Air Quality Program Non Radioactive Emissions TFC-ESHQ-ENV ... · Air Quality Program – Non...

Air Quality Program – Non Radioactive

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TFC-ESHQ-ENV-STD-04, REV C-6

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Ownership matrix

RPP-27195

TABLE OF CONTENTS

1.0 PURPOSE AND SCOPE ................................................................................................................ 2 2.0 IMPLEMENTATION ..................................................................................................................... 2 3.0 STANDARD ................................................................................................................................... 2

3.1 National Emission Standards for Hazardous Air Pollutant (NESHAP).............................. 3 3.2 Standards of Performance for New Stationary Sources ...................................................... 5 3.3 State Regulations for Air Pollutant Sources and Controls .................................................. 7 3.4 Ozone Depleting Substances Requirements ..................................................................... 12 3.5 Asbestos ............................................................................................................................ 13 3.6 Open Burning .................................................................................................................... 13 3.7 Reporting and Notifications .............................................................................................. 14 3.8 Record Keeping ................................................................................................................ 16 3.9 Assessments ...................................................................................................................... 17 3.10 Records ............................................................................................................................. 17

4.0 DEFINITIONS .............................................................................................................................. 17 5.0 SOURCES ..................................................................................................................................... 18

5.1 Requirements .................................................................................................................... 18 5.2 References ......................................................................................................................... 20

TABLE OF ATTACHMENTS

ATTACHMENT A - STATIONARY COMPRESSION IGNITION INTERNAL COMBUSTION

ENGINE MODEL YEAR REQUIREMENTS .......................................................................... 21 ATTACHMENT B - STATIONARY SPARK IGNITION INTERNAL COMBUSTION ENGINE

MANUFACTURE DATE REQUIREMENTS .......................................................................... 22 ATTACHMENT C – METHOD 22 VISIBLE EMISSION SURVEY OUTLINE .................................... 23 ATTACHMENT D – FUGITIVE OR SMOKE EMISSION INSPECTION OUTDOOR LOCATION ... 24 ATTACHMENT E – METHOD 9 VISIBLE EMISSION SURVEY OUTLINE ...................................... 25 ATTACHMENT F – RECORD OF VISUAL DETERMINATION OF OPACITY .................................. 26 ATTACHMENT G – METHOD 9 OBSERVATION RECORD ............................................................... 27


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1.0 PURPOSE AND SCOPE

This standard describes how Washington River Protection Solutions, LLC (WRPS)

Environmental Protection Program manages compliance, regulatory requirements and flow down

of the Non-radioactive Air Program as well as interactions with the regulators, U.S. Department

of Energy (DOE) Office of River Protection (ORP) and Richland Operations (RL), and other

Hanford Site Contractors.

This standard also identifies the requirements and provides direction for the implementation of

those requirements for activities that discharge criteria and toxic air pollutants, and addresses

asbestos, open burning, ozone depleting substances, and greenhouse gases.

The standard describes the processes for implementing WRPS environmental requirements for air

quality in a manner that:

Protects human health and the environment

Meets applicable federal, state, and local environmental regulations, permits, and

compliance agreements and orders

Fulfills contractual obligations with DOE, and all DOE applicable DOE orders and

documents

Implements all applicable tenets of the WRPS Environmental Management System

(EMS) and the WRPS Integrated Safety Management System (ISMS)

Satisfies the compliance obligations element of the International Organization for

Standardization (ISO) 14001, as directed by TFC-PLN-123

Addresses a major element, or significant aspect of the EMS.

This Standard does not apply to projects performed in accordance with the Comprehensive

Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). Those projects

are subject to Applicable or Relevant and Appropriate Requirements and Work Plans developed

under TFC-ESHQ-ENV_PP-C-18. Contact the assigned Environmental Field Representative for

additional guidance.

2.0 IMPLEMENTATION

This standard is effective on the date shown in the header.

3.0 STANDARD

Environmental Protection is responsible for requirement identification, flow down and

implementation. Environmental Protection organization is responsible for the review of

regulatory documents and the identification of new, modified, or obsolete requirements. The

requirements may originate from permits, federal, state or local regulations, U.S. Department of

Energy Orders, contracts or any other enforceable documents. Any new requirements shall be

identified and implemented using TFC-ESHQ-ENV-PP_C-02. Requirements are managed

through TFC-ESHQ-ENV_PP-C-02, and the implementation flow down is documented through


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the use of the Requirements Mapping Database (RMD) Software. Environmental requirements

for the different emission units are documented in RPP 16922.

3.1 National Emission Standards for Hazardous Air Pollutant (NESHAP) (5.1.1, 5.1.2.a, 5.1.3.a, 5.1.4.a)

Hazardous air pollutants are pollutants that are known or suspected to cause cancer or other

health effects.

40 Code of Federal Regulations (CFR) 61, “National Emission Standards for Hazardous Air

Pollutants” identifies and provides emission standards for hazardous air pollutants (HAPs)

emitted from stationary sources.

40 CFR 63, “National Emission Standards for Hazardous Air Pollutants for Source Categories,”

identifies and provides emission standards and the maximum achievable control technologies

(MACT) for HAP emitted from source categories. Of particular interest are 40 CFR 63, Subpart

A, “General Provisions,” and Subpart ZZZZ, “NESHAP for Stationary Reciprocating Internal

Combustion Engines.” The Washington State Department of Ecology (Ecology) adopted the 40

CFR 63 regulations by reference in WAC 173-400-075. Of primary concern are the standards

that apply to stationary engines and asbestos. The stationary engine standards are described in

Section 3.1.1 and the asbestos standards are described in Section 3.6.

40 CFR 60, “Standards of Performance for New Stationary Sources,” identifies general and

performance standards, monitoring and maintenance requirements for new stationary sources. Of

main importance are Subpart A, “General Provisions;” Subpart IIII, “Standards of Performance

for Stationary Compression Ignition internal Combustion Engines;” and Subpart JJJJ, “Standards

of Performance for Stationary Spark Ignition Internal Combustion Engines.” Ecology adopted

the 40 CFR 60 regulations by reference in WAC 173-400-115.

40 CFR 52.21, “Prevention of Significant Deterioration of Air Quality (PSD),” addresses

construction or major modifications of major stationary sources and provides pollutant and

emission rate standards. Due to the Waste Treatment Plant, the Hanford Site is considered to be a

major source; therefore, the major source requirements in the regulations are applicable. Ecology

adopted the 40 CFR 52.21 regulations by reference in WAC 173-400-720(4)(a).

3.1.1 Standards for Stationary Reciprocating Internal Combustion Engines (RICE) (5.1.4.b, 5.1.16, 5.1.18.b, 5.1.18.d, 5.1.18.k)

The NESHAP standards for stationary RICE are addressed in 40 CFR 63, Subpart ZZZZ.

Stationary engines that are brought onto the Hanford Site are required to meet the applicable

requirements. The specific requirements for a particular engine, based on break horse power

(BHP), year, and fuel used, are identified by using the EPA web tool at the link below.

http://www.epa.gov/ttn/atw/icengines/comply.html

See TFC-ESHQ-ENV_PP-C-05 for implementation of permitting and notification requirements

for stationary RICE. The following records must be kept:

Maintenance conducted on the engine

Notification submitted to the regulatory agencies to comply with New Source

Performance Standards (NSPS) requirements


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Hours of operation, including for emergency engines, hours of operation for non-

emergency and emergency use

Other records as required by the 40 CFR 63, Subpart ZZZZ, for specific engines once

identified through use of EPA’s web tool discussed earlier in this Section.

3.1.1.1 Requirements for New or Reconstructed RICE ≤ 500 bhp

Stationary spark ignition (SI) engines with a site rating of ≤ 500 bhp (except new or reconstructed

4 stroke lean burn stationary RICE) are required to meet the SI NSPS described in Section 3.2.1.

New and reconstructed compression ignition (CI) engines with a site rating of ≤ 500 bhp must

meet the CI NSPS standards described in Section 3.2.1.

Additionally, new or reconstructed 4 stroke lean burn stationary engines with a site rating of

> 250 bhp and ≤ 500 brake HP are required to either reduce CO emissions by 93% or more, or

limit the concentration of formaldehyde in the stationary engine exhaust to 14 ppmvd or less, at

15% oxygen.

3.1.1.2 Requirements for Existing RICE ≤ 500 BHP and Non-Emergency RICE > 500 BHP

Existing RICE ≤ 500 bhp of all types (e.g., emergency, non-emergency, and limited use), and all

non-emergency RICE > 500 HP are required to meet the applicable fuel use, emissions

limitations, installation, startup, performance testing, operation, maintenance and work practices

(e.g., oil and filter change requirements), notification, reporting, and recordkeeping requirements.

Existing emergency RICE ≤ 500 bhp are to be operated according to the requirements in 40 CFR

63.6640(f) as described below in Section 3.1.1.3.

3.1.1.3 Requirements for Emergency and Limited Use RICE > 500 BHP

New and reconstructed emergency and limited RICE > 500 HP are only required to meet the

notification requirements of 40 CFR 63.6645.

Emergency RICE > 500 bhp are to be operated and maintained in a manner consistent with safety

and good air pollution control practices for minimizing emissions per 40 CFR 63.6605(b).

Existing, limited use RICE > 500 HP are not subject to 40 CFR 63 ZZZZ requirements.

Existing emergency RICE > 500 HP are not subject to additional requirements unless the engine

has a displacement of less than 30 liters per cylinder, uses diesel fuel, and operates or is

contractually obligated to be available for more than 15 hours per calendar year as specified in 40

CFR 63.6640(f). These engines are required to use fuel that meets the requirements in 40 CFR

80.510(b), except that any existing diesel fuel purchased (or otherwise obtained prior to January

1, 2015, may be used until depleted).

Emergency RICE are to be operated according to the requirements in 40 CFR 63.6640(f). There

is no time limit on the use of emergency stationary RICE in emergency situations. The

emergency stationary RICE may be operated for up to 100 hours per year for the purpose of

maintenance checks and readiness testing, provided that the tests are recommended by Federal,

State or local government, the manufacturer, the vendor, or the insurance company associated

with the engines. The emergency RICE maybe operated up to 50 hours per year in non-


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emergency situations, but those 50 hours per year are counted towards the 100 hours per year

provided for maintenance and testing.

3.2 Standards of Performance for New Stationary Sources (5.1.2.b, 5.1.2.c, 5.1.4.b, 5.1.20.d, 5.1.20.i)

The EPA has developed standards for the performance of control equipment utilized within the

industrial source categories. There are over 60 NSPS for various industry and equipment types

that are identified in the subparts to 40 CFR 60. The subparts typically require notification,

emission limitations, monitoring requirements, recordkeeping requirements, and reporting

requirements. Of primary concern are the NSPS for stationary CI and SI ICE that are described

further in Section 3.2.1.

Ecology incorporates the NSPS in 40 CFR 60 by reference in WAC 173-400-115. There are

some exceptions listed in WAC 173-400-115(c).

3.2.1 Standards for Stationary Spark Ignition and Compression Ignition Internal Combustion

Engines (5.1.2.b, 5.1.2.c, 5.1.6)

The NSPS for stationary SI Internal Combustion Engines (ICE) (e.g., engine fueled by gasoline)

are found in 40 CFR 60, Subpart JJJJ. The NSPS for stationary CI ICE (e.g., engines fueled by

diesel) are found in 40 CFR 60 Subpart IIII. The specific requirements for a particular engine,

based on bhp, year, and fuel used, can be identified by using the EPA web tool for how to comply

at the link below:

http://www.epa.gov/ttn/atw/icengines/comply.html

See TFC-ESHQ-ENV_PP-C-05 for implementation of permitting and notification requirements

for stationary CI and SI ICE.

Stationary engines that are brought onto the Hanford Site are required to be manufactured after

the date identified in Attachment A for SI ICE, must meet the model year listed in Attachment B

for CI ICE, and both must be certified by the manufacturer to meet the applicable emission

standards, and be equipped with an hour meter.

Engine manufacturers must certify that their stationary SI or CI ICE meet emission standards

based on engine sizes and model year or date of manufacture. Only SI or CI ICE that have been

certified to meet the appropriate emission standards shall be used on the Hanford Site. Exceptions

may be made for engines that already exist on the Hanford Site with prior WRPS Environmental

Protection approval, provided that the performance testing and any additional requirements are

met.

Gasoline used in stationary SI ICE must meet the requirements of 40 CFR 80.195. The

requirements include a sulfur per gallon cap of 80 parts per million (ppm).

Stationary CI ICE with a displacement of less than 30 liters (L) per cylinder must use only diesel

fuel that has a maximum sulfur content of 15 ppm and either a minimum cetane index of 40 or a

maximum aromatic content of 35 percent volume (40 CFR 80.510(b) for non-road diesel fuel).

Stationary CI ICE with a displacement of more than or equal to 30 L per cylinder must use only a

fuel that meets a maximum per-gallon sulfur content of 1,000 ppm.


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In order for the engine to be considered a certified engine, the engine and control device must be

operated and maintained in accordance with the manufacturer’s emission related written

instructions. OR If the manufacturer’s instructions will not be followed, then a maintenance plan

and records must be kept to demonstrate compliance, and to the extent practicable, the engine is

to be maintained and operated consistent with good air pollution control practices for minimizing

emissions. In addition, performance testing may be required depending on the horsepower of the

engine.

Emergency CI ICE are to be operated according to the requirements in 40 CFR 60.4211(f) and

Emergency SI ICE are to be operated according to the requirements in 40 CFR 60.42439(d).

There is no time limit on the use of emergency stationary CI or SI ICE in emergency situations.

The emergency stationary CI or SI ICE may be operated for up to 100 hours per year for the

purpose of maintenance checks and readiness testing, provided that the tests are recommended by

Federal, State or local government, the manufacturer, the vendor, or the insurance company

associated with the engines. The emergency CI or SI ICE maybe operated up to 50 hours per year

in non-emergency situations, but those 50 hours per year are counted towards the 100 hours per

year provided for maintenance and testing.

If a stationary CI ICE is equipped with a diesel particulate filter to comply with the emission

standards in § 60.4204, the diesel particulate filter must be installed with a backpressure monitor

that notifies the operator when the high backpressure limit of the engine is approached.

The following records must be kept:

Maintenance conducted on the engine

Manufacturer’s engine certification or verify that the engine has been certified. With the

engine family number from the engine plate, the emission certification information for

most engines can be found on the EPA web page at the link below:

http://www.epa.gov/otaq/certdata.htm

Notifications submitted to the regulatory agencies to comply with NSPS requirements

Hours of operation

Records of any corrective action taken after the backpressure monitor has indicated that

the high backpressure limit of the engine was approached

Other records as required by the NSPS for specific engines once identified through use of

EPA’s web tool discussed earlier in this Section.


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3.3 State Regulations for Air Pollutant Sources and Controls (5.1.16, 5.1.18.e, 5.1.19.b, 5.1.20, 5.1.21, 5.1.22, 5.1.23)

The EPA has delegated enforcement of the Clean Air Act (CAA) to Ecology. In addition to the

federal CAA the Washington State Clean Air Act described in Revised Code of Washington

(RCW) 70.94 was written to further protect humans and the environment from air pollution. The

CAA of Washington is stricter than the federal regulations. The state has also promulgated

administrative codes to implement RCW 70.94.

WAC 173-400, “General Regulations for Air Pollution Sources,” defines emission and

performance standards for both portable and stationary sources, identifies the permitting and

notification requirements, reporting requirements, fees and site inspection requirements. WAC

173-400 adopts 40 CFR 63, Subpart ZZZZ, “National Emission Standards for Hazardous Air

Pollutants for Stationary Reciprocating Internal Combustions Engines,” and 40 CFR 60, Subpart

IIII, “Standards of Performance for Stationary Compression Ignition Internal Combustions

Engines” and 40 CFR 60, Subpart JJJJ, “Standards of Performance for Stationary Spark Ignition

Internal Combustions Engines.” WAC 173-400 also adopts 40 CFR 52.21, “Prevention of

Significant Deterioration of Air Quality” by reference, with some exceptions as identified in

WAC 173-400-720.

WAC 173 401, “Operating Permit Regulation,” establishes the elements of a comprehensive State

air operating permit program, outlining requirements for applications, emission standards, limits,

monitoring, reporting and recordkeeping.

WAC 173 460, “Controls for New Sources of Toxic Air Pollutants”, establishes emission limits

and controls for new toxic emissions sources to protect human health and the environment. If the

emissions from a source exceed the Acceptable Source Impact Levels (ASIL), WAC 173 460

requires a Tier II Health Impacts Assessment to evaluate the health impacts of the project.

WAC 173 455, “Air Quality Fee Rules,” as implemented through the Hanford Site Air Operating

Permit #00 05 006, addresses numerous air quality fees including air contaminant source

registration fees, control technology fees, New Source Review fees, and nonroad engine permit

fees.

The permitting requirements and implementation associated with these rules are addressed in

TFC-ESHQ-ENV_PP-C-05 and the reporting requirements and implementation are addressed in

TFC-ESHQ-ENV_PP-C-10.

3.3.1 General Standards (5.1.20.c)

The following general requirements and emission standards as identified in WAC 173-400-040

apply to all WRPS sources and emission units.

1. Use reasonably available control technology.

2. Ensure that contaminants with more than 20% opacity are not released from any existing

source for more than 3 min/hr.


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3. Ensure that no existing source emits particulate matter in a manner that allows the matter

to be deposited (fallout) beyond the Hanford Site boundary in sufficient quantity to

interfere unreasonably with the use and enjoyment of offsite property.

4. Take reasonable precautions to prevent air pollutant emissions resulting from fugitive

emissions (e.g., use best available control measures that are appropriate for the activity).

5. Minimize dust generation caused by construction, demolition, cleanup, or operation

related activities.

6. Reduce, to a reasonable minimum, any odors that unreasonably interfere with offsite

property use or enjoyment by using recognized good practices and procedures.

7. Ensure that no existing source emits any air pollutant that causes detriment to the health,

safety, or welfare of any offsite person or causes damage to offsite property or

businesses.

8. Ensure that no existing sources emit a gas containing sulfur dioxide from any emission

unit in excess of 1,000 ppm of sulfur dioxide on a dry basis, corrected to 7% oxygen for

combustion sources, and based on the average of any period of 60 consecutive minutes.

9. Do not conceal or mask air pollutants that would violate any federal, state, or local

regulation or standard.

3.3.2 Excess Non-Radioactive Airborne Emissions (5.1.20.g)

Excess emissions are emissions of an air pollutant in excess of any applicable emissions standard.

Excess emissions shall be reported to Ecology, or the authority, as soon as possible if they

represent a potential threat to human health or safety, and if the owner or operator believes them

to be unavoidable emissions. Other excess emissions shall be reported within thirty days after the

end of the month during which the event occurred, or as part of a routine emission monitoring

report (i.e., the AOP Semiannual Report). Ecology, or the Authority, may request submittal of a

full written report including known causes, corrective actions taken and preventive measures to

be taken to minimize or eliminate the chance of recurrence (WAC 173-400-107).

Unavoidable emissions are those due to startup or shutdown, maintenance, and upsets. The

emissions must be reported in a timely manner and the reported information must adequately

demonstrate the following criteria (WAC 173-400-109):

1. Excess emissions due to startup or shutdown:

The emissions could not have been prevented through careful planning and

design; startup or shutdown was done as expeditiously as practicable

All emission monitoring systems were kept in operation unless their shutdown

was necessary to prevent loss of life, personal injury, or severe property damage

Emissions were minimized consistent with safety and good air pollution control

practice during the startup and shutdown period,


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If a bypass of control equipment occurred, such bypass was necessary to prevent

loss of life, personal injury, or severe property damage.

2. Excess emissions due to scheduled maintenance:

The emissions could not have been avoided through reasonable design, better

scheduling for maintenance, or through better operation and maintenance

practices.

3. Excess emissions due to upsets:

The event was not caused by poor or inadequate design, operation, maintenance,

or any other reasonably preventable condition

The event was not of a recurring pattern indicative of inadequate design,

operation, or maintenance

The operator took immediate and appropriate corrective action in a manner

consistent with good air pollution control practice for minimizing emissions

during the event, including slowing or shutting down the emission unit when the

operator knew or should have known that an emission standard or permit

condition was being exceeded

All emission monitoring systems were kept in operation to the extent possible

unless their shutdown was necessary to prevent loss of life, personal injury, or

severe property damage.

Unavoidable excess emissions are violations of the applicable requirement, as are all

excess emissions. They are subject to injunctive relief but are excused from penalty. The

permitting authority decides whether the excess emission were unavoidable. It is the

burden of the owner/operator to prove that the excess emissions were unavoidable.

3.3.3 Prevention of Significant Deterioration (PSD) (5.1.1, 5.1.20.j)

WAC 173-400-720 adopts portions of 40 CFR 52.21 by reference, with some exception as

identified in the regulation. The permitting requirements and processes associated with this rule

are addressed in TFC-ESHQ-ENV_PP-C-05.

3.3.4 New Source Reviews and Permitting Processes (5.1.20.h, 5.1.16, 5.1.23)

The requirements and processes for evaluating air emissions and preparing the associated

documentation to establish or modify criteria and toxic air emissions sources are provided in

TFC-ESHQ-ENV_PP-C-05. The topics addressed are New Source Reviews and criteria and

toxic Notice of Construction (NOC) applications, AOP modification forms, Ecology fee forms,

Health Impact Assessment (HIA) Tier II Reviews, Nonroad engines Notice of Intent (NOI) to

operate, stationary engine permitting, General Air Quality permits/approvals, PSD permitting,

and closure processes for NOC applications and emission sources.


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3.3.5 Air Operating Permit (AOP) (5.1.5, 5.1.13, 5.1.18.a, 5.1.19)

The DOE and Hanford Site Contractors fulfill the requirements of the Hanford Site Title V Air

Operating Permit (AOP) #00-05-006. The AOP was prepared and issued in accordance with the

applicable provisions of 40 CFR 70 and WAC 173-401. It was issued with Ecology as the lead

permitting authority; and contains the terms and conditions set forth by Ecology, Washington

Department of Health (WDOH), and the Benton Clean Air Agency (BCAA) for operation of air

emission sources on the Hanford Site.

TFC-ESHQ-ENV_PP-C-08 establishes the requirements and processes for compliance with the

reporting and renewal requirements of the AOP. TFC-ESHQ-ENV_PP-C-05 implements

requirements and provides direction for the permitting aspects of evaluating, establishing,

modifying and closing sources of criteria and toxic air pollutants (TAP) in accordance with WAC

173-401 and WAC 173-400. (5.1.21.b)

DOE-RL and DOE-ORP have signed a memorandum of agreement (MOA) that describes the

interfaces and authorities for their respective organizations with respect to management and

responsibility for site wide environmental permits, including the AOP. In accordance with the

MOA, DOE-RL is responsible for regulatory compliance and acts as signatory for regulatory

agreements.

For site-wide submittals requiring certification by a responsible official, DOE-ORP provides

appropriate management certification to DOE-RL for incorporation into the final transmittal

along with the DOE-RL management certification. Other submittals to regulatory agencies are

handled by DOE-RL or DOE-ORP, as appropriate, for air emission sources assigned to their

respective contractors.

Hanford Site contractors include all contractors responsible for operation of air emission sources

subject to the requirements of the AOP. Specific duties and responsibilities apply only to assigned

air emission sources and include:

Developing and implementing processes and procedures to effectively evaluate proposed

new/modified air emission sources (i.e., NSR) to determine required air permitting

documentation (e.g., NOC application, AOP modification request form, NSR exemption

notification, temporary/portable source notification, asbestos notification of intent [NOI],

etc.)

Preparing required air permitting documentation for submittal to regulatory agencies

Developing and implementing processes and procedures to maintain and demonstrate

compliance with applicable AOP requirements (monitoring, reporting, recordkeeping,

etc.)

Requesting sufficient funding from DOE each fiscal year to comply with applicable AOP

requirements

Preparing draft documentation in response in regulatory agency requests or enforcement

actions

Providing AOP Team with copies of all submitted NOCs and received approval orders


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Providing AOP Team with data, information and management certifications necessary to

support preparation of required site-wide reports.

The AOP Team consist of Hanford Site contractor staff with the assigned responsibility to

coordinate and manage the overall site AOP program on behalf of DOE as explained in DOE/RL-

2001-25, latest revision, “Hanford Site Title V Operating Permit Program Plan.”

The Hanford Site AOP includes the following sections:

Standard Terms and Conditions (STGC)

Attachment 1 (Ecology Requirements)

Attachment 2 (Health Requirements)

Attachment 3 (BCAA Requirements).

Each section of the AOP was issued with an accompanying Statement of Basis that describes the

basis for requirements included in that section. The statement of basis is not an enforceable part

of the AOP, but provides insight into the thought processes and expectations of the regulatory

agencies with respect to specific permit terms and conditions. It includes references to the

applicable statutory or regulatory provisions, technical supporting information on specific

emission units, and clarifications of specific requirements.

3.3.6 Opacity (5.1.2.d, 5.1.2.e, 5.1.20.c, 5.1.21)

Attachment 1 of the AOP contains the WAC 173-400-040(2) general standard for opacity, which

prohibits visible emissions exceeding 20% opacity for more than 3 minutes in any 1 hour of an air

contaminant from any emissions unit or within a reasonable distance of the emissions unit except

for scheduled soot blowing/grate cleaning or due to documented water (e.g., steam). The term

“emissions unit” is defined in WAC 173-401-200 as, “any part or activity of a stationary source

that emits or has the potential to emit any regulated air pollutant or any pollutant listed under

section 112(b) of the CAA. This term is not meant to alter or affect the definition of the term

"unit" for purposes of Title V of the CAA.”

The general standard for opacity is applicable to each emissions unit operated by WRPS unless

another opacity requirement is specified in Attachment 1 of the AOP for a particular emissions

unit.

Visible emission surveys are needed to assess whether an emissions unit is meeting the applicable

opacity requirements. To determine the type and frequency of visible emission surveys required

for a particular emissions unit, consult the opacity condition in Attachment 1 of the AOP for the

particular emissions unit (for emissions unit with specific opacity requirements) or the periodic

monitoring provisions in Attachment 1 of the AOP (for all other emissions units). If the survey

type is not specified, use one of the following types as appropriate:

General Emission Check: Used to determine whether visible emissions are present

EPA Test Method 22: Used to determine the amount of time that visible emissions are present

EPA Test Method 9: Used to quantify the opacity of visible emissions

A general emission check consists of looking at the location where emissions would be present

and determining whether emissions are visible. It may be performed by anyone and will usually


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be documented via a rounds procedure. A Method 22 survey must only be performed by an

individual trained and knowledgeable regarding the effects of environmental conditions on the

visibility of emissions. Method 22 surveys must be performed per Attachment C and documented

on Attachment D. A Method 9 survey must only be performed by an individual certified to use

this test method. Method 9 surveys must be performed per Attachment E and documented on

Attachments F and G. All visible emission surveys are to be conducted during daylight hours;

and after the unit has reached normal operating temperature and revolutions per minute, or 15

minutes after startup.

3.4 Ozone Depleting Substances Requirements (5.1.7.a, 5.1.7.b, 5.1.10, 5.1.11)

Title 40 CFR 82, “Protection of Stratospheric Ozone,” outlines the rules that address the

requirements set forth by the CAA Title VI. The EPA defines ozone depleting substance (ODS)

as any substance that is designated as either a Class I or Class II substance. A Class I substance

includes chlorofluorocarbons (CFCs), halons, carbon tetrachloride, and methyl chloroform and

has the highest ozone-depleting potential, where Class II substances include

hydrochlorofluorocarbons (HCFCs) and deplete the ozone at a slower pace than Class I

substances. The complete list of Class I and Class II substances can be found in 40 CFR 82,

Subpart A, Appendix A and Appendix B, “Production and Consumption Controls.” Owners of

equipment meeting the definitions of appliances, commercial refrigeration equipment, or

industrial process equipment, and containing ODS shall comply with required practices specified

under 40 CFR 82, Subpart F, “Recycling and Emissions Reduction.”

DOE O 436.1, “Departmental Sustainability,” requires the development of a Site Sustainability

Plan (SSP) which identifies sustainability goals, including those for maximizing the use of safe

alternatives to ODS and phasing out the use of ODS. The SSP also requires an annual report

statusing the performance of its goals.

The Hanford Site AOP requires compliance with the labeling, procurement, maintenance, service,

disposal and recordkeeping standards relevant to stratospheric ozone protection under 40 CFR 82.

Owners of equipment meeting the definitions of appliances, commercial refrigeration equipment,

or industrial process equipment, and containing ozone-depleting substances shall comply with

required practices specified under 40 CFR 82, Subpart F. This is accomplished though

implementation of the Hanford Site ODS Program Plan.

3.4.1 Hanford Site ODS Program

The Hanford Site Ozone-Depleting Substances Program Plan (DOE/RL-2010-86, latest revision)

describes the programs and processes implemented on site to eliminate the acquisition, use and

release of ODS by maximizing the use of non-ODS containing alternatives and how the site

assures compliance with 40 CFR 82 requirements.

The Mission Support Contractor (MSC) is contracted with DOE to provide refrigerated

equipment services for the Hanford Site and manage the ODS Site Program. The scope of the site

program includes all ODS-containing equipment, including refrigeration appliances, MVACs and

fire suppression devices located on the Hanford Site. ODS generated or managed as part of

CERCLA regulated activities are included within the scope of the plan.

Site contractors responsible for buildings containing ODS equipment and/or appliances are

included in the site program and have specific duties and responsibilities to develop and


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implement processes and procedures to maintain and demonstrate compliance with the regulatory

requirements set forth in the Hanford Site ODS Program Plan.

MSC Fleet Services provides servicing, maintenance and repair of motor vehicle air conditioners

(MVAC) for General Services Administration (GSA)-leased or DOE-owned vehicles. Servicing

of vehicles owned or leased by sub-contractors must be in accordance with an approved

Statement of Work.

MSC Refrigeration Equipment Services (MSC RES) provides maintenance, servicing and repair

for stationary heating, ventilation, air conditioning (HVAC) equipment, refrigeration equipment,

and MVAC-like appliances for non-radiological facilities. HVAC and Refrigeration Equipment

Services for radiological facilities may be performed in-house or sub-contracted as necessary.

Contractors that do not use the service of MSC RES must:

Ensure that the technicians are properly trained and certified, and are using certified

recycling or recovering equipment as described in the Hanford Site ODS Program Plan,

Section 5.0.

Contact MSC RES upon receipt of purchased refrigerant containing equipment, and

request that it be included in the Site equipment inventory.

Report leaks to MSC RES so that they may be reported to RL as required.

3.5 Asbestos (5.1.3.b)

Asbestos is regulated by NESHAP 40 CFR 61 Subpart M, “Asbestos NESHAP,” and EPA has

delegated authority to Ecology.

In accordance with the requirements of AOP Attachment 3, and to satisfy the underlying

regulations found in 40 CFR 61, Subpart M, Hanford Site contractors submit Notices of Intent

(NOI) to Ecology for any planned activities that involve demolition or asbestos renovation above

a specific limit. Hanford Site contractors submit NOIs for each individual project, as applicable,

unless the activity is included as part of the site-wide annual NOI. Hanford Site contractors

submit an NOI amendment when the estimated amount of disturbed regulated asbestos-containing

material (RACM) increases by 20 percent or more.

Asbestos requirements are identified and implemented through TFC-ESHQ-S_IH-C-52 and

TFC-ESHQ-ENV-STD-13.

3.6 Open Burning (5.1.9, 5.1.22)

The BCAA has been delegated by Ecology to regulate open burning on the Hanford Site.

Requirements, originally promulgated in WAC 173-425, are implemented through BCAA

Regulation 1, Article 5. Open burning in and around Tank Farms is conducted by the MSC and

the Hanford Fire Department (MSC-RD-EI-15332).

The following materials shall not be burned in any open fire (except for fire training when in

accordance with BCAA, Regulation 1):

Garbage


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Dead animals

Asphaltic products

Waste petroleum products

Paints

Rubber products

Plastics

Cardboard

Treated wood

Construction debris

Metal

Paper (other than what is necessary to start a fire)

Any substance, other than natural vegetation, that normally emits toxic emissions, dense

smoke, or obnoxious odors.

Open burning shall be done between the hours of 9 a.m. and 1 hour before sunset on preset

BCAA approved “burn days.” For those preset days, the BCAA will make a “burn” or “no-burn”

designation based on current monitoring and meteorological data. This designation and any

alternate makeup day information are provided daily on the published burn message telephone

line (509-783-6198) and/or through the following BCAA web link:

http://bentoncleanair.org/index.php/burning/burndecision/

No building, structure, or vessel shall be demolished by intentional burning, either for demolition

or for fire training, without written approval, in the form of a special burning permit, from the

BCAA. The Hanford Fire Department shall be contacted before burning for permission to burn

(based on meteorological conditions and site preparations). A burning permit application shall be

obtained from the Hanford Fire Department. The application shall be provided by designated

individuals to the BCAA at least 5 working days before the proposed activity. Application fees

will be billed directly to DOE RL by the BCAA.

Radioactive contaminated material shall not be disposed of via open burning.

3.7 Reporting and Notifications (5.1.8, 5.1.12, 5.1.13, 5.1.14, 5.1.15, 5.1.18.a, 5.1.18.f, 5.1.19.a)

Reporting and notification requirements are stipulated in their respective regulations and permit

approval orders. Notification requirements as response actions to specific activities are identified

in, and implemented through, TFC-ESHQ-ENV_FS-C-01. Reporting and notifications required

by NOC approval conditions are summarized in TFC-ESHQ-ENV_PP-C-10, Attachment A, and

are implemented either through TFC-ESHQ-ENV_PP-C-10 or TFC-ESHQ-ENV_FS-C-01.

Sitewide air emissions reporting requirements and coordination with the MSC are detailed in

TFC-ESHQ-ENV_PP-C-10, TFC-ESHQ-ENV_PP-C-08, and TFC-ESHQ-ENV_PP-C-13.

Activities should be initiated in a timeframe to support transmittal to the MSC to support

transmittal of the final report to DOE. Details for each report are provided below.

1. In accordance with the requirements of AOP STGC, Section 5.9, and to satisfy the

underlying regulation found in WAC 173-400-105, DOE submits the Hanford Site

Criteria and Toxic Air Emission Inventory Report to Ecology each year no later than 105

days after the end of the previous calendar year with information and data for the

previous calendar year. The primary purpose of the Criteria and Toxic Air Emission

Inventory Report is to document that emissions from Hanford Site operations do not


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exceed applicable standards. The reported emissions are also used to establish the total

AOP fee assessed to DOE by Ecology.

2. In accordance with the requirements of AOP STGC Section 5.6, and to satisfy the

underlying regulation found in WAC 173-401-615, DOE submits semiannual AOP

reports to the regulatory agencies by September 15 (for January 1 through June 30

reporting period) and March 15 (for July 1 through December 31 reporting period) each

year. The primary purpose of the Semiannual AOP Report is to provide a status of

required air emissions monitoring on the Hanford Site.


underlying regulation found in WAC 173-401-630, DOE submits an Annual AOP

Compliance Certification Report to the regulatory agencies each year by July 31 with

information and data for the previous calendar year. The Annual AOP Compliance

Certification Report documents the compliance status of AOP requirements for the

duration of the reporting period.


underlying regulation found in WAC 173-441-050, DOE submits an Annual Greenhouse

Gas Emissions Report to the regulatory agencies each year by October 31 for emissions

in the previous calendar year. This report is submitted electronically. The Greenhouse

Gas Report provides information for separate but associated purposes; to collect accurate

and timely data to inform future federal policy decisions (40 CFR 98), and to establish a

base line and show status in meeting federal and state (WAC 173-441) reduction goals

for greenhouse gases.

Emission sources on the Hanford site are potentially subject to GHG reporting under

EPA, Ecology, and DOE-HQ GHG reporting programs contingent upon program

emissions limits.

In response to the Consolidated Appropriations Act of 2008, the EPA issued 74 FR

56260, “Mandatory Reporting of Greenhouse Gases,” on October 30, 2009, promulgating

40 CFR 98, “Mandatory Greenhouse Gas Reporting.” Contractors on the Hanford site

that operate or maintain any of the source categories listed in 40 CFR 98, Subpart A, are

required to provide information necessary for reporting to the EPA GHG reporting

program. The MSC will periodically re-evaluate this program as circumstances or

information changes. The EPA GHG reporting program is based on calendar year

emissions.

Greenhouse gas reporting requirements are promulgated in 40 CFR 98, “Mandatory

Greenhouse Gas Reporting.” Contractors on the Hanford Site that operate or maintain

any sources listed in Subpart A of 40 CFR 98 are required to report to the EPA

Greenhouse Gas (GHG) reporting program. The Hanford Site does not currently meet

the criteria to require reporting.

Currently, the Hanford site does not contain any of the source categories as listed in

Table A-3 or A-4 of 40 CFR 98, Subpart A. The Hanford site has municipal solid waste

landfills and electrical transmission/distribution equipment listed in Table A-3; however,

Table A-3 provides limitations (i.e., 25,000 metric tons CO2e or more emissions and

17,820 pounds of SF6, respectively), which are not exceeded. The Hanford site does not

have sources listed in Table A-4.


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For facilities that do not contain any of the source categories as listed in Table A-3 or A-4

of 40 CFR 98, Subpart A, regulations still require reporting if the aggregate maximum

rated heat input capacity of the stationary fuel combustion sources at the site is 30mm

BTU/hr or greater, and the site emits 25,000 MT of CO2e or more per year in combined

emissions from all stationary fuel combustion sources. Currently, the Hanford site does

not meet these EPA reporting conditions. Accordingly, the site is not currently subject to

reporting GHG emissions to the EPA based on emission limits. Annually, updated

emissions calculations are performed to determine if the Hanford site has exceeded the

emission threshold from stationary fuel combustion sources. If EPA reporting is

required, the GHG report would be due no later than March 31 of each year for the

previous calendar year.

Washington State GHG reporting requirements are promulgated in WAC 173-441,

“Reporting of Emissions of Greenhouse Gases.” The site has three emission sources

from Table 120-1 that require reporting under the State program. This determination was

based upon CY 2010 emissions and is evaluated every year.

Based upon calendar year 2012 emissions, the Hanford site is subject to WAC 173-441,

“Reporting of Emissions of Greenhouse Gases” because the Hanford site contains three

emission sources from Table 120-1 in WAC 173-441-120 including: General Stationary

Fuel Combustion Sources, Electrical Transmission and Distribution Equipment, and

Municipal Solid Waste Landfills. This applicability determination was based on an

evaluation of GHG emissions documented in DOE/RL-2012-54. The reporting threshold

for all applicable source categories listed in WAC 173-441-120 is 10,000 metric tons

CO2e or more per calendar year in total GHG emissions for the entire Hanford site. The

MSC Energy and Environmental Services (EES) will prepare and submit the annual

report with input from site contractors on behalf of the DOE and other contractors for the

Hanford site. The Ecology GHG reporting program is also based on calendar year

emissions.

DOE also requires its contractors through DOE O 436.1 and site sustainability plans to

measure, report, and reduce their greenhouse gas emissions from direct and indirect

activities. The MSC EES annually prepares GHG emissions report for the Hanford site

to DOE-HQ. With respect to the DOE-HQ GHG reporting program, the Hanford site has

established a fiscal year (FY) 2008 baseline and reported FY 2010 GHG emissions as the

initial reporting year. The DOE-HQ GHG reporting program is based on federal FY

(October 1 through September 30) emissions.

The MSC is responsible for evaluating on a Sitewide basis if reporting is required, and

preparing and submitting the annual report. Hanford site processes and procedures for

reporting were captured by the MSC in DOE/RL-2011-107, latest revision, “Greenhouse

Gas Reporting Program Plan,” DOE/RL-2012-54, latest revision, “Greenhouse Gas

Monitoring Plan.” The WRPS Air Reporting Subject Matter Expert is responsible for

transmitting the data required for reporting to the MSC in accordance with TFC-ESHQ-

ENV_PP-C-13.

3.8 Record Keeping (5.1.19, 5.1.21.a)

Record keeping requirements for the air compliance program are specified in WRPS procedures

which execute the specific task. TFC-ESHQ-ENV-STD-07 describes the types of regulatory

documents produced by WRPS Environmental Protection and Waste Services, which should be


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managed as a record, per WRPS Administrative procedures. The standard is applicable to all

WRPS facilities. The identified records are used to demonstrate compliance with local, state, and

federal environmental regulations.

TFC-BSM-IRM_DC-C-04 describes the process for management of all environmental documents

and records that contain, or potentially contain Controlled Unclassified Information following

MSC-PRO-RM-184, “Information Protection and Clearance.”

3.9 Assessments

Environmental Protection organization will conduct management observations per procedure

TFC-ESHQ-AP-C-03 and conduct assessments, as stated in TFC-ESHQ-ENV-STD-09, of the air

program against the regulations and permits to ensure and continually improve compliance.

3.10 Records

The following records are generated during the performance of this procedure, when required by

this procedure:

Fugitive or Smoke Emission Inspection Outdoor Location

Figure 9-1 Record of Visual Determination of Opacity

Method 22 Checklist

Method 9 Observation Record.

The record custodian identified in the Company Level Records Inventory and Disposition

Schedule (RIDS) is responsible for record retention in accordance with TFC-BSM-IRM_DC-C-

02.

4.0 DEFINITIONS

Emergency Stationary RICE. Any stationary internal combustion engine whose operation is

limited to emergency situations and required testing and maintenance by meeting all of the

criteria in paragraphs (1) through (3) of this definition. All emergency stationary engines must

comply with the requirements specified in §63.6640(f) for RICE, 40 CFR 60.4211(f) for CI ICE,

and 40 CFR 60.4243(d) for SI ICE in order to be considered emergency stationary ICE.

1. The stationary ICE is operated to provide electrical power or mechanical work during an

emergency situation. Examples include stationary RICE used to produce power for

critical networks or equipment (including power supplied to portions of a facility) when

electric power from the local utility (or the normal power source, if the facility runs on its

own power production) is interrupted, or stationary RICE used to pump water in the case

of fire or flood, etc.

2. The stationary RICE is operated under limited circumstances for situations not included

in paragraph (1) of this definition, as specified in §63.6640(f), 40 CFR 63.4243(d), or,

3. The stationary RICE operates as part of a financial arrangement with another entity in

situations not included in paragraph (1) of this definition only as allowed in

§63.6640(f)(2)(ii) or (iii) and §63.6640(f)(4)(i) or (ii).


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Emergency use for diesel-fueled CI ICE > 500 BHP and ≤ 2000 BHP (173-400-930). Means

providing electrical power or mechanical work during any of the following events or conditions:

The failure or loss of all or part of normal power service to the facility beyond the control

of the facility; or

The failure or loss of all or part of a facility's internal power distribution system.

Examples of emergency operation include the pumping of water or sewage and the

powering of lights.

Existing Stationary RICE. A stationary RICE with a site rating > 500 bhp that began construction

or reconstruction before December 19, 2002; OR, a stationary RICE with a site rating ≤ 500 bhp

that began construction or reconstruction before June 12, 2006.

New Stationary RICE. A stationary RICE with a site rating > 500 bhp that began construction

(placement of the order with a manufacturer) on or after December 19, 2002; OR, a stationary

RICE with a site rating ≤ 500 bhp that began construction (placement of the order with a

manufacturer) on or after June 12, 2006.

Reconstructed Stationary RICE. A stationary RICE with a site rating > 500 bhp that began

reconstruction on or after December 19, 2002; OR, a stationary RICE with a site rating ≤ 500 bhp

that began reconstruction on or after June 12, 2006 AND:

4. The fixed capital cost of the new components exceeds 50 percent of the fixed capital cost

that would be required to construct a comparable new source; AND

5. It is technologically and economically feasible for the reconstructed source to meet the

relevant standards.

5.0 SOURCES

5.1 Requirements

1. 40 CFR 52.21, “Prevention of Significant Deterioration of Air Quality.”

2. 40 CFR 60, “Standards of Performance for New Stationary Sources.”

a. Subpart A, “General Provisions.”

b. Subpart IIII, “Standards of Performance for Stationary Compression Ignition

Internal Combustions Engines.”

c. 40 CFR 60, Subpart JJJJ, “Standards of Performance for Stationary Spark

Ignition Internal Combustions Engines.”

d. Appendix A-4, “Test Methods 6 through 10B.”

e. Appendix A-7, "Test Methods 10 through 25E.”

3. 40 CFR 61, “National Emission Standards for Hazardous Air Pollutants.”


b. Subpart ZZZZ, “NESHAP for Stationary Reciprocating Internal Combustion

Engines.”


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4. 40 CFR 63, “National Emission Standards for Hazardous Air Pollutants for Source

Categories.”


b. Subpart ZZZZ, “NESHAP for Stationary Reciprocating Internal Combustion

Engines.”

5. 40 CFR 70, “State Operating Permit Programs.”

6. 40 CFR 80, “Regulation of Fuels and Fuel Additives.”

7. 40 CFR 82, “Protection of Stratospheric Ozone.”

a. Subpart A, “Production and Consumption Controls.”

b. Subpart F, “Recycling and Emissions Reduction.”

8. 40 CFR 98, “Mandatory Greenhouse Gas Reporting.”

9. Benton Clean Air Agency Regulation 1, Article 5, “Open Burning.”

10. DOE O 436.1, “Departmental Sustainability.”

11. DOE/RL-2010-86, “Hanford Site Ozone-Depleting Substances Program Plan.”

12. DOE/RL-2011-107, “Greenhouse Gas Reporting Program Plan.”

13. DOE/RL-2012-54, “Greenhouse Gas Monitoring Plan.”

14. Hanford Site Air Operating Permit (AOP), 00-05-006 Renewal 2, “General Terms and

Standard Conditions.”

15. TFC-ESHQ-ENV_FS-C-01, “Environmental Notification.”

16. TFC-ESHQ-ENV_PP-C-05, “Air Quality Program - Permitting for Toxic and Criteria Air

Pollutant Emissions Activities.”

17. TFC-ESHQ-ENV-STD-07, “Environmental Records.”

18. WAC 173-400, “General Regulations for Air Pollution Sources.”

a. Section 030(66), “Definitions - Reasonable available control technology.”

b. Section 035, “Nonroad Engines.”

c. Section 040, “General Standards for Maximum Emissions.”

d. Section 075, “Emission Standards for Sources Emitting Hazardous Air

Pollutants.”

e. Section 101, “Registration Issuance.”

f. Section 105, “Records, Monitoring, and Reporting.”

g. Section 107, “Excess Emissions.”

h. Section 110, “New Source Review (NSR) for Sources and Portable Sources.”

i. Section 115, “Standards of Performance for New Sources.”

j. Sections 700 to750, Prevention of Significant Deterioration.”


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k. Section 930, “Emergency Engines.”

19. WAC 173 401, “Operating Permit Regulation.”

a. Section 615, “Monitoring and Related Recordkeeping and Reporting

Requirements.”

b. Section 630, “Compliance Requirements.”

20. WAC 173 425, “Outdoor Burning.”

21. WAC 173-441, “Reporting of Emissions of Greenhouse Gases.”

22. WAC 173-455, “Air Quality Fee Rule.”

23. WAC 173-460, “Controls for New Sources of Toxic Air Pollutants.”

5.2 References

1. “Environmental Specification Requirements.”

2. ISO 14001, “Environmental Management Systems-Requirements with Guidance for

Use.”

3. MSC-PRO-RM-184, “Information Clearance.”

4. TFC-BSM-IRM_DC-C-04, “Public Information Repository and Administrative Record

Files.”

5. TFC-ESHQ-AP-C-03, “Management Observation Program.”

6. TFC-ESHQ-ENV_PP-C-02, “Environmental Requirements Management Process.”

7. TFC-ESHQ-ENV_PP-C-05, “Air Quality Program - Permitting for Toxic and Criteria Air

Pollutant Emission Activities.”

8. TFC-ESHQ-ENV_PP-C-13, “Greenhouse Gas Reporting.”

9. TFC-ESHQ-ENV-STD-07, “Environmental Records.”

10. TFC-ESHQ-ENV-STD-09, “Environmental Assessment Program.”

11. TFC-ESHQ-ENV-STD-13, “Asbestos Management Program.”

12. TFC-ESHQ-S_IH-C-52, “Asbestos Exposure Control and Management.”

13. TFC-PLN-123, “Environmental Management System Description.”


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ATTACHMENT A - STATIONARY COMPRESSION IGNITION INTERNAL COMBUSTION

ENGINE MODEL YEAR REQUIREMENTS

SIZE/CLASS EFFECTIVE DATE MODEL YEAR

Any

(excluding fire pump

engines)

After December 31, 2008 ≥ 2007

< 25 HP All

(excluding fire pump

engines)


≥ 25 HP and < 75 HP

Non-emergency


≥ 75 HP and < 175 HP

Non-emergency


≥ 175 HP including

those > 750 HP

Non-emergency


≥ 750 HP

Non-emergency


≥ 804 HP and < 2680 HP

Non-emergency

And Displacement

≥ 10L and < 30L


HP= horse power

L = liter

Unit conversions provided for readers convenience.

1.0 KW = 1.34 HP

1.0 HP = 0.746 KW


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ATTACHMENT B - STATIONARY SPARK IGNITION INTERNAL COMBUSTION ENGINE

MANUFACTURE DATE REQUIREMENTS

[40 CFR 60.4233]

SIZE/ CLASS/ FUEL MANUFACTURE DATE [CFR 60.4230]

≤ 25 BHP /All ≥ July 1, 2008

> 25 BHP Emergency Gasoline ≥ January 1, 2009

> 25 HP and < 500 BHP Non-emergency Gasoline ≥ July 1, 2008

≥ 500 BHP Non-emergency Gasoline

(except ≥ 500 < 1350 BHP Lean Burn)

≥ July 1, 2007

≥ 500 BHP < 1350 BHP Lean Burn ≥ January 1, 2008

> 25 BHP Emergency Rich Burn LPG ≥ January 1, 2009

> 25 BHP and < 500 BHP

Non-emergency Rich Burn LPG

≥ July 1, 2008

≥ 500 HP Non-emergency Rich Burn LPG ≥ July 1, 2007

> 25 BHP and < 100 BHP Non-emergency

(Except Gasoline or Rich Burn LPG)

≥ July 1, 2008

> 25 BHP and < 100 BHP

Emergency (Except Gasoline or Rich Burn LPG)

≥ January 1, 2009

≥ 100 BHP and < 500 BHP


≥ July 1, 2008

≥ 500 BHP


≥ July 1, 2007

BHP = break horse power

LPG = liquid propane gas

Unit conversions provided for readers convenience.

1.0 KW = 1.34 HP

1.0 HP = 0.746 KW


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ATTACHMENT C – METHOD 22 VISIBLE EMISSION SURVEY OUTLINE

--Unless otherwise stated, section references pertain to sections of 40 CFR 60 Appendix A-7--

Scope of Method 22 Survey: Determine the amount of time that visible emissions occur during the

observation period (Section 2.3)

Prerequisites:

Observer must be trained and knowledgeable regarding effects of background contrast, ambient

lighting, observer position relative to lighting, wind, and the presence of uncombined water on

the visibility of emissions (Section 2.3, met by completion of lecture portion of Method 9

certification course)

Timing devices must have unit divisions of at least 0.5 seconds (Section 6.1)

Observation point must enable a clear view of potential emission point(s) of affected facility

(Section 11.1)

Observation point should be at least 15 feet, but not more than 0.25 miles, from emission source

(Section 11.1)

Sunlight must not be shining directly in observer’s eyes (Section 11.1)

Procedure: (Sections 11.2.1 – 11.5)

1. Choose an observation point that meets all prerequisites above for the emission source.

2. From the observation point, fill out the pre-survey portions of the data sheet by recording the

company name, industry, process unit, observer’s name, observer’s affiliation, date, estimated

wind speed, wind direction, and sky condition.

3. Sketch the process unit being observed, including the observer location relative to the emission

unit and sun, and the potential and actual emission points.

4. Clear two timers and have them readily available for use.

5. Record the clock time.

6. Start the first timer and begin continuously watching the emission source.

7. If a visible emission is observed, start the second timer and note the clock time and reading on the

first timer.

8. When the visible emission stops, note the clock time, reading on both timers, and then reset the

second timer.

9. Continue this process until the second timer reading exceeds 10 minutes, or the first timer reading

exceeds 6 minutes and no visible emissions are present.

10. Record the clock time and reading on both timers. Complete the data sheet.


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ATTACHMENT D – FUGITIVE OR SMOKE EMISSION INSPECTION OUTDOOR

LOCATION


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ATTACHMENT E – METHOD 9 VISIBLE EMISSION SURVEY OUTLINE

--Unless otherwise stated, section references pertain to sections of 40 CFR 60 Appendix A-4--

Scope of Method 9 Survey: Determine the opacity of emissions from stationary sources (Section

1.1)

Prerequisites:

Observer must be qualified in accordance with Section 3 (Section 2)

Observation point must provide a clear view of the emissions with the sun oriented in the 140°

sector to the observer’s back (Section 2.1)

The angle created by the line of sight of the observer and the line from the sun to the

observer must be at least 110° (Visible Emissions Field Manual EPA Methods 9 and 22

pg. 17)

As a general rule, if the total vertical angle is less than 60° and the horizontal angle is

above 130°, the resultant angle should be acceptable (Visible Emissions Field Manual

EPA Methods 9 and 22 pg. 17)

Observation point should create a line of vision that is approximately perpendicular to the plume

direction (Section 2.1)

Observation point should be at least three effective stack heights away from the plume (Visible

Emissions Field Manual EPA Methods 9 and 22 pg. 13)

Procedure: (Sections 2.2 – 2.5)

1. Choose an observation point that meets all prerequisites above for the emission source.

2. From the observation point, fill out the pre-survey portions of the data sheet by recording the

name of the plant, emission location, facility type, observer’s name and affiliation, sketch of the

observer’s position relative to the source, date, time, estimated distance to the emission location,

approximate wind direction, estimated wind speed, description of the sky condition (presence and

color of clouds), and plume background.

3. Identify the point in the plume with the greatest opacity where condensed water vapor is not

present, and document this point on the data sheet.

4. Begin observing the plume at the identified point momentarily for 15-second intervals.

5. For each observation, determine the opacity to the nearest 5%, and record it on the data sheet.

6. End the survey after at least 24 observations have been made.

Record the time, estimated distance to the emission location, approximate wind direction, estimated wind

speed, description of the sky condition (presence and color of clouds), and plume background on the data

sheet.


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ATTACHMENT F – RECORD OF VISUAL DETERMINATION OF OPACITY


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ATTACHMENT G – METHOD 9 OBSERVATION RECORD

Page __ of __

Company Observer

Location Type facility

Test Number Point of emissions

Date

Hr. Min.

Seconds Steam plume (check if applicable)

Comments 0 15 30 45 Attached Detached

0

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24


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ATTACHMENT G – METHOD 9 OBSERVATION RECORD (cont.)

Page __ of __

Hr. Min.

Seconds Steam plume (check if applicable)

Comments 0 15 30 45 Attached Detached

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

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Air Quality Program Non Radioactive Emissions TFC-ESHQ-ENV ... · Air Quality Program – Non...

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Transcript of Air Quality Program Non Radioactive Emissions TFC-ESHQ-ENV ... · Air Quality Program – Non...