Facility Name: PCS Nitrogen Fertilizer, L.P. City: Augusta County: Richmond AIRS #: Application #: 40593

Transcription

1 Facility Name: PCS Nitrogen Fertilizer, L.P. City: Augusta County: Richmond AIRS #: Application #: Date SIP Application Received: November 23, 2015 Date Title V Application Received: November 23, 2015 Permit No: V-03-5 Program Review Engineers Review Managers SSPP Joe Aisien David Matos SSCP Anna Lesichar Farhana Yasmin ISMP Cureton Marcus Dan McCain TOXICS Michael Odom Michael Odom 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 operate and Section 502(b)(10) change to the Part 70 source. 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), (2), 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 permit and is presented in the same general order as the permit amendment. This narrative is intended only as an adjunct for the reviewer and has no legal standing. PCS Nitrogen Fertilizer, L.P., TV Page 1 of 12

2 I. Facility Description A. Existing Permits Table 1 below lists the current Title V permit, all administrative amendments and minor and significant modifications to that permit, and any 502(b)(10) changes. Comments are listed in Table 2 below. Table 1: Current Title V Permit and Amendments Permit/Amendment Number Date of Issuance V-03-0 September 11, V-03-1 June 13, V-03-2 November 7, V-03-3 November 26, V-03-4 February 11, 2016 Comments Yes No Table 2: Comments on Specific Permits Permit Number V V V V V-03-4 B. Regulatory Status 1. PSD/NSR/RACT 2 nd Title renewal permit Comments Modification correcting Condition c.iii moisture content excursion value for the Urea Prill Plant. Modification updating Condition c.vi pump pressure and volumetric flow rate excursion values for the neutralizer scrubber controlling the C001 AN Plant. Modification updating Condition c.xiv(D) for the Prill Tower Scrubber exhaust blower motor amperage range for the C002 AN Plant. Modification designating the Synloop startup heater as limited use pursuant to 40 CFR PCS Nitrogen Fertilizer, L.P. (PCS) is classified as a major source of air emissions according to the new source review (NSR) prevention of significant deterioration of air quality (PSD) regulations. The facility is major for nitrogen oxides (NO x ), carbon monoxide (CO), and particulate matter (PM) because the potential to emit (PTE) NO x, CO, and PM is each greater than the PSD major source threshold of 100 tons per year (ton/yr). Note: PCS manufactures nitric acid which is one of the 28 named categories whose major source threshold is 100 ton/yr (nitric acid plants). The facility has taken the following limits to avoid PSD review: PCS Nitrogen Fertilizer, L.P., TV Page 2 of 12

3 The sulfur content of No. 2 fuel oil fired in Boiler H 6531 and the ABB/CE Boiler is limited to 0.15 percent sulfur by weight. The ABB/CE Boiler is limited to firing natural gas and No. 2 fuel oil. Natural gas fired in ABB/CE Boiler is limited to 1,591 million cubic feet during any period of 12 consecutive months. The ABB/CE Boiler is limited to specific emission rates for PM/PM 10, NO X, and CO while firing natural gas. The ABB/CE Boiler is limited to 1,849,020 gallons of fuel oil usage per 12-month period. The ABB/CE Boiler is limited to specific emission rates for PM/PM 10, NO X, and CO while firing fuel oil. Emission of NO X from the ABB/CE Boiler is limited to less than 40 tons per year (ton/yr). The Rental Boiler is limited to firing only natural gas. The Rental Boiler is permitted to operate only when Boiler H6531 or the ABB/CE Boiler is not in operation. Emission of VOC from the Ammonia Plant is limited to 163 tons during any period of 12 consecutive months. Emission of CO from the Ammonia Plant is limited to 166 tons during any period of 12 consecutive months. The gas turbine for the ammonia plant is limited to a minimum steam injection rate of 5,000 pounds per hour (lb/hr) or the value established in the most recent performance test, whichever is greater, on a continuous basis to minimize NO x emission. Emission of NO X from the Ammonia Plant Gas Turbine is limited to 54 ppm at 15 percent oxygen after the completion of the modifications described in Application No Urea prills production from the C002 Urea Plant Prill is limited to 474,000 tons during any period of 12 consecutive months. Emission of PM from the C002 Urea Plant Prill Tower is limited to 0.29 pound per ton (lb/ton) of urea produced. The facility has taken the following limits as a result of a PSD BACT review: Emission of NO X from the C002 Nitric Acid Plant is limited to 3.0 lb/ton of 100 percent nitric acid produced. Opacity from the C002 Nitric Acid Plant is limited to less than 10 percent. Emission of NO x from the C002 Nitric Acid Plant is limited to 507 tons during any period of 12 consecutive months. Emission of CO from the C002 Nitric Acid Plant is limited to 30.0 lb/ton of 100 percent nitric acid on a 12-month rolling average. PCS Nitrogen Fertilizer, L.P., TV Page 3 of 12

4 2. Title V Major Source Status by Pollutant Table 3: Title V Major Source Status Pollutant Is the Pollutant Emitted? If emitted, what is the facility s Title V status for the Pollutant? Major Source Status Major Source Requesting SM Status Non-Major Source Status PM Yes PM 10 Yes PM 2.5 Yes SO 2 Yes VOC Yes NO x Yes CO Yes TRS H 2 S Individual HAP Yes Total HAPs Yes Total GHGs Yes II. Proposed Modification A. Description of Modification This modification is a turnaround repairs and replacement of equipment in the ammonia plant which will result in an increase in production capacity and actual emission rates. The total plant outage will permit PCS to perform needed maintenance on the Urea Plant, Pastille Plant, Nitric Acid Plants, Ammonium Nitrate Plants, and Utilities. The turnaround is a preventive maintenance program that is executed every four to six years during which equipment is replaced to prevent failure of the process equipment during future operation or upgraded to allow capacity expansion. As a result of this turnaround, ammonia production is expected to increase by approximately 5 percent from 2475 tons per day (ton/day) to 2,600 ton/day. This turnaround maintenance or replacement may involve the following equipment: Replacement of the R-6152 ammonia synthetic converter. The replacement converter will have about 15 percent more catalyst which will support increase in production. Replacement/Upgrade of the E-6184 syngas turbine surface condenser to reduce energy consumption. Upgrade of boiler feed water pumps or the addition of parallel pump(s) to improve boiler feed water capacity and reliability. Replacement of the starter steam turbine, which is connected to the GE Gas Turbine, with a continuous running helper turbine to increase horsepower to the main compressor. The helper turbine will utilize 1500 pound steam pressure from the plant, thus improving the energy efficiency of the GE Gas Turbine. Replacement and upgrade of the GE Gas Turbine and air compressor suction chilling media (end of life) and upgrade of chilled water distribution nozzles. PCS Nitrogen Fertilizer, L.P., TV Page 4 of 12

5 Replacement of case, parts and bearings on the Syngas Steam Turbine. Installment of upgraded condensate pumps on the syngas compressor surface condenser. Replacement of the auxiliary process air compressor. Capacity expansion and separation efficiency upgrades in the purifying section (cold box) to support the syngas converter upgrade. Installment of high emissivity refractory coating on the reformer furnace (AM01) to improve energy efficiency of the furnace. Replacement of inefficient heat exchangers, E-6141, E-6157, E-6155A, E-6155B and miscellaneous exchanger modifications to improve performance. Improvements to decrease pressure drop in the plant steam systems and in the recycled process gas to reformer. Improvements in instrumentation and process analyzers for improved plant operation. Upgrade of the urea CO 2 compressor, K6701A and 6701B (low and high pressure cases) for better energy efficiency. Upgrade of CO 2 absorption system to increase solution circulation and the addition of a steam ejector to the solution flash tank to improve CO 2 stripping duty. B. Emissions Change The increase in ammonia production will result in a proportional emission increase of nitrogen oxides (NO x ), sulfur dioxide (SO 2 ), particulate matter with aerodynamic diameter less than or equal to 10 microns (PM 10 ), particulate matter with aerodynamic diameter less than or equal to 2.5 microns (PM 2.5 ), carbon monoxide (CO), and volatile organic compound (VOC). These pollutants are emitted through the turbine/primary reformer stack (ST-12) and the vent from the carbon dioxide solution regenerator (ST- 15).The increased CO 2, CO, and VOC emission will be vented through the ST-15 stack. Since PCS is a major source, any modification which results in a significant emission increase of a regulated NSR pollutant is required to undergo a PSD review. A PSD applicability analysis is necessary to determine if a PSD review is required. There are two approaches to a PSD review analysis: (1) actual-topotential emission increase and (2) actual-to-projected actual emission increase. PCS has chosen the actualto-projected actual emission increase approach for the PSD review analysis for NO x, SO 2, PM 10, PM 2.5, CO, and VOC. Irrespective of the approach chosen, the baseline actual emission (BAE) must be determined. The BAE means the average rate, in tons per year, at which the emissions unit actually emitted the pollutant during any consecutive 24-month period selected by the owner or operator within the 10 year period immediately preceding either the date the owner or operator begin actual construction of the project, or the date a complete permit application is received by the Division for a permit required under this paragraph or by the reviewing authority for a permit required by a plan, whichever is earlier. 1 [Note that the ammonia plant underwent a major modification of the primary reformer and that the plant did not start up with the modified reformer until November 2012.] The baseline period chosen is the 24-month period after the reformer modification, January 2013 through December 2014 since this period is a better representation of actual emissions. The PAE means the maximum annual rate, in tons per year, at which an existing emissions unit is projected to emit a regulated NSR pollutant in any one of the five years(12-month period) following the 1 GA Rule (7)(a)2(i)(II) PCS Nitrogen Fertilizer, L.P., TV Page 5 of 12

6 date the unit resumes regular operation after the project, or in any one of the 10 years following that date, if the project involves increasing the emissions unit's design capacity or its potential to emit that regulated NSR pollutant and full utilization of the unit would result in a significant emissions increase or a significant net emissions increase at the major stationary source. 2 Emissions change = PAE - BAE FE-DG = PAE Emissions change = FE DG - BAE DG = CHA - BAE Emissions change = FE (CHA BAE) BAE = FE - CHA Where: FE = Future Emissions projection (PTE for new units; for existing units, future highest 12- month period of emissions projected, before excluding demand growth DG = CHA = Demand Growth emissions (zero for new units; for existing units, projected changes in emissions that the unit could have accommodated during the baseline period and that are unrelated to the project) Could have accommodated emissions during the baseline period PCS determined the future emissions of NO x, CO, and VOC by plotting the ammonia production rate (ton/month) against the corresponding actual emission rate (ton/month). It estimated the future emission rate by extrapolating the straight line curve at the future production rate of 2,600 ton/day (79,083 ton/month). PCS determined the future actual total MMBtu/month by plotting the ammonia production rate (ton/month) against the corresponding MMBtu/month and extrapolating at the future ammonia production rate of 79, 083 ton/month. The future emission rate of SO 2, PM 10, and PM 2.5 were estimated using the future actual total MMBtu/month and the AP-42 emission factors. PCS estimated the amount of emissions that the unit could have accommodated by using the highest monthly emission rate during the baseline period and annualizing this rate by assuming that this rate occurred throughout the year. Note that in each case the highest monthly emission rate occurred during the baseline period of January 2013 through December 2014 as indicated below: Pollutant Highest Emission Month of occurrence Within Baseline Period? NO x October 2014 Yes SO 2 March/May 2014 Yes PM October 2014 Yes CO October 2014 Yes VOC December 2013 Yes Demand growth emission rates were calculated by subtracting the BAE from the annualized CHA (7)(a)2(ii)(I) PCS Nitrogen Fertilizer, L.P., TV Page 6 of 12

7 Following is a summary of the PSD assessment. [A detailed analysis termed PSD Applicability Assessment is available in the application package.] Baseline Actual Emissions Future Emissions (ton/yr) Could Have Accommodated Emissions Demand Growth Emissions Emissions Increases Stack ID (ton/yr) (ton/yr) (ton/yr) (ton/yr) ST Total Emissions Increase (ton/yr) PSD Significant Level (ton/yr) Pollutant Unit Turbine Reformer NO x Exhaust No Boiler 6531 ST Turbine Reformer ST Exhaust SO No Boiler 6531 ST Turbine Reformer ST Exhaust PM No Boiler 6531 ST Ammonia Plant ST (Turbine Reformer/Regenerator) PM No Boiler 6531 ST Ammonia Plant (Turbine Reformer/Regenerator) ST 12/15/16/ CO No Boiler 6531 ST Ammonia Plant (Turbine Reformer/Regenerator) ST 12/15/16/ VOC No Boiler 6531 ST PSD Triggered? PCS Nitrogen Fertilizer, L.P., TV Page 7 of 12

8 Table 4: Emissions Change Due to Modification Pollutant Is the Pollutant Emitted? Net Actual Emissions Increase (Decrease) (tpy) Net Potential Emissions Increase 3 (Decrease) (tpy) PM Yes PM 10 Yes PM 2.5 Yes SO 2 Yes VOC Yes (11.2) (11.2) NO x Yes (14.3) (14.3) CO Yes TRS No H 2 S No Individual HAP No Total HAPs No Total GHGs Yes 3 This is actually the net emissions change resulting from the modification. Emissions of NO x and VOC are decreasing even while increasing the ammonia production rate because of efficiency improvements made to the system which reduced energy consumption. (See IIA, Description of Modification) PCS Nitrogen Fertilizer, L.P., TV Page 8 of 12

9 C. Title I Modification PSD/NSR Applicability The modification is not subject to PSD/NSR. NSPS Modification The modification does not trigger any new NSPS requirement. NESHAP Modification The modification does not trigger any NESHAP. III. Facility Wide Requirements A. Emission and Operating Caps None applicable. B. Applicable Rules and Regulations None. C. Compliance Status The Permittee has not indicated any non-compliance. D. Operational Flexibility None requested. E. Permit Conditions None. PCS Nitrogen Fertilizer, L.P., TV Page 9 of 12

10 IV. Regulated Equipment Requirements A. Brief Process Description The facility is seeking authorization to perform a turnaround repair and replacement on the existing ammonia plant as indicated in Section IIA. B. Equipment List for the Process Emission Units Applicable Air Pollution Control Devices ID No. Description Requirements/Standards ID No. Description AB01 Boiler H CFR 63 Subpart DDDDD None None (2)(d) (2)(g) AB03 ABB/CE Boiler 40 CFR 63 Subpart DDDDD None None (2)(d) (2)(g) AB02 Rental Boiler 40 CFR 63 Subpart DDDDD None None 40 CFR 60 Subpart Db (2)(b) (2)(d) (2)(g) GT01 Ammonia Plant Gas Turbine 40 CFR 60 Subpart GG ST1 Steam Injection System AM01 Ammonia Plant Primary (2)(d) None None Reformer Furnace (2)(g) AM04 Ammonia Plant Solution (2)(b) None None Regenerator Vent (2)(e) ACI1 ACI Compressor Skid Vent None None None ACI3 ACI Water Stripper (2)(b) None None (2)(e) U201 C002 Urea Plant Prill Tower (2)(b) None None (2)(e) 40 CFR 63 Subpart FFFF G2 U202 C002 Urea Plant Central 40 CFR 63 Subpart FFFF G2 None None Vent Stack (ST-6751) U203 C002 Urea Plant CFR 63 Subpart FFFF G2 None None Process Vent FUG C002 Urea Plant LDAR 40 CFR 63 Subpart FFFF None None Valves, pumps, connectors, agitators, pressure relief devices, compressors, sampling connection systems, open-ended valves or lines, and closed vent systems and control devices 40 CFR 65 Subpart F FUG C002 Urea Plant Wastewater 40 CFR 63 Subpart FFFF G2 None None Stream(s) U108 Formaldehyde Tank 40 CFR 63 Subpart FFFF G2 None None P01 Urea Pastille Plant None None None Crystallization P02 Urea Pastille Plant Dryer (2)(b) (2)(e) F1 Scrubber P03 Urea Pastille Plant Rotoformers (2)(b) (2)(e) P04 Urea Pastille Plant Dome Warehouse (2)(b) (2)(e) N101 C001 Nitric Acid Plant 40 CFR 60 Subpart G N201 C002 Nitric Acid Plant 40 CFR CFR 60 Subpart G F1 F2 C101 AP07 Scrubber Baghouse SCR System NSCR System PCS Nitrogen Fertilizer, L.P., TV Page 10 of 12

11 Emission Units Applicable Air Pollution Control Devices ID No. Description Requirements/Standards ID No. Description NST1 through Nitric Acid Tanks (2)(a)1 AVS1 Acid Vent Scrubber System NST8 AN01 C001 AN Plant Neutralizer (2)(b) VS01 Scrubber (2)(e) A105 C001 AN Plant Prill Tower (2)(b) None None (2)(e) A103 C001 AN Plant Prill Dryer (2)(b) AP08 Cyclone (2)(e) A104 C001 AN Plant Prill Cooler (2)(b) AP09 Cyclone (2)(e) AN02 C002 AN Plant Neutralizer (2)(b) VS02 Scrubber (2)(e) A201 C002 AN Plant Prill Tower (2)(b) AP02 Scrubber (2)(e) A204 C002 AN Plant Prill Dryer (2)(b) AP05 Scrubber (2)(e) A202 C002 AN Plant Prill Cooler (2)(b) (2)(e) AP03 Scrubber AB04 Synloop Startup Heater (H- 6151) C. Equipment & Rule Applicability 40 CFR 63, Subpart A 40 CFR 63, Subpart DDDDD (2)(d) (2)(g) The only pollutant with an actual increase in the emission rate is ammonia which is subject to modelling under the Georgia Toxic Guidelines. All the other pollutant emission limits remain the same. An increase in emissions of any toxic air pollutant (TAP) or the emission of a TAP not previously emitted potentially subjects the facility to the Toxic Guidelines. A TAP is any substance that may have an adverse effect on public health excluding any specific substance that is covered by a state or federal ambient air quality standard. The State of Georgia Guideline For Ambient Impact Assessment of Toxic Air Pollutant Emissions requires ambient impact assessments for toxic chemical compounds emitted into the air. AERMOD dispersion model (v ) was used to perform the air toxic analysis for ammonia by PCS consultant. The annual and 15-minute AACs of ammonia were reviewed based on U.S. EPA IRIS reference concentration (RfC), OSHA Permissible Exposure (PEL), ACGIH Threshold Limit Values (TLV) including STEL (short term exposure limit) or ceiling limit, and NIOSH Recommended Standards (REL) according to the Georgia Air Toxics Guideline. The modeled MGLCs were calculated for 1-hour and annual averaging periods. Table 1 lists the AAC levels and MGLCs of ammonia. The maximum 15-min impact is based on the maximum 1-hour modeled impact multiplied by a factor of The modeled MGLCs are below their respective AAC levels. Therefore, the applicant meets the applicable Georgia Air Toxics Guideline. None None PCS Nitrogen Fertilizer, L.P., TV Page 11 of 12

12 Table 1. Modeled MGLCs and the Respective AACs at Annual and 15-min Averaging Periods Averaging AAC MGLC Averaging AAC MGLC TAP Period [µg/m 3 ] [µg/m 3 ] Period [µg/m 3 ] [µg/m 3 ] Ammonia Annual min D. Compliance Status The facility has not indicated any non-compliance. E. Operational Flexibility None requested. F. Permit Conditions New General Permit Condition which requires the facility to submit performance test results to the US EPA's Central Data Exchange is added. Pursuant to Georgia Rule (7)(b)15(i)(III), new Condition requires the Permittee to monitor the emissions of NO x, VOC, PM, PM 10, PM 2.5, CO, and SO 2 and calculate and maintain a record of the annual emissions in tons per year on a calendar basis for a period of ten years. These records are required to be retained for a period of five years past the end of each calendar year. Pursuant to Georgia Rule (7)(b)15(i)(V), new Condition requires the Permittee to submit a report to the Division, within 60 days after the end of each year, setting out the turnaround annual emissions of NO x, VOC, PM, PM 10, PM 2.5, CO, and SO 2 and, if applicable, the turnaround actual increase in emissions during the calendar year that preceded submission of the report. The Permittee is required to notify the Division if the emissions of NO x, VOC, PM, PM 10, PM 2.5, CO, and SO 2 exceed the indicated amounts. PCS Nitrogen Fertilizer, L.P., TV Page 12 of 12