical, and infectious waste incinerators (HMIWI) each rated at 1,000 lbs/hr and each equipped with an emissions control system and a waste heat recovery boiler, located in Bldg Two (2) small municipal waste combustion units, ECP Model 2500T, each rated at 39 ton/day and each equipped with an emissions control system and a waste heat recovery boiler, located in Bldg /29/98 1/19/ /05/ / / / / /3/ /6/ and C1 and C2 Emergency Diesel Generators Two (2) 993 kw No.2 oil -fired generators, Alban and Caterpillar, located in Bldg / (registered as a group, 4 each) C3 thru C6 Emergency Diesel Generators Four (4) 2,000 kw No. 2 oil fired generators, Williams and Lane, located in Bldg /1985 to 09/1987 Page 4 of 108

6 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO MDE Registration Number Emissions Unit Number C7 C8 C9 C10 C11 C12 C13 C14 C15 C F1 Emissions Unit Name Emergency Diesel Generator Emergency Diesel Generator Emergency Diesel Generator Emergency Diesel Generator Emergency Diesel Generator Emergency Diesel Generator Emergency Diesel Generator Emergency Diesel Generator Emergency Diesel Generator Emergency Diesel Generator Gasoline Storage tanks Emission Unit Description One (1) 900 kw No. 2 oil-fired generator, Caterpillar, located in Bldg One (1) 880 kw No. 2 oil-fired generator, Caterpillar Model 3508, located in Bldg Date of Installation 05/ /2001 One 1,502 BHP (1000 kw) No. 2 oil-fired Caterpillar Model 3508 generator located in 09/2004 Bldg One 2,876 BHP (2000 kw) No. 2 oil -fired generator, Caterpillar Model 3516/SR4B 09/2004 generator located in Bldg One 600 kw Kohler Model 600REOZv located in Bldg /2011 One 764 BHP (570 kw) No.2 oil-fired generator, Caterpillar Model 3456 located at 06/2006 Bldg. 190 (boiler plant) One 685 BHP (511 kw) No. 2 oil-fired Perkins Model CV12TA-RG3 located at Bldg /1988 One 1000 kw Kohler Model 1000REOZMB located in Bldg /2011 One 2000 kw Caterpillar Model SR45/3516C located in Bldg /2012 One 500 kw Kohler Model 500REOZJ located in Bldg /2012 Two (2) 12,000 gallon underground storage tanks, using Stage I vapor recovery systems, fuel feed to 6 dispensers which use Stage II vapor recovery systems. 06/2004 Page 5 of 108

7 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO 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 6 of 108

8 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO REGULATORY REVIEW/TECHNICAL REVIEW/COMPLIANCE METHODOLOGY 1. EMISSION UNITS A1 and A2: Two (2) Cleaver Brooks Model DL76E natural gasfired boilers, each rated at 77 MMBtu/hr. These steam boilers are located in Building 190 and provide space heating, hot water, and process steam for most of the buildings at Fort Detrick. These boilers replaced existing boilers. No control equipment is currently used on these units. The Permittee was issued a minor new source review construction permit in June Therefore, 40 CFR Part 60 Subpart Dc, Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units, is applicable to these boilers. APPLICABLE STANDARDS and LIMITATIONS Visible Emissions Limitations COMAR A(1), which prohibits the discharge of emissions from any fuel-burning equipment in Area II, other than water in uncombined form, greater than 20 percent opacity except as allowed under COMAR A(3), and 40 CFR 60.43c(d) which limits visible emissions to 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity. Compliance Demonstration - When the facility combusted No. 6 fuel oil it was subject to an opacity CEMS requirement under the NSPS 40 CFR part 60 subpart Dc, 60.47c(a). Since the planned operation with residual oil was limited, the EPA approved an alternative monitoring approach for these boilers in accordance with 40 CFR 60.8(b)(3) 1 However, as of March 31, 2015, these boilers no longer combust any fuel oil and continuous opacity monitoring or the EPA alternative monitoring to be conducted while combusting No. 6 fuel oil is no longer required. These boilers now have an uninterruptible supply of natural gas and combust natural gas exclusively. The Permittee must operate and maintain the boiler in a manner to prevent the visible emissions by maintaining an Operations Manual and Preventive Maintenance Plan and monitoring in accordance with the Operations Manual and Preventative Maintenance Plan. The Permittee must maintain a log of all maintenance performed that relates to combustion performance. The Permittee must keep records of the date and time of visible emissions observations, along with the results of each observation and. must report incidents of visible emissions in accordance with permit condition 4 of Section III, Plant Wide Conditions, "Report of Excess Emissions and Deviations." The basis for these monitoring, record keeping, and 1 letter dated 25 May 2004, from Judith M. Katz, Director, Air Protection Division, USEPA to Robert P. Craig, Chief, Environmental Management Office, U.S. Army Garrison at Fort Detrick. Page 7 of 108

9 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO reporting requirements is the Department's authority to create periodic monitoring requirements, COMAR C(3). Control of Particulate Matter COMAR A(2), which states that a person may not cause or permit particulate matter caused by the combustion of solid fuel or residual oil in any fuel burning equipment erected on or after January 17, 1972 to be discharged into the atmosphere in excess of the amounts in Figure 2. This regulation no longer applies since the boilers ceased burning any fuel oil after March 31, 2015 and are now limited to combusting natural gas exclusively. There are no particulate matter emission limitations on boilers combusting only natural gas. Control of Sulfur Oxides COMAR A(1)(b) Control of Sulfur Oxides from fuel burning equipment. A person may not burn, sell, or make available for sale any fuel with a sulfur content by weight in excess of or which otherwise exceeds the following limitations: in Areas I, II, V, and VI, for residual fuel oils, 2 percent. 40 CFR 60.42c(d) which limits the discharge of sulfur dioxide from the combustion of fuel oil to not more than 0.50 lb/million Btu or 0.5 percent by weight. These boilers ceased combusting fuel oil after March 31, 2016 and are now limited to combusting natural gas exclusively. There are no sulfur oxides emission limitations on boilers combusting only natural gas. Control of Nitrogen Oxides Emissions Permit condition 4.1a.2 D provides that the Permittee must comply with one of the following NOx RACT: COMAR F(1) states that a person who owns or operates a space heater as defined in Regulation.01B of this chapter shall do the following: (a) Submit to the Department a list of each affected installation on the premises and the types of fuel used in each installation; (b) Develop an operating and maintenance plan to minimize NO x emissions based on the recommendations of equipment vendors and other information including the source s operating and maintenance experience; (c) Implement the operating and maintenance plan and maintain the plan at the premises for review upon request by the Department; Page 8 of 108

10 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO (d) Require installation operators to attend in-state operator training programs once every 3 years on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and (e) Prepare and maintain a record of training program attendance for each operator at the site, and make these records available to the Department upon request. COMAR F(2) requires that a person who owns or operates an installation that no longer qualifies as a space heater shall inform the Department no later than 60 days after the date when the fuel burning equipment did not qualify, and shall meet the applicable fuelburning equipment RACT requirement in this regulation. COMAR E which states that for fuel-burning equipment with a rated heat input capacity of 100 MMBtu per hour or less, the Permittee shall do the following: (1) Submit to the Department an identification of each affected installation, the rated heat input capacity of each installation, and the type of fuel burned in each; (2) Perform a combustion analysis for each installation at least once each calendar quarter and optimize combustion based on the analysis; (3) Maintain the results of the combustion analysis and stack tests at the site for at least 2 years and make this data available to the Department and EPA upon request; (4) Once every three years, require each operator of the installation to attend operator training programs on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and (5) Prepare and maintain a record of training program attendance for each operator at the site, and make these records available to the Department upon request. Compliance Demonstration with COMAR F. The Permittee must develop and implement the operating and maintenance plan and maintain the plan at the premises for review upon request by the Department. The Permittee must maintain: (a) The operating and maintenance plan at the premises for review by the Department upon request. (b) Records of the quantity of fuel burned each month and calculation of heat input in a manner that the Permittee can determine whether the boiler no longer qualifies as a Space Heater. (c) Records of the training program attendance for each operator at the site. [Authority: COMAR F(1)]. The Permittee must inform the Department no later than 60 days after the date when the boilers no longer qualify as a space heater, and must meet the requirements under COMAR E or identify an alternative NOx RACT requirement under COMAR with which the source will comply. The Permittee shall submit a list of trained operators and training attendance records to the Department upon request. [Authority: COMAR F(2)]. Page 9 of 108

11 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO Rationale The boilers typically operate in manner that meets the definition for a space heater. COMAR B(7) defines "Space heater" as fuel-burning equipment that consumes more than 60 percent of its annual fuel during the period from October 31 of one year through March 31 of the following year. For the purpose of this regulation, annual fuel use is the total fuel consumed during the period October 1 of one year to September 30 of the following year, beginning October 1, When operating as a Space Heater, the Permittee must comply with the NOx RACT requirements of COMAR F. If the operations change so that the boilers do not quality as a Space Heater, the Permittee must comply with the NOx RACT requirements of COMAR E, Requirements for Fuel-burning Equipment with a Rated Heat Input of 100 MMBtu per Hour or Less at the time a boiler no longer operates as a Space Heater. The Permittee shall continue to comply with the NOx RACT for Fuel-burning equipment with a rated heat input of 100 MMBtu per hour or less until the boiler operates for one heating season as a Space Heater. After successfully operating as a space heater for a heating season (Oct 1 to Sept 30), the Permittee may return to complying with the requirements for a Space Heater. Compliance Demonstration with COMAR E. The Permittee must perform a combustion analysis for each installation not qualifying as a space heater at least once each year and optimize combustion based on the analysis. The Permittee must maintain the results of the annual combustion analysis and stack tests at the site and maintain a record of training program attendance for each operator. The Permittee must make the results of the combustion analyses and stack tests available to the Department and EPA upon request. The Permittee must submit a list of trained operators and training attendance records to the Department upon request [Authority: COMAR E]. Operational Limitations Permit Condition C after March 31, 2015, requires the Permittee to combust only natural gas unless the Permittee receives a permit or approval from the Department [Authority: COMAR A]. Note: Previous permit condition E, which limited the annual capacity factor for Number 6 fuel oil of no more than 10 percent in any calendar year [Ref: Letter dated 25 May 2004, from Judith M. Katz, Director, Air Protection Division, USEPA; to Robert P. Craig, Chief, Environmental Management Office, U.S. Army Garrison at Fort Detrick], is now considered obsolete and was not included in the current permit. Exemption from Boiler NESHAP requirements: Since the boilers, as of March 31, 2015 no longer combust any fuel oil and combust only natural gas, the boilers are exempt from the NESHAP requirements in accordance with (e). Page 10 of 108

12 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO Compliance Demonstration Permit condition C requires the Permittee to retain monthly fuel records of each boiler [Authority: COMAR C(3)]. Permit condition C requires the Permittee to submit an annual emissions certification report (permit condition 8 of Section III, Plant Wide Conditions "Emissions Certification Report). The annual certification report must contain the type, quantities, and analyses of all fuels burned. No additional requirements are needed to show compliance with this operational limitation [Authority: C(2)]. 2. EMISSION UNIT A1-1 and A2-1: Two (2) Cleaver Brooks (Model DL766) natural gasfired boilers, each rated at 77 MMBtu/hr. located in Bldg These steam boilers provide space heating, hot water, and process steam for most of the buildings at Fort Detrick. The boilers replaced an existing 165 MMBtu/hr boiler. No add-on control equipment was used on these units. The Permittee was issued a minor new source review construction permit on May 20, 2003, Permit to Construct & -0268N. Therefore, 40 CFR Part 60 Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, is applicable to these boilers. Permit to Construct & -0268N required the Permittee to remove or render inoperative the existing Erie City Iron Works 165 MM/Btu per hour boiler within 180 days of the initial operation of these two Cleaver Brooks boilers in order to avoid New Source Review requirements for NOx. This requirement was satisfied. APPLICABLE STANDARDS and LIMITATIONS Visible Emissions Limitations COMAR A(1), which prohibits the discharge of emissions from any fuel-burning equipment in Area II, other than water in uncombined form, greater than 20 percent opacity except as allowed under COMAR A(3), and 40 CFR 60.43c(d) which limits visible emissions to 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity. Page 11 of 108

13 Compliance Demonstration PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO The Permittee must to demonstrate compliance with the opacity standard when the boilers are burning natural gas by maintaining an Operations Manual and Preventive Maintenance Plan. The Permittee must maintain a log of maintenance performed that relates to combustion performance. The Permittee shall report incidents of visible emissions in accordance with permit condition 4 of Section III, Plant Wide Conditions, "Report of Excess Emissions and Deviations." The basis for these monitoring, record keeping, and reporting requirements is the Department's authority to create periodic monitoring requirements, COMAR C. Rationale for Periodic Monitoring. Boilers that burn natural gas rarely have visible emissions if properly operated and maintained. The Permittee is required to maintain on site an operations manual, a preventative maintenance plan, and records of maintenance performed that relate to combustion performance. Control of Particulate Matter COMAR A(2), which states that a person may not cause or permit particulate matter caused by the combustion of fuel in any fuel burning equipment created on or after January 17, 1972 to be discharged into the atmosphere in excess of the amounts in Figure 2. This regulation no longer applies since the boilers ceased burning any fuel oil after March 31, There are no particulate matter emission limitations on boilers combusting only natural gas. Control of Sulfur Oxides COMAR A(1)(b) Control of Sulfur Oxides from fuel burning equipment. A person may not burn, sell, or make available for sale any fuel with a sulfur content by weight in excess of or which otherwise exceeds the following limitations: in Areas I, II, V, and VI, for residual fuel oils, 2 percent. 40 CFR 60.42c(d) which limits the discharge of sulfur dioxide from the combustion of fuel oil to not more than 0.50 lb/million Btu or 0.5 percent by weight. These regulations no longer apply since the boilers ceased burning any fuel oil after March 31, There are no sulfur oxides emission limitations on boilers combusting only natural gas. Control of Nitrogen Oxides Emissions In order to avoid major new source review, the Permittee netted out emissions of NOx by agreeing to shut down an existing boiler and accepting a NOx emissions rate limitation of Page 12 of 108

14 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO pounds per MMBtu while burning natural gas and an annual limit of 80.4 tons of NOx from these two boilers. Permit to Construct Number & N issued May 20, The boilers shall be equipped with low NOx burners and flue gas recirculation equipment as necessary to discharge not more than lb/million Btu while firing natural gas. Permit to Construct Number & N issued May 20, The total NOx emissions from the two boilers shall not exceed 80.4 tons in any consecutive 12-month period. NOx RACT Requirements COMAR F which states that a person who owns or operates a space heater as defined in Regulation.01B of this chapter shall do the following: (a) Submit to the Department a list of each affected installation on the premises and the types of fuel used in each installation; (b) Develop an operating and maintenance plan to minimize NO x emissions based on the recommendations of equipment vendors and other information including the source s operating and maintenance experience; (c) Implement the operating and maintenance plan and maintain the plan at the premises for review upon request by the Department; (d) Require installation operators to attend in-state operator training programs once every 3 years on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and (e) Prepare and maintain a record of training program attendance for each operator at the site, and make these records available to the Department upon request. COMAR F also requires that a person who owns or operates an installation that no longer qualifies as a space heater shall inform the Department no later than 60 days after the date when the fuel burning equipment did not qualify, and shall meet the applicable fuelburning equipment RACT requirement in this regulation. COMAR E which states that for fuel-burning equipment with a rated heat input capacity of 100 MMBtu per hour or less, the Permittee shall do the following: (a) Submit to the Department an identification of each affected installation, the rated heat input capacity of each installation, and the type of fuel burned in each; (b) Perform a combustion analysis for each installation at least once each calendar quarter and optimize combustion based on the analysis; (c) Maintain the results of the combustion analysis and stack tests at the site for at least 2 years and make this data available to the Department and EPA upon request; Page 13 of 108

15 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO (d) Once every three years, require each operator of the installation to attend operator training programs on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and (e) Prepare and maintain a record of training program attendance for each operator at the site, and make these records available to the Department upon request. Compliance demonstration. The boilers will typically operate in manner that meets the definition for a space heater. COMAR B(7) defines "Space heater" as fuel-burning equipment that consumes more than 60 percent of its annual fuel during the period from October 31 of one year through March 31 of the following year. For the purpose of this regulation, annual fuel use is the total fuel consumed during the period October 1 of one year to September 30 of the following year, beginning October 1, When operating as a Space Heater, the Permittee must comply with the NOx RACT requirements of COMAR F. If the operations change so that the boilers do not quality as a Space Heater, the Permittee must comply with the NOx RACT requirements of COMAR E, Requirements for Fuel-burning Equipment with a Rated Heat Input of 100 MMBtu per Hour or Less at the time a boiler no longer operates as a Space Heater. The Permittee must continue to comply with the NOx RACT for Fuel-burning equipment with a rated heat input of 100 MMBtu per hour or less until the boiler operates for one heating season as a Space Heater. After successfully operating as a space heater for a heating season (Oct 1 to Sept 30), the Permittee may return to complying with the requirements for a Space Heater. Previous permit condition D(1) requiring the Permittee to measure the NO x content of the flue gases from each boiler for a 5-minute period once a month using a portable gas analyzer was deemed no longer necessary and deleted. Additionally, previous permit condition D(2) requiring the Permittee to calculate monthly the quantity of NOx emissions emitted during a calendar month and for the previous consecutive 12 month period from the two boilers was also considered unnecessary since, even operating continuously (8,760 hour/year) at maximum load, the NOx emissions from both boilers would be less than 80.4 tons per year, keeping in mind that the boilers typically operate as space heaters. Operational Limitations Permit condition C, requires that, after March 31, 2015, the Permittee must combust only natural gas unless the Permittee receives a permit or approval from the Department [Authority: COMAR A]. Exemption from Boiler NESHAP requirements: Since the boilers, as of March 31, 2015, will no longer combust any fuel oil and combust only natural gas are exempt from NESHAP requirements. Page 14 of 108

16 Compliance Demonstration PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO Permit condition C requires the Permittee to retain monthly fuel usage records for each boiler [Authority: COMAR C(3)].: Additionally, the Permittee is required to submit an annual emissions certification report (permit condition 8 of Section III, Plant Wide Conditions "Emissions Certification Report). Permit Condition E requires that the annual certification report must contain the type, quantities, and analyses of all fuels burned. 4. EMISSION UNITS A8, A9: Two (2) No.2 fuel oil-fired boilers, each rated at 3.35 MMBtu/hr, located in Bldg EMISSION UNITS A8-1 and A9-1: Two (2) dual natural gas/no.2 fuel oil-fired boilers, each rated at 3.35 MMBtu/hr, located in Bldg These boilers provide space heating and hot water for residential buildings at Fort Detrick. No control equipment is currently used on these units. Emission Units A8 and A9 were registered with the Department in 1988 and No reconstruction or modification has occurred on these boilers since then. However, an after-the-fact Permit to Construct was issued by the Department on July 16, 2014 for the boilers designated as A8-1 and A9-1 above, which replaced boilers A6 and A7 in September The NSPS, 40 CFR part 60 subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, is not applicable since the individual heat input capacity is less than 10 million Btu/hr. However, the boilers are subject to certain work practice requirements under the area source NESHAP, 40 CFR part 63, subpart JJJJJJ. APPLICABLE STANDARDS and LIMITATIONS Visible Emissions Limitations COMAR A(1), which prohibits the discharge of emissions from any fuel-burning equipment in Area II, other than water in uncombined form, greater than 20 percent opacity except as allowed under COMAR A(3). COMAR A(3) provides that Section A(1) and (2) of this regulation do not apply to emissions during load changing, soot blowing, startup, 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. Page 15 of 108

17 Compliance Demonstration PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO The Permittee shall properly operate and maintain the boilers in a manner to prevent visible emissions. The Permittee shall maintain an operations manual and preventive maintenance plan, and a log of maintenance performed that relates to combustion performance. The Permittee shall report incidents of visible emissions in accordance with permit condition 4 of Section III, Plant Wide Conditions, "Report of Excess Emissions and Deviations." The basis for these monitoring, record keeping, and reporting requirements is the Department's authority to create periodic monitoring requirements, COMAR C. Rationale for Periodic Monitoring Boilers that burn No.2 fuel oil with a rated heat input capacity of less than 10 MM Btu/hr typically never have visible emissions if properly operated and maintained. Boilers in this size range are set up to operate in an automatic mode without oversight of an operator. The completion of annual preventative maintenance as recommended by the boiler manufacturer, focusing on combustion performance, is sufficient to maintain compliance with the no visible emissions requirement. Even though there is not a specific schedule to perform observations of the stack emissions, the Permittee is required under the general reporting requirement for excess emissions and deviations to report incidents when visible emissions exceed 20 percent opacity. Control of Particulate Matter COMAR A(3)(c), exempts natural gas and distillate fuel oil from a numerical particulate matter standard. Control of Sulfur Oxides COMAR A, Control of Sulfur Oxides from Fuel Burning Equipment, A person may not burn, sell, or make available for sale any fuel with a sulfur content by weight in excess of or which otherwise exceed the following limitations: (1) In Areas I, II, V, and VI: Distillate fuel oils, 0.3 percent. Compliance Demonstration The Permittee must obtain a certification from the fuel supplier indicating that the oil complies with the limitation on the sulfur content of fuel oil. The Permittee shall retain fuel supplier certifications of sulfur content in fuel. The Permittee shall report fuel supplier certifications of sulfur content in fuel to the Department upon request. The basis for these monitoring, record keeping, and reporting requirements is the Department's authority to create periodic monitoring requirements, COMAR C. Page 16 of 108

18 Control of Nitrogen Oxides Emissions PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO COMAR F(1) A person who owns or operates a space heater as defined in Regulation.01B of this chapter shall: (a) (b) (c) (d) (e) Submit to the Department a list of each affected installation on the premises and the types of fuel used in each installation; Develop an operating and maintenance plan to minimize NO x emissions based on the recommendations of equipment vendors and other information including the source s operating and maintenance experience; Implement the operating and maintenance plan and maintain the plan at the premises for review upon request by the Department; Require installation operators to attend in-state operator training programs once every 3 years on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and Prepare and maintain a record of training program attendance for each operator at the site, and make these records available to the Department upon request. COMAR F(2) A person who owns or operates an installation that no longer qualifies as a space heater shall inform the Department no later than 60 days after the date when the fuel burning equipment did not qualify, and shall meet the applicable fuel-burning equipment RACT requirement in this regulation. COMAR B(5) Operator Training: (a) (b) For the purpose of this regulation, the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation. The operator training course sponsored by the Department shall include an in-house training course that is approved by the Department. [Authority: COMAR E(3)] Compliance Demonstration The Permittee must develop an operating and maintenance plan to minimize NO x emissions based on the recommendations of equipment vendors and other information including the source s operating and maintenance experience. The Permittee must keep a copy of the operation and maintenance plan on-site and records of fuel use which demonstrate that the boiler Page 17 of 108

19 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO meets the definition of a space heater [Authority COMAR K(3) and COMAR C] Operational Limitations. Permit condition D(1) requires the Permittee to burn only No. 2 fuel oil in units A8 and A9 and only No. 2 fuel oil or natural gas in units A8-1 and A9-1 unless the Permittee applies for and receives an approval or permit from the Department to burn an alternative fuel. [Authority: COMAR A] Permit condition D(2) requires the Permittee to conduct initial and subsequent boiler tuneups in accordance with the procedures specified in (b) [Authority: 40 CFR part 63, subpart JJJJJJ, (b), (b), , and, Table 2, item 12]: (a) (b) Prior to the issuance of this Part 70 Permit, the Permittee must complete an initial tune-up of the boilers A8, A9, A8-1, and A9-1 and submit the required Notifications of Compliance Status to the EPA. Note: Ms. Rhonda B. Wolf, Air Program Manager/Environmental Engineer, USAG Fort Detrick, in an dated March 18, 2015 informed MDE-ARMA that the required tune-ups for these boilers were conducted over the period from 12/16 12/19/2014 and the Notification of Compliance Status was submitted electronically to EPA s Compliance and Emissions Data Reporting Interface (CEDRA) on March 18, The Permittee must conduct subsequent tune-ups of each boiler every 5 years. Each 5-year tune-up must be conducted no more than 61 months after the previous tune-up. Compliance Demonstration. Permit condition D(1) requires the Permittee to maintain a record of the quantity of each type fuel burned [Authority: COMAR C(1)(c)] Permit condition D(1) requires the Permittee to submit an annual emissions certification report (permit condition 8 of Section III, Plant Wide Conditions "Emissions Certification Report). The annual certification report must contain the type, quantities, and analyses of all fuels burned. Permit condition D(2) requires the Permittee to maintain the records and copies of all notifications and reports required by 40 CFR (c) and (d) make them available to the Department and EPA upon request. The following paragraphs apply [Authority: ]: (c) (1) requires the Permittee to keep a copy of each notification and report submitted to comply with this subpart and all documentation supporting any Initial Notification or Notification of Compliance Status submitted. Page 18 of 108

20 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO (c)(2) requires the Permittee to keep records to document conformance with the work practices, emission reduction measures, and management practices required by (c)(2)(i) require that records must identify each boiler, the date of tune-up, the procedures followed for tune-up, and the manufacturer's specifications to which the boiler was tuned. With regard to the tune-up every 5 years, the Permittee must maintain the following information [Authority: condition E(1), Permits to Construct and issued on July 16, 2014; 40 CFR (b)(6)]: (a) The concentration of CO in the effluent stream in parts per million, by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler; (b) A description of any corrective actions taken as part of the tune-up of the boiler. (c)the type and amount of fuel used over the 12 months prior to the tune-up of the boiler, but only if was physically and legally capable of using more than one type of fuel during that period. Units using a shared fuel meter may estimate the fuel use by each unit (c)(4) requires the Permittee to keep records of the occurrence and duration of each malfunction of the boiler or of the associated pollution control equipment affecting compliance with a Subpart JJJJJJ requirement (e.g., oxygen trim system) (c)(5) requires the Permittee to keep records of actions taken during periods of malfunction to minimize emissions in accordance with general duty to minimize emissions in 63,11205(a), including corrective actions to restore the malfunctioning boiler, air pollution or monitoring equipment to its normal or usual manner (d) The records must be in a form suitable and readily available for expeditious review. You must keep each record for 5 years following the date of each recorded action. You must keep each record on-site or be accessible from a central location by computer or by other means that instantly provide access at the site for at least 2 years after the date of each recorded action. You may keep the records off site for the remaining 3 years. Permit condition D(2)(a) requires the Permittee to submit an initial notification to the EPA Administrator or delegated authority by no later than January 20, 2014 or within 120 days of startup of boilers [Authority: 40 CFR (a)(2]. Note: The initial notification for boilers A6 through A9 was submitted on September 13, The initial notification for boilers A8-1 and A9-1 was submitted late on March 10, 2014, with an after-the-fact permit application. Boilers A8-1 and A9-1 were installed in September 2013, replacing boilers A8 and A9, Page 19 of 108

21 PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK PART 70 PERMIT NO Permit condition D(2)(b) requires the Permittee to complete an initial tune-up of the boilers A8, A9, A8-1, and A9-1 and to submit the required Notifications of Compliance Status to electronically to EPA. Permit condition D(2)(c) requires that the Notification of Compliance Status must include the information and certification(s) of compliance in paragraphs (a)(4))(i) through (v), as applicable, and signed by a responsible official [Ref: (a)(4)]. (i) Submit the information required in 63.9h(2), except the information listed in 63.9h(2)(i)(B), (D), (E), and (F). If the Permittee conducts any opacity or visible emission observations, or other monitoring procedures or methods, the Permittee must submit that data to the Administrator at the appropriate address listed in Note: Since the Permittee is not required to conduct performance tests or use CMS and is not subject to any emission limits under 40 CFR part 63, subpart JJJJJJ, Table 1, The requirement to submit this data to the EPA Administrator under paragraph (a)(4)(i) does not apply to these emission units. (ii) Certify that, This facility complies with the requirements in to conduct an initial tune-up of the boiler. (iii) (v) not applicable. (vi) The notification must be submitted electronically using the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) ( However, if the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, the written Notification of Compliance Status must be submitted to the Administrator at the appropriate address listed in Note: The required tune-ups were conducted between 12/16-12/19/2014 and the Notification of Compliance Status was submitted electronically to EPA s Compliance and Emissions Data Reporting Interface (CEDRA) on March 18, Permit condition D(2)(d) requires that, every five (5) years, by March 1 after the tune-ups are conducted, the Permittee must prepare and submit to the delegated authority, upon request, a compliance certification report that contains the following information [Authority: condition E(2), Permits to Construct and issued on July 16, 2014 and 40 CFR (b)]: (i) Company name and address. (ii) Statement by a responsible official, with the official s name, title, phone number, address, and signature, certifying the truth, accuracy and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of this subpart. Your notification must include the following certification(s) of compliance, as applicable, and signed a responsible official: Page 20 of 108