- DRAFT - Background Information for SIP Revision ELT Minneapolis River Road Industrial Facility, Fridley, Minnesota

Transcription

1 Background Information for SIP Revision ELT Minneapolis River Road Industrial Facility, Fridley, Minnesota This document provides background information on the submittal of Air Emission Permit No as the State Implementation Plan (SIP) enforceable document for the ELT Minneapolis River Road Industrial Facility (ELT) at 4800 River Road in Fridley, Anoka County, Minnesota. This facility is included in Minnesota s SIP for sulfur dioxide (SO 2 ). Reasons for Changes and Placing Applicable Conditions into Joint Title I/FESOP Document ELT owns and operates boilers and emergency generators. These were part of a purchase agreement dated November 22, 2005, between BAE Systems Land and Armaments (formerly United Defense, LP), Inc and ELT. Minnesota s SO 2 SIP for the Twin Cities area currently includes Title I SIP conditions for these boilers and generators. Those Title I SIP conditions are found in Air Emission Permit No , issued to United Defense, LP in November In August 2004, EPA published a direct final notice approving the Title I SIP conditions into Minnesota s SIP (69 FR 51181). However, EPA s notice describes the incorporated joint document as Air Emission Permit No It appears that the cover page to the incorporated joint document listed the permit with this number, although the MPCA s permit tracking system and the remaining pages in the joint document list the document as Air Emission Permit This SIP revision serves to generally update the facility in the SIP. First, is serves to resolve the issue of which joint document is included in the SIP, ensuring that the correctly numbered permit is incorporated into the SIP as the joint document. It also accounts for the change in ownership of the facility, and some changes in how the emissions units and groups are described. Boilers 1, 2, and 3 were listed in the joint document issued to United Defense as EU001, EU002, and EU003 and associated with the stacks SV026 and SV027 under GP002. These are now grouped under GP001, with the stacks numbered SV001 and SV002. Similar changes were made for the emergency generators. The changes are further described in Attachment 4. Finally, the incorporation of the current joint document includes several Title I conditions that are not related to the SIP. With this SIP revision, the MPCA is requesting that these conditions be removed. Many of these non-sip Title I conditions relate to emission units that are not owned by ELT. This revision does not involve any substantive changes to the SIP conditions. All fuel restrictions and SO 2 emission limits that apply to the boilers and emergency generators remain the same as those currently approved into the SIP. Some changes to the SIP conditions were made in order to be consistent with the MPCA s current practices for joint documents, but these changes are administrative and provide detail clarifying for the facility when SIP revisions are required. 1

2 No new authorizations are part of this SIP revision, and no modeling was conducted as no emission limits or stack parameters have changed. The MPCA requests that EPA include the Title I SIP conditions from Air Emission Permit No , issued to ELT and serving as a joint document, into Minnesota s SIP to replace the Title I conditions from Air Emission Permit No Attachments to Background Document Attachment 1: Permit No ; joint Title I/FESOP document Attachment 2: Permit technical support document Attachment 3: Permit No ; Title I SIP conditions only Attachment 4: Marked up United Defense currently approved joint document Attachment 5: Public notice Attachment 6: Completeness Review This summary was prepared by Catherine Neuschler, Environmental Analysis and Outcomes Division of the MPCA. 2

3 Attachment 1: Permit No ; joint Title I/FESOP document Attachment 2: Permit technical support document Attachment 3: Permit No ; Title I SIP conditions only See proposed joint document (Air Emission Permit No ) currently on notice 3

4 Attachment 4: Marked up United Defense currently approved joint document 4

5 AIR EMISSION PERMIT NO 'IS ISSUED TO United Defense LPRJS Navy UNITED DEFTNSE LP ARMAMENT SYSTEkIS DIVISION 4500 East River Road Fridley, Anoka County, Minnesota The emission units, control equipment and emission stacks at the stationary.source authorized in this permit are as described in the following perrriit application(s): -- June 1 5,1995 This permit authorizes the Permittees to operate and construct the stationary source at the address listed above unless otherwise noted in Table A. The Permittees must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. ' Permit Type: State; Syn Min Part 70 'Issue Date: November 25, 2002 Expiration: Permit does not expire A11 Title I Conditions do not expire. "Title I Condition: SIP for SO2 NAAQS 40 CFR pt. 50 and MN State Implementation Plan (SIP)" or Title I Condition: MN State Implementation Plan (SIP); 40 CFR fj 50.5" are required to go through the federal State Implementation Plan approval pro ajor Facilities section Manager Majors and Remediation Division for Karen A. Studders Commissioner Minnesota Pollution Control Agency % TDD (for hearing and speech impaired only): (65 1) Printed on recycled paper containing at least IO%fibers from paper recycled by consumers

6 PERMIT NO ' FACILITY DESCRIPTION: The Naval industrial Reserve Ordnance Plant (NIROP) is operated by United Defense, L.P. The NIROP IS owned by the U.S. Navy under the cognizance of the Naval Seas System Command, Washington, D.C. The operating contractor is Armament Systems Division (ASD) of United Defense, L.P. ASD is responsible for the day to day operation of the total plant. Thus this permit application is being made by Armament Systems Division, United Defense, L.P. as operator/part owner and the U.S. Navy as part owner. The facility covered by this permit application is a manufacturing plant divided into two distinct areas on the basis of ownership. The larger area to the north consists is owned by the 1J.S. Navy and covers approximately 82 acres and is occupied by buildings containing approximately 1,567,000 square feet of space. These bulidings and property (hereafter referred to as Naval. Lndustrial Rcserve Ordnance Plant) are contiguous and adjacent to buildings and property just to the south owned by United Defense, I..P. The United Defense owned buildings and property total 326,000 square feet and approximately 59 acres respectively. The two areas described above are collectively considered the total plant. The facility designs, engineers, manufactures and tests components for advanced military weapon systems. The facility consists of boilers, diesel standby electric generators, painting and blasting booths. a

7 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: United Defense LP Permit Number: Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What TO do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A(Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements... r---- Subject Item: Total Facility I- - What to do -- STATE IMPLEMENTATION PLAN (SIP) REQUIREMENTS of Fuel: less than 0.05 percent by weight of No. 2 Fuel Oil and -. General Conditions for the S)P. The Administrative Order general conditions are still federally enforcable until US EPA REMOVES THE REQUIREMENTS FROM THF SIP I T --P I hdr - Why to do it I Title I Condition: SIP for SO2 NAAQS 40 CFR pt. 50, and MN State Implementation Plan (SIP) for SO2 I Title I Condition: SIP for SO2 NAAQS 40 CFR pt. 50 and MN State lmplementation Plan (SIP) for SO2 - Title I Condition-: SIP for SO2 NAAQS 40 I and MN State Implementation Plan (SIP) for SO2 in the computer modeling performed to demonstrate that the's02 maintenance will the SO2 NAAQS. Retain all records at the stationary source for a period of five (5) years from the I date of the required monitoring. sample, measurement, or report that corresponds with the M.N Stale lmplemenlation Plan Title I Condition. REQUIREMENTS This permit establishes limits on the facility to keep it a minor source under 40 Section 70.2 and 40 CFR Section The Permittee cannot make any change at the source that would make the source a major source under New Source Review and NESHAPS until a major permit amendment has been issued. This includes changes that might otherwise quality as insignificant modifications and lminor or moderate amendments. Volatile Organic Compounds: less than or equal to 90 tonslyear using 12-month Rolling Sum to be calculated by the 28th day of each month for the previous 12-month period. All emission units. except those deemed to be insignificant activities under Minn. R and fuel combustion sources shall be included in this calculated. VOC contents for each VOC-containing material shall be determined as desceunder the Material Content Requirement. Nitrogen Oxides: less than or equal to 90 tonslyear using 12-month Rolling Sum to be calcuated by the 28th day of each month for the pervious 12-month period. All emission units, except those deemed to be insignificant activities under Minn. R , and those added to the facility as allowed in this permit shall be included in this calculation. Particulate Matter < 10 micron: less than or equal to 90 tonslyear using 12-month Rolling Sum to be calculated by the 28th day of each month for the pervious 12-month period as described in the permit. All particulate matter be conservatively assumed to be particulate matter less than 10 microns. HAP-Single: less than or equal to 9.0 tonslyear using 12-month Rolling Sum to be calculated by the 28th day of each month for the pervious 12-month period. not including fuel combustion HAP and emissions from Insignificant Activities listed in Minn. R HAP contents for each HAP-containing material shall be determined as described under the Material Content Requirement. The calculation of HAP usage may take into account reco~eredlrec~cled~~~~s as described under the Waste Credil requirment in this permit. using 12month Rolling Sum to be calculated by the 28th day of each month for the pervious 12-month period, not including fuel combustion HAP and emissians from Insignificant Activities listed in Minn. R. rn W6P conients for each HAP-containing material shall be determined as described under the Material Content ~e~uirernent. The calcula*ion of HAP usage may take into account rewvered/recycled HAPS as described under requirement in this permit. I C Title I condition: Recordkeeping Implementation Plan (SIP) for SO2 7-1 hdr Title I Condition: Limit to avoid classification as a major source amd modification under 40 CFR Section 52.21; and to avoid major source classification under 40 CFR Section 70.2 and 40 CFR Section 63.2 major source under 40 CFR Section 52.21; 40 CFR Section 70.2; to avoid major source classification under 40 CFR Section 63.2 Title I Condition: Limit to avoid classification as a I major source under 40 CFR Section 70.2 major source under 40 CFR 52.2; 40 CFR Section 70.2 Title I Condition: Limit to avoid classification as a major source under 40 CFR Section 63.2: and Minn. R Title I Condition: Limit to avoid classification as a major source under40 CFR Section 63.2; and Minn. R I A-I

8 TABLE A: LIMITS AND OTHER REQUIREMENTS "~acilit~ Name: United Defense LP Permit Number: Pre-authorized Changes: The Permittee may replace or move emission units, or add new emission units similar but not limited to the following: spray guns, spraying and coating booths, powder paint booths. abrasive blast booths, control equipment. welding booths. dip tanks, space heating units, ovens, boilers, emergency generators, make-up air units as we1l.a~ coating. reagents and other solvent or material changes provided PMIPMIO. NOx, VOC and HAP emissions are tracked and calculated as required by this permit. All changes must meet the requirements as listed in this section T~tle I Condition: Liniit to avoid classification as a major source and modification under 40 CFR 52.21; and to avoid major source classification under 40 CFR 63.2 If a proposed change triggers an applicable requirement that is not contained in this permit, the change must go through the appropriate procedure in Minn. R. ch

9 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: United Defense LP Permit Number: Subject Item: GP 002 Boilers subject to NSPS Associated Items: EU 001 Boiler 1 EU 002 Boiler 2 EU 003 Boiler 3 (81098) SV 026 Boiler 2 and 3 SV 027 Boiler 1 What to do - P Why to do it I I AND REQUIREMENTS -- hdr Sulfur Content of Fuel: less than 0.05 percent by weight of No. 2 fuel oil. [This limit I Condition: SIP for SO2 NAAQS 40 CFR pt. 50 is more strigent than the NSPS limit.] and MN State Implementation Plan (SIP No. 2 Fuel Oil Certification: The owner or operator shall obtain and maintain written documentation of each shipment of No. 2 fuel oil received for the boilers. The written documentation shall include the following information: the sulfur content of the fuel and the method used to determine the sulfur content. - Fuel Restriction: Authorized to burn natural gas and No. 2 fuel oil only. Title I Condition: SIP for SO2 NAAQS 40 CFR pt. 50 and MN State Implementation Plan (SIP) Title I Condition: SIP for SO2 NAAQS 40 CFR pt. 50 and MN State Implementation Plan (SIP)

10 . TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: United Defense LP Permit Number: Subject Item: GP 003 Standby Generators -. Associated Items: EU 016 Standby Generator - Sub 3 (w) EU 017 Standby Generator -Sub 3 (e) EU 018 Standby Generator - Sub 1 EU 019 Standby Generator-Boiler EU 020 Standby Generator - Bdg 37 SV 045 Curnmins Stdby Generator-Sub 3 (w) SV 046 Cummins Stdby Generator-Sub 3(e) SV 047 Caterpillar Stdby Generator-Sub 1 SV 048 Calerpillar Stdby Generator-Boiler Rm I - SV 049 Caterpillar Stdby Generator-Boiler Bdg 37 What to do -- Why to do it -~ B. OTHER LIMITS AND REQUIREMENTS -- Sulfur Content of Fuel: less than 0.05 percent by weight of diesel fuel. - Diesel Fuel Oil Certification: The owner or operator shall obtain and maintain written documentation of each shipment of diesel fuel oil received for the boilers. The written documentation shall include the following information: the sulfur content of the fuel and the method used to determine the sulfur content. Fuel Restriction: Authorized to burn diesel fuel oil only hdr Title I Condition: SIP for SO2 NAAQS 40 CFR pt. 50 and MN State Implementation Plan (SIP) - Title I Condition: SIP for SO2 NAAQS 40 CFR pt. 50 and MN State Implementation Plan (SIP) - Title I Condition: SIP for SO2 NAAQS 40 CFR pt. 50 and MN State Implementation Plan (SIP) I :

11 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: United Defense LP Permit Number: Subject Item: Associated Items: GP 004 Emission Control Equipment (Paint Booths) CE 004 Mat or Panel Filter( 24th Ave) CE 006 Mat or Panel Filter(Paint System CE 010 Mat or Panel Filter(l2th Ave) I - -I What to do -- Matter: greater than or equal to 92.0 percent control efficiency (capture efficiency of the booth x collection efficiency of the filter) Particulate Matter i 10 micron: greater than or equal to 92 percent control efficiency (capture efficiency of the booth x collection efficiency of the filter) listed control equipment under Minn. R to The Permittee shall operate and maintain the fabric filter at all times that any process equipment -- Why to do it Title I Condition: Limit taken to avoid classification as a major source and modification under 40 CFR Section 52.21; Minn. R Title I Condition: Limit taken to avoid classification as a major source and modification under 40 CFR 70.2; 40 CFR Section 52.21; Minn. R hdr - Title I Condition: Limit taken to avoid classification as a major source and modification under 40 CFR Section 52.21; Minn. R

12 TABLE A: LIMITS AND OTHER REQUIREMENTS Facility Name: United Defense LP Permit Number: Subject Item: Associated Items: GP 005 Emission Control Equipment (Blast Booths) CE 001 Fabric Filter - Low Temperature, i.e., Tc180 Degrees F CE 005 Fabric Filter - Low Temperature, i e., T<180 Degrees F I , - What to do The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Total Particulate Matter: greater than 99.0 percent control efficiency The Permittee shall operate and maintain the control equipment such that it achieves an overall control efficiency for Particulate Matter < 10 micron: greater than 99.0 percent control efficiency i Why to do it Title I Condition: Limit taken to avoid classification as a major source and modification under 40 CFR 70.2; 40 CFR Section 52.21: Minn. R Title I Condition: Limit taken to avoid classification as a major source and modification under 40 CFR 70.2; 40 CFR Section 52.21; Minn. R I

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14 Attachment 5: Public notice See MPCA public notice web page. 5

15 Attachment 6: Completeness Review A. Administrative Materials (40 CFR pt. 51, Appendix V, Part 2.1) The EPA s Criteria for Determining the Completeness of Plan Submittals, published at 40 CFR pt. 51, Appendix V (2001), requires states to provide the basic documents that show that the State has properly followed the administrative requirements called for by the CAA for the adoption of SIPs. The requirements, and how this SIP revision complies with these requirements, are discussed here: 1) Formal Letter of Submittal: A formal letter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof. Attached to this SIP revision request is a formal letter of submittal from the MPCA Commissioner, Paul Eger, to the Acting EPA Region V Administrator, Bharat Mathur. The office of the Commissioner of the MPCA is statutorily created at Minnesota Statute , subd. 1 (a) (2000). The Commissioner is appointed by the Governor, and the duties of the position include acting as the state agent to apply for, receive, and disburse federal funds made available to the state by federal law or rule and regulations promulgated thereunder for any purpose related to the power and duties of the MPCA or the Commissioner. The Commissioner shall comply with any and all requirements of such federal law or such rules and regulations promulgated thereunder to facilitate application for, receipt, and disbursement of such funds. Minn. Stat subd. 3 (2000). 2) Evidence of State Adoption of Plan and Issuance of Orders in Final Form Evidence that the State has adopted the plan in the State code or body of regulations; or issued the permit, order, consent agreement (hereafter document ) in final form. That evidence shall include the date of adoption or final issuance as well as the effective date of the plan, if different from the adoption/issuance date. Attachment 1 contains the joint Title I/FESOP document, which consists of Air Emission Permit No , which includes relevant SIP conditions, labeled Title I Condition: SIP for SO2 NAAQS. This Air Emission Permit became effective at the state level as soon as it was signed. All Title I conditions are non-expiring. 3) Legal Authority Documentation: Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. This SIP revision request is based on the MPCA s Twin Cities Area SO 2 SIP submitted on May 29, 1992 and updated July 12, 1993, which contained an Administrative Order for United Defense, LP. In December 2002, the MPCA submitted United Defense s Air Emission Permit No , issued November 25, 2002, as a joint document containing SIP conditions to 6

16 replace the Order. EPA approved this joint document into Minnesota s SIP on August 18, 2004 (69 FR 51181). Appendix C of the original May 1992 submittal documents MPCA s legal authority to adopt ambient air quality standards for SO2, issue orders to sources to control their emissions, and to enforce those rules and orders. On May 2, 1995, EPA approved MPCA s revised operating permit program as a SIP revision (60 FR 21447). MPCA submitted the operating permit program for inclusion in the SIP in part so that permits issued under the program could be considered federally enforceable vehicles for imposing emissions limitations on culpable sources located in nonattainment areas. EPA s conclusion that MPCA has the authority to issue permits with non-expiring Title I SIP conditions in order to replace Administrative Orders has been further documented in an April 4, 1997 letter from Michael Sandusky of the MPCA to David Kee of EPA Region 5, a July 3, 1997 letter from David Kee of EPA Region 5 to Michael Sandusky of the MPCA and in a June 15, 2006 letter from Jay Bortzer of EPA Region 5 to David Thornton of the MPCA. Copies of these letters have been submitted with previous SIP revisions. 4) Compliance with State Procedures: Evidence that the state followed all of the procedural requirements of the State s laws and constitution in conducting and completing the adoption/issuance of the plan. MPCA complied with all relevant state procedures for issuing the permit as well as the SIP revision. 5) Public Notice: Evidence that public notice was given of the proposed change consistent with the procedures approved by the EPA, including the date of the publication of the notice. The public notice for the permit and associated SIP revision was published in the St. Paul Pioneer Press on February 17, 2010, with the public comment period commencing on February 26, 2010 and ending on March 29, During the public comment period, a copy of the permit and SIP revision request was made available at the MPCA office located in St. Paul and on the MPCA s website. A copy of the public notice is attached. (Attachment 5). 6) Public Hearing Certification Certification that public hearing(s) were held in accordance with the information provided in the public notice and the State s laws and constitution, if applicable. The public notice states: A public information meeting will only be held if one is requested during the public comment period. If such a meeting is requested, it will be held from 3:00 pm to 4:00 pm on Thursday, April 1, 2010, at the MPCA St. Paul Office, 520 Lafayette Road North, Minnesota. To find out if a public meeting will be held, please call Catherine Neuschler at 651-7

17 , after the close of the public comment period. The public information meeting will provide information, receive public input, and answer questions about both the proposed permit and SIP revision. No public meeting was requested. 7) Public Comments and State Response: Compilation of the public comments and State s response thereto. <to be filled in> B. Technical Support: 1) Pollutants Regulated: Identification of all regulated pollutants affect by the plan. The regulated pollutant subject to this SIP revision request is SO 2. 2) Source Identification Identification of the locations of affected sources including the EPA attainment/nonattainment designation of the locations and the state of the Attainment Plan for the affected area(s). The affected source within the former Twin Cities SO 2 nonattainment area is ELT Minneapolis, LLC, River Road Industrial. Further information on the facility is included in the attached Technical Support Document. 3) Emissions Quantification: Quantification of the changes in the plan; allowable emissions from the affected sources; estimates of changes in current actual emissions from affected sources or, where appropriate, quantification of the changes in actual emissions through calculations of the differences between certain baseline levels and allowable emissions anticipated as a result of the revision. The changes allowed in this SIP revision do not impact overall emissions from the facility. 4) NAAQS Protections: The State s demonstration that the NAAQS, prevention of significant deterioration increments, reasonable further progress demonstration, and visibility, as applicable, are protected if the plan is approved and implemented. Because the SIP revision does not allow any increase in emissions, the facility impact on the NAAQS will not change. 8

18 5) Modeling Information Modeling information required to support the proposed revision, including input data, output data, models used, justification of the model selections, ambient monitoring data used, meteorological data used, justification for use of off-site data (where used), modes of models used, assumptions, and other information relevant to the determination of adequacy of the modeling analysis. Modeling was not done because there were not changes at the facility. 6) Continuous Emission Reduction Evidence, where necessary, that emission limitations are based on continuous emission reduction technology. These requirements are included in the permit and joint Title I/Title V document issued to the source. This document is attached as Attachment 1. 7) Emission Level Assurance Evidence that the plan contains emission limitations, work practice standards and recordkeeping/requirements, where necessary, to ensure emissions levels. Again, the above requirements are addressed in the permit and joint Title I/Title V document as shown in Attachment 1. 8) Compliance/Enforcement Compliance and enforcement strategies, including how compliance will be determined in practice. The above requirements are addressed in the permit and joint Title I/Title V document as shown in Attachment 1. 9) Special Economic and Technological Justifications: Special economic and technological justifications required by any applicable EPA policies, or an explanation of why such justifications are not necessary. This requirement does not apply to this submittal. Conclusion The MPCA expects that the Twin Cities area will remain in compliance with the SO 2 NAAQS. 9

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