Michigan Department of Environmental Quality Air Quality Division State Registration Number RENEWABLE OPERATING PERMIT ROP Number STAFF REPORT
SRN:
Located at
, , , Michigan
Permit Number:
Staff Report Date: July 28, 2014
This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD), prepare a report that sets forth the factual basis for the terms and conditions of the Renewable Operating Permit (ROP).
Page: 1 TABLE OF CONTENTS
Page: 2 Michigan Department of Environmental Quality Air Quality Division State Registration Number RENEWABLE OPERATING PERMIT ROP Number JULY 28, 2014 STAFF REPORT
Purpose
Major stationary sources of air pollutants, and some non-major sources, are required to obtain and operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a stationary source’s applicable requirements and compliance with them by consolidating all state and federal air quality requirements into one document.
This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the draft permit terms and conditions including citations of the underlying applicable requirements, an explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the stationary source.
General Information
Stationary Source Mailing Address:
, Michigan Source Registration Number (SRN): North American Industry Classification System (NAICS) Code: Number of Stationary Source Sections: Is Application for a Renewal or Initial Issuance? Application Number: Responsible Official: ,
AQD Contact: ,
Date Permit Application Received: January 31, 2014 Date Application Was Administratively Complete: Is Application Shield In Effect? Date Public Comment Begins: July 28, 2014 Deadline for Public Comment: August 27, 2014
Page: 3 Source Description is an automotive research and development test facility in Superior Township, Washtenaw County, Michigan. HATCI operates four engine dynamometer test cells and four enclosed vehicle test stations. Ancillary equipment at the facility includes underground and above ground storage tanks and two emergency generators.
The following table lists stationary source emission information as reported to the Michigan Air Emissions Reporting System in the submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant Tons per Year Carbon Monoxide (CO) 81 Lead (Pb) NA
Nitrogen Oxides (NOx) 4 Particulate Matter (PM) <1
Sulfur Dioxide (SO2) <1 Volatile Organic Compounds (VOCs) 4 Individual Hazardous Air Pollutants (HAPs) ** Total Hazardous Air Pollutants (HAPs) NA **As listed pursuant to Section 112(b) of the federal Clean Air Act.
In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of Greenhouse Gases in tons per year of CO2e is less than 100,000. CO2e is a calculation of the combined global warming potentials of six Greenhouse Gases (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).
See Parts C and D in the draft ROP for summary tables of all processes at the stationary source that are subject to process-specific emission limits or standards.
Regulatory Analysis
The following is a general description and history of the source. Any determinations of regulatory non- applicability for this source are explained below in the Non-Applicable Requirement part of the Staff Report and identified in Part E of the ROP.
The stationary source is located in County, which is currently designated by the U.S. Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants.
The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR), Part 70, because the potential to emit exceeds 100 tons per year.
The stationary source is considered to be a minor source of HAP emissions because the potential to emit of any single HAP regulated by the federal Clean Air Act, Section 112, is less than 10 tons per year and the potential to emit of all HAPs combined are less than 25 tons per year.
The stationary source is considered a “synthetic minor” source in regards to the Prevention of Significant Deterioration regulations of PART 18, Prevention of Significant Deterioration of Air Quality, of Act 451 and 40 CFR, PART 52.21 because the stationary source accepted legally enforceable permit conditions limiting the potential to emit of to less than 250 tons per year.
Page: 4 EU-EMERGEN, EU-FIREPUMP at the stationary source are subject to the National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines promulgated in 40 CFR, Part 63, Subparts A and ( Area Source MACT). The ROP contains special conditions provided by HATCI for applicable requirements from 40 CFR, Part 63, Subparts A and . The AQD is not delegated the regulatory authority for this area source MACT; therefore, the special conditions for the Area Source MACT contained in FG-MACT-ZZZZ-EMERGENCY were not reviewed by the AQD.
EU-EMERGEN at the stationary source subject to the Standards of Performance for promulgated in 40 CFR, Part 60, Subparts A and . This standard contains the compliance requirements required by the RICE Area Source MACT for this engine.
EU-UST1, EUGASAST1, EU-UST#2-3-4, EU-UST#5-6, AND EU-UST#7 at the stationary source subject to the National Emissions Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities promulgated in 40 CFR, Part 63, Subparts A and (GDF Area Source MACT). The ROP contains special conditions provided by HATCI for applicable requirements from 40 CFR, Part 63, Subparts A and . The AQD is not delegated the regulatory authority for this area source MACT; therefore, the special conditions for the GDF Area Source MACT contained in FG-GASDISPGACT were not reviewed by the AQD.
HATCI’s ROP contains the following emission units grouped into the indicated flexible groupings:
EU-Dyno1, EU-Dyno2, EU-Dyno3, EU-Dyno4 (FG-DYNOS), EU-VEC1, EU-VEC2, EU-VEC3, EU-VEC4, EU-MDYNE1 (FG-CHASSIS), EU-UST#2-3-4, EU-UST#5-6, EU-UST#7 (FG-UST), EU under FG-UST combined with EU-UST#1 and EU-GASAST1 (FG-GASDISPGACT), EU-EMERGEN (FG-NSPS_SI- ICE), EU-FIREPUMP (FG-MACT-ZZZZ-EMERGENCY), EU-COLDCLEANERS (FG-COLDCLEANERS).
FG-FACILITY contains all process equipment source-wide including equipment covered by other permits, grand-fathered equipment and exempt equipment. The Table contains the facility-wide combined emission limits for NOx, CO, 1,3-Butadiene, and Benzene, and the material usage limit of 230,000 gallons of fuel (unleaded gasoline, ethanol blends, diesel, natural gas, and hydrogen) and of that, 75,000 gallons may be used for uncontrolled engine testing. Limits are per 12 month rolling time period as determined at the end of each calendar month.
FG-DYNOS is comprised of four engine testing dynamometer test cells, EU-Dyno1 through EU-Dyno4. The engines tested are required to have an automotive catalyst (catalytic converter) when operating in controlled mode. Each cell is equipped with a single exhaust stack. A fuel usage monitor is required capable of separately tracking fuel usage for engine testing in controlled and uncontrolled mode. A device for monitoring and recording natural gas is also required. The dynamometers are subject to the Part 18 administrative rules (adopted PSD rules). Rule 1803 and Rule 1804 are applicable to the NOx emission limit. Rule 1804 is also applicable to the CO emission limit.
In the ROP both FG-FACILITY and/or the FG-DYNOS are subject to administrative rules R 336.1205 (1) (a) & (3) (Rule 205), R 336.1224 (Rule 224), R 336.1225 (Rule 225), R 336.1301 (Rule 301), R 336.1331 (Rule 331), R 336.1602 (Rule 602), R 336.1702 (a) (Rule 702), R 336.1901 (Rule 901), R 336.1910 (Rule 910), R 336.2802 (Rule 1802), R 336.2803 (Rule 1803), R 336.2804 (Rule 1804), R 336.2810 (Rule 1810) and the federal 40 CFR 52.21 (c) and (d).
FG-CHASSIS contains four enclosed vehicle test stations. The vehicles tested will be fueled by unleaded gasoline, ethanol blends, diesel, natural gas, or hydrogen and equipped with a catalytic converter. Each station is equipped with a single exhaust stack. For purposes of this permit, unleaded gasoline and ethanol blends are considered equivalent fuels.
Page: 5 In the ROP the FG-CHASSIS are subject to administrative rules Rule 205, Rule 224, Rule 225, Rule 301, Rule 331, Rule 602, Rule 702, Rule 901, Rule 1802, Rule 1803, Rule 1804, and 40 CFR 52.21(c) & (d).
FG-UST contains the three underground storage tanks, EU-UST#2-3-4, EU-UST#5-6, EU-UST#7, for unleaded gasoline, ethanol blends, and diesel. One tank has three separate compartments, one has two compartments, and one has one compartment. The USTs are equipped with vapor balance equipment and submerged fill pipes.
In the ROP the FG-UST are subject to administrative rules Rule 205, Rule 224, Rule 225, Rule 702, R 336.1703 (1) & (2) (Rule 703), Rule 901, and the federal 40 CFR Part 63, Subpart A and Subpart CCCCCC.
FG-GASDISPGACT in the ROP contains a new federal applicable requirement, the National Emission Standard for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities (Area Source, Maximum Achievable Control Technology standard), promulgated in 40 CFR, Part 63, Subparts A and CCCCCC (GDF MACT or GACT). During technical review HATCI provided information that the stationary source contains two GDF (defined in 40 CFR Part 63, Subpart CCCCCC):
1.) FG-UST and EU-UST#1 and 2.) EU-GASAST1 an Above Ground Storage Tank located at a separate location (from USTs) within the stationary source and is treated as a separate affected source.
HATCI’s maximum monthly gasoline throughput at the time of ROP application was less than 10,000 gallons. However HATCI’s Table FG-GASDISPGACT contains both the applicable requirements for a source dispensing less than 10,000 gallons of gasoline throughput per year, and the applicable requirements for a source dispensing between 10,000 gallons and 100,000 gallons of gasoline. HATCI proposed this in the event their GDFs applicability changes in the future. Each GDF could potentially be subject to a different threshold. Records of monthly throughput are required on the basis of total volume of gasoline that is loaded into, or dispensed from, all gasoline storage tanks at each GDF during a month. If an affected source’s throughput ever exceeds an applicable throughput threshold, the affected source will remain subject to the requirements for sources above the threshold, even if the affected source throughput later falls below the applicable throughput threshold (40 CFR 63, 63.11111(i)). Again, the ROP contains special conditions provided by HATCI for applicable requirements from 40 CFR, Part 63, Subparts A and CCCCCC. The AQD is not delegated the regulatory authority for this area source MACT; therefore, the special conditions for the GDF MACT contained in FG-GASDISPGACT were not reviewed by the AQD.
FG-NSPS_SI-ICE in the ROP contains the federal applicable requirements pursuant to the Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (New Source Performance Standard, NSPS 40 CFR Part 60 Subpart JJJJ). HATCI’s RO application included one new (constructed after June 12, 2006) 224 horsepower stationary natural gas (Spark Ignition, SI) emergency generator installed in 2011 and identified as EU-EMERGEN. HATCI provided AQD with the 2011 EPA Certified Gas Industrial Generators listing which included their Generic engine Model and exhaust emissions data. As long as EU-EMERGEN is operated and maintained according to the manufacturer’s recommendations it is considered to be certified and emission testing is not required.
FG-MACT-ZZZZ-EMERGENCY in the ROP contains the federal applicable requirements pursuant to the National Emission Standard for Hazardous Air Pollutants for Source Category: Reciprocating Internal Combustion Engines (Area Source), promulgated in 40 CFR, Part 63, Subparts A and ZZZZ (RICE MACT). HATCI’s RO application included one existing 322 horsepower stationary diesel (Compression Ignition, CI) emergency fire pump installed in 2005 and identified as EU-FIREPUMP. (As discussed above, EU-EMERGEN is also an affected source under this standard however the standard refers this source to the applicable requirements indicated under FG-NSPS_SI-ICE.) During Technical Review AQD did remove conditions related to “existing SI-ICE” from the HATCI Template because the stationary
Page: 6 source does not have any existing SI-ICE and therefore any future construction/installation of ICE will require further review to determine whether it may be considered to be a new source (after June 2006) subject to the NSPS JJJJ (SI-ICE) or NSPS IIII (CI-ICE).
FG-COLDCLEANERS Any cold cleaner that is grandfathered or exempt from Rule 201 pursuant to Rule 278 and Rule 281(h) or Rule 285(r)(iv). Existing cold cleaners were placed into operation prior to July 1, 1979. New cold cleaners were placed into operation on or after July 1, 1979.
Permit History On November 3, 2008, New Source Review Permit to Install (PTI) No. 285-08 was issued by MDEQ, AQD for previously installed process equipment FG-DYNOS (EU-Dyno1-4) and FG-CHASSIS (EU- Chassis1-3). FG-DYNOS and FG-CHASSIS were initially permitted to operate with gasoline fuel. Modeling was performed for CO, and the toxic air contaminants (TACs). All TAC impacts were below applicable screening levels and all criteria pollutants were below the NAAQS and increment.
On March 19, 2009, PTI No. 285-09A was issued by MDEQ, AQD to add an additional Chassis Dynamometer (EU-Chassis 4).
On January 12, 2010, PTI No. 285-08B was issued by MDEQ, AQD for an increased throughput limit for EU-UST#1 from 60,000 to 85,000 gallons per 12-month rolling time period and a decreased throughput limit of EU-UST#7 from 60,000 to 30,000 gallons per 12-month rolling time period. A Consent Order AQD No. 8-2011 became effective on October 6, 2011, and resolved prior permitting compliance issues regarding the initial installation and operation of the facility. PTI No. 285-08B was attached as Exhibit A.
On February 21, 2013, PTI No. 285-08C was issued by MDEQ, AQD to increase the fuel usage limits with an increase in the emission limit of carbon monoxide (CO) above Title V thresholds, but below PSD thresholds. The source requested reorganization of their current permit to increase flexibility. They requested that the fuel limits and CO emission limits be relocated to FG-FACILITY. The requested CO limits were set at less than 225 tons per year (tpy), negating the need for public comment. In addition, the applicant requested to remove EU-UST#1 from the permit. The permit required the source to submit an ROP application within 12 months. This permit is a PSD opt-out. Permit No. 285-08B was voided upon issuance.
The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring Submittals."
No emission units are subject to the federal Compliance Assurance Monitoring rule under 40 CFR, Part 64, because all emission units at the stationary source either do not have a control device or those with a control device do not have potential pre-control emissions over the major source thresholds.
Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the stationary source. Part A contains regulatory citations for general conditions.
Page: 7 Source-wide Permit to Install (PTI)
Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a footnote designation in the integrated ROP/PTI document.
Streamlined/Subsumed Requirements
This permit does not include any streamlined/subsumed requirements pursuant to Rules 213(2) and 213(6).
Non-applicable Requirements
Part E of the draft ROP lists requirements that are not applicable to this source as determined by the AQD, if any were proposed in the application. These determinations are incorporated into the permit shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to Rule 213(6)(a)(ii).
Processes in Application Not Identified in Draft ROP
The following table lists processes that were included in the ROP application as exempt devices under Rule 212(4). These processes are not subject to any process-specific emission limits or standards in any applicable requirement.
Exempt Description of Rule 212(4) Rule 201 Emission Unit ID Exempt Emission Unit Exemption Exemption Rule 212(4)(b) Rule 212(4)(b) Rule 212(4)(b) Rule 212(4)(b) Rule 212(4)(d)
Draft ROP Terms/Conditions Not Agreed to by Applicant
This permit does not contain any terms and/or conditions that the AQD and the applicant did not agree upon pursuant to Rule 214(2).
Compliance Status
The AQD finds that the stationary source is expected to be in compliance with all applicable requirements as of the effective date of this ROP.
Page: 8 Action taken by the DEQ
The AQD proposes to approve this permit. A final decision on the ROP will not be made until the public and affected states have had an opportunity to comment on the AQD’s proposed action and draft permit. In addition, the U.S. Environmental Protection Agency (USEPA) is allowed up to 45 days to review the draft permit and related material. The AQD is not required to accept recommendations that are not based on applicable requirements. The delegated decision maker for the AQD is , District Supervisor. The final determination for ROP approval/disapproval will be based on the contents of the permit application, a judgment that the stationary source will be able to comply with applicable emission limits and other terms and conditions, and resolution of any objections by the USEPA.
Page: 9 Michigan Department of Environmental Quality Air Quality Division State Registration Number RENEWABLE OPERATING PERMIT ROP Number
{DATE} STAFF REPORT ADDENDUM {ROP NO.}
Purpose
A Staff Report dated July 28, 2014, was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments received on the draft ROP during the comment period as described in . In addition, this addendum describes any changes to the ROP resulting from these pertinent comments.
General Information
Responsible Official: ,
AQD Contact: ,
Summary of Pertinent Comments
No pertinent comments were received during the comment period.
Changes to the July 28, 2014 ROP
No changes were made to the ROP.
Page: 10