United States Environmental Protection Agency Region 9 – Pacific Southwest
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United States Environmental Protection Agency Region 9 – Pacific Southwest www.epa.gov/caa-permitting/tribal-minor-new-source-review-permitting-region-9 Technical Support Document for Review of Request for Coverage Request for Coverage under the General Air Quality Permit for New or Modified Minor Source Concrete Batch Plants in Indian Country FNF CONSTRUCTION, INC. WINDOW ROCK AIRPORT PROJECT September 2020 Applicant: Tressia Contreras, Environmental Manager FNF Construction, Inc. 115 South 48th Street Tempe, Arizona 85281 Phone: (480) 929-6733 Email: [email protected] Source: Window Rock Airport Source Location: Beacon Road Window Rock, Arizona 86515 Latitude 35.651699° N, Longitude 109.067320° W Source ID #: 31 Application #: 2020-005-GP Docket: https://www.regulations.gov/ [Docket # EPA-R09-OAR-2020-0366] Summary Pursuant to the provisions of Clean Air Act (CAA) sections 110(a) and 301(d) and the Federal Indian Country Minor New Source Review (NSR) Program at Code of Federal Regulations (CFR) title 40, sections 49.151-161 (Tribal Minor NSR Program), the United States Environmental Protection Agency (EPA) Region 9 is approving a Request for Coverage under the General Air Quality Permit for New or Modified Minor Source Concrete Batch Plants in Indian Country (Concrete Batch Plants General Permit) to FNF Construction, Inc. (FNF or Applicant) for the construction and operation of a soil cement mixing plant, which is a portable concrete batch plant, at the Window Rock Airport in Window Rock, Apache County, Arizona within the Navajo Nation tribal land. The Concrete Batch Plants General Permit, the permit under which the Applicant is seeking coverage, was issued by the EPA under the Tribal Minor NSR Program on October 14, 2016, with an effective date of November 14, 2016. See 81 Fed. Reg. 70944 (October 14, 2016). This technical support document (TSD) provides EPA Region 9’s analysis of whether the Source is within the category of emissions sources to which the Concrete Batch Plants General Permit applies and whether the source meets the criteria to be eligible for coverage under the Concrete Batch Plants General Permit. This analysis and other information required by 40 CFR 49.157(a) will be made available to the public through the online docket for this action and at the EPA Region 9 office. Additional information for accessing the publicly available information is provided at the end of this TSD. Page 2 of 10 Technical Support Document General Permit – FNF Construction, Inc. Window Rock Airport Project Source Description and Project Summary The Applicant submitted a Request for Coverage under the Concrete Batch Plants General Permit on June 30, 2020 for the construction and operation of the Source, located at the Window Rock Airport in Window Rock, Apache County, Arizona within the Navajo Nation tribal land. This Request for Coverage provides the basis for our review and determination of eligibility for coverage under the permit. The Applicant also provided supplemental information by e-mail on July 10, 2020 in response to requests for information from the EPA. On July 27, 2020, the EPA determined that FNF’s Request for Coverage under the Concrete Batch Plants General Permit was complete. The geographic area where the Project will be located is designated attainment and/or unclassifiable under the CAA for all National Ambient Air Quality Standards (NAAQS) pollutants. The Source, which is a soil cement mixing plant, is portable concrete batch plant facility, will consist of two concrete batch plants that will include a concrete silo, mixer, concrete feeder, conveyor, water tank, baghouse, diesel generator, and other support equipment. The soil cement mixing plant is an Accumix 6008 Continuous Mixing Pugmill mixing plant. The EPA granted approval for Phase I of this Project on April 18, 2018 for the temporary operation of the concrete batch plant for a period of 30 days. The proposed Project was to reconstruct the existing Runway 2-20 (7,000 feet by 75 feet). Phase I included a cement production of 8,200 cubic yards per year. The Applicant is currently requesting approval for Phase II of this Project for the temporary operation of the concrete batch plant for a period of 45 days. Phase II of this Project includes a cement production of 7,000 cubic yards per year. Equipment Description The subject portable concrete batch plant will have a projected annual concrete production of 7,000 cubic yards. The proposed operation will include the equipment listed within the table below. Table 1. List of Affected Emission Units Description ID # Hopper, Silo, Controls on Unit Equipment Size Make / Model Year of Construction Mixer Equipment Name or Bin 1 X Concrete Silo Baghouse 600 TPH Accumix 600B 1986 Moisture in 2 X Aggregate Hopper 600 TPH Accumix 600B 1986 Material 3 X Mixer Pugmill Wet Enclosed -- Accumix 600B 1986 4 Concrete Feeder Baghouse 60 TPH Accumix 600B 1986 5 Water Tank N/A 850 Gallons Accumix 600B 1986 6 Conveyor Wet Material -- Accumix 600B 1986 7 X Dump Hopper Wet Material 1.5 Cubic Yards Accumix 600B 1986 8 Concrete Baghouse Baghouse -- Accumix 600B 1986 9 Engine N/A 230 HP Accumix 600B 1986 Page 3 of 10 Technical Support Document General Permit – FNF Construction, Inc. Window Rock Airport Project Table 2. Materials Handling – Transferring, Loading, Unloading, Conveyors, and Dropping Control Technology Maximum Average Cover Material Moisture Conveyor Conveyor ID # Description Water Chemical with Transferred Content None with ½ with ¾ Spray Additive full (tpy) (%) cover cover cover 2 Loader Drop 600 TPH Varies X -- -- -- -- -- 6 Conveyor 1.5 Cubic Saturated X -- -- -- -- -- Yards 7 Dump 1.5 Cubic Saturated X -- -- -- -- -- Yards Background The CAA Tribal Minor NSR program is potentially applicable to owners and operators of sources located, or planning to locate, on Indian reservations or in other areas of Indian country over which an Indian tribe, or the EPA, has demonstrated that the tribe has jurisdiction and where there is no EPA- approved NSR program in place.1 Currently, the Navajo Nation does not have an EPA-approved NSR program, so the EPA is the permitting authority for new or modified stationary sources of air pollutants on the Navajo Nation tribal land. The EPA reviews applications and issues permits for the construction and operation of new and modified stationary sources on tribal land in accordance with the Tribal NSR program. As part of the Tribal NSR program, the EPA adopted general permits for certain categories of minor sources to which the Tribal NSR Program applies. The purpose of a general permit is to provide for the protection of air quality while simplifying the permit issuance process for similar facilities to minimize the burden on the reviewing authority and the regulated sources. As noted above, EPA issued the Concrete Batch Plants General Permit under the Tribal Minor NSR Program on October 14, 2016, and the permit became effective November 14, 2016. See 81 Fed. Reg. 70944 (October 14, 2016). New and modified minor sources may apply for coverage under the Concrete Batch Plants General Permit if the total potential to emit for new, modified, and existing units is below major source thresholds and the source can meet the throughput limits and other terms and conditions set forth in the general permit. Sources seeking coverage must also demonstrate that they meet all eligibility criteria. Applicability of the Tribal Minor NSR Program The preconstruction permitting program is triggered for new or modified sources in locations covered by the Tribal NSR Program based on potential increases in air pollutants according to the applicability criteria in 40 CFR 49.153. Generally, source owners and operators first determine whether their new or modified source is subject to the CAA major NSR permitting program (pursuant to 40 CFR 52.21 for areas designated as attainment/unclassifiable for the NAAQS and/or 40 CFR 49.166 through 49.175 for areas designated as nonattainment for the NAAQS). For new or modified sources that are not subject 1 See 40 CFR 49.151(c)(1), 49.152(d). Page 4 of 10 Technical Support Document General Permit – FNF Construction, Inc. Window Rock Airport Project to major NSR review, the owner and operator must evaluate whether the Tribal Minor NSR Program applies. The minor NSR permitting thresholds vary depending on whether the area in which the Source is or will be located is designated attainment and/or unclassifiable for the NAAQS, or designated nonattainment for the NAAQS. In this case, the Source is to be located within Apache County, Arizona within the Navajo Nation tribal land which is designated attainment/unclassifiable under the CAA for all NAAQS pollutants. Thus, our consideration of the applicable permitting thresholds is based on the Tribal Minor NSR thresholds for attainment areas in Table 4 below. Emissions Calculations and Potential to Emit The emission calculations for the Source are provided below in Table 3. Table 3. Summary of Total Potential to Emit (PTE) in tons per year (tpy) Single Process / Equipment PM PM10 PM2.5 SO2 NOx CO VOC Total HAP HAP Materials Handling and Loading 35.58 17.48 2.27 -- -- -- -- -- -- Auxiliary Heater 0.00 0.00 0.00 0.00 0.00 0.00 0.00 -- 0.00 Non-Emergency Engines 2.22 2.22 2.22 2.07 31.23 6.73 2.49 -- 0.03 Emergency Generators -- -- -- -- -- -- -- -- -- Vehicle Traffic 0.00 0.00 -- -- -- -- -- -- -- Storage Piles 0.0004 0.0002 -- -- -- -- -- -- -- Solvent Degreasing -- -- -- -- -- -- -- -- -- Controlled Emissions 37.80 19.69 4.49 2.07 31.23 6.73 2.49 0.00 0.03 The Tribal NSR Rule establishes specific PTE thresholds for new or modified stationary sources that trigger the requirement to obtain a preconstruction permit under the Tribal Minor NSR program.