PERMIT APPLICATION REVIEW SUMMARY

Transcription

1 AFS #: Application #: FY Date: 9/5/2008 Page 1 of 5 APPLICATION & OTHER COMMUNICATION: Date Description 6/11/2007 Compliance Referral by Christie Peshka. 8/6/2007 LOD # issued to Nutter. 8/30/2007 Application received (incomplete) for Caterpillar engine (engine #1) Pegson and CedarRapids (crusher #2) crushing plants. 8/30/2007 Permit Application Fee received. 10/8/2007 Nutter requests extension of time to respond to LOD. 10/17/2007 DES extends time to submit complete permit application and pay emission and modeling fees 11/5/2007 Temporary Permit Application received (incomplete). 11/19/2007 Air Dispersion Modeling Report received. 2/1/2008 Pegson replaced with Nordberg Lite 105. Nordberg Lite 105 to be permitted under GSP. 2/21/2008 Air Emissions Inventory Report and fee received for 2006 for CedarRapids. 3/25/2008 Replacement of tower and enclosure of Caterpiller /11/2008 Revised modeling files received for Caterpillar /17/2008 Air Emissions Inventory Report and fees received for past 5 years ( ) for Pegson and for 2007 for CedarRapids 5/27/2008 Modeling Fees received 6/6/2008 Administrative Completeness Letter Sent (TP - Application Shield does not apply). 7/31/2008 Subpart OOO Testing Completed 9/4/2008 Nordberg Lite 105 ARD-3 forms received to fold into permit. Statewide NMMP-GSP is pending reissuance. PROJECT DESCRIPTION The temporary permit covers one engine and two portable crushing plants. The Caterpillar 3412C is a stationary engine (greater than 1.5 MMBtu/hr) associated with a portable CedarRapids crusher (greater than 150 tph). Both these units require permits. The portable Pegson crusher originally applied for in 2007 has been replaced with a Nordberg LT 105 with a Caterpillar C-9 engine. This portable Nordberg crusher (greater than 150 tph) requires a permit, but its integral non-road engine does not. Neither the PowerScreen screener (not a crushing plant) nor its integral non-road engine requires a permit. FACILITY DESCRIPTION Nutter Enterprises owns and operates a sand and gravel quarry. The Facility is capable of year round operations, but typically operates during the construction season from 6:00 am to 4:00 pm on weekdays. Occasionally the Facility operates on weekend days. Facility operations include drilling, blasting, crushing, screening, loading/unloading and hauling. In addition to processing sand and gravel, the Facility also processes recycled asphalt pavement and recycled concrete.

2 AFS #: Application #: FY Date: 9/5/2008 Page 2 of 5 DEVICE DESCRIPTION The following gives the details of the engine and two crushing plants: Manufacturer Model No. Serial No. Engine Output Rating Caterpillar 3412C 81Z hp Subpart Date Mfg/ Installed Control IIII Applicable? / 2006 None No Manufacturer Model No. Serial No. Output Capacity Date Manufactured Control Subpart OOO Applicable? Cedarapids CSC6203MVP380T tph 2006 wet suppression Yes Nordberg LT tpy 2008 wet suppression Yes POLLUTION CONTROL EQUIPMENT There is no pollution control equipment associated with the engine. The crushing plants have wet dust suppression (controlled). EMISSION CALCULATIONS Emission rates for all pollutants, were calculated using USEPA AP-42 (5 th Edition 1/95), Section 3.4, Large Stationary Diesel and All Stationary Dual-fuel Engines (updated 10/96) and Section Crushed Stone Processing and Pulverized Mineral Processing and can be found at: H:\Permitting\Source Files\Nutter\Nutter_Calcs.xls Potential Emissions are based on the Caterpillar 3412C engine and the CedarRapids portable crushing Facility running at maximum capacity for 8760 hours/year. The Facility requested operating hours of 10 hours per day; 1250 hours per year and modeled these restrictions themselves for DES review. Annual fuel limits are reflected in the Permitted Emissions based on requested annual hours, daily limits are not required. These limits are reflected in the Permitted Emissions. Emission Factor (lb/kgal) Generator CO NOx PM 10 TSP SO 2 VOC Potential Emissions (tpy) 1 CO NOx PM 10 TSP SO 2 VOC Crushing Plant Engine Equipment Facility Total Permitted Emissions (tpy) CO NOx PM 10 TSP SO 2 VOC Crushing Plant Engine Equipment Facility Total Permitted Emissions based on: 1250 hours per year 10 hours per day Facility wide Potential to Emit includes generator and equipment operation

3 AFS #: Application #: FY Date: 9/5/2008 Page 3 of 5 STACK INFORMATION The following table details the permitted stack parameters for the engine. Engine Caterpillar 3412C MODELING Maximum Exit Diameter (ft) Minimum Height (ft) Velocity (ft/s) Temp(F) Flow (acfm) Stack Configuration ,131 4,047 vertical Modeling was conducted for this source by RSG, Inc. on 11/16/2007 and was received by PEHB on 11/19/2007. Revised modeling was submitted by RSG, Inc. on 4/11/2008 to account for the change in height of the trailer and control tower associated with the CedarRapids. EMISSION TESTING Visible emissions testing pursuant to requirements in NSPS Subpart OOO, was planned for completion by June 2, Testing was completed on July 31, SITE VISITS/INSPECTIONS Date Description 5/1/2007 A full on-site compliance inspection was conducted by Christie Peshka. Nutter is operating its crushing plants without a permit; Nutter is not submitting Annual Emission Reports; Nutter has not submitted any annual emission-based fees for the crushing plants; During the inspection, moderate to heavy fugitive dust emissions were observed due to vehicular travel; and testing in accordance with 40 CFR 60, Subpart OOO is required at this Facility and has not been conducted. 10/4/2007 Dave Cribbie and Muriel Lajoie of the Permitting and Environmental Health Bureau and Jim Black of the Technical Services Bureau visited the site and met with John Hinkley of RSG, Inc. in order to determine which pieces of equipment required permitting/modeling. ANNUAL EMISSION REPORTS/FEES This is an existing Facility operating without a permit. The following emissions were taken from the emissions reports received on 2/21/2008 and 4/17/2008. Fees were received on 4/17/2008. CHANGES FROM PREVIOUS PERMIT This is the first permit at the source. 1 10/17/2008 LOD No. ARD

4 AFS #: Application #: FY Date: 9/5/2008 Page 4 of 5 REVIEW OF REGULATIONS State Regulations Env-A 600 Permitting (d) Applicable The generator has a design rating greater than 1.5 MMBtu/hr (m) Applicable The portable crushing plants have a capacity greater than 150 tons/hour (q) Applicable The Facility has an applicable NSPS Standard under 40 CFR 60 Subpart OOO (y) Not Applicable The Facility is not required to take a fuel limit to meet NAAQS, but requested one in the submitted modeling. Therefore the requested fuel limit will be folded into the permit as an annual fuel limit. Env-A 700 Permit Fee System Applicable source subject to annual emission-based fees Env-A 900 Owner or Operator Recordkeeping and Reporting Obligations 903 Applicable record fuel usage information 904 and 908 Not Applicable permitted emissions of VOCs < 10 tpy 905 and 909 Applicable if actual NOx emissions are 10 tpy. 907 Applicable Annual emissions report 911 Applicable Permit deviation reporting. Env-A 1200 Prevention, Abatement and Control of Stationary Source Air Pollution Not Applicable Facility opting out of NOx RACT by limiting NOx emissions to less than 50 tpy. Env-A 1400 Regulated Toxic Air Pollutants Not Applicable Not applicable to sources burning virgin fuel. Env-A 1600 Fuel Specifications Applicable sulfur limit for #2 fuel oil (diesel) is 0.40% by weight. Env-A 2000 Fuel Burning Devices Applicable visible emissions from the generators limited to 20% Applicable TSP emissions from the generators limited to 0.30 lb/mmbtu. Env-A 2800 Sand and Gravel Sources, and Cement and Concrete Sources Applicable visible emissions limit of 20% (note federal standard is stricter) Applicable fugitive emission control system Applicable fugitive dust control from vehicular movement and stockpiling within plant property Env-A 3700 NOx Emissions Reduction Fund for NOx-Emitting Generation Sources Not Applicable o The Caterpillar 3412C is a portable engine as it is connected to the portable Cedarapids crusher by only an electrical connection and it is not permanently fixed to the ground or a structure.

5 AFS #: Application #: FY Date: 9/5/2008 Page 5 of 5 Federal Regulations 40 CFR 60, Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants Applicable to devices installed after August 31, visible emissions limit of 15% for crushers visible emission limit of 10% for transfer points testing requirements (completed 7/31/2008) 40 CFR 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Not Applicable Engine was manufactured prior to April 1, SUMMARY AND CONCLUSIONS The Facility will be capable of meeting all regulations and standards for air quality. The Temporary Permit will be drafted for the Facility. H:\Permitting\Source Files\Nutter\Nutter_Eng Sum.doc