CAFB_NSR_1517M5R1_13Jun14.pdf

SUSANA MARTINEZ

GOVERNOR

JOHN A. SANCHEZ

LIEUTENANT GOVERNOR

New Mexico

ENVIRONMENT DEPARTMENT

525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505-1816

Phone (505) 476-4300 Fax (505) 476-4375 www.nmenv.state.nm.us

RYAN FLYNN

CABINET SECRETARY

BUTCH TONGATE

DEPUTY SECRETARY

Template version: 4/28/14

Air Quality Bureau

NEW SOURCE REVIEW PERMIT

Issued under 20.2.72 NMAC

Certified Mail No: 7005 1820 0001 5772 7550 Return Receipt Requested

NSR Permit No: 1517-M5R1 Facility Name: Cannon Air Force Base

Facility Owner/Operator: United States Air Force Permittee Name: Cannon Air Force Base Mailing Address: 27 SOCES/CEIE, 506 North Air Commando Way Cannon AFB, NM 88103

TEMPO/IDEA ID No: 106-PRN20140001 AIRS No: 35-009-0004

Permitting Action: Technical Revision Source Classification: PSD Minor and Major Title V

Facility Location: 34°22’49.6” N and -103°18’50.8” W County: Curry

Air Quality Bureau Contact Joseph Kimbrell Main AQB Phone No. (505) 476-4300

June 13, 2014 Richard L. Goodyear, PE Date Bureau Chief

NSR Permit No. 1517-M5R1 Page 2 of 33

TABLE OF CONTENTS

Part A FACILITY SPECIFIC REQUIREMENTS

A100 Introduction A101 Permit Duration A102 Facility: Description A103 Facility: Applicable Regulations A104 Facility: Regulated Equipment A105 Facility: Control Equipment A106 Facility: Allowable Emissions A107 Facility Allowable Startup, Shutdown, and Maintenance (SSM) Emissions A108 Facility: Hours of Operation A109 Facility: Reporting Schedules A110 Facility: Fuel Sulfur Requirements A111 Facility: 20.2.61 NMAC Opacity A112 Alternative Operating Scenario – Not Required A113 Compliance Plan – Not Required A114 Reducing Facility Emissions – Not Required

EQUIPMENT SPECIFIC REQUIREMENTS

A200 Oil and Gas Industry – Not Required A300 Construction Industry – Not Required A400 Power Generation Industry – Not Required A500 Solid Waste Disposal (Landfills) Industry– Not Required A600 Cannon Air Force Base A601 Source Category External Combustion (ECOM) A602 Source Categories Fuel Dispensing and Fuel Storage Tanks A603 Source Category Surface Coating – Paint Booths A604 Internal Combustion Engines to be addressed in Title V permit A605 Source Category Miscellaneous Chemical Use to be addressed in Title V permit .. 14

Part B GENERAL CONDITIONS B100 Introduction B101 Legal B102 Authority B103 Annual Fee B104 Appeal Procedures B105 Submittal of Reports and Certifications B106 NSPS and/or MACT Startup, Shutdown, and Malfunction Operations B107 Startup, Shutdown, and Maintenance Operations B108 General Monitoring Requirements B109 General Recordkeeping Requirements B110 General Reporting Requirements B111 General Testing Requirements B112 Compliance B113 Permit Cancellation and Revocation B114 Notification to Subsequent Owners

NSR Permit No. 1517-M5R1 Page 3 of 33

B115 Asbestos Demolition B116 Short Term Engine Replacement

Part C MISCELLANEOUS C100 Supporting On-Line Documents C101 Definitions C102 Acronyms

PART A FACILITY SPECIFIC REQUIREMENTS

A100 Introduction

A. This permit, NSR 1517-M5R1, supersedes all portions of Air Quality Permit 1517-M5, issued September 21, 2013.

A101 Permit Duration

A. The term of this permit is permanent unless withdrawn or cancelled by the Department.

A102 Facility: Description

A. This facility is a military installation that is home to the U.S. Air Force 27th Special Operations Wing (SOW), whose primary mission is to plan and execute specialized contingency operations using advanced aircraft and tactics. This function requires the operation of several regulated air emission sources. Stationary sources include external combustion equipment, paint booths, fuel loading activities, fuel storage tanks, fuel dispensing activities, and miscellaneous chemical usage.

B. This facility is located approximately 7 miles west of Clovis, New Mexico in Curry County.

C. This technical revision includes the following and does not increase the allowable emissions and does not relax conditions:

(1) Reevaluation of PSD applicability for Cannon AFB. The aerospace ground equipment (AGE) which are exempt under 20.2.72.202.A.(13) NMAC, has been determined by NMED as not subject to PSD and should not be included in this permit.

(2) Notification of replacement gasoline storage tanks (units 22004, 22005, 22006) at the Army and Air Force Exchange Service (AAFES) gasoline service station.

NSR Permit No. 1517-M5R1 Page 4 of 33

(3) Implement a fuel use cap for all non-exempt basewide external combustion units to facilitate flexibility for additional future units, excluding Family Housing natural gas usage.

(4) Update permit conditions A602B, A604 and A605 to reflect corrections due to current applicability and errors previous written.

D. Table 102.A and Table 102.B show the total potential emissions from this facility for information only, not an enforceable condition, excluding exempt sources or activities.

Table 102.A: Total Potential Pollutant Emissions from Entire Facility1 Pollutant Emissions (tons per year) Nitrogen Oxides (NOx) 22.3 Carbon Monoxide (CO) 18.8 Volatile Organic Compounds (VOC) 106.0 Sulfur Dioxide (SO2) < 1 Total Suspended Particulates (TSP) 3.0 Particulate Matter less than 10 microns (PM10) 3.0 Particulate Matter less than 2.5 microns (PM2.5) 2.3 Green House Gas (GHG) (CO2e) 95,884

1 Table 102.A does not include the PTE of NSR exempt equipment that is included in the Title V permit.

Table 102.B: Total Potential HAPs that exceed 1.0 ton per year1 Pollutant Emissions (tons per year) Butyl Carbitol Acetate 1.9 Ethylbenzene 4.2 Ethylene Glycol Monoethyl Ether Acetate 1.3 Hexamethylene-1, 6-Diisocyanate 5.8 Hexane 1.7 Methanol 2.7 Methyl Isobutyl Ketone 9.7 Methylene Chloride 2.3 Methyl tert Butyl Ether 2.0 Phenol 1.0 Toluene 9.8 Xylene 9.1 Yellow Titanate Pigment 2.0 Individual HAP 9.92 Total HAPs*

24.92

NSR Permit No. 1517-M5R1 Page 5 of 33

1 Table 102.B does not include the PTE of exempt equipment or insignificant and trivial activities.

2 Individual and Total HAP emissions are limited to 9.9 and 24.9 tons per year, respectively.

A103 Facility: Applicable Regulations

A. The permittee shall comply with all applicable sections of the requirements listed in Table 103.

Table 103.A: Applicable Requirements

Applicable Requirements Federally Enforceable

Unit No.

20.2.1 NMAC General Provisions X Entire facility

20.2.3 NMAC Ambient Air Quality Standards X Entire facility

20.2.7 NMAC Excess Emissions X Entire facility

20.2.61.109 NMAC Smoke and Visible

Emissions X

Non-Exempt Basewide External Combustion Units

20.2.70 NMAC Operating Permits X Entire facility

20.2.71 NMAC Operating Permit Emission Fees X Entire facility

20.2.72 NMAC Construction Permit X Entire facility

20.2.73 NMAC Notice of Intent and Emissions

Inventory Requirements X Entire facility

20.2.75 NMAC Construction Permit Fees X Entire facility

20.2.77 NMAC New Source Performance X Select units

20.2.82 NMAC MACT Standards for Source

Categories of HAPS X Select units 40 CFR 50 National Ambient Air Quality Standards X Entire facility

40 CFR 63, Subpart A X 15001, 15003, 22001, 22002, 22004, 22005, 22006

40 CFR 63, Subpart CCCCCC X 15001, 15003, 22001, 22002, 22004, 22005, 22006

A104 Facility: Regulated Equipment

A. Table 104.A lists all of the process equipment authorized for this facility. Emission units that were identified as exempt activities and/or equipment (as defined in

20.2.72.202 NMAC) not regulated pursuant to the Act are not included.

NSR Permit No. 1517-M5R1 Page 6 of 33

Table 104.A: Regulated Equipment list Unit No. Source Description Make

Model Serial No. Capacity Construction Date1

ECOM

Basewide External

Combustion of Natural Gas

Various Various

446.6 million scf/yr fuel consumption

Various

14001 External Combustion Heater, Building 199

Hastings/ L-240-105-8628 41794-2 8.628

MMBtu/hr 1992

14002 External Combustion Heater, Building 199

Hastings/ L-240-105-8628 41793-2 8.628

MMBtu/hr 1992

14003 External Combustion Heater, Building 199

Rapids SA Series/ SA89 919112 8.25 MMBtu/hr 1992

14004 External Combustion Heater, Building 199

Rapids SA Series/ SA89 919114 8.25 MMBtu/hr 1992

14007 External Combustion Heater, Building 4607

Camus/ Force Dyna Series O41215453 5.0 MMBtu/hr 10/15/2012

14008 External Combustion Heater, Building 4607

Camus/ Force Dyna Series 111114765 5.0 MMBtu/hr 10/15/2012

14009 External Combustion Heater, Building 4607

Camus/ Force Dyna Series 111114766 5.0 MMBtu/hr 10/15/2012

14010 External Combustion Heater, Building 4608

Hydro Engineering, EHGV 4/3000

13090075 0.36 MMBtu/hr 6/30/2013

14011 Parachute Drying

Tower Heater, Building

TBD TBD 0.525

MMBtu/hr TBD

14012 External Combustion Heater, Building 4607

Weather-Rite, RAM-25-H2 unknown 2.0 MMBtu/hr 10/15/2012

14013 Washrack Heater, Building 4608

Hydro Engineering, EHGV 4/3000

13090076 0.36 MMBtu/hr 6/30/2013

15001 Fuel Dispensing for Tanks 22001 and 22002 NA NA NA May 2009

15003 Fuel Dispensing for Tanks 22004, 22005, and 22006

NA NA NA 1992

15004 Fuel Dispensing for Tanks 22007 and 22008 NA NA NA TBD

21001 Aircraft Paint Booth, Building 199

Miscellaneous Parts NA NA 1992

21002 Parts Paint Booth, Building 199

Global Finishing Solutions NA NA 1992

21003 Paint Booth, Building

Miscellaneous Parts NA NA TBD

21005 Aircraft Paint Booth, Building 4607

Miscellaneous Parts NA NA 12/2010

NSR Permit No. 1517-M5R1 Page 7 of 33

Unit No. Source Description Make

Model Serial No. Capacity Construction Date1

21006 Parts Paint Booth, Building 4607

Global Finishing Solutions/

IDB-3012

NA NA 12/2010

22001 E-85 Storage Tank 313 TESCA/ STI-F911 UL-142 NA 12,000 gallon 5/2009

22002 Gasoline Storage Tank

TESCA/

STI-F911 UL-142 NA 12,000 gallon 5/2009

22004 Gasoline Storage Tank 1111R

Containment Solutions NA 10,000 gallon 12/2013

22005 Gasoline Storage Tank 1111M

Containment Solutions NA 10,000 gallon 12/2013

22006 Gasoline Storage Tank 1111P

Containment Solutions NA 10,000 gallon 12/2013

22007 Aviation Gasoline Storage Tank 1 TBD NA 3,000 gallon TBD

22008 Aviation Gasoline Storage Tank 2 TBD NA 3,000 gallon TBD

1 Construction Date is synonymous with Installation Date.

2 All TBD (to be determined) units and like-kind engine replacements must be evaluated for applicability to NSPS and NESHAP requirements.

A105 Facility: Control Equipment

A. Table 105.A lists all the pollution control equipment required for this facility. Each emission point is identified by the same number that was assigned to it in the permit application.

Table 105.A: Control Equipment List:

Control Equipment Unit No. Control Description Pollutant being controlled

Control for Unit

Number1 21001 Paint Booth Filters PM, including some HAP and TAP species. 21001 21002 Paint Booth Filters PM, including some HAP and TAP species. 21002 21003 Paint Booth Filters PM, including some HAP and TAP species. 21003 21005 Paint Booth Filters PM, including some HAP and TAP species. 21005 21006 Paint Booth Filters PM, including some HAP and TAP species. 21006 1 Control for unit number refers to a unit number from the Regulated Equipment List

NSR Permit No. 1517-M5R1 Page 8 of 33

A106 Facility: Allowable Emissions

A. The following Section lists the emission units and their allowable emission limits.

(40 CFR 50, 20.2.72.210.A and B.1 NMAC).

Table 106.A: Allowable Emissions

Unit No.

Source Category

(Section No.)

NOx tpy

CO

tpy

VOC

tpy

SO2

tpy

TSP

tpy

PM10

tpy

PM2.5

tpy HAP tpy

14001 - 14004, 14007 - 14011

External Combustion

ECOM (A601) 22.3 18.8 1.2 0.1 1.7 1.7 1.7 4

15001, 15003, 15004

Fuel Dispensing (A602A) - - 46.2 - - - - 4

22001, 22002, 22004, 22005, 22006, 22007, 22008

3Fuel Storage Tanks (A602C) - - 11.0 - - - - 4

21001, 21002, 21003, 21005, 21006

Surface Coating – Paint Booths (A603) - - 47.6 - 1.3 1.3 0.6 4

1 Nitrogen dioxide emissions include all oxides of nitrogen expressed as NO2 2 For this Title V facility, the Title V annual fee assessments are based on the sum of allowable tons per year emission limits in Sections A106 and A107 in the Title V permit, not this permit.

3 Emissions represent worse case for multiple units in one building.

4 facility-wide individual HAP and Total HAP emissions are limited to 9.9 and 24.9 tons per year, respectively.

“-” indicates the application represented emissions of this pollutant are not expected.

“<” indicates the application represented uncontrolled emissions are less than 1.0 pph or 1.0 tpy for this pollutant. Allowable limits are not imposed on this level of emissions, except for flares and pollutants with controls.

“*” indicates hourly emission limits are not appropriate for this operating situation.

B. Any tank breathing and working losses were computed using the USEPA Tanks program Version 4.0.9d. Emission rates computed using the same parameters but with a different Department approved algorithm that exceed these values will not be deemed non-compliance with this permit.

C. There are no tank flashing emissions at this facility.

D. Individual HAP and Total HAP emissions are limited to 9.9 and 24.9 tons per year, respectively.

A107 Facility Allowable Startup, Shutdown, and Maintenance (SSM) Emissions

A. Allowable SSM emission limits are not imposed at this time. The permittee shall maintain records in accordance with Condition B109.C.

NSR Permit No. 1517-M5R1 Page 9 of 33

A108 Facility: Hours of Operation

A. This facility is authorized for continuous operation. No monitoring, recordkeeping, and reporting requirements are required to demonstrate compliance with continuous hours of operation.

A109 Facility: Reporting Schedules

A. No reports are required unless the Department specifically requests submittal of certain records that are to be retained by the Permittee according to the requirements of General Condition B110. This statement is not applicable to Federal reporting requirements.

A110 Facility: Fuel Sulfur Requirements

A. Non-Exempt Base-wide External Combustion Units Requirement: All non-exempt base-wide external combustion emission units shall fire only natural gas containing no more than 20.0 grains of total sulfur per 100 dry standard cubic feet.

Monitoring: The use of natural gas fuel, as defined in this permit, shall constitute compliance with this permit condition.

Recordkeeping: The permittee shall demonstrate compliance with the natural gas limit on total sulfur content by maintaining records of a current, valid purchase contract, tariff sheet or transportation contract for the gaseous fuel, specifying the allowable limit or less.

Reporting: The permittee shall report in accordance with Section B110.

A111 Facility: 20.2.61 NMAC Opacity

A. 20.2.61 NMAC Opacity Limit Requirement: Visible emissions from all stationary combustion emission stacks shall not equal or exceed an opacity of 20 percent.

Monitoring: Use of natural gas fuel constitutes compliance with 20.2.61 NMAC unless opacity equals or exceeds 20% averaged over a 10-minute period. When visible emissions are observed during steady state operation, opacity shall be measured over a 10-minute period, in accordance with the procedures at 40 CFR 60, Appendix A, Method 9 as required by 20.2.61.114 NMAC Recordkeeping: The permittee shall record dates of any opacity measures and the corresponding opacity readings in accordance with 40 CFR 60, Appendix A, Method 9.

Reporting: The permittee shall report in accordance with Section B110.

A112 Alternative Operating Scenario – Not Required

A113 Compliance Plan – Not Required

NSR Permit No. 1517-M5R1 Page 10 of 33

A114 Reducing Facility Emissions – Not Required

EQUIPMENT SPECIFIC REQUIREMENTS

A200 Oil and Gas Industry – Not Required

A300 Construction Industry – Not Required

A400 Power Generation Industry – Not Required

A500 Solid Waste Disposal (Landfills) Industry– Not Required

A600 Cannon Air Force Base

A601 Source Category External Combustion (ECOM)

A. Emission rates for External Combustion (Source Category ECOM) Unit No.

NOx pph NOx tpy

CO

pph

CO

tpy

VOC

pph

VOC

tpy SO2 pph SO2 tpy TSP pph

TSP

tpy

14001 0.85 3.7 0.71 3.1 0.047 0.20 0.0051 0.022 0.064 0.28

14002 0.85 3.7 0.71 3.1 0.047 0.20 0.0051 0.022 0.064 0.28

14003 0.81 3.5 0.68 3.0 0.044 0.19 0.0049 0.021 0.061 0.27

14004 0.81 3.5 0.68 3.0 0.044 0.19 0.0049 0.021 0.061 0.27

14007 0.49 2.1 0.41 1.8 0.027 0.12 0.0029 0.013 0.037 0.16

14008 0.49 2.1 0.41 1.8 0.027 0.12 0.0029 0.013 0.037 0.16

14009 0.49 2.1 0.41 1.8 0.027 0.12 0.0029 0.013 0.037 0.16

14010 0.035 0.15 0.030 0.13 0.0019 0.0085 0.0002 0.0009 0.0027 0.012

14011 0.051 0.23 0.043 0.19 0.0028 0.012 0.0003 0.0014 0.0039 0.017

14012 0.20 0.86 0.16 0.72 0.011 0.047 0.0012 0.0052 0.015 0.065

14013 0.035 0.15 0.030 0.13 0.0019 0.0085 0.0002 0.0009 0.0027 0.012 “-” indicates the application represented emissions of this pollutant are not expected.

B. Non-Exempt Base-wide External Combustion Requirement: Total natural gas usage for non-exempt base-wide external combustion units at Cannon AFB, excluding military family housing, shall not exceed 453.3 million scf/yr.

Compliance with this throughput limitation demonstrates compliance with the allowable emission limits in Table 106.A for these units.

Monitoring: The permittee shall monitor the monthly and monthly rolling 12-month total

NSR Permit No. 1517-M5R1 Page 11 of 33 throughput of natural gas usage for non-exempt base-wide external combustion units.

Recordkeeping: The permittee shall calculate and record the total monthly and monthly rolling 12-month total of natural gas usage for non-exempt base-wide external combustion units.

Reporting: In accordance with Section B110 of this permit.

A602 Source Categories Fuel Dispensing and Fuel Storage Tanks

A. Emission rates for Source Category Fuel Dispensing and Fuel Storage Tanks Unit No. VOC pph VOC tpy

15001, 15002,15004 10.5 46.2

22001 0.038 0.17

22002 0.6 2.6

22004 0.72 3.1

22005 0.48 2.1

22006 0.36 1.6

22007 0.17 0.74

22008 0.17 0.74 “-” indicates the application represented emissions of this pollutant are not expected.

B. Fuel Dispensing (Units 15001, 15003, and 15004) Requirement: Total fuel dispensed shall not exceed the following:

1) Unit 15001 shall not exceed 1,212,924 gallons per year.

2) Unit 15003 shall not exceed 6,387,500 gallons per year.

3) Unit 15004 shall not exceed 303,230 gallons per year.

Compliance with the throughput limitations demonstrates compliance with the allowable VOC emissions for these units and the source category total shown in Table 106.A.

Monitoring: The permittee shall monitor the monthly and monthly rolling 12-month total amount of fuel dispensed from units 15001, 15003, and 15004.

Recordkeeping: The permittee shall calculate and record the monthly and monthly rolling 12-month total of fuel dispensed for each unit.

Reporting: In accordance with Section B110 of this permit.

C. 40 CFR 63 Subpart CCCCCC Applicability to Gasoline Dispensing Facilities and Associated Gasoline Storage Tanks

Requirement: Units 15001, 15003, 22001, 22002, 22004, 22005, and 22006 are subject to federal NESHAP found in 40 CFR 63, Subpart A – General Provisions, and Subpart CCCCCC – NESHAP for Gasoline Dispensing Facilities and shall comply with both the notification requirements in Subpart A and with the specific requirements of Subpart CCCCCC.

1) Units 15003, 22004, 22005, and 22006 must comply with the requirements in §63.11118.

2) Units 15001, 22001, and 22002 must comply with §63.11117.

Monitoring: The permittee shall comply with all applicable monitoring requirements of 40 CFR

NSR Permit No. 1517-M5R1 Page 12 of 33

63, Subparts A and CCCCCC.

Recordkeeping: The permittee shall comply with all applicable recordkeeping requirements of 40 CFR 63, Subparts A and CCCCCC.

Reporting: The permittee shall comply with all applicable reporting requirements of 40 CFR 63, Subparts A and CCCCCC.

D. Fuel Storage Tanks (Units 22001, 22002, 22004, 22005, 22006, 22007, 22008) Requirement: Total throughput for the fuel storage tanks shall not exceed the following:

1. Units 22001 and 22002 shall each not exceed 606,462 gallons per year;

2. Unit 22004 shall not exceed 3,650,000 gallons per year;

3. Unit 22005 shall not exceed 1,825,000 gallons per year;

4. Unit 22006 shall not exceed 912,500 gallons per year; and

5. Units 22007 and 22008 shall each not exceed 151,615 gallons per year.

Compliance with these throughput limitation demonstrates compliance with the allowable emissions for these units shown in Table 106.A.

Monitoring: The permittee shall monitor the monthly and monthly rolling 12-month total throughput for each storage tank.

Recordkeeping: The permittee shall keep records of the amount of fuel delivered to each storage tank. The permittee shall calculate the total throughput for each month and the monthly rolling 12-month total.

Reporting: The permittee shall report in accordance with Section B110.

A603 Source Category Surface Coating – Paint Booths

A. Emission rates for Source Category Surface Coating Unit No.

VOC

pph

VOC

tpy

TSP

pph

TSP

tpy

PM10

pph

PM10

tpy

PM2.5

pph

PM2.5

tpy

21001- 21002 115.7 11.4 4.5 0.6 4.5 0.6 1.3 0.2

21003 127.1 13.4 6.2 0.2 6.2 0.2 3.6 0.1

21005- 21006 198.1 22.8 3.2 0.5 3.2 0.5 2.0 0.3

“-” indicates the application represented emissions of this pollutant are not expected.

B. Units 21001, 21002, 21003, 21005, 21006 Requirement: The permittee shall not exceed the following hourly and annual usage rates.

The usage rates are derived from a master materials list of materials used at the facility and assigned an MSDS #, and submitted as part of the air permit application. Compliance with the usage rates will be demonstrated by cross-referencing the master materials list and MSDS # with the usage records. General usage rates are provided by paint booth and material type, and the more restrictive usage limitations are given in parentheses. Compliance with the maximum hourly and annual usage rates demonstrates compliance with the allowable VOC emissions for

NSR Permit No. 1517-M5R1 Page 13 of 33 these units shown in Table 106.A.

Unit No. Material Maximum Hourly and Annual Usage Control

21001 and 21002

Paint/Solvent General usage rates shall be limited to: 9 gal/hr and 2,400 gal/yr (MSDS# 34a,b; 47a,b; 49a,b; 61; 74a,b; 107a,b = 1 gal/hr) (MSDS# 3b, 20b, 88 = 1200 gal/yr each) Paint

Booth Filter Non-spray

General usage rates shall be limited to: 5 gal/hr and 450 gal/yr (MSDS# 25 = 225 gal/yr)

Aerosol 1 gal/hr and 150 gal/yr

21003 Paint/Solvent General usage rates shall be limited to: 12 gal/hr and 2,535 gal/yr (MSDS# 1, 2, 7 = 1000 gal/yr each)

Paint Booth Filter

21005 and 21006

Paint/Solvent General usage rates shall be limited to: 15 gal/hr and 4,800 gal/yr (MSDS# 34a,b; 47a,b; 49a,b; 61; 107a,b = 1 gal/hr) (MSDS# 3b, 20b, 88 = 2000 gal/yr each) Paint

Booth Filter Non-spray

General usage rates shall be limited to: 10 gal/hr and 900 gal/yr (MSDS# 1, 25 = 450 gal/yr each)

Aerosol 2 gal/hr and 300 gal/yr

Monitoring:

1. The permittee shall monitor the usage of each material that is a source of VOC, HAP, and/or particulate matter emissions from surface coating operations;

2. The permittee shall continuously monitor the differential pressure across each paint booth filter; and

3. Air filters shall be replaced in accordance with manufacturer specifications regarding differential pressure.

Recordkeeping:

1. The permittee shall record the usage of each coating material, including any new material which shall be identified as new. Records, at a minimum, shall include the date, time, material name, MSDS ID corresponding to the spreadsheets developed for this application, location of usage, and the amount of material used;

2. The permittee shall calculate the actual emission rate (tons/month) and the monthly rolling 12-month total (tons/year) for each HAP emitted, total combined HAPs and total VOCs for the previous calendar month (tons/month). This calculation shall be based on usage logs and emission factors for each material. The emission factors shall be based on the spreadsheets developed by the applicant and submitted with the application for NSR 1517M4.

3. The permittee shall calculate the actual emission rate (tons/month) and the monthly rolling 12-month total (tons/year) emission rate for particulate matter. This calculation shall be

NSR Permit No. 1517-M5R1 Page 14 of 33 based on usage logs and the emission factors developed for this application, for each paint booth.

4. The permittee shall keep onsite a copy of the manufacturer specifications and the records for each paint booth of the date filters are changed.

5. Prior to using any new coating material, the permittee shall evaluate the material and calculate the emission factor (lb/quantity) of all the pollutants that would result from using that material. The record of the calculation shall include a copy of the information that was relied upon when making the calculation.

Reporting: The permittee shall report in accordance with Section B110.

A604 Internal Combustion Engines to be addressed in Title V permit

A. Operating Restrictions for 20.2.72 NMAC Exempt ICE

B. Fuel Sulfur Requirements – Internal Combustion

C. Emission Calculations – Internal Combustion

D. New Source Performance Standards (NSPS) 40 CFR 60, Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines - General Requirements – Addressed in Title V Permit only

E. NSPS 40 CFR 60 Subpart IIII - Emission Standards from Paragraph 60.4205(a) and (c). – Addressed in Title V Permit only

F. National Emissions Standards for Hazardous Air Pollutants (NESHAP) 40 CFR Subpart ZZZZ - Stationary Reciprocating Internal Combustion Engines – General Requirements – Addressed in Title V Permit only

A605 Source Category Miscellaneous Chemical Use to be addressed in Title V permit

NSR Permit No. 1517-M5R1 Page 15 of 33

PART B GENERAL CONDITIONS

B100 Introduction

A. The Department has reviewed the permit application for the proposed construction/modification/revision and has determined that the provisions of the Act and ambient air quality standards will be met. Conditions have been imposed in this permit to assure continued compliance. 20.2.72.210.D NMAC, states that any term or condition imposed by the Department on a permit is enforceable to the same extent as a regulation of the Environmental Improvement Board.

B101 Legal

A. The contents of a permit application specifically identified by the Department shall become the terms and conditions of the permit or permit revision. Unless modified by conditions of this permit, the permittee shall construct or modify and operate the Facility in accordance with all representations of the application and supplemental submittals that the Department relied upon to determine compliance with applicable regulations and ambient air quality standards. If the Department relied on air quality modeling to issue this permit, any change in the parameters used for this modeling shall be submitted to the Department for review. Upon the Department’s request, the permittee shall submit additional modeling for review by the Department. Results of that review may require a permit modification. (20.2.72.210.A NMAC)

B. Any future physical changes, changes in the method of operation or changes in restricted area may constitute a modification as defined by 20.2.72 NMAC, Construction Permits. Unless the source or activity is exempt under 20.2.72.202 NMAC, no modification shall begin prior to issuance of a permit. (20.2.72 NMAC Sections 200.A.2 and E, and 210.B.4)

C. Changes in plans, specifications, and other representations stated in the application documents shall not be made if they cause a change in the method of control of emissions or in the character of emissions, will increase the discharge of emissions or affect modeling results. Any such proposed changes shall be submitted as a revision or modification. (20.2.72 NMAC Sections 200.A.2 and E, and 210.B.4)

D. The permittee shall establish and maintain the property’s Restricted Area as identified in plot plan submitted with the application. (20.2.72 NMAC Sections 200.A.2 and E, and 210.B.4)

E. Applications for permit revisions and modifications shall be submitted to:

Program Manager, Permits Section

NSR Permit No. 1517-M5R1 Page 16 of 33

New Mexico Environment Department

525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505

F. At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate the source including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. (20.2.7.109, 20.2.72.210.A, 20.2.72.210.B, 20.2.72.210.C, 20.2.72.210.E NMAC) The establishment of allowable malfunction emission limits does not supersede this requirement.

B102 Authority

A. This permit is issued pursuant to the Air Quality Control Act (Act) and regulations adopted pursuant to the Act including Title 20, Chapter 2, Part 72 of the New Mexico Administrative Code (NMAC), (20.2.72 NMAC), Construction Permits and is enforceable pursuant to the Act and the air quality control regulations applicable to this source.

B. The Department is the Administrator for 40 CFR Parts 60, 61, and 63 pursuant to the delegation and exceptions of Section 10 of 20.2.77 NMAC (NSPS), 20.2.78 NMAC (NESHAP), and 20.2.82 NMAC (MACT).

B103 Annual Fee

A. The Department will assess an annual fee for this Facility. The regulation 20.2.75 NMAC set the fee amount at $1,500 through 2004 and requires it to be adjusted annually for the Consumer Price Index on January 1. The current fee amount is available by contacting the Department or can be found on the Department’s website.

The AQB will invoice the permittee for the annual fee amount at the beginning of each calendar year. This fee does not apply to sources which are assessed an annual fee in accordance with 20.2.71 NMAC. For sources that satisfy the definition of “small business” in 20.2.75.7.F NMAC, this annual fee will be divided by two.

(20.2.75.11 NMAC)

B. All fees shall be remitted in the form of a corporate check, certified check, or money order made payable to the “NM Environment Department, AQB” mailed to the address shown on the invoice and shall be accompanied by the remittance slip attached to the invoice.

NSR Permit No. 1517-M5R1 Page 17 of 33

B104 Appeal Procedures

A. Any person who participated in a permitting action before the Department and who is adversely affected by such permitting action, may file a petition for hearing before the Environmental Improvement Board. The petition shall be made in writing to the Environmental Improvement Board within thirty (30) days from the date notice is given of the Department's action and shall specify the portions of the permitting action to which the petitioner objects, certify that a copy of the petition has been mailed or hand-delivered and attach a copy of the permitting action for which review is sought. Unless a timely request for hearing is made, the decision of the Department shall be final. The petition shall be copied simultaneously to the Department upon receipt of the appeal notice. If the petitioner is not the applicant or permittee, the petitioner shall mail or hand-deliver a copy of the petition to the applicant or permittee. The Department shall certify the administrative record to the board. Petitions for a hearing shall be sent to: (20.2.72.207.F NMAC)

Secretary, New Mexico Environmental Improvement Board 1190 St. Francis Drive, Runnels Bldg. Rm. N2153 Santa Fe, New Mexico 87502

B105 Submittal of Reports and Certifications

A. Stack Test Protocols and Stack Test Reports shall be submitted electronically to Stacktest.AQB@state.nm.us or as directed by the Department.

B. Excess Emission Reports shall be submitted as directed by the Department.

(20.2.7.110 NMAC)

C. Routine reports shall be submitted to the mailing address below, or as directed by the Department:

Manager, Compliance and Enforcement Section New Mexico Environment Department Air Quality Bureau 525 Camino de los Marquez, Suite 1 Santa Fe, NM 87505

B106 NSPS and/or MACT Startup, Shutdown, and Malfunction Operations

A. If a facility is subject to a NSPS standard in 40 CFR 60, each owner or operator that installs and operates a continuous monitoring device required by a NSPS regulation shall comply with the excess emissions reporting requirements in accordance with 40 CFR 60.7(c), unless specifically exempted in the applicable subpart.

mailto:Stacktest.AQB@state.nm.us

NSR Permit No. 1517-M5R1 Page 18 of 33

B. If a facility is subject to a NSPS standard in 40 CFR 60, then in accordance with 40 CFR 60.8(c), emissions in excess of the level of the applicable emission limit during periods of startup, shutdown, and malfunction shall not be considered a violation of the applicable emission limit unless otherwise specified in the applicable standard.

C. If a facility is subject to a MACT standard in 40 CFR 63, then the facility is subject to the requirement for a Startup, Shutdown and Malfunction Plan (SSM) under 40 CFR 63.6(e)(3), unless specifically exempted in the applicable subpart.

B107 Startup, Shutdown, and Maintenance Operations

A. The establishment of permitted startup, shutdown, and maintenance (SSM) emission limits does not supersede the requirements of 20.2.7.14.A NMAC. Except for operations or equipment subject to Condition B106, the permittee shall establish and implement a plan to minimize emissions during routine or predictable start up, shut down, and scheduled maintenance (SSM work practice plan) and shall operate in accordance with the procedures set forth in the plan. (SSM work practice plan)

(20.2.7.14.A NMAC)

B108 General Monitoring Requirements

A. These requirements do not supersede or relax requirements of federal regulations.

B. The following monitoring requirements shall be used to determine compliance with applicable requirements and emission limits. Any sampling, whether by portable analyzer or EPA reference method, that measures an emission rate over the applicable averaging period greater than an emission limit in this permit constitutes noncompliance with this permit. The Department may require, at its discretion, additional tests pursuant to EPA Reference Methods at any time, including when sampling by portable analyzer measures an emission rate greater than an emission limit in this permit; but such requirement shall not be construed as a determination that the sampling by portable analyzer does not establish noncompliance with this permit and shall not stay enforcement of such noncompliance based on the sampling by portable analyzer.

C. If the emission unit is shutdown at the time when periodic monitoring is due to be accomplished, the permittee is not required to restart the unit for the sole purpose of performing the monitoring. Using electronic or written mail, the permittee shall notify the Department’s Compliance and Enforcement Section of a delay in emission tests prior to the deadline for accomplishing the tests. Upon recommencing operation, the permittee shall submit any pertinent pre-test notification requirements set forth in the current version of the Department’s Standard Operating Procedures For Use Of Portable Analyzers in Performance Test, and shall accomplish the monitoring.

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D. The requirement for monitoring during any monitoring period is based on the percentage of time that the unit has operated. However, to invoke the monitoring period exemption at B108.D(2), hours of operation shall be monitored and recorded.

(1) If the emission unit has operated for more than 25% of a monitoring period, then the permittee shall conduct monitoring during that period.

(2) If the emission unit has operated for 25% or less of a monitoring period then the monitoring is not required. After two successive periods without monitoring, the permittee shall conduct monitoring during the next period regardless of the time operated during that period, except that for any monitoring period in which a unit has operated for less than 10% of the monitoring period, the period will not be considered as one of the two successive periods.

(3) If invoking the monitoring period exemption in B108.D(2), the actual operating time of a unit shall not exceed the monitoring period required by this permit before the required monitoring is performed. For example, if the monitoring period is annual, the operating hours of the unit shall not exceed 8760 hours before monitoring is conducted. Regardless of the time that a unit actually operates, a minimum of one of each type of monitoring activity shall be conducted during any five-year period.

E. For all periodic monitoring events, except when a federal or state regulation is more stringent, three test runs shall be conducted at 90% or greater of the unit’s capacity as stated in this permit, or in the permit application if not in the permit, and at additional loads when requested by the Department. If the 90% capacity cannot be achieved, the monitoring will be conducted at the maximum achievable load under prevailing operating conditions except when a federal or state regulation requires more restrictive test conditions. The load and the parameters used to calculate it shall be recorded to document operating conditions and shall be included with the monitoring report.

F. When requested by the Department, the permittee shall provide schedules of testing and monitoring activities. Compliance tests from previous NSR and Title V permits may be re-imposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions.

G. If monitoring is new or is in addition to monitoring imposed by an existing applicable requirement, it shall become effective 120 days after the date of permit issuance. For emission units that have not commenced operation, the associated new or additional monitoring shall not apply until 120 days after the units commence operation. All pre-existing monitoring requirements incorporated in this permit shall continue to apply from the date of permit issuance.

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B109 General Recordkeeping Requirements

A. The permittee shall maintain records to assure and verify compliance with the terms and conditions of this permit and any other applicable requirements that become effective after permit issuance. The minimum information to be included in these records is:

(1) equipment identification (include make, model and serial number for all tested equipment and emission controls);

(2) date(s) and time(s) of sampling or measurements;

(3) date(s) analyses were performed;

(4) the qualified entity that performed the analyses;

(5) analytical or test methods used;

(6) results of analyses or tests; and

(7) operating conditions existing at the time of sampling or measurement.

B. Except as provided in the Specific Conditions, records shall be maintained on-site or at the permittee’s local business office for a minimum of two (2) years from the time of recording and shall be made available to Department personnel upon request.

Sources subject to 20.2.70 NMAC “Operating Permits” shall maintain records on-site for a minimum of five (5) years from the time of recording.

C. Malfunction emissions and routine and predictable emissions during startup, shutdown, and scheduled maintenance (SSM):

(1) The permittee shall keep records of all events subject to the plan to minimize emissions during routine or predictable SSM. (20.2.7.14.A NMAC)

(2) If the facility has allowable SSM emission limits in this permit, the permittee shall record all SSM events, including the date, the start time, the end time, a description of the event, and a description of the cause of the event. This record also shall include a copy of the manufacturer’s, or equivalent, documentation showing that any maintenance qualified as scheduled. Scheduled maintenance is an activity that occurs at an established frequency pursuant to a written protocol published by the manufacturer or other reliable source. The authorization of allowable SSM emissions does not supersede any applicable federal or state standard. The most stringent requirement applies.

(3) If the facility has allowable malfunction emission limits in this permit, the permittee shall record all malfunction events to be applied against these limits, including the date, the start time, the end time, and a description of the event.

Malfunction means any sudden, infrequent, and not reasonably preventable failure of air pollution control and monitoring equipment, process equipment, or a process to operate in a normal or usual manner which causes, or has the potential

NSR Permit No. 1517-M5R1 Page 21 of 33 to cause, the emission limitations in an applicable standard to be exceeded.

Failures that are caused in part by poor maintenance or careless operation are not malfunctions. (40 CFR 63.2, 20.2.7.7.E NMAC) The authorization of allowable malfunction emissions does not supersede any applicable federal or state standard.

The most stringent requirement applies. This authorization only allows the permittee to avoid submitting reports under 20.2.7 NMAC for total annual emissions that are below the authorized malfunction emission limit.

B110 General Reporting Requirements (20.2.72 NMAC Sections 210 and 212)

A. Records and reports shall be maintained on-site or at the permittee’s local business office unless specifically required to be submitted to the Department or EPA by another condition of this permit or by a state or federal regulation. Records for unmanned sites may be kept at the nearest business office.

B. The permittee shall notify the Department’s Compliance Reporting Section using the current Submittal Form posted to NMED’s Air Quality web site under Compliance and Enforcement/Submittal Forms in writing of, or provide the Department with (20.2.72.212.A and B):

(1) the anticipated date of initial startup of each new or modified source not less than thirty (30) days prior to the date. Notification may occur prior to issuance of the permit, but actual startup shall not occur earlier than the permit issuance date;

(2) after receiving authority to construct, the equipment serial number as provided by the manufacturer or permanently affixed if shop-built and the actual date of initial startup of each new or modified source within fifteen (15) days after the startup date; and

(3) the date when each new or modified emission source reaches the maximum production rate at which it will operate within fifteen (15) days after that date.

C. The permittee shall notify the Department’s Permitting Program Manager, in writing of, or provide the Department with (20.2.72.212.C and D):

(1) any change of operators or any equipment substitutions within fifteen (15) days of such change;

(2) any necessary update or correction no more than sixty (60) days after the operator knows or should have known of the condition necessitating the update or correction of the permit.

D. Results of emission tests and monitoring for each pollutant (except opacity) shall be reported in pounds per hour (unless otherwise specified) and tons per year. Opacity shall be reported in percent. The number of significant figures corresponding to the full accuracy inherent in the testing instrument or Method test used to obtain the data

NSR Permit No. 1517-M5R1 Page 22 of 33 shall be used to calculate and report test results in accordance with 20.2.1.116.B and C NMAC. Upon request by the Department, CEMS and other tabular data shall be submitted in editable, MS Excel format.

E. The permittee shall submit reports of excess emissions in accordance with

20.2.7.110.A NMAC.

B111 General Testing Requirements

A. Compliance Tests

(1) Compliance test requirements from previous permits (if any) are still in effect, unless the tests have been satisfactorily completed. Compliance tests may be re-imposed if it is deemed necessary by the Department to determine whether the source is in compliance with applicable regulations or permit conditions. (20.2.72 NMAC Sections 210.C and 213)

(2) Compliance tests shall be conducted within sixty (60) days after the unit(s) achieve the maximum normal production rate. If the maximum normal production rate does not occur within one hundred twenty (120) days of source startup, then the tests must be conducted no later than one hundred eighty (180) days after initial startup of the source.

(3) Unless otherwise indicated by Specific Conditions or regulatory requirements, the default time period for each test run shall be at least 60 minutes and each performance test shall consist of three separate runs using the applicable test method. For the purpose of determining compliance with an applicable emission limit, the arithmetic mean of results of the three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the three runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances, beyond the owner or operator's control, compliance may, upon the Department approval, be determined using the arithmetic mean of the results of the two other runs.

(4) Testing of emissions shall be conducted with the emissions unit operating at 90 to 100 percent of the maximum operating rate allowed by the permit. If it is not possible to test at that rate, the source may test at a lower operating rate, subject to the approval of the Department.

(5) Testing performed at less than 90 percent of permitted capacity will limit emission unit operation to 110 percent of the tested capacity until a new test is conducted.

(6) If conditions change such that unit operation above 110 percent of tested capacity is possible, the source must submit a protocol to the Department within 30 days of such change to conduct a new emissions test.

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B. EPA Reference Method Tests

(1) All compliance tests required by this permit, unless otherwise specified by Specific Conditions of this permit, shall be conducted in accordance with the requirements of CFR Title 40, Part 60, Subpart A, General Provisions, and the following EPA Reference Methods as specified by CFR Title 40, Part 60, Appendix A:

(a) Methods 1 through 4 for stack gas flowrate

(b) Method 5 for TSP

(c) Method 6C and 19 for SO2

(d) Method 7E for NOX (test results shall be expressed as nitrogen dioxide (NO2) using a molecular weight of 46 lb/lb-mol in all calculations (each ppm of NO/NO2 is equivalent to 1.194 x 10-7 lb/SCF)

(e) Method 9 for opacity

(f) Method 10 for CO

(g) Method 19 may be used in lieu of Methods 1-4 for stack gas flowrate upon approval of the Department. A justification for this proposal must be provided along with a contemporaneous fuel gas analysis (preferably on the day of the test) and a recent fuel flow meter calibration certificate (within the most recent quarter).

(h) Method 7E or 20 for Turbines per 60.335 or 60.4400

(i) Method 29 for Metals

(j) Method 201A for filterable PM10 and PM2.5

(k) Method 202 for condensable PM

(l) Method 320 for organic Hazardous Air Pollutants (HAPs)

(m) Method 25A for VOC reduction efficiency

(n) Method 30B for Mercury

(2) Alternative test method(s) may be used if the Department approves the change

C. Periodic Monitoring and Portable Analyzer Requirements

(1) Periodic emissions tests (periodic monitoring) may be conducted in accordance with EPA Reference Methods or by utilizing a portable analyzer. Periodic monitoring utilizing a portable analyzer shall be conducted in accordance with the requirements of ASTM D 6522-00. However, if a facility has met a previously approved Department criterion for portable analyzers, the analyzer may be operated in accordance with that criterion until it is replaced.

NSR Permit No. 1517-M5R1 Page 24 of 33

(2) Unless otherwise indicated by Specific Conditions or regulatory requirements, the default time period for each test run shall be at least 20 minutes.

Each performance test shall consist of three separate runs. The arithmetic mean of results of the three runs shall be used to determine compliance with the applicable emission limit.

(3) Testing of emissions shall be conducted in accordance with the requirements at Section B108.E.

(4) During emissions tests, pollutant, O2 concentration and fuel flow rate shall be monitored and recorded. This information shall be included with the test report furnished to the Department.

(5) Pollutant emission rate shall be calculated in accordance with 40 CFR 60, Appendix A, Method 19 utilizing fuel flow rate (scf) and fuel heating value (Btu/scf) obtained during the test.

D. Test Procedures:

(1) The permittee shall notify the Department’s Program Manager, Compliance and Enforcement Section at least thirty (30) days before the test date and allow a representative of the Department to be present at the test.

(2) Equipment shall be tested in the "as found" condition. Equipment may not be adjusted or tuned prior to any test for the purpose of lowering emissions, and then returned to previous settings or operating conditions after the test is complete.

(3) Contents of test notifications, protocols and test reports shall conform to the format specified by the Department’s Universal Test Notification, Protocol and Report Form and Instructions. Current forms and instructions are posted to NMED’s Air Quality web site under Compliance and Enforcement Testing.

(4) The permittee shall provide (a) sampling ports adequate for the test methods applicable to the facility, (b) safe sampling platforms, (c) safe access to sampling platforms and (d) utilities for sampling and testing equipment.

(5) The stack shall be of sufficient height and diameter and the sample ports shall be located so that a representative test of the emissions can be performed in accordance with the requirements of EPA Method 1 or ASTM D 6522-00 as applicable.

(6) Where necessary to prevent cyclonic flow in the stack, flow straighteners shall be installed

(7) Unless otherwise indicated by Specific Conditions or regulatory requirements, test reports shall be submitted to the Department no later than 30 days after completion of the test.

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B112 Compliance

A. The Department shall be given the right to enter the facility at all reasonable times to verify the terms and conditions of this…