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Thomma, Alison (DEQ) Thomma, Alison (DEQ) From: Angie Wanger <[email protected]> Sent: Wednesday, December 10, 2014 11:31 PM To: DEQ-ROP Cc: Keith C. Miller; Ross P. Olson Subject: N7362 - ROP Renewal Application Attachments: 1. ROP Application Form.pdf; 2. N7362_ROP_MARK-UP.doc; 3. Supplemental Information.pdf; 4. Plans Referenced in ROP (MAP OMM SSMP).pdf; Cover Letter.pdf To Whom It May Concern, Please find the attached ROP Renewal Application for Graymont Western Lime – Port Inland Plant (N7362) located in Gulliver, Michigan. This email includes the following attachments which comprise of the full renewal application: ROP Application Form (“1. ROP Application Form.pdf”) ROP mark‐up (Word version) (“2. N7362_ROP_MARK‐UP.doc”) Supplemental Data (“3. Supplemental Information.pdf”) [this contains GHG PTE calculations‐ROP Application Form includes additional attachments] Plans referenced in ROP (“4. Plans Referenced in ROP (MAP OMM SSMP).pdf”) [note FDP is an Appendix in the ROP] We are also providing the cover letter less attachments (“Cover Letter.pdf”) which we included with our hard‐copy submittal. It is provided with the electronic submittal to provide context/information about the ROP Renewal Application. A hard copy of the ROP Renewal Application (including original signatures) was sent via UPS and should arrive at the Marquette office on December 11, 2014. Please do not hesitate to contact me (651‐275‐9900) or Ross Olson at Graymont (920‐437‐4054 x1475) with any questions regarding the ROP Renewal Application. We look forward to a response from MDEQ regarding administrative completeness within 15 days of December 11, 2014. Thank you and regards, …………………………………………………………………………………………………. Angie Wanger, CM Managing Consultant Trinity Consultants 12445 55th Street North, Suite A2 | Lake Elmo, MN 55042 Office: 651‐275‐9900 x4 | Fax: 651‐351‐3987 Email: [email protected] | LinkedIn: www.linkedin.com/in/angiewanger Stay current on environmental issues. Subscribe today to receive Trinity's free Environmental Quarterly. Learn about Trinity’s courses for environmental professionals. 1 _________________________________________________________________________ The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from any computer. _________________________________________________________________________ 2 December 5, 2014 Ed Lancaster Michigan Department of Environmental Quality Upper Peninsula ‐ Air Quality Division 1504 West Washington Street Marquette, MI 49855 RE: Renewable Operating Permit Renewal Application for Permit No. MI‐ROP‐N7362‐2010a Graymont Western Lime Inc. – Port Inland Plant SRN Code: N7362 Dear Mr. Lancaster, Please find the enclosed renewal application for the Graymont Western Lime Inc.’s (Graymont) lime manufacturing plant located in Gulliver, Michigan (herein Port Inland Plant). The Port Inland Plant currently operates under Renewable Operating Permit (ROP) No. MI‐ROP‐N7362‐2010 issued by the Michigan Department of Environment Quality (MDEQ) on July 1, 2010, revised on May 1, 2012 and expires on June 30, 2015. Pursuant to R336.1210(7) (Rule 210(7)) and General Condition 35 of the current ROP, an administratively complete renewal application must be submitted at least six (6) months prior to permit expiration, or not later than December 31, 2014. A copy of the ROP renewal form is attached to this letter (Attachment 1). Pursuant to the MDEQ guidance, a redline/strikeout version of the current ROP with the proposed changes to the ROP is included in this letter as Attachment 2. Facility‐wide greenhouse gas (GHG) potential to emit (PTE) calculations are included in Attachment 3. Three facility changes have occurred onsite since the previous application. However, all of these facility changes qualify for Permit to Install (PTI) exemptions. In addition, there are some regulatory updates that are incorporated into the ROP renewal form and permit redline. These facility changes and regulatory updates are further discussed in the following sections. Graymont recently went through a facility name change from Western Lime Inc. to Graymont Western Lime Inc. While this change appears to have been incorporated into the current ROP, the administrative PTI is conservatively included in the renewal application for completeness. FACILITY CHANGES As noted above, the following facility changes have occurred at the site since the last permit issuance, described by emissions unit/process: Coal Pre‐Crusher (EUCOALPRECRUSHER) ‐ The coal pre‐crusher is an attachment to the existing coal chute. The coal chute connects at the top and bottom of the pre‐crusher via a sealed flange. There were no predicted emission increases from the coal pre‐crusher. Graymont conducted a permit applicability analysis for the installation of the coal pre‐crusher and determined that the coal pre‐crusher did not require a PTI pursuant to R336.1290 (Rule 290). Flexible Group “FGR290” is included in the permit markup to incorporate Rule 290 emission limit, recordkeeping and reporting requirements. December 5, 2014‐ Page 2 Kiln Run Silo 231 ‐ The Port Inland Plant added an additional kiln run silo, controlled by Baghouse 231 (described below). The installation of the additional kiln run silo did not require a PTI pursuant to R336.1284(k) (Rule 284(k)). Baghouse 231 (EUBAGHOUSE 231) ‐ The Port Inland Plant added a fabric filter baghouse that is associated with the feed conveyor and the Kiln Run Silo 231. The installation of the baghouse did not require a PTI pursuant to Rule 284(k). The renewal application also includes the Michigan Air Emission Reporting System (MAERS) stack form associated with the fabric filter baghouse. Graymont proposes to add the new fabric filter baghouse (EUBAGHOUSE231) associated with Kiln Run Silo 231 to the existing Flexible Group “FGBAGHOUSES.” Loadout bin 144 ‐ An additional product loadout bin was added to the three existing product loadout bins. The new product loadout bin and conveyor are controlled by the existing Baghouse 141 (EUBAGHOUSE141). There have been no operational or design changes to Baghouse 141 to accommodate the additional product loadout bin. Therefore, the addition of the product loadout bin did not require a PTI, pursuant to Rule 284(k). REGULATORY CHANGES This section includes a summary of potentially applicable rules that either were promulgated during the term of the current ROP or may be applicable upon renewal of the Port Inland Plant’s ROP. RICE MACT EPA recently finalized amendments to 40 CFR 63, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants (NESHAP) for stationary reciprocating internal combustion engines (RICE). In order to determine applicable requirements, Graymont reviewed the applicability of this rule for the 68.5 horsepower diesel‐fired Yanmar Engine at the Port Inland Plant. NESHAP Subpart ZZZZ applies to all existing, new, or reconstructed stationary RICE; therefore, the engine identified above is subject to this regulation. The requirements under NESHAP Subpart ZZZZ depend on unit and source characteristics such as existing versus new, emergency versus non‐emergency and area versus major source of HAP. The Port Inland Plant’s kiln auxiliary drive engine is classified as an existing, non‐emergency engine at a major source of HAP. Accordingly, Graymont expects the applicable RICE MACT provisions to be added to its ROP under a new Flexible Group “FGRICEMACT” and has included them in the ROP markup in Attachment 2. FGRICEMACT will apply to any RICE subject to NESHAP Subpart ZZZZ. Table 1. RICE unit at Port Inland Plant subject to RICE MACT Engine Information MACT Applicability Engine Rating Fuel Commenced Subject to MACT Engine Name (HP) Type Construction Date MACT? Classification Classification Non‐ Yanmar 68.5 Diesel Pre 6/12/2006 Yes Existing CI < 100 hp emergency CI Yanmar Engine – RICE MACT Compliance Requirements Non‐emergency Compression Ignition Engine 1. Comply with the following maintenance limitations (§63.6602, Table 2c): December 5, 2014‐ Page 3 a. Change oil and filter every 1,000 hours of operation or annually, whichever comes first; b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, replace as necessary; c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. 2. Operate and maintain engine according to manufacturer’s instructions (§63.6625(e)). 3. Record maintenance conducted on the engine to demonstrate required work practices have been met (§63.6655(e)). 4. No notifications are required (§63.6645(a)(5)). NSPS Subpart Y 40 CFR 60 Subpart Y (NSPS Subpart Y) applies to coal preparation facilities and processing plants which process more than 181 megagrams (Mg) (200 tons) of coal per day, per 40 CFR 60.250(a).1 The kiln at the facility is designed to consume 8 tons per hour of solid fuel (with 90% of the grind passing a No. 200‐mesh screen). The conveyor system which will feed into the coal pre‐crusher is rated at 100 ton per hour; this capacity rating was included with regard to NSPS Subpart Y applicability pursuant to 40 CFR 60.250(a). Assuming 24 hours of operation per day, and that the coal pre‐crusher will not be physically modified to limit the coal processing capacity (i.e., the production rate of the coal pre‐crusher will be equal to that of the conveyor system), Graymont has a coal processing capacity of 2,400 tons of coal per day. Therefore, the coal pre‐crusher is subject to NSPS Subpart Y because it is capable of processing more than 200 tons per day of coal. As a result, the following opacity standard requirement applies to the coal pre‐crusher: The coal pre‐crusher shall not emit any gases which exhibit 10 percent opacity or greater pursuant to §60.254(b)(1).2 An initial performance test for opacity will be conducted pursuant to §60.255(b)(2).
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