Application to Revise Conditions in Air Quality Control Minor Permit No. AQ0108MSS02
Bailey Power Plant Prepared for: Ketchikan Public Utilities
August 2020
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Bailey Power Plant
Prepared for: Ketchikan Public Utilities 1065 Fair Street Ketchikan, AK 99901
prepared by
SLR INTERNATIONAL CORPORATION 2700 Gambell Street, Suite 200 Anchorage, Alaska 99503 (907) 222-1112
August 2020
[THIS PAGE INTENTIONALLY LEFT BLANK] Alaska Department of Environmental Conservation Air Quality Minor Permit Application
STATIONARY SOURCE IDENTIFICATION FORM
Section 1 Stationary Source Information Name: Bailey Power Plant SIC: 4911 Project Name (if different): Contact: Jennifer Holstrom Physical Address: 3935 Tongass Avenue City: Ketchikan State: AK Zip: 99901 Ketchikan, AK 99901 Telephone: (907) 228-4733 E-Mail Address: [email protected] Northing: Easting: Zone: UTM Coordinates (m) or Latitude/Longitude: Latitude: 51° 21' North Longitude: 131° 35' West
Section 2 Legal Owner Section 3 Operator (if different from owner) Name: Ketchikan Public Utilities Name: Mailing Address: 1065 Fair Street Mailing Address: City: Ketchikan State: AK Zip: 99901 City: State: Zip: Telephone #: (907) 225-5505 Telephone #: E-Mail Address: [email protected] E-Mail Address:
Section 4 Designated Agent (for service of process) Section 5 Billing Contact Person (if different from owner) Name: Mitch Seaver, City of Ketchikan Attorney Name: Kim Hendricks, Secretary II Mailing Address: 334 Front Street Mailing Address: 1065 Fair Street City Ketchikan State: AK Zip: 99901 City: Ketchikan State: AK Zip: 99901 Telephone #: (907) 228-5627 Telephone #: (907) 225-5505 E-Mail Address: [email protected] E-Mail Address: [email protected]
Section 6 Application Contact Name: Alana Riste Mailing Address: 1800 Blankenship Road, Suite 440 City: West Linn State: OR Zip: 97068 Telephone: (503) 905-3207 E-Mail Address: [email protected]
Section 7 Desired Process Method (Check only one – see 18 AAC 50.542(a) for process descriptions and restrictions) Fast track for a permit classification under Public comment [18 AAC 50.542(d)] 18 AAC 50.502 [18 AAC 50.542(b)]
AIR QUALITY CONTROL MINOR PERMIT APPLICATION Page 1 of 8 Revision Date: December 15, 2016 STATIONARY SOURCE IDENTIFICATION FORM STATIONARY SOURCE IDENTIFICATION FORM
Section 8 Source Classification(s) (Check all that Section 9 Modification Classification(s) (Check all that apply) apply) [18 AAC 50.502(b)] [18 AAC 50.502(c)(3)] Asphalt Plant [> 5 ton per hour] NOx Increase > 10 tpy [and existing PTE > 40 tpy]
Thermal Soil Remediation Unit [> 5 ton per hour] SO2 Increase > 10 tpy [and existing PTE > 40 tpy] Rock Crusher [> 5 ton per hour] PM-10 Increase > 10 tpy [and existing PTE > 15 tpy] Incinerator(s) [total rated capacity > 1000 lb/hour] PM-2.5 Increase > 10 tpy [and existing PTE > 10 tpy] Coal Preparation Plant CO Increase > 100 tpy [and existing PTE > 100 tpy Port of Anchorage Facility in a nonattainment area]
If you checked any of the above, is (are) the emission [18 AAC 50.502(c)(4)] unit(s) new, relocated*, or existing? NOx Increase > 40 tpy [and existing PTE ≤ 40 tpy] SO2 Increase > 40 tpy [and existing PTE ≤ 40 tpy] PM-10 Increase > 15 tpy [and existing PTE ≤ 15 tpy] [18 AAC 50.502(c)(1)] PM-2.5 Increase > 10 tpy [and existing PTE ≤ 10 tpy]
New or relocated* stationary source with potential CO Increase > 100 tpy [and Existing PTE ≤ 100 tpy emissions greater than: in a nonattainment area]
Basis for calculating modification: 40 tons per year (tpy) NOx 40 tpy SO2 Projected actual emissions minus baseline actual emissions 15 tpy PM-10 New potential emissions minus existing potential emissions 10 tpy PM-2.5 0.6 tpy lead 100 tpy CO in a nonattainment area
Section 10 Permit Action Request (Check all that apply) [18 AAC 50.502(c)(2)] Construction or relocation* of a: [18 AAC 50.508] Portable oil and gas operation Establish Plant-wide Applicability Limitation (PAL) > 10 MMBtu/hr fuel burning equipment in a SO2 Establish emission reductions to offset nonattainment pollutant special protection area Owner Requested Limit* (ORL) Revise or Rescind Title I Permit Conditions * * Relocation does NOT include moving equipment Permit Number: AQ0108MSS02 Condition No. 6 from one place to another within your current Date: August 30, 2019 stationary source boundary.
*Which to use? See http://www.dec.state.ak.us/air/ap/docs/orlrtc.pdf
Section 11 Existing Permits and Limits
For an existing stationary source, do you have an existing: (Check all that apply) Air quality permit Number(s)*: AQ0108TVP05, AQ0108MSS02, and AQ0108CPT01 (9713- AC017)
Owner Requested Limit(s) Permit Number(s): Pre-Approved Emission Limit (PAEL) Number(s)**:
* All active construction, Title V, and minor permit numbers. **Optional. Please provide this number if possible. http://dec.alaska.gov/Applications/Air/airtoolsweb/
AIR QUALITY CONTROL MINOR PERMIT APPLICATION Page 2 of 8 Revision Date: December 15, 2016 STATIONARY SOURCE IDENTIFICATION FORM STATIONARY SOURCE IDENTIFICATION FORM
Section 12 Project Description Provide a short narrative describing the project. Discuss the purpose for conducting this project, what emission units/activities will be added/modified under this project (i.e., project scope), and the project timeline. If the project is a modification to an existing stationary source, describe how this project will affect the existing process. Include any other discussion that may assist the Department in understanding your project or processing your application. Include a schedule of construction.
Please use additional copies of this sheet if necessary.
Ketchikan Public Utilities (KPU) is submitting an air quality minor permit application to replace Condition 6 of Air Quality Control Minor Permit No. AQ0108MSS02 with a condition requiring the use of ultra-low sulfur diesel (ULSD) fuel to protect ambient air quality. Condition 6 requires the installation of an ambient air quality monitoring station for sulfur dioxide (SO2) and nitrogen dioxide (NO2) if the diesel fuel fired in emissions unit (EU) ID 4 exceeds 2,120,900 gallons per consecutive 12-month period. See Attachment C for a detailed project description.
A PSD Increment Compliance Evaluation is included in Attachment C. A modeling analysis was conducted for NO2 and an Ambient Demonstration is included in Attachment D. Attachment B includes the proposed changes to Air Quality Control Minor Permit No. AQ0108MSS02. The requested change will result in a reduction in potential SO2 emissions, as shown in Attachment E.
KPU requests ADEC incorporate the changes to Air Quality Control Minor Permit No. AQ0108MSS02 into Air Quality Operating Permit No. AQ0108TVP05 via administrative amendment per 18 AAC 50.542(e) and 18 AAC 50.326(c)(2).
AIR QUALITY CONTROL MINOR PERMIT APPLICATION Page 3 of 8 Revision Date: December 15, 2016 STATIONARY SOURCE IDENTIFICATION FORM STATIONARY SOURCE IDENTIFICATION FORM
Section 12 Project Description Continued For PALs under Section 10 of this application, include the information listed in 40 C.F.R. 52.21(aa)(3), adopted by reference in 18 AAC 50.040 [18 AAC 50.540(h)].
For a limit to establish offsetting emissions under Section 10 of this application, specify the physical or operational limitations necessary to provide actual emission reductions of the nonattainment air pollutant; including [18 AAC 50.540(i)]:
• A calculation of the expected reduction in actual emissions; and
• The emission limitation representing that quantity of emission reduction.
AIR QUALITY CONTROL MINOR PERMIT APPLICATION Page 4 of 8 Revision Date: December 15, 2016 STATIONARY SOURCE IDENTIFICATION FORM STATIONARY SOURCE IDENTIFICATION FORM
Section 12 Project Description Continued For ORLs under Section 10 of this application [18 AAC 50.540(j)], include:
A description of each proposed limit, including for each air pollutant a calculation of the effect the limit will have on the stationary source's potential to emit and the allowable emissions [18 AAC 50.225(b)(4)];
A description of a verifiable method to attain and maintain each limit, including monitoring and recordkeeping requirements [18 AAC 50.225(b)(5)];
Citation to each requirement that the person seeks to avoid, including an explanation of why the requirement would apply in the absence of the limit and how the limit allows the person to avoid the requirement [18 AAC 50.225(b)(6)];
A statement that the owner or operator of the stationary source will be able to comply with each limit [18 AAC 50.225(b)(8)];
AIR QUALITY CONTROL MINOR PERMIT APPLICATION Page 5 of 8 Revision Date: December 15, 2016 STATIONARY SOURCE IDENTIFICATION FORM STATIONARY SOURCE IDENTIFICATION FORM
Section 12 Project Description Continued For revising or rescinding Title I permit conditions under Section 10 of this application [18 AAC 50.540(k)], include:
An explanation of why the permit term or condition should be revised or rescinded [18 AAC 50.540(k)(2)];
See Attachment A
The effect of revising or revoking the permit term or condition on [18 AAC 50. 540 (k)(3)]: • Emissions; See Attachment A
• Other permit terms; See Attachment A
• The underlying ambient demonstration, if any; See Attachment A
• Compliance monitoring; and See Attachment A
For revising a condition that allows avoidance of a permit classification, the information required for that type of permit, unless the revised condition would also allow the owner or operator to avoid the classification. [18 AAC 50.540(k)(4)]
See Attachment A
AIR QUALITY CONTROL MINOR PERMIT APPLICATION Page 6 of 8 Revision Date: December 15, 2016 STATIONARY SOURCE IDENTIFICATION FORM
STATIONARY SOURCE IDENTIFICATION FORM
Section 16 Mailing Address Submit the minor permit application to the Permit Intake Clerk in the Department’s Anchorage office. Submitting to a different office will delay processing. The mailing address and phone number for the Anchorage office is:
Permit Intake Clerk Alaska Department of Environmental Conservation Air Permit Program 555 Cordova Street Anchorage, Alaska 99501 (907) 269-6881
AIR QUALITY CONTROL MINOR PERMIT APPLICATION Page 8 of 8 Revision Date: December 15, 2016 STATIONARY SOURCE IDENTIFICATION FORM ATTACHMENT A Required Elements for Revising Permit Conditions
[THIS PAGE INTENTIONALLY LEFT BLANK] Attachment A Required Elements for Revising Permit Conditions 18 AAC 50.540(k)
The following table provides a summary of the required elements for this application to revise terms and conditions in Air Quality Control Minor Permit No. AQ0108MSS02.
Regulatory Citation Requirement Location
18 AAC 50.540(k)(1) Copy of Title I permit Attachment F Explanation of why permit term or 18 AAC 50.540(k)(2) Attachments B, C, and D condition should be revised or rescinded Effect of revising or revoking the permit term or conditions on emissions, other Attachments B, C, D, and 18 AAC 50.540(k)(3) permit terms, the underlying ambient E demonstration, and compliance monitoring For a condition that allows an owner or operator to avoid a permit classification, Not applicable. The the information required of an applicant requested changes do 18 AAC 50.540(k)(4) for that type of permit, unless the not change the original revised condition would also allow the permit classification. owner or operator to avoid the classification.
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[THIS PAGE INTENTIONALLY LEFT BLANK] ATTACHMENT B Requested Revisions to Air Quality Control Minor Permit AQ0108MSS02 [THIS PAGE INTENTIONALLY LEFT BLANK] ATTACHMENT B REQUESTED REVISIONS TO AIR QUALITY CONTROL MINOR PERMIT NO. AQ0108MSS02
Ketchikan Public Utilities (KPU) is requesting the specific changes, outlined in the following table, to Air Quality Control Minor Permit No. AQ0108MSS02. Text to be removed is in strikethrough format and text to be added is underlined.
Citation Permit Condition Reason for Permit Condition
Burn only diesel fuel that meets ultra-low sulfur diesel (ULSD) specifications in EU IDs 1 through 5. a. Keep the receipts of each fuel Replace Condition 6 with the shipment indicating the sulfur proposed condition. The proposed content of all the fuel delivered at condition to combust only fuel that the stationary source and meets ULSD specifications ensures provide copies of the fuel compliance with the National receipts in the operating report Ambient Air Quality Standards Permit AQ0108MSS02 required by the applicable (NAAQS)/Alaska Ambient Air Quality Condition 6 Ambient Air operating permit issued to the Standards (AAAQS) and the Quality Monitoring stationary source under AS Prevention of Significant 46.14 and 18 AAC 50; and Deterioration (PSD) increments for
b. Notify the Department, as SO2. An ambient demonstration described in the applicable has been conducted to ensure that operating permit issued to the monitoring is not necessary for
stationary source under AS nitrogen dioxide (NO2), see 46.14 and 18 AAC 50, if any fuel Attachments D and G. burned in EU IDs 1 through 5 does not meet ULSD specifications.
The requested conditions have the following effects on the Bailey Power Plant permitted facility.
Emissions – The requested change lowers the potential emissions of SO2 at the stationary source. See Attachment E.
Underlying Ambient Demonstration – The underlying ambient demonstration at this stationary source is affected by this change. See Attachments D and G.
Compliance Monitoring – Monitoring requirements are included in the proposed condition in the table above.
Avoidance of Classification – The permit conditions are to protect ambient air quality and PSD increments. The changes requested do not change the original permit classification.
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[THIS PAGE INTENTIONALLY LEFT BLANK] ATTACHMENT C PSD Nitrogen Dioxide Increment Compliance Evaluation [THIS PAGE INTENTIONALLY LEFT BLANK] ATTACHMENT C PSD NITROGEN DIOXIDE INCREMENT COMPLIANCE EVALUATION
This minor air quality permit application has been prepared to rescind Condition 6 in Air Quality Control Minor Permit No. AQ0108MSS02 for the Ketchikan Public Utilities (KPU) Bailey Power Plant (BPP), per 18 Alaska Administrative Code (AAC) 50.508(6). Under 18 AAC 50.540(k)(3)(c), the minor air quality permit application must include a demonstration of the effect that revoking the permit condition has on the underlying ambient demonstration, if applicable. On January 14, 2020, KPU and Alaska Department of Environmental Conservation (ADEC) met to discuss rescinding Condition 6, including identifying the intended purpose of the monitoring requirement. At that meeting, KPU and ADEC agreed to the following conclusions. An enforceable requirement to combust only ultra-low sulfur diesel (ULSD) in the BPP
engines would ensure compliance with the applicable sulfur dioxide (SO2) National Ambient Air Quality Standard (NAAQS)/Alaska Ambient Air Quality Standard (AAAQS)
and the Prevention of Significant Deterioration (PSD) SO2 increment. This permit
application includes a request for to replace the SO2 monitoring requirement with a
requirement to combust ULSD in all BPP engines, negating the need to provide an SO2 ambient air quality demonstration. The purpose of Condition 6 is to validate the dispersion modeling results that
demonstrated compliance with the annual nitrogen dioxide (NO2) NAAQS/AAAQS, but
not the annual NO2 increment. The required annual NO2 ambient air quality modeling analysis is included as an element of the permit application. Because ambient air quality monitoring cannot be used to demonstrate compliance with increment, the monitoring required by Condition 6 is not relevant with respect to ensuring
compliance with the PSD NO2 increment. As a result, NO2 increment modeling analysis is not needed for KPU to satisfy the requirements under 18 AAC 50.540(k)(3)(c) to rescind Condition 6 in Permit No. AQ0108MSS02.
Although a PSD NO2 increment modeling analysis is not required, KPU agreed to provide an analysis demonstrating that no changes have been made to the BPP emissions units that were modeled to support Air Quality Construction Permit No. 9713-AC017. The analysis is summarized below.
1. BPP Operating Reasons – In the application for Construction Permit No. 9713-AC017, the stated reasons for operating the BPP are: a. “Emergency power supply. In the event of a transmission system, or loss of generation at the hydroelectric facilities, the Bailey Powerhouse provides backup power to the system.” b. “Replacement power (energy). Low water conditions at the hydroelectric plants require an alternative power supply for the KPU system, which the Bailey Powerhouse provides on an as-needed basis.” c. “Supplemental peak power (peak demand). Depending on the operating conditions of the hydroelectric plants in the system, and depending on the load
Ketchikan Public Utilities Bailey Power Plant Page C-1 August 2020 Minor Permit Application
conditions, the Bailey Powerhouse can provide KPU with supplemental peaking power on an as-needed basis.”
These reasons for operating the BPP have not changed nor have new reasons been added.
2. Physical Changes or Changes in the Method of Operation – No physical changes or changes in the method of operation of the engines have been made since the dispersion modeling was conducted to support Construction Permit No. 9713-AC017.
3. NOX Emission Rate – No changes have been made to the NOX emission rates that were modeled to support Construction Permit No. 9713-AC017. Per Table 5.2 of the Technical
Analysis Report (TAR) for Construction Permit No. 9713-AC017, the modeled NOX emission rates were based on the potential emissions of the modeled emissions unit, which were based on annual operating limits in terms of hours per year. Permit No. AQ0108MSS02 changed the form of those limits to gallons of diesel fuel per 12
consecutive months, but did not increase the potential NOX emissions. As a result, the
NOx emission values modeled to Construction Permit No. 9713-AC017 continue to be representative.
4. Exhaust Stack Parameters – No changes have been made to engine exhaust parameters since the dispersion modeling was conducted to support Construction Permit No. 9713- AC017. Stack heights, stack diameters, and stack orientation have not changed. Caps have not been added to the stacks.
5. BPP Building Structural Changes – No changes that would affect downwash have been made to BPP structures since the dispersion modeling was conducted to support Construction Permit No. 9713-AC017.
Based on this analysis, no changes have been made to the BPP emissions units that were modeled to support Construction Permit No. 9713-AC017. As a result, the analysis of the BPP
NOX emissions on NO2 increment consumption remains valid.
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ATTACHMENT D Ambient Demonstration
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1.0 Background
Ketchikan Public Utilities (KPU) is authorized to operate five diesel-fired generator engines at the Bailey Power Plant (BPP) under conditions specified in Air Quality Construction Permit No. 9713- AC017, Air Quality Control Minor Permit No. AQ0108MSS02, and Air Quality Operating Permit No. AQ0108TVP05. Prior to the issuance of Permit No. AQ0108MSS02, Condition IV.D in Permit No. 9713-AC017 required KPU to conduct post-construction ambient air quality monitoring for nitrogen dioxide (NO2) and sulfur dioxide (SO2) if KPU operates Engine No. 4 (Emissions Unit (EU) ID 4) for more than 3,340 hours during any 12-month period. This operating limit is based on dispersion modeling conducted for Permit No. 9713-AC017, which was issued on June 4, 1998. The Alaska Department of Environmental Conservation (ADEC) issued Permit No. AQ0108MSS02 on August 30, 2019 to replace Condition IV.D. in Permit No. 9713-AC017 with Permit No. AQ0108MSS02, Condition 6. That condition requires KPU to conduct post- construction ambient air quality monitoring for NO2 and SO2 if the quantity of diesel fuel fired in EU ID 4 exceeds 2,120,900 gallons during any consecutive 12-month period.
This minor air quality permit application has been prepared to rescind Condition 6 in Permit No. AQ0108MSS02, per 18 Alaska Administrative Code (AAC) 50.508(6). Under 18 AAC 50.540(k)(3)(c), the minor air quality permit application must include a demonstration of the effect that revoking the permit condition has on the underlying ambient demonstration, if applicable. On January 14, 2020, KPU and ADEC met to discuss rescinding Condition 6, including identifying the intended purpose of the monitoring requirement. With respect to ambient NO2, KPU and ADEC agreed that the purpose of the ambient air quality monitoring condition is to validate the dispersion modeling results that demonstrated compliance with the annual NO2 National Ambient Air Quality Standard (NAAQS)/Alaska Ambient Air Quality Standard (AAAQS), but not the annual
NO2 increment. As a result, a NO2 increment modeling analysis is not needed for KPU to satisfy the requirements under 18 AAC 50.540(k)(3)(c) to rescind Condition 6 in Permit No. AQ0108MSS02. Consistent with the intended purpose of Condition 6, this report describes the modeling analysis that has been conducted to demonstrate compliance with the annual NO2 NAAQS/AAAQS.
2.0 Modeling Methodology
The modeling approach is based on the latest version of the U.S. Environmental Protection Agency (EPA)-approved AERMOD (version 19191) model. AERMOD is a steady-state, Gaussian dispersion model developed to simulate the dispersion of emissions at distances within 50 kilometers (km) of the stationary source. The latest version of AERMET (19191), AERMINUTE (15272), and AERSURFACE (20060) were used to prepare meteorological data and atmospheric stability parameter inputs for use in AERMOD. Terrain elevations from National Elevation Dataset (NED) files, acquired from the U.S. Geological Survey (USGS), were processed in the latest version of AERMAP (18081) to develop the receptor terrain elevations and corresponding hill
Ketchikan Public Utilities Page D-1 August 2020 Bailey Power Plant Minor Permit Application height scale required by AERMOD. The most recent version of the Building Profile Input Program with Plume Rise Model Enhancements (BPIPPRM, version 04274) was used to model the effects of building downwash on the dispersion of emissions.
2.1 Operating Scenarios and Model Emissions Unit Inventory
Modeled nitrogen oxides (NOX) emission rates were based upon the following specific operating limits in Permit No. AQ0108MSS02:
• EU IDs 1 and 2 fire no more than 511,995 gallons of diesel fuel, combined, per year; • EU ID 3 fires no more than 1,289,920 gallons of diesel fuel per year; and • EU ID 4 fires no more than 2,825,750 gallons of diesel fuel per year.
EU ID 5 was modeled as being operated for 500 hours per year (hr/yr), which is consistent with EPA guidance for estimating the number of hours that an emergency generator could be expected to operate under worst-case conditions (EPA 1995). Modeled NOX emissions from EU IDs 1, 2,
3, and 5 were based on NOX emission factors from EPA AP-42, Compilation of Air Pollutant
Emission Factors, Volume I: Stationary Point and Area Sources. Modeled NOX emissions from EU ID 4 were based on 2016 source test data, which is the most recent source test data available for EU ID 4.
Per 40 CFR 51, Appendix W, Section 8.2.2(d), the modeling analysis includes an assessment of annual average NO2 impacts based on the operation of EU IDs 1 through 4 at 100 percent, 75 percent, and 50 percent of maximum engine operating loads, respectively. Table 2-1, Table 2-2, and Table 2-3 provide the respective modeled physical parameters and modeled emission rates for EU IDs 1 through 5 for the three operating scenarios. KPU does not have vendor data or source test data that indicate the exhaust flows and exhaust temperatures for 75 percent and 50 percent operating loads. In the alternative, the actual engine exhaust flow rates were assumed to vary linearly with the engine operating load and engine exhaust temperatures were estimated based on the respective engine exhaust temperature at 100 percent load multiplied by 0.90 for the 75 percent load scenario, and by 0.85 for the 50 percent load scenario.
All exhaust points and structures used for AERMOD input were referenced to the Universal Transverse Mercator (UTM) Zone 9 coordinate system. All BPP EUs were modeled as vertical and uncapped point sources, except for EU ID 5 (Emergency Engine), which was modeled as a source with a horizontal, uncapped exhaust stack.
Figure 2-1 depicts a site layout of the BPP. Following the guidance provided in the EPA Guidelines for Determination of Good Engineering Practice Stack Height (EPA-450/4-80-023R, June 1985), direction-specific building downwash dimensions were calculated using the Building Profile Input Program, PRIME version (BPIPPRM), version 04274. Building coordinates and heights for each structure that could influence a modeled EU were entered into BPIPPRM and the output dimensions were used to provide direction-specific downwash dimensions to the AERMOD model. The buildings and structures used in the downwash analysis are shown in Figure 2-1 along with all BPP EU exhaust locations.
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Table 2-1. Modeled BPP EU Parameters – 100 Percent Load Scenario Location Emissions Unit NO Modeled Exhaust Parameters (UTM Zone 9) X Emission Stack Rate Base Temp Velocity Diameter Name Model ID Easting (m) Northing (m) Height (g/s) Elev. (m) (K) (m/s) (m) (m) Engine No. 1 ENGINE1 329,058.73 6,137,872.85 1.72 8.50 16.76 644 30.7 0.81
Engine No. 2 ENGINE2 329,054.20 6,137,867.31 1.72 8.50 16.76 644 30.7 0.81
Engine No. 3 ENGINE3 329,046.85 6,137,859.13 8.66 8.50 21.95 716 29.6 1.07
Engine No. 4 ENGINE4 329,042.88 6,137,851.70 16.7 8.50 21.95 621 54.5 1.02 Emergency ENGINE5 329,041.97 6,137,897.23 0.075 8.50 3.05 728 26.6 0.20 Engine
Table 2-2. Modeled BPP EU Parameters – 75 Percent Load Scenario Location Emissions Unit NO Modeled Exhaust Parameters (UTM Zone 9) X Emission Stack Rate Base Temp Velocity Diameter Name Model ID Easting (m) Northing (m) Height (g/s) Elev. (m) (K) (m/s) (m) (m) Engine No. 1 ENGINE1 329,058.73 6,137,872.85 1.72 8.50 16.76 580 23.0 0.81
Engine No. 2 ENGINE2 329,054.20 6,137,867.31 1.72 8.50 16.76 580 23.0 0.81
Engine No. 3 ENGINE3 329,046.85 6,137,859.13 8.66 8.50 21.95 645 22.2 1.07
Engine No. 4 ENGINE4 329,042.88 6,137,851.70 16.7 8.50 21.95 559 40.9 1.02 Emergency ENGINE5 329,041.97 6,137,897.23 0.075 8.50 3.05 728 26.6 0.20 Engine
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Table 2-3. Modeled BPP EU Parameters – 50 Percent Load Scenario Location Emissions Unit NO Modeled Exhaust Parameters (UTM Zone 9) X Emission Stack Rate Base Temp Velocity Diameter Name Model ID Easting (m) Northing (m) Height (g/s) Elev. (m) (K) (m/s) (m) (m) Engine No. 1 ENGINE1 329,058.73 6,137,872.85 1.72 8.50 16.76 548 15.3 0.81
Engine No. 2 ENGINE2 329,054.20 6,137,867.31 1.72 8.50 16.76 548 15.3 0.81
Engine No. 3 ENGINE3 329,046.85 6,137,859.13 8.66 8.50 21.95 609 14.8 1.07
Engine No. 4 ENGINE4 329,042.88 6,137,851.70 16.7 8.50 21.95 528 27.3 1.02 Emergency ENGINE5 329,041.97 6,137,897.23 0.075 8.50 3.05 728 26.6 0.20 Engine
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Figure 2-1. BPP Facility Layout
.
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For a cumulative ambient air quality impact assessment, emissions from the BPP model EU inventory and off-site stationary sources were modeled to compute a cumulative impact. The off- site source inventory was based on the proximity of off-site stationary sources to the BPP and whether a certain off-site source has the potential to cause a significant concentration gradient that will overlap with the predicted impacts from the BPP EUs. Based on these criteria, the E.C. Phillips and Son, Inc., Ketchikan Plant, was included as an off-site source in the cumulative ambient air quality impact assessment. Table 2-4 provides the modeled physical parameters and modeled emission rate for the offsite source inventory.
The resulting air pollutant concentrations from the KPU BPP EUs and the off-site source inventory were then added to a representative background annual NO2 concentration and assessed against the annual NO2 NAAQS/AAAQS.
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Table 2-4. Modeled Offsite Source Parameters Location Offsite Source Modeled Parameters 1 (UTM Zone 9) NO Emission Base Stack X Temp. Velocity Diameter Description Model ID Easting (m) Northing (m) Rate Elev. Height (K) (m/s) (m) (g/s) (m) (m) E.C. Phillips and Son, Inc. ECPSONS 330,924 6,136,732 2.18 8.80 4.27 728 29.1 0.20 Ketchikan Plant
1 The modeled parameters are based on information in Permit AQ0026ORL01 and are representative of the predominant NOX emission sources at the stationary source.
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2.2 AERMET Meteorological Data Analysis
The latest versions of AERMET (19191) and AERMINUTE (15272) were used to process meteorological data used for atmospheric boundary layer and meteorology parameters used in the AERMOD algorithms. National Oceanic and Atmospheric Administration National Weather Service (NWS) upper air and surface meteorological data were used in the analysis.
2.2.1 Meteorological Data
Per 40 CFR Part 51, Appendix W, five years, 2015 through 2019, of representative NWS meteorological data were used with AERMOD to estimate potential annual NO2 impacts. Hourly surface meteorological data collected at the NWS Automated Surface Observing System (ASOS) station located at the Ketchikan International Airport (PAKT) were used with corresponding upper air meteorological data collected at the Annette Island Airport (PANT), which is approximately 22 miles southeast of the PAKT ASOS station. The PAKT ASOS station is located approximately 0.5 miles to the west of the BPP. The coordinates of the PAKT ASOS station are 55.359º N latitude and 131.722º W longitude, which were used in the AERMET input files.
Figure 2-2 depicts a wind rose of the surface wind data collected at the PAKT ASOS station during the 2015 through 2019 period.
Because AERMOD does not simulate air dispersion under calm or missing wind conditions, AERMINUTE was used to process 2-minute average wind data collected at the PAKT ASOS station during 2015 through 2019 to supplement calm and missing wind data in the 1-hour average PAKT ASOS data files input to AERMET. AERMINUTE includes an option to process wind data collected at an ASOS station that uses a sonic anemometer instead of a cup and vane anemometer. During January 2003 a sonic anemometer was installed at the PAKT ASOS station. As a result, the 2015 through 2019 PAKT ASOS 2-minute average wind data were processed using the AERMINUTE Ice Free Wind option for data collected on and after the sonic anemometer installation date.
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Figure 2-2. Ketchikan International Airport Wind Rose – 2015 through 2019
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2.2.2 AERMET Geophysical Input Parameters
AERMET uses upper air and surface meteorological data with site-specific geophysical inputs to calculate the atmospheric boundary layer parameters supplied to AERMOD for use in the air dispersion model algorithms. The geophysical input parameters are albedo, Bowen ratio, and surface roughness length. The procedures used to determine these input parameters are outlined in the EPA AERMOD Implementation Guide (Revised August 2019). The recommendations for determining the geophysical input parameters are summarized as follows:
Albedo is based on a simple unweighted arithmetic mean for a representative domain defined by a 10 km by 10 km grid with a resolution of 1 square kilometer (km2) and centered on the surface measurement site.
Bowen Ratio is based on a simple unweighted geometric mean for the same representative domain that is used to define the site-specific albedo.
Surface Roughness Length is based on an inverse-distance weighted geometric mean for a default upwind distance of 1 km relative to the surface meteorological measurement site. Surface roughness length may be varied by sector to account for variations in land cover near the measurement site, but the sector widths should be no smaller than 30 degrees.
EPA has developed the AERSURFACE processor (EPA, 2020) to determine site characteristics based on digitized land cover data in accordance with the recommendations from the AERMOD Implementation Guide. Per 40 CFR 51, Appendix W, Section 8.4.2(b) the latest version of AERSURFACE (version 20060) was used to process 2016 National Land Classification Data (2016 NLCD) from the USGS to determine albedo, Bowen ratio and surface roughness length values for processing the 2015 through 2019 ASOS PAKT data sets with AERMET.
EPA recommends supplementing the NLCD data set used in AERSURFACE with concurrent USGS percent impervious and percent tree canopy data. EPA further states that the NLCD data set should not be supplemented with only impervious data or only tree canopy data. Because a 2016 USGS impervious data set for Ketchikan is unavailable, AERSURFACE was used to process the 2016 NLCD data set without the use of impervious or tree canopy data.
AERSURFACE was used to determine the seasonal surface characteristics for the land cover categories for each month of the year. The following five seasonal categories are used in AERSURFACE:
• Midsummer with lush vegetation, • Autumn with un-harvested cropland, • Late autumn after frost and harvest, or winter with no snow; • Winter with continuous snow on ground; and • Transitional spring with partial green coverage or short annuals.
To determine the seasonal classification for each month of each year, the AERSURFACE
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seasonal classification was used based on ambient temperature and snow cover data collected at the PAKT ASOS station from 2015 through 2019.
2.3 Model Receptors
EPA defines ambient air as that portion of the atmosphere, external to buildings, to which the general public has access. For the purpose of modeling source emissions, the area in which KPU controls public access is not ambient air. As a result, model receptors were placed only along, and outside of, the BPP Powerhouse footprint.
Terrain elevations from National Elevation Dataset (NED) files acquired from the U.S. Geological Survey were processed in the latest version of AERMAP (18101) to develop receptor terrain elevations and corresponding hill height scales input to AERMOD. Figure 2-3 shows the full receptor field that was used for the modeling analysis. The near grid receptor field consists of receptors located outward from the BPP Powerhouse footprint with 25-meter spacing within a 500 meter by 500 m area. Because the maximum air pollutant impacts were predicted inside the near field receptor grid, the grid extent did not need to be adjusted.
Other receptor grids used for the analysis include:
• A middle receptor field comprised of receptors spaced 100-meters apart within a 2.5 km by 2.5 km area centered over the BPP.
• A far receptor field comprised of receptors spaced 500-meters apart within a 100 km2 area centered over the BPP.
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Figure 2-3. Model Receptor Grid
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2.4 Background Ambient Air Quality Data
Background ambient air quality data are required in a cumulative impact analysis to represent the contribution of ambient air pollutant levels from non-modeled sources (40 CFR 51, Appendix W,
Section 8.3.1). Because ambient NO2 monitoring has never been conducted in the vicinity of the
BPP, KPU requested ADEC agreement to use an ambient NO2 data set collected by the City of Unalaska as part of the Dutch Harbor Power Plant (DHPP) Ambient Air Monitoring Program during
September 1, 2016 through August 31, 2017 to represent ambient background NO2 levels in the vicinity of the BPP. In an email dated June 15, 2020, ADEC approved the use of the DHPP ambient NO2 data set to represent ambient background NO2 levels for the KPU BPP dispersion modeling analysis. Attachment A provides a copy of the KPU request and ADEC approval. The annual average NO2 concentration measured at the DHPP Ambient Air Monitoring Station during the 2016-2017 monitoring year was 15.9 micrograms per cubic meter (µg/m3). This value is used to represent the annual average ambient NO2 background level in the vicinity of the BPP.
2.5 NO2 Modeling Approach
Because the NAAQS and AAAQS for NOX are expressed in terms of NO2, additional calculations and modeling approaches were used to determine ambient NO2 impacts from modeled NOX emissions. For this analysis, the Ozone Limiting Method (OLM) was used in accordance with 40 CFR 51, Appendix W.
The use of the OLM requires in-stack NO2-to-NOX ratios for the modeled emissions units and background ozone (O3) data. Source specific NO2-to-NOX ratios for diesel-fired engines are provided in NO2-to-NOX ratios per Source Tests Approved by the Alaska Department of Environmental Conservation, updated August 23, 2013. Based on the source-specific in-stack
NO2-to NOX data, NO2-to-NOX ratios of 0.10 were assumed for diesel-fired engines.
Hourly O3 data concurrent with the calendar year 2015 through 2019 meteorological data sets are not available, but on-site O3 data were collected as part of the Alaska Electric Light & Power
(AEL&P) Ambient Air Monitoring Program (ADEC, 2018). The highest hourly O3 concentration measured at the AEL&P Ambient Air Monitoring Station was 0.048 parts per million (ppm). This concentration was assigned as the O3 concentration for each hour modeled, providing a conservative estimate of NO-to-NO2 conversion using the OLM.
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3.0 Dispersion Model Results
Table 3-1 provides the maximum ambient air quality impacts for all modeled scenarios for the full model receptor field. Table 3-1 shows that the maximum modeled annual average NO2 impact is 70.4 μg/m3, which corresponds with the 50 percent operating load scenario. Adding the annual average NO2 background level to the maximum modeled annual average ambient concentration 3 results in an annual average NO2 concentration equal to 86.3 μg/m , which is 86.3 percent of the annual average NO2 NAAQS/AAAQS.
The modeling analysis demonstrates that operating the engines at higher loads results in lower modelled ambient NO2 impacts. Because the BPP generators are used as backup to hydroelectric generating units, the BPP generator engines are more likely to be operated at higher loads during periods when hydroelectric generated power is not available (e.g., extended periods of low precipitation, failure of hydroelectric power transmission lines). As a result, the 50-percent operating load scenario results conservatively represent modeled compliance in a worst-case scenario that is not likely to occur.
Figure 3-1 provides an isopleth of the maximum cumulative annual NO2 concentrations for the full receptor field and shows that the maximum modeled impacts are located within 100 meters to the northwest of the BPP.
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Table 3-1. Ambient NO2 Demonstration Results
3 Annual Maximum Modeled NO2 Impact (μg/m ) Background Maximum Percent NO2 Model NO2 Cumulative of NAAQS/ Scenario Concentration NO2 Impact NAAQS/ 2005 2006 2007 2008 2009 AAAQS (μg/m3) (μg/m3) AAAQS (μg/m3)
100 Percent 51.5 48.8 45.6 40.1 43.6 15.9 67.4 100 67.4 Operating Load
75 Percent 58.7 55.0 52.3 46.8 51.1 15.9 74.6 100 74.6 Operating Load
50 Percent 70.4 64.9 61.7 58.5 60.7 15.9 86.3 100 86.3 Operating Load
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Figure 3-1. Isopleth of Cumulative Annual Average NO2 Concentrations 50 Percent Operating Load Scenario
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4.0 References
ADEC, NO2-to-NOX ratios per Source Tests Approved by the Alaska Department of Environmental Conservation, Revised August 23, 2013, Retrieved November 10, 2016 from: http://dec.alaska.gov/air/ap/docs/NO2-NOx%20Instack%20Ratios%20from%20Source%20 Tests%208-23-13.xlsx.
ADEC, Ambient Concentrations Measured at Various Industrial Monitoring Sites, Revised May 22, 2018, Retrieved June 10, 2020 from: https://dec.alaska.gov/media/9162/industrial-data-summary052218.xlsx.
ADEC, Title 18 Alaska Administrative Code, Chapter 50, Air Quality Control, as amended through January 8, 2020.
EPA, Guidelines for Determination of Good Engineering Practice Stack Height, EPA-450/4-80- 023R, Office of Air Quality Planning and Standards, Research Triangle Park, N.C., June 1985.
EPA, Calculating Potential to Emit (PTE) for Emergency Generators, Memorandum from John S. Seitz to EPA Regional Directors, September 6, 1995.
EPA, Revisions to the Guideline on Air Quality Models: Enhancements to the AERMOD Dispersion Modeling System and Incorporation of Approaches to Address Ozone and Fine Particulate Matter; Final Rule, 40 CFR Part 51, Appendix W, Office of Air Quality Planning and Standards, Research Triangle Park, N.C., January 17, 2017
EPA, User’s Guide for the AERMOD Terrain Preprocessor (AERMAP), EPA-454/B-18-004, Office of Air Quality Planning and Standards, Research Triangle Park, N.C., April 2018.
EPA, AERMOD Implementation Guide, Office of Air Quality Planning and Standards, Research Triangle Park, N.C., August 2019.
EPA, User’s Guide for the AMS/EPA Regulatory Model (AERMOD), EPA-454/B-19-028, Office of Air Quality Planning and Standards, Research Triangle Park, N.C., August 2019.
EPA, User’s Guide for the AERMOD Meteorological Preprocessor (AERMET), EPA-454/B-19- 029. Office of Air Quality Planning and Standards, Research Triangle Park, N.C., August 2019.
EPA, User’s Guide for AERSURFACE Tool, EPA-454/B-20-009, Office of Air Quality Planning and Standards, Research Triangle Park, N.C., Revised February 2020.
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Attachment A Ambient Background NO2 Data Proposal and Approval
Ketchikan Public Utilities Response to Alaska Department of Environmental Conservation (ADEC) Comment Addressing the Use of Existing Ambient Air Monitoring Data for the Bailey Power Plant Modeling Protocol Ketchikan Public Utilities (KPU) submitted a modeling protocol for the Bailey Power Plant (BPP) to ADEC on February 26, 2020. In a letter dated May 14, 2020, ADEC rejected the use of ambient air pollutant data collected in Juneau to establish the background concentration of ambient nitrogen dioxide (NO2). ADEC requested that KPU either collect and use site-specific ambient pollutant data or propose the use of a different ambient air quality data set in lieu of the 2011 ambient air data set collected at the Alaska Electric Light & Power Ambient Air Meteorological Monitoring Program located at Juneau, Alaska. In response to the ADEC letter, KPU is requesting ADEC agreement that ambient air monitoring data recently collected at Prince Rupert, British Columbia are representative ambient background data for the BPP location. KPU researched available ambient air data sets that could potentially be used to represent existing ambient background NO2 levels in the vicinity of the BPP location. The requirements for background ambient air data used to support dispersion modeling for an air quality permit application are generally outlined in Title 40 Code of Federal Regulations (40 CFR) 51, Appendix W, section 8.3. Specifically, the monitoring network used to develop background concentrations should conform to U.S. Environmental Protection Agency (EPA) Prevention of Significant Deterioration (PSD) quality assurance standards. Per 40 CFR 51, section 8.3.3, Recommendations for Multi-Source Areas, the ambient background data used for a dispersion modeling analysis should represent ambient pollutant levels attributable to natural sources, other unidentified sources in the vicinity of the project, and regional contributions from distance sources as determined by the procedures in section 8.3.2, Recommendations for Isolated Single Sources.
Ambient NO2 monitoring has not been conducted in the vicinity of the BPP. The conditions that KPU will request ADEC revise or rescind in Air Quality Control Construction Permit No. 9713- AC017 are based on a modeling analysis that included an ADEC-approved ambient NO2 data set collected in Portland, Oregon to conservatively represent ambient background NO2 levels in the vicinity of the BPP. As a result, the background annual average NO2 concentration used for the dispersion modeling analysis prepared to support Permit No. 9713-AC017 was 36 micrograms 3 per cubic meter (g/m ), which is 36 percent of the annual average NO2 National and Alaska ambient air quality standard (NAAQS/AAAQS).
Table 1 provides a summary of two ambient NO2 data sets that KPU identified for possible use as an ambient background NO2 data set for the BPP project. KPU selected these data sets based on the quality of the data, the timeliness of data collection, and the monitoring locations. The data sets under consideration were collected at Prince Rupert, British Columbia and Dutch Harbor, Alaska, respectively. The data sets are summarized in Table 1. These monitoring sites are located at coastal areas characterized by complex terrain. The ambient air quality in these areas is influenced by mobile sources including vehicles and marine vessels, residential area sources, and industrial stationary sources, which are the same type of sources that affect the air quality in the vicinity of the BPP.
KPU requests ADEC approval to use the Prince Rupert, British Columbia ambient NO2 data set collected in 2019 to represent ambient background NO2 levels in the vicinity of the BPP. If ADEC
Page 1 May 2020 were to determine that using the Prince Rupert NO2 data set is not appropriate, then KPU requests ADEC approval to use the City of Unalaska NO2 data set collected in 2016 and 2017 to represent ambient background NO2 levels in the vicinity of the BPP. The basis for this request, including separate assessments of the Prince Rupert and Unalaska ambient NO2 data sets, are provided in the following sections.
Table 1. Summary of Ambient NO2 Monitoring Data Sets
Annual Monitoring Monitoring Latitude / Monitoring Average NO Organization Location Longitude Period 2 Concentration
Prince Rupert Prince Rupert, 54.292 °N, January 1, 2019 – 9.0 g/m3 Port Authority British Columbia 130.352 °W December 31, 2019
53.893 °N, September 1, 2016 – City of Unalaska Dutch Harbor, AK 15.9 g/m3 166.539 °W August 31, 2017
BPP Site Description Figure 1 is a photograph looking to the southeast over the City of Ketchikan, which has an estimated population of 8,289 people as of 2018, according to the U.S. Census Bureau. Figure 2 depicts the BPP in a small industrial area located along the Tongass Narrows in the foreground and shows residential areas, the Ketchikan Port and Harbor, and cruise ship docks at downtown Ketchikan in the background. Figure 2 is an aerial image of Ketchikan with a superimposed image of a wind rose from surface wind data collected at the Ketchikan International Airport (PAKT) National Weather Service (NWS) meteorological station during the 2015 through 2019 period. The wind rose shows that the predominant wind components in the vicinity of the BPP are from the southeast and northwest. This wind pattern facilitates the transport of nitrogen oxide (NOX) emissions from vehicles and marine vessels, residential area sources, and industrial stationary sources located to the northwest and southeast of the BPP to the project area.
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Figure 1. Aerial Photograph of Ketchikan, Alaska
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Figure 2. Aerial Image of Ketchikan, Alaska
Page 4 May 2020
Prince Rupert, British Columbia Prince Rupert, British Columbia is located approximately 90 km to southeast of Ketchikan. Statistics Canada estimates 11,733 people resided in Prince Rupert during 2016. Prince Rupert has the deepest natural harbor in North America and is connected to the Trans-Canada Highway and Canadian National Railway. The primary industrial and commercial activities at Prince Rupert are shipping, fishing, and tourism. Figure 3 is an aerial image of Prince Rupert and shows the location of the Prince Rupert Fairview (Fairview) ambient air monitoring site. The Fairview ambient air monitoring station is owned and operated by the Prince Rupert Port Authority under the oversight of the British Columbia Government and Environment and Climate Change Canada (ECC Canada) National Air Pollution Surveillance (NAPS) Program. The Fairview ambient air monitoring station was commissioned in July 2017 and measures ambient levels of NOX (nitrogen oxide (NO) and NO2), particulate matter (PM2.5 and PM10), sulfur dioxide (SO2), and ozone (O3). The Prince Rupert Port Authority collected the first valid annual NO2 data set at the Fairview ambient air monitoring site during 2019. The 3 annual average NO2 concentration during this period was 9.0 g/m .
The 2019 annual NO2 data set meets the Canadian NAPS quality assurance requirements, which are similar to EPA PSD ambient air data quality assurance requirements. Valid NOX data were collected for more than 80 percent of each quarter for four consecutive quarters during the 2019 monitoring year. The most recent version of the NAPS quality assurance and quality control manual can be accessed at: https://www.ccme.ca/files/Resources/air/Ambient%20Air%20Monitoring%20and%20QA- QC%20Guidelines_en%20SECURE.pdf. Figure 3 includes a wind rose of surface wind data collected at the Fairview ambient air monitoring site during 2019 superimposed over the aerial image of Prince Rupert. The 2019 Fairview wind data indicates that significant wind components at the Fairview monitoring site are from the east, east-southeast, and southeast with secondary wind components from the southwest through northwest (225° through 310°) and account for approximately 33 percent of the winds observed during 2019. This wind pattern is conducive to transporting NOX emissions from sources at the Fairview Container Terminal, Alaska and British Columbia Ferry Terminals, and other nearby residential, commercial, and industrial NOX sources to the Fairview ambient air monitoring site.
KPU proposes to use the Prince Rupert Fairview annual NO2 data set to represent ambient background NO2 levels at the BPP project site for the following reasons.
The communities of Ketchikan and Prince Rupert have similar NOX emission sources that contribute to ambient background NO2 levels in the respective areas.
The Fairview NO2 data set was collected less than one year ago. As a result, the data are representative of existing ambient background NO2 concentrations.
The 2019 Fairview ambient NO2 data set meets ECC Canada NAPS quality assurance standards, which are similar to EPA PSD quality assurance standards.
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Figure 3. Aerial Image of Prince Rupert, British Columbia
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City of Unalaska, Dutch Harbor Power Plant Monitoring Program
If ADEC determines that the Prince Rupert, British Columbia ambient NO2 data set is not suitable to represent background ambient air for the KPU BPP dispersion modeling, then KPU proposes using an ambient NO2 data set collected by the City of Unalaska as part of the Dutch Harbor Power Plant (DHPP) Ambient Air Monitoring Program from September 1, 2016 through August 31, 2017. The DHPP is a PSD major stationary source which, according to the Statement of Basis for Air Quality No. AQ0215TVP04, has a potential to emit 1,240 tons per year of NOX. The DHPP ambient air monitoring site was selected to meet PSD preconstruction monitoring requirements that could be triggered by a potential modification to the DHPP that would result in a significant increase of potential NOX emissions. As a result, the monitoring station was sited next to the DHPP because this location was determined to be representative of the location of the maximum impact from existing sources in the area and the location of the predicted maximum impact due to a potential modification to the DHPP. The annual average ambient NO2 concentration observed during the DHPP ambient air monitoring program was 15.9 g/m3. Figure 4 shows an aerial image of Unalaska and depicts the approximate location of the DHPP ambient air monitoring site. The DHPP monitoring site is located less than one kilometer south of the Unalaska Airport and is adjacent to an area with a combination of residential, commercial, and industrial structures. Figure 4 includes a wind rose of surface wind data collected at the Unalaska Airport NWS meteorological monitoring site during the ambient monitoring program. As shown, the prevalent winds during the DHPP ambient air monitoring program were from the southeast, southwest and northwest. This wind pattern indicates that the DHPP ambient air data characterizes NO2 concentrations resulting from NOX emissions from vehicles, aircraft operations, marine vessels, residential and commercial area sources, and industrial stationary sources, including the DHPP.
Should ADEC determine that the Prince Rupert Fairview annual NO2 data set is not appropriate to represent ambient background NO2 levels at the BPP project, then KPU proposes using the City of Unalaska DHPP ambient NO2 data set as an alternative for the following reasons.
The communities of Ketchikan and Unalaska have similar NOX emission sources that contribute to ambient background NO2 levels in the respective areas.
The DHPP NO2 data set was collected less than five years ago. As a result, the data are representative of existing ambient background NO2 levels.
ADEC has previously determined that the City of Unalaska DHPP ambient NO2 data meet EPA PSD quality assurance standards.
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Figure 4. Aerial Image of Unalaska, Alaska
Page 8 May 2020
From: Renovatio, James J (DEC)
Hi Jennifer,
The Department has had an opportunity to review and discuss KPU’s response to its concerns regarding the proposed ambient demonstration outlined in their 26 February, 2020 modeling protocol. Monitoring and Permitting staff find that KPU’s proposal to use ambient data from the City of Unalaska’s recent monitoring effort for the Dutch Harbor Power Plant will offer a representative position for the forthcoming ambient demonstration. Staff note, however, that KPU’s response appears to remain silent regarding the omission of a strategy to evaluate the impact on NO2 increment in accordance with the requirements of 18 AAC 50.540(k)(3)(C).
Based on some team discussion, I suspect this may be addressed through citation of past discussions, though the matter remains uncertain at this point. I have reached‐out to Isaac for clarification, but the Department will eventually need to address the matter in a way that offers a discoverable basis. Department staff will follow‐up regarding any potential action items as needed. Thank you for your efforts and quick response,
James
From: Jennifer Holstrom
James
Please see Ketchikan Public Utilities’ (KPU’s) attached Response to ADEC Comment Addressing the Use of Existing Ambient Air Monitoring Data for the Bailey Power Plant Modeling Protocol.
On February 26, 2020, KPU submitted a modeling protocol for the Bailey Power Plant to ADEC. In a letter dated May 14, 2020, ADEC rejected the use of ambient air pollutant data collected in Juneau to establish the background concentration of ambient nitrogen dioxide (NO2). ADEC requested that KPU either collect and use site‐specific ambient pollutant data or propose the use of a different ambient air quality data set.
We appreciate your timely review of the attached response. Please let me know if you have any questions or need additional information.
Regards,
JENNIFER HOLSTROM, Senior Project Engineer Ketchikan Public Utilities | 2930 Tongass Avenue, Ketchikan, Alaska 99901
1 Telephone: 907‐228‐4733 | Email: jenniferh@ktn‐ak.us
2 ATTACHMENT E Sulfur Dioxide Emissions
[THIS PAGE INTENTIONALLY LEFT BLANK] Table 1. Significant Emission Unit Inventory Ketchikan Public Utilities - Bailey Power Plant
Emission Unit Fuel Installation Maximum Maximum ID Description Make/Model Type Date Operation Capacity 1 Engine No. 1 Worthington, SWB 16 Cylinder Diesel 1969 4,500 kW 511,995 gal/yr 1 2 Engine No. 2 Worthington, SWB 16 Cylinder Diesel 1969 4,500 kW 3 Engine No. 3 Colt Pielstik, 18PC2V400 Diesel 1976 1,289,920 gal/yr 1 6,450 kW 4 Engine No. 4 Wartsila, 12V46 Diesel 1998 2,825,750 gal/yr 1 10,500 kW 5 Emergency Engine Detroit Diesel, 8V71T 70837305 Diesel 1980 500 hr/yr 2 250 kW
Note 1 Operation limits for EU IDs 1 and 2, 3, and 4 listed in Condition 4.1 through 4.3 in Air Quality Control Permit No. AQ0108MSS02. 2 Operation of 500 hr/yr is based on EPA's default assumption for estimating the number of hours that an emergency generator could be expected to operate under worst-case conditions (EPA's Memorandum: Calculating Potential to Emit for Emergency Generators, EPA, 1995).
Ketchikan Public Utilities Bailey Power Plant Minor Permit Application E-1 August 2020 Table 2. Insignificant Emission Unit Inventory Ketchikan Public Utilities - Bailey Power Plant
Emission Unit Fuel Maximum Rating/Size Description Type Operation Unit 1 Diesel Day Tank NA 300 gallons 8,760 hr/yr Unit 1 Crankcase Oil Day Tank NA 1,000 gallons 8,760 hr/yr Unit 2 Diesel Day Tank NA 300 gallons 8,760 hr/yr Unit 2 Crankcase Oil Day Tank NA 1,000 gallons 8,760 hr/yr Unit 3 Diesel Day Tank NA 1,000 gallons 8,760 hr/yr Unit 4 Diesel Day Tank NA 1,000 gallons 8,760 hr/yr
Ketchikan Public Utilities Bailey Power Plant Minor Permit Application E-2 August 2020 Table 3. Potential to Emit Calculations - Sulfur Dioxide (SO 2) Emissions Ketchikan Public Utilities - Bailey Power Plant
Emission Unit Fuel Maximum Fuel Factor SO2 Emission Maximum Annual Annual SO2 ID Description Rating/Capacity Type Sulfur Content Reference Factor Operation Emissions Significant Emission Units 1 Engine No. 1 4,500 kW Diesel 15 ppmw S Mass Balance 1 0.00021 lb/gal 2 511,995 gal/yr 0.05 tpy 2 Engine No. 2 4,500 kW Diesel 15 ppmw S Mass Balance 1 0.00021 lb/gal 2 3 Engine No. 3 6,450 kW Diesel 15 ppmw S Mass Balance 1 0.00021 lb/gal 2 1,289,920 gal/yr 0.14 tpy 4 Engine No. 4 10,500 kW Diesel 15 ppmw S Mass Balance 1 0.00021 lb/gal 2 2,825,750 gal/yr 0.30 tpy 5 Emergency Engine 250 kW Diesel 15 ppmw S Mass Balance 1 0.00021 lb/gal 2 500 hr/yr 0.001 tpy 3,4
Significant Emission Units - Total Potential to Emit - SO 2 0.5 tpy Insignificant Emission Units NA Unit 1 Diesel Day Tank 300 gallons NANA NANA 8,760 hr/yr 0.00 tpy NA Unit 1 Crankcase Oil Day Tank 1,000 gallons NANA NANA 8,760 hr/yr 0.00 tpy NA Unit 2 Diesel Day Tank 300 gallons NANA NANA 8,760 hr/yr 0.00 tpy NA Unit 2 Crankcase Oil Day Tank 1,000 gallons NANA NANA 8,760 hr/yr 0.00 tpy NA Unit 3 Diesel Day Tank 1,000 gallons NANA NANA 8,760 hr/yr 0.00 tpy NA Unit 4 Diesel Day Tank 1,000 gallons NANA NANA 8,760 hr/yr 0.00 tpy
Insignificant Emission Units - Total Potential to Emit - SO 2 0.0 tpy
Total Potential to Emit - SO2 0.5 tpy
Notes: 1 Mass balance:
For diesel units, the SO2 emission factor is calculated based on the sulfur content in diesel fuel
Molar mass ratio is 32 lb S/mol : 64 lb SO 2/mol; Stoichiometry: 1 mol S = 1 mol SO2 SO2 Emission Factor, lb/gal = (Molar mass ratio, 2 lb SO2:1 lb S) x (weight % S in fuel) x (density of fuel, lb/gal) / 100% 2 Diesel density: 7.11 lb/gal 3 Diesel high heat value: 137,000 Btu/gal (HHV) AP-42, Appendix A, page A-5 4 Diesel engine heat rate: 7,000 Btu/hp-hr AP-42, Table 3.3-1
Conversion factors: 1.341 hp/kW
Ketchikan Public Utilities Bailey Power Plant Minor Permit Application E-3 August 2020 [THIS PAGE INTENTIONALLY LEFT BLANK] ATTACHMENT F Air Quality Control Minor Permit AQ0108MSS02
[THIS PAGE INTENTIONALLY LEFT BLANK] DEPARTMENT OF ENVIRONMENTAL CONSERVATION AIR QUALITY CONTROL MINOR PERMIT
Minor Permit: AQ0108MSS02 Final Date – August 30, 2019
Revises Permit: Construction Permit 9713-AC017
The Alaska Department of Environmental Conservation (Department), under the authority of AS 46.14 and 18 AAC 50, issues Air Quality Control Minor Permit AQ0108MSS02 to the Permittee listed below.
Permittee: Ketchikan Public Utilities 1065 Fair Street Ketchikan, AK 99901 Stationary Source: Bailey Power Plant Location: Latitude / Longitude: 51º 21’ North / 131º 35’ West Project: Revisions to Construction Permit 9713-AC017 Permit Contact: Jennifer Holstrom (907) 228-4733 [email protected]
The Permittee submitted an application for Minor Permit AQ0108MSS02 under 18 AAC 50.508(6) in order to revise the terms and conditions of a Title I permit. This permit satisfies the obligation of the Permittee to obtain a minor permit under 18 AAC 50. As required by AS 46.14.120(c), the Permittee shall comply with the terms and conditions of this permit.
______James R. Plosay, Manager Air Permits Program
G:\AQ\PERMITS\AIRFACS\Ketchikan Public Utilities\Bailey Powerhouse 0108\Minor\MSS02\Final\AQ0108MSS02 Final Permit and TAR.docx Ketchikan Public Utilities Minor Permit AQ0108MSS02 Bailey Power Plant Power Plant Final Date: August 30, 2019
Table of Contents
Section 1 Emissions Unit Inventory ...... 1 Section 2 Fee Requirements...... 2 Section 3 Ambient Air Quality Protection Requirements...... 3 Section 4 Recordkeeping, Reporting, and Certification Requirements ...... 5 Section 5 Standard Permit Conditions ...... 6 Section 6 Permit Documentation ...... 7 Section 7 Complaint Form ...... 8 Attachment 1 – Visible Emissions Form ...... 9 Attachment 2 - ADEC Notification Form ...... 11
Page ii Ketchikan Public Utilities Minor Permit AQ0108MSS02 Bailey Power Plant Power Plant Final Date: August 30, 2019
Abbreviations and Acronyms
AAC ...... Alaska Administrative Code NESHAPs ...... National Emission Standards for ADEC ...... Alaska Department of Hazardous Air Pollutants [as Environmental Conservation contained in 40 C.F.R. 61 and 63] AOS ...... Air Online Services NOx ...... nitrogen oxides AS ...... Alaska Statutes NRE ...... nonroad engine ASTM ...... American Society for Testing and NSPS ...... New Source Performance Materials Standards [as contained in 40 C.F.R. 60] BACT ...... best available control technology O & M ...... operation and maintenance bhp ...... brake horsepower O2 ...... oxygen CDX ...... Central Data Exchange PAL ...... plantwide applicability limitation CEDRI ...... Compliance and Emissions Data Reporting Interface PM-10 ...... particulate matter less than or equal to a nominal 10 microns in C.F.R...... Code of Federal Regulations diameter CAA ...... Clean Air Act PM-2.5 ...... particulate matter less than or equal CO ...... carbon monoxide to a nominal 2.5 microns in Department ...... Alaska Department of diameter Environmental Conservation ppm ...... parts per million dscf ...... dry standard cubic foot ppmv, ppmvd ...... parts per million by volume on a EPA ...... US Environmental Protection dry basis Agency psia ...... pounds per square inch (absolute) EU ...... emissions unit PSD ...... prevention of significant gr/dscf ...... grain per dry standard cubic foot (1 deterioration pound = 7000 grains) PTE ...... potential to emit gph ...... gallons per hour SIC...... Standard Industrial Classification HAPs ...... hazardous air pollutants [as defined SIP ...... State Implementation Plan in AS 46.14.990] SPC ...... Standard Permit Condition or hp ...... horsepower Standard Operating Permit ID ...... emissions unit identification Condition
number SO2 ...... sulfur dioxide kPa ...... kiloPascals The Act ...... Clean Air Act LAER ...... lowest achievable emission rate TPH ...... tons per hour MACT ...... maximum achievable control tpy ...... tons per year technology [as defined in 40 C.F.R. VOC ...... volatile organic compound [as 63] defined in 40 C.F.R. 51.100(s)] MMBtu/hr ...... million British thermal units per VOL ...... volatile organic liquid [as defined hour in 40 C.F.R. 60.111b, Subpart Kb] MMSCF ...... million standard cubic feet vol% ...... volume percent MR&R ...... monitoring, recordkeeping, and wt% ...... weight percent reporting wt%Sfuel ...... weight percent of sulfur in fuel
Page iii Ketchikan Public Utilities Minor Permit AQ0108MSS02 Bailey Power Plant Power Plant Final Date: August 30, 2019
Section 1 Emissions Unit Inventory
Emissions Unit (EU) Authorization. The Permittee is authorized to install and operate the EUs listed in Table 1 in accordance with the minor permit application and the terms and conditions of this permit. The information in Table 1 is for identification purposes only, unless otherwise noted in the permit. The specific EU descriptions do not restrict the Permittee from replacing an EU identified in Table 1. Table 1 – EU Inventory
Construction/ Rating/Max EU # EU Description Make/Model De-rated A Installation Capacity Date Worthington Diesel Engine 3.5 MW 1 Engine No. 1 SWB 16 cylinder, SN:VO- 4.5 MW 1969 4,694 hp 3674 Worthington Diesel Engine 3.5 MW 2 Engine No. 2 SWB 16 cylinder, SN:VO- 4.5 MW 1969 4,694 hp 3675 Colt Pielstik Diesel Engine 5.5 MW 3 Engine No. 3 6.45 MW 1976 18PC2V400, SN: P04206093 7,376 hp
Wartsila Diesel Engine 4 Engine No. 4 10.5 MW N/A 1998 12V46, SN:4554312
Detroit Diesel 5 Emergency Engine 250 kW N/A 1980 8V21T, SN:70837305
Cummins QSK60-G6 NR2 6 Backup Engine No. 1 2,000 kW N/A 2018 B SN: 33197962
Cummins QSK60-G6 NR2 7 Backup Engine No. 2 2,000 kW N/A 2018 C SN: 33176579
Notes:
A EUs 1 through 3 cannot operate at nameplate, due to the age and condition of the units.
B Installation date. EU 6 is a Tier 2 diesel engine manufactured on May 31, 2013
C Installation date. EU 7 is a Tier 2 diesel engine manufactured in 2008. 1. The Permittee shall comply with all applicable provisions of AS 46.14 and 18 AAC 50 when installing a replacement EU, including any applicable minor or construction permit requirements.
Page 1 Ketchikan Public Utilities Minor Permit AQ0108MSS02 Bailey Power Plant Power Plant Final Date: August 30, 2019
Section 2 Fee Requirements
2. Fee Requirements. The Permittee shall pay to the Department all assessed permit fees. Fee rates are set out in 18 AAC 50.400 – 499.
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Section 3 Ambient Air Quality Protection Requirements
3. Conditions IV.A.5, IV.B.2, IV.B.3, and IV.C.2 of Construction Permit 9713-AC017 are rescinded and replaced by Condition 4 of this permit. 4. The Permittee shall limit the operation of EUs 1 through 4 as described below in order to protect the annual NO2; 24-hour and annual PM-10; 1-hour and 8-hour CO; and 3-hour, 24-hour, and annual SO2 National Ambient Air Quality Standards (NAAQS); and the annual NO2; 3-hour, 24-hour, and annual SO2; maximum allowable increases (increments) for Class II areas:1 4.1 EUs 1 and 2 shall not combust more than 511,995 gallons of diesel fuel, combined, per 12 consecutive month period. 4.2 EU 3 shall not combust more than 1,289,920 gallons of diesel fuel per 12 consecutive month period. 4.3 EU 4 shall not combust more than 2,825,750 gallons of diesel fuel per 12 consecutive month period. 4.4 EU 2 shall not exceed 10 hours a day concurrent with EUs 1, 3, and 4 operating at full load.2 For the purposes of this condition, full load is defined as the maximum achievable load for each unit (i.e., 3,150 kW for EUs 1 and 2; 4,950 kW for EU 3; and 9,450 kW for EU 4). 4.5 When EU 2 is operated: a. monitor and record the startup and shutdown dates and times, and record the time that each of EUs 1, 3, and 4 were operating during that period; and b. calculate and record the number of hours each day that EU 2 operated concurrently with EUs 1, 3, and 4. 4.6 Operate and maintain a non-resettable fuel flow meter on each of EUs 1 through 4 accurate to within ± 5 percent. 4.7 Maintain a log of the operation time, duration, fuel consumption, and power production for each EUs 1 through 4. 4.8 By the 15th day of each month, calculate and record: a. the gallons of fuel combusted in EUs 1 and 2 combined, EU 3, and EU 4 for the previous month (if the meter is not operational assume continuous operation for that period); and
1 The limits rescinded and replaced by Condition 4 were established to protect the NAAQS and increments, assuming a sulfur content of 0.25 percent sulfur by weight, as described in the Technical Analysis Report for Construction Permit AQ9713-AC017 dated February 4, 1998. 2 EUs 1 through 3 were de-rated in 1997 due to the age and condition of the units as described in Table 2.2.2 of the Technical Analysis Report for Construction Permit 9713-AC017.
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b. the total gallons of fuel combusted in EUs 1 and 2 combined, EU 3, and EU 4 during the previous 12 consecutive month period. 4.9 Report in each operating report required by the applicable operating permit issued to the source under AS 46.14 and 18 AAC 50 the following information: a. the duration of operation (hours), fuel consumption, and total power production (kW-hr) for each of EUs 1 through 4 for each month; and b. the fuel consumption totals determined under Condition 4.8 for EUs 1 and 2 combined, EU 3, and EU 4. 4.10 Report as excess emissions and permit deviation as described in the applicable operating permit issued to the source under AS 46.14 and 18 AAC 50, whenever Conditions 4.1 through 4.9 are not met. 5. Condition IV.D for Construction Permit No. 9713-AC017 is rescinded and replaced with Condition 6 of this permit. 6. Ambient Air Quality Monitoring. If EU 4 exceeds 2,120,900 gallons of diesel fuel consumed during any 12 consecutive month period, then the Permittee shall operate, maintain, and calibrate one ambient air contaminant monitoring station within six months. The station must be sited within the zone of maximum predicted sulfur dioxide (SO2) and nitrogen dioxide (NO2) has significant contribution. The station must be operated, maintained, and calibrated as follows: 6.1 Submit to the Department for approval, an ambient air monitoring Quality Assurance Project Plan (QAPP) for SO2, NOx, and NO2, prepared in accordance with the Department’s Quality Assurance Project Plan for the State of Alaska Monitoring & Quality Assurance Program. The plan shall identify the monitoring site and rationale for site selection, and shall be submitted not later than three months after EU 4 exceeds 2,120,900 gallons of diesel fuel consumed per 12 consecutive month period.
6.2 Equip the station to continuously measure SO2, NOx, NO2, wind speed, and wind direction. 6.3 Operate the station in accordance with the procedures specified in the Department’s Quality Assurance Project Plan for the State of Alaska Monitoring & Quality Assurance Program, and as outlined in Ketchikan Public Utilities’ approved QAPP to collect no less than one year of ambient data. 6.4 Operate the station to obtain a minimum of 80 percent data capture per calendar quarter for all parameters measured. 6.5 Submit an ambient monitoring report summarizing the half-year monitoring data as part of the Operating Report required in the applicable operating permit issued to the source under AS 46.14 and 18 AAC 50. Include semi-annual monitoring system quality assurance/quality control or calibration audit results as part of the report.
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Section 4 Recordkeeping, Reporting, and Certification Requirements
7. Certification. The Permittee shall certify any permit application, report, affirmation, or compliance certification submitted to the Department and required under the permit by including the signature of a responsible official for the permitted stationary source following the statement: “Based on information and belief formed after reasonable inquiry, I certify that the statements and information in and attached to this document are true, accurate, and complete.” Excess emissions reports must be certified either upon submittal or with an operating report required for the same reporting period. All other reports and other documents must be certified upon submittal. 7.1 The Department may accept an electronic signature on an electronic application or other electronic record required by the Department if a. A certifying authority registered under AS 09.25.510 verifies that the electronic signature is authentic; and b. The person providing the electronic signature has made an agreement with the certifying authority described in Condition 7.1a that the person accepts or agrees to be bound by an electronic record executed or adopted with that signature. 8. Submittals. Unless otherwise directed by the Department or this permit, the Permittee shall submit reports, compliance certifications, and/or other submittals required by this permit, via the Department’s AOS System at http://dec.alaska.gov/applications/air/airtoolsweb using the Permittee Portal option. 8.1 Alternatively, documents certified in accordance with Condition 18 may be submitted either by: a. Email under a cover letter using [email protected]; or b. Certified mail to the following address: ADEC Air Permits Program, ATTN: Compliance Technician, 610 University Ave., Fairbanks, AK 99709-3643.
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Section 5 Standard Permit Conditions
9. The Permittee must comply with each permit term and condition. Noncompliance with a permit term or condition constitutes a violation of AS 46.14, 18 AAC 50, and, except for those terms or conditions designated in the permit as not federally enforceable, the Clean Air Act, and is grounds for 9.1 an enforcement action; or 9.2 permit termination, revocation and reissuance, or modification in accordance with AS 46.14.280. 10. It is not a defense in an enforcement action to claim that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with a permit term or condition. 11. Each permit term and condition is independent of the permit as a whole and remains valid regardless of a challenge to any other part of the permit. 12. The permit may be modified, reopened, revoked and reissued, or terminated for cause. A request by the Permittee for modification, revocation and reissuance, or termination or a notification of planned changes or anticipated noncompliance does not stay any permit condition. 13. The permit does not convey any property rights of any sort, nor any exclusive privilege. 14. The Permittee shall allow the Department or an inspector authorized by the Department, upon presentation of credentials and at reasonable times with the consent of the owner or operator to 14.1 enter upon the premises where an emissions unit subject to this permit is located or where records required by the permit are kept; 14.2 have access to and copy any records required by this permit; 14.3 inspect any stationary source, equipment, practices, or operations regulated by or referenced in the permit; and 14.4 sample or monitor substances or parameters to assure compliance with the permit or other applicable requirements.
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Section 6 Permit Documentation
Date Document Details June 27, 2019 Application Received
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Section 7 Complaint Form
COMPLAINT FORM
Date Time:
Activities Involved:
Provide a description of reported complaint. Attach sheets as necessary.
If applicable, operational conditions which contributed to the complaint:
If applicable, ambient conditions which contributed to the complaint:
If applicable, describe measures taken to immediately address the complaint.
If applicable, describe measures taken to address preventing the condition which generated the complaint.
If applicable, describe any reason that you feel the complaint may not be a violation:
Based on information and belief formed after reasonable inquiry, I certify that the statements and information in and attached to this document are true, accurate and complete.
______Printed Name Signature Date
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Attachment 1 – Visible Emissions Form
VISIBLE EMISSION OBSERVATION FORM This form is designed to be used in conjunction with EPA Method 9, “Visual Determination of the Opacity of Emissions from Stationary Sources.” Temporal changes in emission color, plume water droplet content, background color, sky conditions, observer position, etc. should be noted in the comments section adjacent to each minute of readings. Any information not dealt with elsewhere on the form should be noted under additional information. Following are brief descriptions of the type of information that needs to be entered on the form: for a more detailed discussion of each part of the form, refer to “Instructions for Use of Visible Emission Observation Form.”
• Source Name: full company name, parent company or division or • Sky Conditions: indicate cloud cover by percentage or by subsidiary information, if necessary. description (clear, scattered, broken, overcast). • Address: street (not mailing or home office) address of facility • Wind Speed: record wind speed; can use Beaufort wind scale or where VE observation is being made. hand-held anemometer to estimate. • Phone (Key Contact): number for appropriate contact. • Wind Direction From: direction from which wind is blowing; can use compass to estimate to eight points. • Source ID Number: number from NEDS, agency file, etc. • Ambient Temperature: in degrees Fahrenheit or Celsius. • Process Equipment, Operating Mode: brief description of process equipment (include type of facility) and operating rate, % • Wet Bulb Temperature: can be measured using a sling capacity, and/or mode (e.g. charging, tapping, shutdown). psychrometer • Control Equipment, Operating Mode: specify type of control • RH Percent: relative humidity measured using a sling device(s) and % utilization, control efficiency. psychrometer; use local US Weather Bureau measurements only if nearby. • Describe Emission Point: for identification purposes, stack or emission point appearance, location, and geometry; and whether • Source Layout Sketch: include wind direction, sun position, emissions are confined (have a specifically designed outlet) or associated stacks, roads, and other landmarks to fully identify unconfined (fugitive). location of emission point and observer position. • Height Above Ground Level: stack or emission point height • Draw North Arrow: to determine, point line of sight in direction of relative to ground level; can use engineering drawings, Abney emission point, place compass beside circle, and draw in arrow level, or clineometer. parallel to compass needle. • Height Relative to Observer: indicate height of emission point • Sun’s Location: point line of sight in direction of emission point, relative to the observation point. move pen upright along sun location line, mark location of sun when pen’s shadow crosses the observer’s position. • Distance from Observer: distance to emission point; can use rangefinder or map. • Observation Date: date observations conducted. • Direction from Observer: direction plume is traveling from • Start Time, End Time: beginning and end times of observation observer. period (e.g., 1635 or 4:35 p.m.). • Describe Emissions and Color: include physical characteristics, • Data Set: percent opacity to nearest 5%; enter from left to right plume behavior (e.g., looping, lacy, condensing, fumigating, starting in left column. Use a second (third, etc.) form, if readings secondary particle formation, distance plume visible, etc.), and continue beyond 30 minutes. Use dash (-) for readings not made; color of emissions (gray, brown, white, red, black, etc.). Note explain in adjacent comments section. color changes in comments section. • Comments: note changing observation conditions, plume • Visible Water Vapor Present?: check “yes” if visible water vapor characteristics, and/or reasons for missed readings. is present. • Range of Opacity: note highest and lowest opacity number. • If Present, is Plume…: check “attached” if water droplet plume forms prior to exiting stack, and “detached” if water droplet plume • Observer’s Name: print in full. forms after exiting stack. • Observer’s Signature, Date: sign and date after performing VE • Point in Plume at Which Opacity was Determined: describe observation. physical location in plume where readings were made (e.g., 1 ft • Organization: observer’s employer. above stack exit or 10 ft. after dissipation of water plume). • Certified By, Date: name of “smoke school” certifying observer • Describe Plume Background: object plume is read against, include and date of most recent certification. texture and atmospheric conditions (e.g., hazy). • Background Color: sky blue, gray-white, new leaf green, etc.
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Attachment 2 - ADEC Notification Form
Excess Emissions and Permit Deviation Reporting State of Alaska Department of Environmental Conservation Division of Air Quality Bailey Power Plant AQ0108MSS02 Stationary Source Name Air Quality Permit Ketchikan Public Utilities Company Name Date When did you discover the Excess Emissions/Permit Deviation? Date: / / Time: :/ When did the event/deviation? Begin Date: / / Time: : (Use 24-hr clock.) End Date / / Time: : (Use 24-hr clock.) What was the duration of the event/deviation? : (hrs:min) or days (total # of hrs, min, or days, if intermittent then include only the duration of the actual emissions/deviation) Reason for notification: (please check only 1 box and go to the corresponding section) Excess Emissions Complete Section 1 and Certify Deviation from permit conditions complete Section 2 and certify Deviation from COBC, CO, or Settlement Agreement Complete Section 2 and certify
Section 1. Excess Emissions (a) Was the exceedance Intermittent or Continuous (b) Cause of Event (Check one that applies): Start Up/Shut Down Natural Cause (weather/earthquake/flood) Control Equipment Failure Scheduled Maintenance/Equipment Adjustments Bad fuel/coal/gas Upset Condition Other (c) Description Describe briefly, what happened and the cause. Include the parameters/operating conditions exceeded, limits, monitoring data and exceedance.
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(d) Emission unit(s) Involved: Identify the emission units involved in the event, using the same identification number and name as in the permit. Identify each emission standard potentially exceeded during the event and the exceedance.
EU EU Name Permit Condition Exceeded/Limit/Potential Exceedance
(e) Type of Incident (please check only one): Opacity % Venting (gas/scf) Control Equipment Down Fugitive Emissions Emission Limit Exceeded Record Keeping Failure Marine Vessel Opacity Failure to monitor/report Flaring Other:
(f) Unavoidable Emissions: Do you intend to assert that these excess emissions were unavoidable? YES NO Do you intend to assert the affirmative defense of 18 AAC 50.235? YES NO
Certify Report (go to end of form)
Page 12 Ketchikan Public Utilities Minor Permit AQ0108MSS02 Bailey Power Plant Power Plant Final Date: August 30, 2019
Section 2. Permit Deviations
(a) Permit Deviation Type (check only one box corresponding with the section in the permit) Emission Unit Specific General Source Test/Monitoring Requirements Recordkeeping/Reporting/Compliance Certification Standard Conditions Not Included in Permit Generally Applicable Requirements Reporting/Monitoring for Diesel Engines Insignificant Emission Unit Stationary Source-Wide Other Section: (title of section and section # of your permit)
(b) Emission unit(s) Involved: Identify the emission unit involved in the event, using the same identification number and name as in the permit. List the corresponding Permit condition and the deviation.
EU Emission Unit Name Permit Condition /Potential Deviation
(c) Description of Potential Deviation: Describe briefly, what happened and the cause. Include the parameters/operating conditions and the potential deviation.
(d) Corrective Actions: Describe actions taken to correct the deviation or potential deviation and to prevent future recurrence.
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Certification:
Based on information and belief formed after reasonable inquiry, I certify that the statements and information in and attached to this document are true, accurate, and complete.
Printed Name: Title: Date:
Signature: Phone Number:
NOTE: This document must be certified in accordance with 18 AAC 50.345(j)
To submit this report:
1. Department’s Air Online Services using the Permittee Portal option:
http://dec.alaska.gov/applications/air/airtoolsweb
If submitted online, report must be submitted by an authorized E-Signer for the stationary source.
Or
2. Fax to: 907-451-2187
Or 3. Email to: [email protected] Or 4. Mail to: ADEC Air Permits Program 610 University Avenue Fairbanks, AK 99709-3643
Or
5. Phone Notifications: 907-451-5173
Phone notifications require a written follow-up report.
Page 14 [THIS PAGE INTENTIONALLY LEFT BLANK] ATTACHMENT G Electronic Copy of Permit Application and Modeling Files