Chapter 6 - Air Pollution Control.pdf

CHAPTER 6 : AIR POLLUTION CONTROL

1. PURPOSE

This chapter establishes the procedures and responsibilities for complying with the provisions of FGA’s air quality permit(s) and associated requirements. FGA currently has an Air Quality Operating/Construction Permit issued by the Alaska Department of Environmental Conservation (ADEC). A copy of Permit No. 238TVP01 is provided in Attachment 1. From time to time, the construction and subsequent operation of new (i.e., not permitted in Permit No. 238TVP01) stationary emission units or significant changes in the operation of existing stationary emission units of air pollution may need to be authorized by a Air Quality Construction Permit and/or revisions to the Air Quality Operating/Construction Permit.

2. SCOPE

This procedure is applicable to all Garrison departments, tenants, or contractors that: (1) construct or operate stationary emissions units of air pollution; (2) receive or distribute fuel to be combusted in stationary emission units; (3) service or repair refrigeration or fire suppressant equipment containing ozone depleting substances; (4) undertake asbestos-related activities subject to 40 CFR Part 61, Subpart M ( National Emission Standard for Asbestos); (5) undertake activities covered in FGA’s Fugitive Dust Control Plan (Attachment 2); (6) undertake open burning; or (7) perform measurements or observations required under FGA’s air quality permit(s).

3. RESPONSIBILITIES

a. FGA Garrison Commander

The Garrison Commander is the responsible official for environmental compliance at Fort Greely and provides overall policy and guidance associated with environmental compliance. The Commander is the air quality permit holder for FGA and has ultimate responsibility to insure permit compliance. The Commander will consult regularly with FGAENV to insure that the installation’s environmental policies and procedures are consistent with federal, state and Army requirements and are properly implemented. The Commander will consult regularly with all installation tenant organizations and departments and facilitate resolution of conflicts regarding environmental matters that cannot be resolved at lower levels.

b. FGA Directorate of Public Works (DPW)

(1) Director of Public Works

Through delegation from the Commander, the Director serves as the Garrison’s responsible official for air permit matters. The Director oversees operation of all stationary emission units in the main cantonment area and is the facility and building POC under the air permit.

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(2) Utility Operations

Utilities Operations operates fuel burning equipment within the cantonment area, maintains operational records, and performs visual emission observations on cantonment area emission units.

(3) Maintenance and Operations

Either directly or through the base operations contractor, Maintenance and Operations maintains roads, implements dust suppression practices in the cantonment area, and undertakes some earthmoving, stockpiling and clearing activities.

(4) Environmental Division (FGAENV)

FGAENV oversees air quality compliance and performs monitoring, record-keeping, and reporting activities associated with the air quality permit(s).

FGAENV will submit all required reports and documents to regulatory agencies and serve as FGA’s primary point of contact on environmental compliance.

FGAENV will advise DPW, tenants, contractors and other activities of environmental requirements and provide assistance in achieving and maintaining compliance. In the event of non-compliant activities, FGAENV will seek resolution. As the Garrison Commander’s environmental representative, the FGAENV will be the point of contact for interface with Federal, State, and local environmental regulatory agencies on all environmental compliance matters associated with Garrison and tenant activities.

c. Directorate of Logistics

The Directorate of Logistics manages the FGA Main Cantonment Area POL Facility and maintains records of fuel deliveries and disbursements from the facility.

d. Installation Management Agency – Pacific Area Region Office (IMA-PARO)

The IMA-PARO oversees environmental management and compliance activities at Fort Greely and provides resources for environmental program implementation. IMA-PARO insures Fort Greely’s environmental program conforms to DoD and Army requirements and provides policy and programmatic guidance to FGAENV.

SMDC-ENV oversees mission-related activities regarding compliance with air quality requirements at FGA, facilitates contractual support to FGAENV upon request, and provides assistance when requested by FGAENV with environmental program management and execution. SMDC-ENV coordinates permitting activities with MDA and assists FGAENV in liaison with state and federal regulatory agencies.

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f. Missile Defense Agency – Ground-based Missile Defense (GMD)

The GMD, through the Fort Greely Site Manager, manages all operations and activities at the Missile Defense Complex (MDC). The Site Manager will insure that all contractors and personnel providing services or conducting operations at the MDC comply with this procedure and any related federal and state environmental requirements. The Site Manager will promptly consult with FGAENV and/or the Garrison Commander, regarding any special considerations (e.g., security) or other issues that may affect environmental compliance at the MDC.

g. Installation Activities, Tenants, Contractor and Personnel at FGA

All installation activities, tenants, contractors and personnel at FGA will comply with this procedure. This procedure applies to all tenants, contractors, or personnel that: (1) maintain and operate emission units regulated under the air quality permit shall maintain operating records, perform any required monitoring or testing for the emission unit(s), and report those data to FGAENV; (2) receive fuel from other than the FGA POL facility in the main cantonment area to be combusted in stationary emission units; (3) service or repair refrigeration or fire suppressant equipment containing ozone depleting substances; (4) undertake asbestos-related activities subject to 40 CFR Part 61, Subpart M ( National Emission Standard for Asbestos); (5) undertake activities covered in FGA’s Fugitive Dust Control Plan (Attachment 2); or (6) undertake open burning.

4. OPERATIONS

a. Combustion Units - Limitations

(1) Permit No. 238TVP01 requires that all fuel oil combusted at Fort Greely have a sulfur content not exceeding 0.12% by weight.

(2) Permit No. 238TVP01 restricts operation of certain emission units at FGA by either limiting the number of operating hours in any 12-month period or limiting the amount of fuel (or solid waste) that can be combusted in the unit. These limitations are summarized below:

Table 1 - Fort Greely Emission Unit Limitations - Summary Unit ID Description Operator Operating Limits Comment

FGBF01

FGBF02

Bldg 101 - Boilers 2@8.37MMBtu/hr

DPW No more than 734,800 gal per 12 months, combined

FGBF14

FGBF15

FGBF16

Bldg 606 - Boilers 2@57.9 MMBtu/hr 1@67.3 MMBtu/hr

DPW No more than 8,037,100 gal per 12

FGBF19

FGBF20

FGBF21

Missile Defense Complex (MDC) - Utility Bldg Boilers 3@8.37 MMBtu/hr

GMD/

Boeing

No more than 734,800 gal per 12 months combined before permanent power plant begins operation. No more than 1,102,195 gal per 12 months combined after permanent power plant begins operation.

FGIC01 FAA Bldg - Genset 635 hp Detroit

DPW No more than 500 hrs per 12 months

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Table 1 Continued - Fort Greely Emission Unit Limitations - Summary Unit ID Description Operator Operating Limits Comment

FGIC02 Bldg 133 - Pump 100 hp

FGIC03

FGIC04

Bldg 501 - Gensets Cummings 310 hp Kohler 160 hp

DPW No more than 1,300 hrs per 12

FGIC05

FGIC06

FGIC07

Bldg 606 - Gensets 3@1,440 hp

DPW No more than 1,950 hrs per 12

FGIC08

FGIC09

Bldg 606 - Gensets 2@1,765 hp

DPW No more than 1,300 hrs per 12

FGIC10 Bldg 606 - Pump 100 hp

FGIC11 Bldg 606 - Pump

FGIC12 Bldg 606 - Pump

FGIC13 Bldg 625 - Pump

DPW No more than 500 hrs per 12 months

MOGAS fired

FGIC14 MDC - MEB Genset 1495 hp Detroit

GMD/

Boeing

No more than 250 hrs per 12 months

FGIC15 MDC - R&C Genset 1495 hp Detroit

GMD/

Boeing

FGIC16 MDC - IS Genset 150 hp Volvo

GMD/

Boeing

FGIC17 MDC - MAB Genset 743 hp Volvo

GMD/

Boeing

FGIC18 MDC - IDT Genset 645 hp Volvo

GMD/

Boeing

FGIC19 MDC - Water Supply Genset 1495 hp Detroit

GMD/

Boeing

FGIC20A &

20B

MDC - DSCS Gensets 2@691 hp Caterpillar

GMD/

Boeing

12 months, each

FGIC21

FGIC22

FGIC23

FGIC24

MDC - Interim PP Gensets 4@2636 hp Caterpillar

GMD No more than 329,280 gal per 12 months, combined.

Cease operation prior to operation of FGIC25-32 (Permanent PP)

FGIC25

FGIC26

FGIC27

FGIC28

FGIC29

FGIC30

FGIC31

FGIC32

MDC - Permanent PP Gensets 8@2636 hp Caterpillar

GMD No more than 617,400 gal per 12 months, combined.

No more than 6 units running concurrently

Future units

FGOB01 Mid-post open burn pit DPW/

BASEOPS

No more than 30.4 tons per month.

No more than 365 tons per year.

Cease operation prior to operation of FGIN01

FGIN01 Mid-post MSW incinerator DPW/

BASEOPS

No more than 4.0 tons per day.

No more than 1,400 tons per 12

b. Fugitive Dust Control

Fort Greely’s Fugitive Dust Control Plan is provided in Attachment 2. All installation activities, tenants, contractors, or personnel undertaking activities such as: clearing and grubbing; material stockpiling; earthmoving; borrow pit operations; road construction; or maintenance that are potential sources of fugitive dust shall implement the dust suppression measures identified in the plan.

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Additionally, all construction contracts for projects involving significant clearing and grubbing, earthmoving, borrow pit operations, and/or material stockpiling shall have a requirement for the contractor to prepare and implement a fugitive dust suppression plan. At a minimum, the plans must incorporate the applicable control measures identified in the Fort Greely Fugitive Dust Control Plan. Copies of the plans shall be provided to FGAENV.

c. Asbestos

All installation activities, tenants, contractors, or personnel undertaking asbestos removal, abatement or repair activities shall comply with the requirements given in Chapter 7 (Asbestos Removal, Transportation, and Disposal) of the Fort Greely Environmental Procedures Manual.

d. Ozone Depleting Substances

All installation activities, tenants, contractors, or personnel servicing, maintaining, or repairing appliances or equipment containing Class I or II Ozone Depleting Substances shall comply with the applicable provisions of 40 CFR Part 82, Subpart F.

e. Open Burning

Open burning is prohibited at Fort Greely unless specifically authorized by FGAENV, the Fire Department, and the Director of Public Works. Any installation activity, tenant, contractor, or person seeking to perform open burning must submit a written request for authorization to FGAENV. At a minimum, the request must include: a justification for open burning and a detailed description of the precautions and measures that will be taken to insure compliance with Condition 45 of Permit No. 238TVP01.

f. General Operations

All installation activities, tenants, contractors, or personnel operating emission units at FGA shall perform regular maintenance and operate the units in accordance with the manufacturer’s recommended practices. Any malfunction or operating situation that may increase emissions above those authorized in Permit No. 238TVP01 (re: Table 1) from the unit(s) shall be reported to FGAENV and, if possible, timely corrected.

g. New Emission Units and Modifications to Existing Units

No stationary emission unit may be constructed, installed, or modified prior to informing FGAENV and completing any required permit actions.

5. SURVEILLANCE

a. Fuel Deliveries

(1) Main Cantonment Area Fuel Facility (FGA POL Facility)

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For each delivery of fuel oil to the facility, the operator shall obtain a fuel analysis from the supplier. At a minimum, the analysis must include the percent sulfur by weight, density, and heat content (e.g., Btu/lb) of the fuel delivered. The operator shall also record the amount of fuel delivered.

(2) Independent Fuel Deliveries

For each delivery of fuel oil for combustion in stationary emission units that does not originate from or through the FGA POL Facility, the entity receiving the fuel shall obtain a fuel analysis of the fuel delivered. At a minimum, the analysis must include the percent sulfur by weight, density, and heat content of the fuel delivered.

b. Visual Emission Observations - Routine

Visual Emission Observations are performed using the method in 40 CFR Part 60, Appendix A-4 (Method 9). Emission unit operators shall be responsible to insure required observations are performed by certified emission observers.

Visual emission observations of the emission units listed in Table 1 may be required.

Observations are required of some units upon initial operation and for others the requirement begins after an operational threshold is exceeded. Once an initial visual emission observation is required and performed, a sequence of observations is initiated as follows:

(1) After the first observation, perform 18-minute observations at least once in each calendar month that the emission unit operates.

(2) If after three monthly observations no six-minute average is greater than 15% opacity and no single observation is greater than 20% opacity, the observation frequency may be reduced to semi-annual. Semi-annual observations must be taken between four and seven months after the previous observation.

(3) If after two semi-annual 18-minute observations no six-minute average is greater than 15% opacity and no single observation is greater than 20% opacity, the observation frequency may be reduced to annual. Annual observations must be taken between 10 and 13 months after the previous observations and consist of at least three 18-minute sets of observations.

(4) If during any observation a six-minute average is greater than 15% opacity or a single observation is greater than 20% opacity, the observation frequency shall be increased to monthly in accordance with paragraph 5.b(1) above.

Routine visual emission observations are initiated after an emission unit either begins operations or exceeds an operational threshold. Table 2 below provides these thresholds.

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Table 2 - Fort Greely Emission Unit Thresholds For Visual Emission Observations

Unit ID Description Operator Threshold Comment

FGBF01

FGBF02

Bldg 101 - Boilers 2@8.37MMBtu/hr

DPW By June 30, 2004 VE observation sequence in progress

FGBF14

FGBF15

FGBF16

Bldg 606 - Boilers 2@57.9 MMBtu/hr 1@67.3 MMBtu/hr

DPW By June 30, 2004 VE observation sequence in progress

FGBF19

FGBF20

FGBF21

MDC - Utility Bldg Boilers 3@8.37 MMBtu/hr

GMD/

Boeing

By June 30, 2004 for FGBF 19 and FGBF20. Within 6 months of initiating operations for FGBF21

VE observation sequence in progress.

FGIC01 FAA Bldg - Genset 635 hp Detroit

DPW Within 90 days of exceeding 420 operating hrs in 12 months

FGIC02 Bldg 133 - Pump

DPW Within 90 days of exceeding 500

FGIC03 Bldg 501 - Genset Cummings 310 hp

DPW Within 90 days of exceeding 415

Bldg 501 - Genset Kohler 160 hp

DPW Within 90 days of exceeding 805

FGIC05 Bldg 606 - Genset DSQ316/54033 1440hp

DPW Within 90 days of exceeding 115 operating hrs in 12 months

VE observation sequence in progress

FGIC06 Bldg 606 - Genset DSQ316/54032 1440hp

DPW Within 90 days of exceeding 115 operating hrs in 12 months

VE observation sequence in progress

FGIC07 Bldg 606 - Genset DSQ316/54031 1440hp

DPW Within 90 days of exceeding 115 operating hrs in 12 months

VE observation sequence in progress

FGIC08 Bldg 606 - Genset DSQ38/59019 1765 hp

DPW Within 90 days of exceeding 90 operating hrs in 12 months

VE observation sequence in progress

FGIC09 Bldg 606 - Genset DSQ38/59020 1765 hp

DPW Within 90 days of exceeding 90 operating hrs in 12 months

VE observation sequence in progress

FGIC10 Bldg 606 - Pump 100 hp

FGIC11 Bldg 606 - Pump

FGIC12 Bldg 606 - Pump

FGIC13 Bldg 625 - Pump

DPW Within 90 days of exceeding 225 operating hrs in 12 months

MOGAS fired

FGIC14 MDC - MEB Genset 1495 hp Detroit

GMD/

Boeing

Within 90 days of exceeding 175

GMD/

Boeing

GMD/

Boeing

Within 90 days of exceeding 250

GMD/

Boeing

GMD/

Boeing

Genset 1495 hp Detroit

GMD/

Boeing

FGIC20A &

20B

MDC - DSCS Gensets 2@474 hp Caterpillar

GMD/

Boeing

FGIC21 MDC - Interim PP 2636 hp Caterpillar

GMD Within 90 days of exceeding 105 operating hrs in 12 months

VE observation sequence in progress

FGIC22 MDC - Interim PP 2636 hp Caterpillar

GMD Within 90 days of exceeding 105 operating hrs in 12 months

VE observation sequence in progress

FGIC23 MDC - Interim PP 2636 hp Caterpillar

GMD Within 90 days of exceeding 105 operating hrs in 12 months

VE observation sequence in progress

FGIC24 MDC - Interim PP 2636 hp Caterpillar

GMD Within 90 days of exceeding 105 operating hrs in 12 months

VE observation sequence in progress

FGIC25 MDC - Permanent PP 2636 hp Caterpillar

GMD Within 90 days of exceeding 700 operating hours in 12 months

Future unit

FGIC26 MDC - Permanent PP 2636 hp Caterpillar

GMD Within 90 days of exceeding 700 operating hours in 12 months

Future unit

FGIC27 MDC - Permanent PP 2636 hp Caterpillar

GMD Within 90 days of exceeding 700 operating hours in 12 months

Future unit

FGIC28 MDC - Permanent PP 2636 hp Caterpillar

GMD Within 90 days of exceeding 700 operating hours in 12 months

Future unit

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Table 2 - Continued Fort Greely Emission Unit Thresholds For Visual Emission Observations

Unit ID Unit ID Unit ID Unit ID Unit ID FGIC29 MDC - Permanent PP

2636 hp Caterpillar GMD Within 90 days of exceeding 700 operating hours in 12 months Future unit

FGIC30 MDC - Permanent PP 2636 hp Caterpillar

GMD Within 90 days of exceeding 700 operating hours in 12 months

Future unit

FGIC31 MDC - Permanent PP 2636 hp Caterpillar

GMD Within 90 days of exceeding 700 operating hours in 12 months

Future unit

FGIC32 MDC - Permanent PP 2636 hp Caterpillar

GMD Within 90 days of exceeding 700 operating hours in 12 months

Future unit

FGIN01 Mid-post MSW incinerator DPW/

BASEOPS

Within 6 months of initiating operations

c. Visual Emission Observations - Initial, One-time

In addition to the routine visual emission observations described in Paragraph 5.b above, several emission units must have 18-minute visual emission observations within 6 months of beginning operations. These observations do not, in and of themselves, initiate the monthly, semi-annual and annual observation sequence described in Paragraph 5.b. Emission unit operators shall be responsible to insure required observations are performed by certified emission observers

The following emission units are subject to this requirement:

FGIC20A: MDC - DSCS Genset, Caterpillar 3456 691 hp FGIC20B: MDC - DSCS Genset, Caterpillar 3456 691 hp FGIC21: MDC - Interim PP, Caterpillar 3516BDITA 2636 hp FGIC22: MDC - Interim PP, Caterpillar 3516BDITA 2636 hp FGIC23: MDC - Interim PP, Caterpillar 3516BDITA 2636 hp FGIC24: MDC - Interim PP, Caterpillar 3516BDITA 2636 hp FGIC25: MDC - Permanent PP, Caterpillar 3516BDITA 2636 hp FGIC26: MDC - Permanent PP, Caterpillar 3516BDITA 2636 hp FGIC27: MDC - Permanent PP, Caterpillar 3516BDITA 2636 hp FGIC28: MDC - Permanent PP, Caterpillar 3516BDITA 2636 hp FGIC29: MDC - Permanent PP, Caterpillar 3516BDITA 2636 hp FGIC30: MDC - Permanent PP, Caterpillar 3516BDITA 2636 hp FGIC31: MDC - Permanent PP, Caterpillar 3516BDITA 2636 hp FGIC32: MDC - Permanent PP, Caterpillar 3516BDITA 2636 hp

d. Operational Monitoring

(1) Fuel Consumption

Fuel consumption must be monitored by the operator(s) at the frequency and for the emission units listed in Table 3 below.

Table 3 - Fuel Consumption Monitoring Requirements Unit ID Description Operator Frequency Comment

FGBF01

FGBF02

Bldg 101 - Boilers 2@8.37MMBtu/hr

DPW Daily or monthly, combined

FGBF14

FGBF15

Bldg 606 - Boilers 2@57.9 MMBtu/hr

DPW Daily, individual

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Table 3 – Continued Fuel Consumption Monitoring Requirements

Unit ID Description Operator Frequency Comment FGBF16 Bldg 606 - Boiler

1@67.3 MMBtu/hr DPW Daily or monthly

FGBF19

FGBF20

FGBF21

MDC - Utility Bldg Boilers 3@8.37 MMBtu/hr

GMD/

Boeing

Daily or monthly, combined

FGIC21-24

MDC - Interim PP Gensets 4@2636 hp Caterpillar

GMD Daily or monthly, combined

FGIC25-32

MDC - Permanent PP Gensets 8@2636 hp Caterpillar

GMD Daily or monthly, combined Future units

FGOB01 Mid-post open burn pit DPW/

BASEOPS

Daily or monthly waste combusted

FGIB01 Mid-post MSW Incinerator DPW/

BASEOPS

Daily waste combusted

(2) Operating Hours

Monthly operating hours must be monitored by the operator(s) for the emission units in Table 4 below.

Table 4 - Units Requiring Monthly Operating Hour Monitoring Unit ID Description Operator Comment

FGIC01 FAA Bldg - Genset 635 hp Detroit

DPW

FGIC02 Bldg 133 - Pump 100 hp

DPW

FGIC03 Bldg 501 - Genset Cummings 310 hp

DPW

Bldg 501 - Genset Kohler 160 hp

DPW

FGIC05 Bldg 606 - Genset DSQ316/54033 1440hp

DPW

FGIC06 Bldg 606 - Genset DSQ316/54032 1440hp

DPW

FGIC07 Bldg 606 - Genset DSQ316/54031 1440hp

DPW

FGIC08 Bldg 606 - Genset DSQ38/59019 1765 hp

DPW

FGIC09 Bldg 606 - Genset DSQ38/59020 1765 hp

DPW

FGIC10 Bldg 606 - Pump 100 hp

DPW

FGIC11 Bldg 606 - Pump 100 hp

DPW

FGIC12 Bldg 606 - Pump 100 hp

DPW

FGIC13 Bldg 625 - Pump 100 hp

DPW

FGIC14 MDC - MEB Genset 1495 hp Detroit

Genset 1495 hp Detroit

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Table 4 – Continued Units Requiring Monthly Operating Hour Monitoring

Unit ID Description Operator Comment FGIC20A and 20B

MDC - DSCS Gensets 2@474 hp Caterpillar

GMD/

Boeing

Record individually

FGIC21-24 MDC - Interim PP 4@2636 hp Caterpillar

GMD Record Individually

FGIC25-32 MDC - Permanent PP 8@2636 hp Caterpillar

GMD Future Units, Record Individually

(3) MDC Permanent Power Plant (FGIC25-32) NOx Emission Monitoring

Upon beginning operations of the MDC Permanent Power Plant the operator shall conduct weekly NOx emission sampling for each of emission units FGIC25-32 that is in operation to determine that Selective Catalytic Reduction (SCR) controls are achieving 85% NOx reduction. Monitor and record as follows:

(a) Use a MSI 150 diesel engine exhaust gas tester instrument or an equivalent approved by the Alaska Department of Environmental Conservation.

(b) Measure the NOx and O2 concentration and stack temperature at sampling ports upstream and downstream of the SCR control at each traverse point. Ensure that handheld analyzer sampling traverse points are representative of exhaust flow.

(c) Record the results from each traverse point and calculate and record the average percent NOx removal by SCR control: sum up the results from each traverse point and calculate the average NOx concentration upstream and downstream of the SCR unit; calculate the percent efficiency.

(d) If the NOx measurements demonstrate that SCR is achieving less than 85% NOx removal, notify FGAENV immediately.

(e) Conduct NOx emission sampling within 24 hours after catalyst bed replacement, catalyst elements changes, or changes in SCR control system: set points, load curve (mapping), and urea injection rate.

e. Source Testing

(1) Particulate Matter - Emission Units FGIC01-32 (Engines/Gensets)

If an 18-minute Method 9 visual emission observations results in an 18-minute average opacity in excess of 15% for a unit with a stack diameter of less than 18 inches, or if a 18-minute Method 9 visual emission observation results in an average opacity of greater than 20% for units with stack diameters greater than 18 inches, the unit operator shall notify FGAENV and either:

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(a) Make repairs and retest the unit to insure that the 18-minute average opacity does not exceed the applicable limit stated above, or

(b) Conduct a particulate matter source test in accordance with Section 12 of Permit No. 238TVP01. Any such source test shall be the responsibility of the operator and shall be coordinated with FGAENV to facilitate consultation and reporting with the ADEC.

(2) Particulate Matter - Emission Units FGBF01-02, FGBF14-16, FGBF19-21 (Boilers)

If corrective maintenance fails to eliminate visible emissions greater than 20% opacity for two or more consecutive 18-minute observations within a 6 month period, the operator shall notify FGAENV and conduct a particulate matter source test in accordance with Section 12 of Permit No. 238TVP01. Any such source test shall be the responsibility of the operator and shall be coordinated with FGAENV to facilitate consultation and reporting with the ADEC.

(3) NOx - Emission Units FGIC05-09

(a) For Emission Units FGIC05-07 a NOx source test in accordance with Section 12 of Permit No. 238TVP01 shall be conducted within 6 months if the aggregate 12-month rolling period operating hours exceed 1,755 hours. Any such source test shall be the responsibility of the operator and shall be coordinated with FGAENV to facilitate consultation and reporting with the

ADEC.

(b) For Emission Units FGIC08-09 a NOx source test in accordance with Section 12 of Permit No. 238TVP01 shall be conducted within 6 months if the aggregate 12-month rolling period operating hours exceed 1,170 hours. Any such source test shall be the responsibility of the operator and shall be coordinated with FGAENV to facilitate consultation and reporting with the

ADEC.

(4) NOx - Emission Units FGIC25-32

(a) Within 6 months after initial startup the operator shall conduct a NOx source test any other tests in accordance with Condition 28.4(c) and Section 12 of Permit No. 238TVP01. The source test and other requirements shall be the responsibility of the operator and shall be coordinated with FGAENV to facilitate consultation and reporting with the ADEC.

(b) The source test required by Paragraph 5.e(4)(a) above shall be repeated no less than every 8760 hours of operation for each unit .

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(c) The operator shall conduct a NOx source test in accordance with Condition 28.1

(5) NOx - Emission Units FGBF01-02

Within 6 months after the aggregate 12-month rolling period fuel consumption exceeds 588,000 gallons, the operator shall conduct a NOx and O2 source test on either unit in accordance with Section 12 of Permit No. 238TVP01. Any such source test shall be the responsibility of the operator and shall be coordinated with FGAENV to facilitate consultation and reporting with the ADEC.

(6) NOx - Emission Units FGBF14-16

Within 6 months after the aggregate 12-month rolling period fuel consumption exceeds 7,233,390 gallons, the operator shall conduct a NOx and O2 source test on Unit FGBF16 and either of Units FGBF14 or 15 in accordance with Condition 28.3(b) and Section 12 of Permit No. 238TVP01. Any such source test shall be the responsibility of the operator and shall be coordinated with FGAENV to facilitate consultation and reporting with the ADEC.

(7) NOx - Emission Units FGBF19-21

(a) Prior to the operation of the MDC Permanent Power Plant (FGIC25-32) and within 6 months after the aggregate 12-month rolling period fuel consumption exceeds 588,000 gallons, the operator shall conduct a NOx and O2 source test on either unit in accordance with Section 12 of Permit No. 238TVP01. Any such source test shall be the responsibility of the operator and shall be coordinated with FGAENV to facilitate consultation and reporting with the ADEC.

(b) After operation of the MDC Permanent Power Plant and within 6 months after the aggregate 12-month rolling period fuel consumption exceeds 882,000 gallons, the operator shall conduct a NOx and O2 source test on either unit in accordance with Section 12 of Permit No. 238TVP01. Any such source test shall be the responsibility of the operator and shall be coordinated with FGAENV to facilitate consultation and reporting with the ADEC.

f. PM10 Monitoring Station

FGAENV will operate and maintain the PM10 monitoring station located at Fort Greely in accordance with Condition 31 of Permit No. 238TVP01.

g. Fugitive Dust Controls

FGAENV will conduct periodic inspections to insure fugitive dust suppression measures are being implemented.

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6. RECORD-KEEPING AND REPORTING

FGAENV will maintain all official records required by FGA’s air quality permit(s).

All installation activities, tenants, contractors, or personnel operating permitted emission units at FGA or responsible for surveillance activities described in Paragraph 5 above, shall maintain records and report as follows:

a. Fuel Deliveries

(1) FGA POL Facility

The operator shall maintain fuel delivery records consisting of: dates of delivery, fuel analyses for each delivery, and amounts of fuel delivered. Additionally, the operator shall maintain records of any operator-arranged deliveries made directly (i.e., not through disbursements from POL bulk storage) by the fuel supplier to MDC sources. The records shall include the dates of delivery, fuel analyses for each delivery and amounts of fuel delivered. Attachment 3 provides a suggested form to record these data.

The operator shall provide FGAENV with the records and fuel analyses described above by the 10th of each month for the previous month. The operator shall immediately notify FGAENV if any fuel delivery exceeds 0.12% sulfur by weight.

(2) Independent fuel deliveries (Not from FGA POL Facility)

The operator shall maintain fuel delivery records consisting of: dates of delivery, fuel analyses for each delivery and amounts of fuel delivered.

The operator shall provide FGAENV with the records and fuel analyses described above by the 10th of each month for the previous month. The operator shall immediately notify FGAENV if any fuel delivery exceeds 0.12% sulfur by weight.

b. Visual Emission Observations

(1) All visual emission observations made under Paragraphs 5.b and 5.c above shall be recorded on the form provided in Attachment 4.

(2) Copies of the visual emission observations forms shall be provided to FGAENV by the 10th of each month for any observations made during the previous month.

c. Operational Monitoring

(1) Fuel Consumption Records

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(a) Fuel consumption records maintained under Paragraph 5.d(1) above may be recorded on the appropriate form provided in Attachments 5-6 or in a format preferred by the operator(s). Reporting formats for future emission units (e.g., MDC Permanent Power Plant will be separately provided at a later date.

(b) Copies of the fuel (or solid waste) consumption records shall be provided to FGAENV by the 10th of each month for fuel consumption during the previous month.

(c) The DPW shall record the fuel deliveries made to the tanks (buildings) identified on the form provided in Attachment 7 or in a format preferred by the operator(s) and provide those data to FGAENV by the 10th of each month for fuel deliveries during the previous month.

(d) Operators shall immediately notify FGAENV of any anticipated or actual exceedance of the fuel consumption limitations shown in Table 1.

(2) Operating Hours

(a) Operating hour records maintained under Paragraph 5.d(2) above may be recorded on the appropriate form provided in Attachments 6, or 8-10 or in a format preferred by the operator(s). Reporting formats for future emission units (e.g., MDC Permanent Power Plant will be separately provided at a later date.

(b) Copies of the operating hour records shall be provided to FGAENV by the

10th of each month for the operating hours during the previous month.

(c) Operators shall immediately notify FGAENV of any anticipated or actual exceedance of the operating hour limitations shown in Table 1.

(3) MDC Permanent Power Plant NOx Emission Monitoring

(a) The NOx emission monitoring and calculations required under Paragraph 5.d(3) above shall be recorded in a format preferred by the operator.

(b) Copies of the NOx monitoring results and calculations shall be provided to

FGAENV by the 10th of each month for the monitoring and calculations of the previous month.

(c) The operator shall immediately notify FGAENV if the monitoring and calculations indicate that less than 85% NOx removal is being achieved.

d. Source Testing

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(1) If either a particulate matter or NOx and O2 source test is required under Paragraph 5.e above or by request of the ADEC, the operator shall notify FGAENV. All source tests shall be performed in accordance with Section 12 of Permit No. 238TVP01.

(2) The operator shall prepare a Test Plan in accordance with Condition 55 of Permit

No. 238TVP01 and submit it to FGAENV 45 days prior to the scheduled test date for test required under Paragraph 5.e above or 75 days prior to the test date for a test requested by ADEC. FGAENV will transmit the Test Plan to ADEC.

(3) The operator shall notify FGAENV at least 15 days prior to the date for the source test. FGAENV will provide written notification of the test date to ADEC.

(4) No later that 45 days after completing a source test, the operator shall submit a

Test Report to FGAENV. The Test Report shall be in the format set out in the ADEC Source Test Report Outline. FGAENV will transmit the Test Report to ADEC.

e. Future Units

(1) For Emission Units FGIC21-32, the operator shall submit: the make; model; serial number; specification sheet; a vendor guarantee that particulate emissions do not exceed

0.05 grains per cubic foot of exhaust (corrected to standard conditions and averaged over three hours); and electronic control settings (if applicable) to FGAENV within 30 days after initial startup. FGAENV will transmit the data to ADEC.

(2) For Emission Unit FGIN01, the operator shall submit the make, model, serial number and specification sheet to FGAENV within 30 days after initial startup.

FGAENV will transmit the data to ADEC.

f. Reporting Under Permit No. 238TVP01

In general, FGAENV will maintain all official records, respond to information request from ADEC, respond to air quality related complaints, and make, either directly or via the Director of Public Works, all required notifications and reports to ADEC. These reports include, but are not limited to:

(1) Semi-annual Facility Operating Reports (August 1 and February 1)

(2) Annual Compliance Certification (March 31)

(3) Assessable emissions estimate (March 31)

(4) Source test plans and reports (as required)

(5) Excess emissions and permit deviation reports (as required)

(6) NSPS reports (quarterly)

(7) NESHAPS (asbestos) reports (annually and as required)

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7. REFERENCES

(1) ADEC Air Quality Operating/Construction Permit No. 238TVP01

(2) ADEC Air Quality Construction Permit No. 238CP03

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Air Pollution Control – Attachment 1

Air Quality Operating/Construction Permit

[Printed Copies of this Document for Operational Use Only – Controlled Electronic Document Available from DPW Envir.]

DEPARTMENT OF ENVIRONMENTAL CONSERVATION

AIR QUALITY OPERATING/CONSTRUCTION PERMIT

Permit No. 238TVP01 Issue Date: November 14, 2003 Application No. A000238 Expiration Date: December 31, 2008 Revision 1: December 31, 2003 Revision 2: January XX, 2005

The Department of Environmental Conservation, under the authority of AS 46.14 and 18 AAC 50, issues a revised operating/construction permit to the Permittee, U.S. Army Garrison Ft. Greely, for the operation of Fort Greely, Alaska.

This permit satisfies the obligation of the owner and operator to obtain an operating permit as set out in AS 46.14.130(b).

As set out in AS 46.14.120(c), the Permittee shall comply with the terms and conditions of this operating/construction permit.

All facility-specific terms and conditions of Air Quality Control Construction Permit No.

238CP03, issued November 2, 2004 have been incorporated into this Operating Permit.

This Operating/Construction Permit Revision 2 becomes effective January XX, 2005.

Jim Baumgartner, Title V Manager

Air Permits Program

G:\AQ\Permits\AIR Permits\AirFacs\Ft. Greely\Ft Greely Revision 1\Ft. Greely TV Permit 238TVP01 Revision 2.doc

Permit No.238TVP01 Issued: November 14, 2003 Revision 2 Expires: December 31, 2008

Revision 2: January XX, 2005 Page 2 of 51

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Table of Contents List of Abbreviations Used in this Permit

Section 1. Identification Section 2. General Emission Information Section 3. Emission Unit Inventory and Description Section 4. Emission Fees Section 5. Emission Unit-Specific Requirements

Fuel-Burning Equipment Sulfur Compound Emissions for EU IDs FGBF01-02, FGBF14-16, FGBF19-21, FGIC01-12, FGIC 14-32, and FGIN01 EU s Subject to Federal New Source Performance Standards (NSPS), Subpart A Steam Generating Emission Units Subject to NSPS Subpart Dc Federal Procurement 40 CFR Part 82, Subpart D

Section 6. Visible Emissions and PM Monitoring, Recordkeeping and Reporting For Liquid-Fired Sources (EU IDs FGBF01-02, FGBF14-16, FGBF19-21, FGIC01-32, FGIN01)

For Liquid-Fired Engines (EU IDs FGIC01-32) For Liquid Fuel-Fired Boilers (EU IDs FGBF01-02, FGBF14-16, FGBF19-21)

Section 7. ORL to Avoid Classification as a PSD Major Stationary Source Section 8. Conditions to Protect and Monitor Ambient Air Quality Section 9. Facility-Wide Requirements

Halon Prohibitions, 40 CFR 82 Section 10. Insignificant Sources Section 11. Generally Applicable Requirements Section 12. General Source Testing and Monitoring Requirements Section 13. General Recordkeeping, Reporting, and Compliance Certification Requirements41 Section 14. Standard Conditions Not Otherwise Included in the Permit Section 15. Permit As Shield from Inapplicable Requirements Section 16. Visible Emissions Forms

Visible Emissions Field Data Sheet Visible Emissions Observation Record

Section 17. ADEC Notification Form

Revision 2 Expires: December 31, 2008

Revision 2: January XX, 2005 Page 3 of 51

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List of Abbreviations Used in this Permit AAC .......................Alaska Administrative Code ADEC .....................Alaska Department of Environmental Conservation AS...........................Alaska Statutes ASTM.....................American Society for Testing and Materials BACT .....................Best Available Control Technology BHp ........................Boiler Horsepower C.F.R. .....................Code of Federal Regulations CO ..........................Carbon Monoxide dscf .........................Dry standard cubic foot EPA ........................US Environmental Protection Agency gr./dscf....................grain per dry standard cubic foot (1 pound = 7000 grains) GPH........................gallons per hour HAPs or HACs .......Hazardous Air Pollutants or Hazardous Air Contaminants [HAPs or HACs as defined in AS 46.14.990(14)] ID............................Emission Unit Identification Number kPa..........................kiloPascals LAER .....................Lowest Achievable Emission Rate MACT ....................Maximum Achievable Control Technology as defined in 40 C.F.R. 63.

MR&R....................Monitoring, Recordkeeping, and Reporting NESHAPs...............Federal National Emission Standards for Hazardous Air Pollutants [NESHAPS as contained in 40 C.F.R. 61 and 63] NOX ........................Nitrogen Oxides NSPS ......................Federal New Source Performance Standards [NSPS as contained in 40 C.F.R. 60] O & M ....................Operation and Maintenance O2............................Oxygen PM-10.....................Particulate Matter less than or equal to a nominal ten microns in diameter ppm ........................Parts per million ppmv, ppmvd..........Parts per million by volume on a dry basis psia .........................Pounds per Square Inch (absolute) PSD.........................Prevention of Significant Deterioration PTE.........................Potential to Emit SIC..........................Standard Industrial Classification SO2..........................Sulfur dioxide TPH ........................Tons per hour TPY ........................Tons per year VOC .......................volatile organic compound [VOC as defined in 18 AAC 50.990(103)] VOL........................volatile organic liquid [VOL as defined in 40 C.F.R. 60.111b, Subpart Kb] vol% .......................volume percent wt%.........................weight percent

Revision 2 Expires: December 31, 2008

Revision 2: January XX, 2005 Page 4 of 51

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Section 1. Identification

Names and Addresses

Permittee: U. S. Army Garrison Fort Greely Mailing Address: P.O. Box 31310 Fort Greely, Alaska 99731 Telephone Number: (907) 873-4211

Facility Name: Fort Greely, Alaska

Location: 63 58′ North; 145 43′ West

Physical Address: Just south of Delta Junction, bordering the Richardson Highway to the west

Owner: U.S. Army Garrison Fort Greely P.O. Box 31310 Fort Greely, Alaska 99731

Operator: U.S. Army Garrison Fort Greely P.O. Box 31310 Fort Greely, Alaska 99731

Permittee’s Responsible Official Robert E. Cornelius LTC, SF Garrison Commander Fort Greely Garrison

(907) 873-4211

Designated Agent: Christine Boerst, Environmental Coordinator P.O. Box 31310 Fort Greely, Alaska 99731-1310

(907) 873-4665

Facility and Building Contact: Lawrence M. Ryan Director of Public Works P.O. Box 31310 Fort Greely, Alaska 99731-1310

(907) 873-4582

Facility Process Description

SIC Code of the Facility: 9711 National Security

[18 AAC 50.350(b)(1), 1/18/97]

Revision 2 Expires: December 31, 2008

Revision 2: January XX, 2005 Page 5 of 51

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Section 2. General Emission Information [18 AAC 50.350(b)(1), 1/18/97]

Emissions of Regulated Air Contaminants:

Nitrogen oxides, sulfur dioxide, carbon monoxide, particulate matter, volatile organic compounds (VOC), asbestos, CFC-12, HCFC-22, Halon-1301, R-502

Facility Classifications:

(1) 18 AAC 50.300(c)(1) [without EU limitations, the facility has the potential to emit 250

TPY or more of a regulated air contaminant in an attainment or unclassifiable area for that contaminant per 18 AAC 50.015]

Operating Permit Classifications:

(1) 18 AAC 50.325(b)(1) [emits or has the potential to emit 100 TPY or more of a regulated air contaminant]

(2) 18 AAC 50.325(b)(3) [contains a source subject to one or more of the standards adopted by reference in 18 AAC 50.040 (a) – (c)]

Revision 2 Expires: December 31, 2008

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Section 3. Emission Unit Inventory and Description [18 AAC 50.350(d)(2), 1/18/97]

The Emission Units listed in Table 1 have specific monitoring, record keeping, or reporting conditions in this permit. Emission unit descriptions and ratings are given for identification purposes only.

Table 1 – Emission Units Inventory

EU ID Location Description Rating/Size Installation Date

Liquid Fuel-Fired Boilers

FGBF01 Bldg 101 Boiler: Cleaver-Brooks CB100-200 8.37 MMBtu/hr 1983

FGBF02 Bldg 101 Boiler: Cleaver-Brooks CB100-200 8.37 MMBtu/hr 1983

FGBF14 Bldg 606 Boiler: English Tube 92-193A 57.9 MMBtu/hr 1993

FGBF15 Bldg 606 Boiler: English Tube 92-193B 57.9 MMBtu/hr 1993

FGBF16 Bldg 606 Boiler: Erie Iron City 67.3 MMBtu/hr 1954

FGBF19 Utility Bldg Boiler 8.37 MMBtu/hr 2003

FGBF20 Utility Bldg Boiler 8.37 MMBtu/hr 2003

FGBF21 Utility Bldg Boiler 8.37 MMBtu/hr 2004/2005

Liquid Fuel-Fired Emergency Power Generation Sets

FGIC01 FAA Detroit 063HK35 635 hp 2003

FGIC03 Bldg 501 Cummings 100D34 310 hp

FGIC04 Bldg 501 Kohler 100R02 160 hp

FGIC05 Bldg 606 Enterprise DSQ316/54033 1440 hp 1953

FGIC06 Bldg 606 Enterprise DSQ316/54032 1440 hp 1953

FGIC07 Bldg 606 Enterpirse DSQ316/54031 1440 hp 1953

FGIC08 Bldg 606 Enterprise DSQ38/59019 1765 hp 1962

FGIC09 Bldg 606 Enterprise DSQ38/59020 1765 hp 1962

FGIC14 MEB1 Detroit 16V2000 R163K36 1495 hp 2003/2004

FGIC15 R&C2 Detroit 16V2000 R163K36 1495 hp 2003/2004

FGIC16 IS3 Volvo TD520GE 150 hp 2003/2004

FGIC17 MAB4 Volvo TAD1631GE 743 hp 2003/2004

Revision 2 Expires: December 31, 2008

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FGIC18 IDT5 Volvo TAD1630GE 645 hp 2003/2004

FGIC19 Water Supply Detroit 16V2000 R163K36 1495 hp 2003/2004

FGIC20 DSCS6 Caterpillar 3456 474 hp 2004

FGIC21 Interim Power Fac. Caterpillar 3516BDITA 2636 hp 2004

FGIC22 Interim Power Fac. Caterpillar 3516BDITA 2636 hp 2004

FGIC23 Interim Power Fac. Caterpillar 3516BDITA 2636 hp 2004

FGIC24 Interim Power Fac. Caterpillar 3516BDITA 2636 hp 2004

FGIC25 Power Plant Caterpillar 3516BDITA 2636 hp 2006

FGIC26 Power Plant Caterpillar 3516BDITA 2636 hp 2006

FGIC27 Power Plant Caterpillar 3516BDITA 2636 hp 2006

FGIC28 Power Plant Caterpillar 3516BDITA 2636 hp 2006

FGIC29 Power Plant Caterpillar 3516BDITA 2636 hp 2006

FGIC30 Power Plant Caterpillar 3516BDITA 2636 hp 2006

FGIC31 Power Plant Caterpillar 3516BDITA 2636 hp 2006

FGIC32 Power Plant Caterpillar 3516BDITA 2636 hp 2006

Standby Pumps

FGIC02 Bldg 133 100 hp

FGIC10 Bldg 606 100 hp

FGIC11 Bldg 606 100 hp

FGIC12 Bldg 606 100 hp

FGIC13 Bldg 625 MOGAS-Fired 100 hp

MSW Combustors

FGOB01 Mid-post Open burn pit NA

FGIN01 Mid-post Type 1 MSW Incinerator 4 tpd 2004

1. Mechanical/Electrical Building (MEB)

2. Readiness and Control (R&C)

3. Interceptor Storage (IS)

4. Missile Assembly Building (MAB)

5. In-Flight Interceptor Communications System Data Terminal (IDT)

6. Defense Satellite Communication System (DSCS)

Revision 2 Expires: December 31, 2008

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Section 4. Emission Fees

1. Assessable Emissions. The Permittee shall pay to the Department an annual emission fee based on the facility’s assessable emissions as determined by the Department under 18 AAC 50.410. The assessable emission fee rate is set out in 18 AAC 50.410(b). The Department will assess fees per ton of each air contaminant that the facility emits or has the potential to emit in quantities greater than 10 tons per year. The quantity for which fees will be assessed is the lesser of

1.1 the facility's assessable potential to emit of 409 TPY; or

1.2 the facility’s projected annual rate of emissions that will occur from July 1 to the following June 30, based upon actual annual emissions emitted during the most recent calendar year or another 12 month period approved in writing by the Department, when demonstrated by

a. an enforceable test method described in 18 AAC 50.220;

b. material balance calculations;

c. emission factors from EPA’s publication AP-42, Vol. I, adopted by reference in 18 AAC 50.035; or

d. other methods and calculations approved by the Department.

[18 AAC 50.346(a)(1), 5/3/02 and 18 AAC 50.350(c) & 50.400 – 50.420, 1/18/97]

2. Assessable Emission Estimates. Emission fees will be assessed as follows:

2.1 no later than March 31 of each year, the Permittee may submit an estimate of the facility’s assessable emissions to ADEC, Air Permits Program, ATTN: Assessable Emissions Estimate, 410 Willoughby Ave., Juneau, AK 99801-1795; the submittal must include all of the assumptions and calculations used to estimate the assessable emissions in sufficient detail so the Department can verify the estimates; or

2.2 If no estimate is received on or before March 31 of each year, emission fees for the next fiscal year will be based on the potential to emit set forth in condition 1.1.

[18 AAC 50.346(a)(1), 5/3/02 and 18 AAC 50.350(c) & 50.400 – 50.420, 1/18/97]

Revision 2 Expires: December 31, 2008

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Section 5. Emission Unit-Specific…