Facility Name: BASF Corporation Attapulgus Operations City: Attapulgus County: Decatur AIRS #: Application #: 22788

Transcription

1 Facility Name: BASF Corporation Attapulgus Operations City: Attapulgus County: Decatur AIRS #: Application #: Date SIP Application Received: August 11, 2014 Date Title V Application Received: August 11, 2014 Permit No: Program Review Engineers Review Managers SSPP Claudette Ayanaba Hamid Yavari SSCP John Harrison Sean Taylor ISMP Dan McCain Dave Sheffield TOXICS n/a n/a Permitting Program Manager Eric Cornwell Introduction This narrative is being provided to assist the reader in understanding the content of the referenced SIP permit to construct and proposed operating permit amendment. Complex issues and unusual items are explained in simpler terms and/or greater detail than is sometimes possible in the actual permit. This permit is being issued pursuant to: (1) Sections (1) and (10) of the Georgia Rules for Air Quality Control, (2) Part 70 of Chapter I of Title 40 of the Code of Federal Regulations, and (3) Title V of the Clean Air Act Amendments of The following narrative is designed to accompany the draft permit and is presented in the same general order as the permit. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the permit in response to comments received during the EPA review process will be described in an addendum to this narrative. BASF Corporation Attapulgus Operations, TV Page 1 of 11

2 I. Facility Description A. Existing Permits Table 1 below lists the current Title V permit, and all administrative amendments and minor and significant modifications and 502(b)(10) changes. Comments are listed in Table 2 below. Table 1: Current Title V Permit and Amendments Comments Permit/Amendment Number Date of Issuance Yes No V-04-0 March 1, 2013 Off-Permit Change April 10, 2013 Off-Permit Change September 17, 2014 Table 2: Comments on Specific Permits B. Regulatory Status Permit Number Comments Off-Permit Change Install vents on re-slurry tanks. Issued April 10, Off-Permit Change Various repairs and upgrades. Issued September 17, PSD/NSR/RACT This facility is presently classified as a major stationary source as defined by Federal Prevention of Significant Air Quality Deterioration (PSD) regulation, 40 CFR Specifically, the Attapulgus Plant has the potential to emit more than 250 tons per year of nitrogen oxides. Condition contains PSD limits and also addresses limits of fuel use in the boilers. The boilers are only allowed to burn fuel oil number 1 or 2 and natural gas. BASF Corporation Attapulgus Operations, TV Page 2 of 12

3 2. Title V Major Source Status by Pollutant Table 3: Title V Major Source Status If emitted, what is the facility s Title V status for the Pollutant? Pollutant Is the Pollutant Emitted? Major Source Status Major Source Requesting SM Status Non-Major Source Status PM PM 10 PM 2.5 SO 2 VOC NO x CO TRS H 2 S Individual HAP Total HAPs Total GHGs BASF Corporation Attapulgus Operations, TV Page 3 of 12

4 II. Proposed Modification A. Description of Modification BASF Corporation-Attapulgus Operations will reconstruct Boiler #4 and Boiler #5 through significant maintenance and repairs. An application is considered for Minor Modification with Construction as written in State Rule (10)(e)5 and the Georgia EPD Air Permit Application Processing Procedures (Procedures) if the following conditions are met. Criteria for Establishment Minor Modifications: a. Do not violate any applicable requirement (i.e., do not change any emissions caps or operational limits); b. Do not require or change a case-by-case determination of an emission limitation or other standard (e.g. BACT, RACT, LAER, 112(g)). c. Do not require source specific determination for temporary sources of ambient impacts, or visibility or increment analysis. d. Do not establish or change federally enforceable emission caps to avoid classification under Title 1 (e.g. PSD Avoidance). e. Do not involve alternative emission limit approvals. f. Are not modifications under any provisions of Title 1 (i.e., PSD, Non-attainment NSR, NSPS, NESHAP). g. Do not involve significant changes to monitoring, reporting, or record keeping in an existing permit. (Generally, significant implies relaxation of monitoring frequency, wholesale changes in monitoring schemes; parameter range changes and increased monitoring frequency are not significant) Reconstruction, as defined by NSPS Subpart A General Provisions 60.15, is any change where fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility. According to the Procedures reconstruction does not constitute a Title I change since it is not defined as a NSPS modification. Changes made to the facility will not avoid a Title 1 classification such as the NESHAP JJJJJJ avoidance. There is no establishment or change in federally enforceable emission caps. The requirements of the NESHAP JJJJJJ definition of a liquid-fired boiler are normal operating procedures for Attapulgus Operations. B. Emissions Change The following Table 4 displays the expected emission increases from the changes made to Boiler #4 and Boiler #5. A more detailed description of calculations using PSD Actual-to-Projected Actual (ATPA) guidelines is given in Part C. of this section. BASF Corporation Attapulgus Operations, TV Page 4 of 12

5 C. PSD/NSR Applicability Table 4: Net Potential Emissions Pollutant Is the Pollutant Emitted? Net Potential Emissions Increase (Decrease) (tpy) PM 0.49 PM PM SO VOC 0.83 NO x CO Total GHGs 20,019 Attapulgus Operations is considered a major source for PSD purposes and has chosen to conduct an ATPA test. The planned modifications do not exceed any PSD modification thresholds and therefore does not trigger PSD review. Since the PTE is below the threshold, netting is not required but the company has conducted an analysis. The baseline actual emissions(bae) are subtracted from the projected actual emissions(pae) as written in federal rule 40 CFR 52.21(a)(2)(c) and State Rule Chapter (7)(a)3. The emissions for the BAE and PAE are calculated by multiplying natural gas and fuel oil usage by emission factor tables in AP42 Chapters 1.4 and 1.3 for natural gas and fuel oil respectively. In this case the potential emissions are used as the PAE. A detailed account of the calculations can be found in the application submitted for this modification, Application No Several other modifications are occurring at the plant simultaneously. The following table reflects the sum of all the changes made. Off-Permit change issued on September 17, 2014 was for modifications including replacing Flash Dryer #3 Baghouse, repairing Calciners #1 and #4, upgrading dust collection system, adding a capture system for certain fugitive NH 3 emissions, and upgrading the NO x scrubber. For PSD purposes the results will be the sum of all changes made, the off-permit change plus the repairs made to Boilers #4 and #5. Table 5: ATPA for boilers. BAE (tpy) Pollutant ( ) PAE(tpy) PAE-BAE (tpy) PSD Threshold (tpy) PM PM PM SO VOC NO x CO Total GHGs 33,305 46,518 13,213 75,000 BASF Corporation Attapulgus Operations, TV Page 5 of 12

6 III. Facility Wide Requirements This modification will not affect any facility-wide requirements. Condition in the original permit contains a PSD limit of 300,000 gallons of distillate fuel oil per year. The boilers will also use distillate fuel oil. 40 CFR Part 60 Subpart A General Provisions are required by Condition The reconstructed boilers are subject to this regulation in original Permit No V BASF Corporation Attapulgus Operations, TV Page 6 of 12

7 IV. Regulated Equipment Requirements A. Brief Process Description The facility houses three steam-generating boilers. Boiler #4(C001A) was installed in 1974 and has a heat rating of 52.7 MMBtu/hr. With a heat rating of 51.9 MMBtu/hr, Boiler #5(C001B) was constructed in This modification will be for the reconstruction of Boiler #4 and #5 which includes significant maintenance and repair work. Boiler #6(C113), installed in 2006 and rated at 91 MMBtu/hr heat input will incur no changes. Boiler #6, due to its construction year, is already subject to 40 CFR Subpart Dc and other testing, monitoring, record-keeping, and reporting requirements. Due to the reconstruction Boilers #4 and #5 will now have similar requirements. B. Equipment List for the Process Emission Units Specific Limitations/Requirements Air Pollution Control Devices ID No. Description Applicable Corresponding Requirements/Standards Permit Conditions ID No. Description (2)(d) (2)(g) 40 CFR 60, Subpart A 3.2.9, 3.3.2, 3.3.3, 3.3.5, 3.3.6, 3.4.3, C001A Boiler No CFR 60, Subpart Dc 3.4.4, 4.2.2, , 40 CFR PSD 6.1.7, 6.2.4, 6.2.5, None N/A Avoidance 40 CFR 63 Subpart JJJJJJ 6.2.6, 6.2.7, 6.2.9, , , Avoidance C001B Boiler No. 5 C. Equipment & Rule Applicability Emission and Operating Caps (2)(d) (2)(g) 40 CFR 60, Subpart A 40 CFR 60, Subpart Dc 40 CFR PSD Avoidance 40 CFR 63 Subpart JJJJJJ Avoidance 3.2.9, 3.3.2, 3.3.3, 3.3.5, 3.3.6, 3.4.3, 3.4.4, 4.2.2, , 6.1.7, 6.2.4, 6.2.5, 6.2.6, 6.2.7, 6.2.9, , , An operating cap is placed on the boilers in the original Permit No V-04-0, Condition Boilers #4 and #5 are allowed to burn only fuel oil and natural gas. Applicable Rules and Regulations - Federal Rules Boilers #4 and #5 will be subject to Subpart Dc Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units. Subpart Dc requires opacity and sulfur content limits. Visible emissions are limited to 20% opacity for a 6-minute average according to 40 CFR 60.43c(c). 40 CFR 60.42c(d) and 40 CFR 60.42c(i) state that the fuel oil used cannot contain more than 0.5 % sulfur. These boilers are not subject to the PM limit in 40 CFR 60.43c(e)1 because this does not apply to boilers constructed, reconstructed, or modified after February 28, None N/A BASF Corporation Attapulgus Operations, TV Page 7 of 12

8 Provision defines a gas-fired boiler as any boiler that burns gaseous fuels not combined with any solid fuels and burns liquid fuel only during periods of gas curtailment, gas supply interruption, startups, or periodic testing on liquid fuel. Periodic testing of liquid fuel shall not exceed a combined total of 48 hours during any calendar year. By definition of a gas-fired boiler, these boilers are exempt from 40 CFR 63 Subpart JJJJJJ National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources. State Rules The original Permit No V-04-0 contains state rules that the boilers already comply with. The boilers must continue to act in accordance with State Rule(g) for a sulfur content limit and State Rule(d) for a PM and opacity limit. D. Compliance Status The facility did not report any compliance problems in their application. E. Operational Flexibility F. Permit Conditions Existing Conditions Condition limits the boilers for only natural gas and/or fuel oil use. Modified Conditions - Conditions 3.3.2, 3.3.3, and were updated and modified by adding requirements for Boilers #4 and #5 NSPS Subpart Dc. The general requirement for compliance with NSPS Subpart Dc is Condition Condition sets a 20% opacity limit for all the boilers. The sulfur content limit of 0.5% of the fuel oil is contained in Condition According to NESHAP JJJJJJ definition of liquid-fired boilers, Condition limits the facility to only burn natural gas and only burn fuel oil during certain situations. The use of fuel oil for testing cannot exceed 48 hours per year. BASF Corporation Attapulgus Operations, TV Page 8 of 12

9 V. Testing Requirements (with Associated Record Keeping and Reporting) Initial testing on Boiler #6 (C113) in original Permit No V-04-0 Condition has been completed. Condition is added and will require opacity testing on Boilers #4 and #5. This condition outlines the procedure for conducting a Method 9 performance test. The test insures compliance with the opacity standard in Condition and satisfies NSPS Dc provision 60.47c(a)(1). BASF Corporation Attapulgus Operations, TV Page 9 of 12

10 VI. Monitoring Requirements (with Associated Record Keeping and Reporting) The fuel oil reports maintained are able to satisfy 60.48c(f) and therefore the boilers are exempt from installing a Continuous Opacity Monitor (COM) to comply with 60.47c(c). The regulation states in 60.47c(c), Owners and operators of an affected facilities that burn only distillate oil that contains no more than 0.5 weight percent sulfur and/or liquid or gaseous fuels with potential sulfur dioxide emission rates of 26 ng/j (0.060 lb/mmbtu) heat input or less and that do not use a post-combustion technology to reduce SO2 or PM emissions and that are subject to an opacity standard in 60.43c(c) are not required to operate a COMS if they follow the applicable procedures in 60.48c(f). The same applies to Continuous Emission Monitor (CEM) for monitoring SO2. The regulation states in 60.46c(e), The monitoring requirements of paragraphs (a) and (d) of this section shall not apply to affected facilities subject to 60.42c(h) (1), (2), or (3) where the owner or operator of the affected facility seeks to demonstrate compliance with the SO2 standards based on fuel supplier certification, as described under 60.48c(f), as applicable. Condition of original Permit No V-04-0 covers the fuel oil verification requirements outlined in 60.48c(f). Subsequent Method 9 performance tests required in Condition can be replaced with the monitoring described in Condition The monitoring outlined will satisfy provision 60.47c(a) and the schedule is outlined in Condition BASF Corporation Attapulgus Operations, TV Page 10 of 12

11 VII. Other Record Keeping and Reporting Requirements Two conditions were added to and one condition was modified in Condition Condition 6.1.7(a)(i) was added to include an excess emission is any opacity reading equal to or greater than the opacity limit contained in Condition Condition 6.1.7(b)(ii), modified from the original Permit No V-04-0, states that the sulfur content of the fuel oil cannot exceed 0.5 percent by weight. The new condition matches the permit vault language and includes the reference. Condition 6.1.7(c)(viii) has been added and any visible emissions observed according to Condition is known as an excursion. Condition complies with 60.48c(f) requirement for fuel oil verification. Verification of the type of fuel oil used is done by either keeping fuel oil receipts or conducting a fuel analysis. The facility must keep records of the natural gas and fuel oil combusted in the boilers in Condition to comply with provision 60.48c(g). The records taken in Conditions and must be included in the semi-annual report as outlined in Condition According to NESHAP JJJJJJ, a written record is required to be kept of all fuel oil fired in the boilers as spelled out in Condition BASF Corporation Attapulgus Operations, TV Page 11 of 12

12 VIII. Specific Requirements A. Operational Flexibility B. Alternative Requirements C. Insignificant Activities D. Temporary Sources E. Short-Term Activities F. Compliance Schedule/Progress Reports G. Emissions Trading H. Acid Rain Requirements I. Prevention of Accidental Releases J. Stratospheric Ozone Protection Requirements K. Pollution Prevention L. Specific Conditions BASF Corporation Attapulgus Operations, TV Page 12 of 12

13 Addendum to Narrative The 45-day EPA review started on January 22, 2015 and ended on March 9, Comments were not received by the Division. BASF Corporation Attapulgus Operations, TV Addendum Page 1 of 1