20180924_New_Source_Review_Permit_MDNR_Permit_to_Construct.pdf

SEP 2 ~ 2018

Mr. Mark Lenox Chief, Compliance Branch USAG Fort Leonard Wood 8112 Nebraska Ave, BLDG 11400, ATTN: IMLD-PWE Fort Leonard Wood, MO 65473 dnr.mo. gov

RE: New Source Review Permit- Project Number: 2018-06-040

Dear Mr. Lenox:

Enclosed with this letter is your permit to construct. Please study it carefully and refer to Appendix A for a list of common abbreviations and acronyms used in the permit. Also, note the special conditions on the accompanying pages. The document entitled, "Review of Application for Authority to Construct," is part of the permit and should be kept with this permit in your files.

Operation in accordance with these conditions, your new source review permit application and with your operating permit is necessary for continued compliance. The reverse side of your permit certificate has important information concerning standard permit conditions and your rights and obligations under the laws and regulations of the State of Missouri.

This permit may include requirements with which you may not be familiar. If you would like the department to meet with you to discuss how to understand and satisfy the requirements contained in this permit, an appointment referred to as a Compliance Assistance Visit (CA V) can be set up with you. To request a CA V, please contact your local regional office or fill out an online request. The regional office contact information can be found at the following website:

http://dnr.mo.gov/regions/. The online CA V request can be found at http://dnr.mo.gov/cav/compliance.htm.

If you were adversely affected by this permit decision, you may be entitled to pursue an appeal before the administrative hearing commission pursuant to Sections 621.250 and 643 .075.6 RS Mo. To appeal, you must file a petition with the administrative hearing commission within thirty days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed; if it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the administrative hearing commission, whose contact information is: Administrative Hearing Commission, United States Post Office Building, 131 West High Street, Third Floor, P.O. Box 1557, Jefferson City, Missouri 65102, phone: 573-751-2422, fax: 573-751-5018, website: www.oa.mo.gov/ahc .

~+1

Rec ye led paper

RECEIVED OCT O 3 2018

Mr. Mark Lenox Page Two

If you have any questions regarding this permit, please do not hesitate to contact Ryan Schott, at the Department of Natural Resources' Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102 or at (573) 751-4817. Thank you for your attention to this matter.

Sincerely, AIR POLLUTION CONTROL PROGRAM r·-·- -, . v·· /. ·r, 'v~i-~ (_____/f'-! l . /1 I '·~ ll Susan Hecke . p

New Source Review Unit Chief

SH:rsj

Enclosures c: Southeast Regional Office PAMS File: 2018-06-040

Permit Number: 0 9 201 8 - O O 5

[±][§] MISSOURI mr ,cl) I DEPARTMENT OF

~ ~ NATURAL RESOURCES

MISSOURI AIR CONSERVATION COMMISSION

PERMIT TO CONSTRUCT

Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to construct the air contaminant source(s) described below, in accordance with the laws, rules and conditions as set forth herein .

Permit Number: 0 9 2 0 1 8 - O O 5 Project Number: 2018-06-040 Installation Number: 169-0004

Parent Company: US Army IMCOM - Directorate of Training (IDT)

Parent Company Address: 8112 Nebraska Ave, BLDG 11400, Fort Leonard Wood, MO 65473

Installation Name:

Installation Address:

Location Information:

USAG Fort Leonard Wood

1334 1st Street, Fart Leonard Wood, MO 654 73

Pulaski County (S21, T35N, R8W)

Application for Authority to Construct was made for:

The installation of a combined heat and power plant. This review was conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required.

D Standard Conditions (on reverse) are applicable to this permit.

0 Standard Conditions (on reverse) and Special Conditions are applicable to this permit.

'.l -·; ---; < I /,S.------·

Pre{ared by Ryan Schott New Source Review Unit SEP 2 4 2018

Effective Date

STANDARD CONDITIONS:

Permission to construct may be revoked if you fail to begin construction or modification within two years from the effective date of this permit. Permittee should notify the Enforcement and Compliance Section of the Air Pollution Control Program if construction or modification is not started within two years after the effective date of this permit, or if construction or modification is suspended for one year or more.

You will be in violation of 10 CSR 10-6.060 if you fail to adhere to the specifications and conditions listed in your application, this permit and the project review. In the event that there is a discrepancy between the permit application and this permit, the conditions of this permit shall take precedence. Specifically, all air contaminant control devices shall be operated and maintained as specified in the application, associated plans and specifications.

You must notify the Enforcement and Compliance Section of the Department's Air Pollution Control Program of the anticipated date of startup of this (these) air contaminant source(s). The information must be made available within 30 days of actual startup. Also, you must notify the Department's regional office responsible for the area within which you are located within 15 days after the actual startup of this (these) air contaminant source(s).

A copy of the permit application and this permit and permit review shall be kept at the installation address and shall be made available to Department's personnel upon request.

You may appeal this permit or any of the listed special conditions to the Administrative Hearing Commission (AHC), P.O. Box 1557, Jefferson City, MO 65102, as provided in RSMo 643.075.6 and 621.250.3. If you choose to appeal, you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered, whichever date was earlier.

If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed. If it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the AHC.

If you choose not to appeal, this certificate, the project review and your application and associated correspondence constitutes your permit to construct. The permit allows you to construct and operate your air contaminant source(s), but in no way relieves you of your obligation to comply with all applicable provisions of the Missouri Air Conservation Law, regulations of the Missouri Department of Natural Resources and other applicable federal, state and local laws and ordinances.

The Air Pollution Control Program invites your questions regarding this air pollution permit.

Please contact the Construction Permit Unit using the contact information below.

Contact Information:

Missouri Department of Natural Resources

Air Pollution Control Program P.O. Box 176

Jefferson City, MO 65102-0176

(573) 751-4817

The regional office information -can be found at the following website:

http://dnr.mo.gov/regions/

- 2 -

Project No 2018-06-040 Permit No. 0 9 2 O 1 8 - O Q !

SPECIAL CONDITIONS:

The perm1ttee is authorized to construct and operate subject to the following special conditions:

The special conditions listed in this permit were included based on the authority granted to the Missouri Air Pollution Control Program by the Missouri Air Conservation Law (specifically

643. 075) and by the Missouri Rules listed in Title 10, Division 1 0 of the Code of State Regulations (specifically 10 CSR 10-6 060). For specific details regarding conditions, see 10 CSR 10-6.060 paragraph (12)(A)10. "Conditions required by permitting authority. "

USAG Fort Leonard Wood Pulaski County (S21, T35N, R8W)

1. HAP Emission Limitation A. USAG Fort Leonard Wood shall emit less than 10.0 tons individually and

25.0 tons combined of HAPs in any consecutive 12-month period from the entire installation. This includes all HAP emission sources currently permitted for use at the installation (boilers, water heaters, space heaters, generators, engines, tanks, parts washers, and paint booths), as well as the engine included in this permit (EP-01 ). A complete list of existing HAP emission sources can be found in operating permit OP2017-033.

B. USAG Fort Leonard Wood shall demonstrate compliance with Special Condition 1.A using Attachments K, L & Min operating permit OP2017- 033 or equivalent forms, such as electronic forms approved by the Air Pollution Control Program.

2. Record Keeping and Reporting Requirements A. USAG Fort Leonard Wood shall maintain all records required by this permit for not less than five years and shall make them available immediately to any Missouri Department of Natural Resources' personnel upon request.

B. USAG Fort Leonard Wood shall report to the Air Pollution Control Program's Compliance/Enforcement Section at P 0. Box 176, Jefferson City, MO 65102 or by email at AirComplianceReporting@dnr.mo.gov, no later than 10 days after the end of the month during which any record required by this permit shows an exceedance of a limitation imposed by this permit.

- 3 -

REVIEW OF APPLICATION FOR AUTHORITY TO CONSTRUCT AND OPERATE

SECTION (5) REVIEW

Installation Address:

USAG Fort Leonard Wood 1334 1 st Street

Project Number: 2018-06-040 Installation ID Number: 169-0004 O O 5 Permit Number: 0 9 2 0 1 8 -

Parent Company:

US Army IMCOM - Directorate of Training (IDT) 8112 Nebraska Ave, BLDG 11400

Fort Leonard Wood, MO 65473 Pulaski County (S21, T35N, R8W)

Fort Leonard Wood, MO 65473

REVIEW SUMMARY

• USAG Fort Leonard Wood has applied for authority to install a combined heat and power plant.

• The application was deemed complete on July 5, 2018.

• The only expected HAP emissions are the products of natural gas combustion.

• 40 CFR 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines and 40 CFR 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines apply to the engine.

• No air pollution control equipment is being used with the new equipment.

• This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. Potential emissions of all pollutants are below de minimis levels.

• This installation is located in Pulaski County, an attainment area for all criteria pollutants.

• Although parts of the installation (fossil fuel boilers) are classified under item number 21 on the List of Named Installations found in 10 CSR 10-6.020(3)(8) Table 2, the installation as a whole (SIC 9711) is not considered a named source; therefore, the installation's major source level is 250 tons per year and fugitive emissions are not counted toward major source applicability, while the named source equipment has a major source level of 100 tons per year and fugitive emissions are counted toward major source applicability.

-4-

• Emissions testing is not required for the equipment as a part of this permit. Testing may be required as part of other state, federal , or applicable rules.

• Submittal of an update to your Part 70 Operating Permit (OP2017-033) is required within 1 year of equipment startup.

• Approval of this permit is recommended with special conditions.

INSTALLATION DESCRIPTION

USAG Fort Leonard Wood is a federal military installation located on approximately 63,000 acres of land in Pulaski County. The primary purpose of the installation is to train enlisted and officer personnel in basic combat training, military engineering, and motor vehicle operations. This includes bridging, demolitions, placement and removal of land mines; placement and breaching of obstacles designated to prevent movement; and construction and maintenance of buildings, utility systems, and roads. Training is also provided in operations, repair, and maintenance of heavy equipment, as well as tracked/wheeled vehicles.

USAG Fort Leonard Wood is an existing major source for PM10 & NOx, a synthetic de minimis source for HAPs, and a minor source for all other pollutants. The installation has a Part 70 Operating Permit under OP2017-033. The following New Source Review permits have been issued to USAG Fort Leonard Wood from the Air Pollution Control Program.

T bl 1 P a e erm1 IS Ory ·t H t Project Number Permit Number Description

2015-11-046 032015-007A Addition of two generators to the asphalt plant

2014-10-049 032015-007 Installation of an asphalt plant

2014-1 0-048 012015-001 Surface coating operation

2013-02-035 052013-012 Dual-fuel boiler (EP-002B8) at Building 311A

2012-07-100 0995-0178 Crushing plant amendment

2009-07-02 5 072009-012 Temporary permit for Prime Power School

2008-09-029 042009-006 Crushing plant

2008-07-094 082002-024 Soil and vegetation monitoring plan

2008-03-097 082002-0248 Soil and vegetation sampling changes

2008-03-010 092008-001 40 ton per year NOx limit for Prime Power School

2007 -10-028 082002-024 Monitoring network changes

2007-05-036 082002-024C Soil and vegetation sampling

2005-10-039 082002-0248 Reporting requirements

2005-09-013 072003-022A Sulfur and nitrogen determinations

2005-09-014 082002-024A New training areas

2004-05-116 082002-024A Monitor location

2003-06-026 072003-022 Installation of a new dual-fuel boiler in Building 311A

- 5 -

Project. Number Permit Number Description

2003-04-125 062003-015 Installation of a replacement generator at the Forney Air Field

2003-04-124 062003-005 Installation of two replacement dry cleaning machines

2003-01-058 52000-004A Removal of quarterly reporting requirements for fire training activities

2001-12-051 082002-024 Replacement for permits 0695-010 & 1099-001 plus amendments

2001-12-052 • 022002-009 Corrective action for the addition of a replacement asphalt plant

2001-07-017 1099-001C Addition of language allowing an alternate compliance mechanism

2001-02-056 1099-001B Addition of smoke training site to be added to the approved list

2000-11-040 052001-011 25 ton per year voe limit on several existing fuel storage tanks

2000-10-072 052001-010 30 ton per year voe limit on painting in Buildings 5138, 5265, 5266

2000-05-011 1099-001A Increase in the allowable insignificant level of fog oil usage to

2000-03-057 082000-006 Construction of an ATF explosive range and classroom

2000-03-043 052000-004 Construction of a structure to conduct fire training exercises

2000-01-079 1099-001A Addition of operational scenarios to the original Look-Up Tables

1999-09-040 0999-015 Switching of fuels in the fog oil generators to JP-8

1999-03-020 0699-022 The installation of an emergency generator

1998-11-105 1099-001 Modification to relocate the Chemical and Military Police Schools

1998-07-029 0998-032 Increase of the CARC paint usage in the Building 5138 paint booth

1998-05-090 0695-010A Extension for Construction Permit No. 0695-01 0

1998-04-027 0495-013A Incinerator replacement

3860-0004-033 0897-013 Installation of six used oil heaters

3860-0004-032 0697-003 Modification of paint booth in Construction Permit No. 0294-007

3860-0004-031 0294-007A Addition of the usage of a clear coat material in Building 5266

3860-0004-030 0590-004A Authority to burn Type (5) medical/infectious waste materials

3860-0004-028 0895-030 Increase in capacity of above ground storage tanks and fuel switch

3860-0004-027 0879-002 Installation of a refuse incinerator

3860-0004-026 0495-013 Construction of a Chemical Decontamination Training Facility

3860-0004-025 0995-017 Installation of a rock crushing plant

3860-0004-023 0794-011 Installation/modification of eight boilers

3860-0004-022 0294-007 Construction of four paint booths in Building 5138

3860-0004-021 0392-011 Construction of a rock crushing/screening plant

3860-0004-020 0891-003 Construction of a rock crushing/screening plant

3860-0004-019 0790-007 Construction of a rock crushing/screening plant

3860-0004-018 0590-004 Authority to incinerate Type 0, 1, & 4 wastes

3860-0004-017 0983-019 Construction of a Type IV waste incinerator

3860-0004-016 0979-030 Construction of a fuel oil fired boiler for space hearting

3860-0004-015 0695-010 Construction of a static and mobile fog oil smoke training facility

3860-0004-010 0879-010 & Construction of two additional incinerators 0879-011

3860-0004-005 0179-006 to Construction of eleven petroleum storage tanks

0179-016

- 6 -

Formaldehyde 10.0/2 4.34 N/D 5.43 9.77

Hexane 10.0/10 1.00 N/D 0.11 1.11

Methanol 10.0/10 0.03 N/D 0.26 0.29

*Total HAPs 25.0 19.03 0.01 7.42 <25.0 SMAL = Screening Model Action Level; N/D = Not Determined *All individual HAPs not listed have a potential to emit less than their respective SMALs

AMBIENT AIR QUALITY IMPACT ANALYSIS

Table 3 summarizes the ambient air quality impact analysis, which was performed in order to determine the impact of all pollutants with a potential to emit greater than their respective SMALs. The modeled impact is the maximum value for each pollutant when the engine (EP-01) is operating continuously.

Table 3: Ambient Air Quality Impact Analysis Summary .. ::. . : •• Modeled Impact Limited Impact

Pollutant ·

· RAL (µg/m3) Averaging Time (µg/m3) (µg/m3)

6.9 24-hour 0.15 N/A Acrolein

0.02 Annual 0.02 N/A

9.8 24-hour 1.53 N/A

Formaldehyde 0.8* Annual 0.26 N/A

RAL = Risk Assessment Level; N/A = Not Applicable *Formaldehyde has a listed 10x Annual RAL, which is within the APCP's acceptable chronic exposure level

Modeling was performed using the EPA's AERSCREEN screen modeling software. The stack characteristics entered into the modeling software are listed in Table 4.

T bl 4 AERSCREEN I t P t a e npu arame ers

Equipment· Stack Height Stack Inside · Stack Gas Exit Stack Gas Exit

Dispersion Diameter Velocity Temperature

Description (m) (m) (mis) (K) Coefficient

Natural Gas Engine

13.72 0.61 14.55 466.48 Rural (EP-01)

PERMIT RULE APPLICABILITY

This review was conducted in accordance with Section (5) of Missouri State Rule 10 CSR 10-6.060, Construction Permits Required. Potential emissions of all pollutants are below de minimis levels.

APPLICABLE REQUIREMENTS

USAG Fort Leonard Wood shall comply with the following applicable requirements. The Missouri Air Conservation Laws and Regulations should be consulted for specific record keeping, monitoring, and reporting requirements. Compliance with these emission

- 8 -

PROJECT DESCRIPTION

USAG Fort Leonard Wood is proposing to install a combined heat and power plant to support and supplement the power provided to the installation. Within Building 2369, two boilers currently provide high temperature hot water to the installation. For this project, a 2,500 kW natural gas fired 4-stroke lean-burn engine (EP-01) will be installed to provide additional power to the grid and capture heat for use in the high temperature hot water system. Also, two 300-gallon storage tanks (EP-02 & EP-03) will be installed to handle fresh/waste lubricating oil for the engine.

EMISSIONS/CONTROLS EVALUATION

The 2,500 kW natural gas fired engine is subject to NSPS JJJJ; therefore, potential NOx, CO, and VOC emissions were calculated using the emission standards in Table 1 of this subpart. Potential emissions of all other pollutants were calculated using emission factors taken from Table 3.2-2 in AP-42 Section 3.2 Natural Gas-fired Reciprocating Engines (August 2000).

The two 300-gallon storage tanks will contain only lubricating oil for the new engine.

Emissions from working and breathing losses are expected to be negligible and were not evaluated for this project.

Table 2 provides an emissions summary for this project. Existing potential emissions were taken from the installation's most recent operating permit (OP2017-033); however, the asphalt plant permitted under Construction Permit No. 032015-007 (and amended under 032015-007 A) was not constructed and will not operate. Therefore, potential emissions from the asphalt plant were removed from the installation's existing potential emissions. Existing actual emissions were taken from the installation's most recent EIQ.

Potential emissions of the project represent the potential of the new equipment, assuming continuous operation (8,760 hours per year).

Table 2: Emissions Summary tons per year

Regulatory Existing Existing Potential

New Potential Actual Emissions

Pollutant De Minimis Potential Emissions Emissions of of the

Levels/SMAL Emissions (2017 EIQ) the Project Installation

PM 25.0 N/D N/D N/D N/D

PM10 15.0 320.03 2.30 0.01 320.04

PM2s 10.0 200 55 0.94 0.01 200.56

SOx 40.0 83.66 0 05 0.06 83 72

NOx 40.0 259.43 13.40 32.37 291.80 voe 40.0 81.45 1.21 22.66 104.11 co 100.0 98.98 8. 13 64.75 163. 73

Acetaldehyde 10 0/9 2.40 NID 0.86 3.26

Acrolein 10.0/0.04 0.34 N/D 0.53 0.87

- 7 -standards, based on information submitted in the application, has been verified at the time this application was approved. For a complete list of applicable requirements for your installation, please consult your operating permit.

GENERAL REQUIREMENTS

• Start-Up, Shutdown, and Malfunction Conditions, 10 CSR 10-6.050

• Operating Permits, 10 CSR 10-6.065

• Submission of Emission Data, Emission Fees and Process Information, 10 CSR 10-6.110

, Per 10 CSR 10-6.110(4)(8)2.A, a full EIQ is required annually

• Restriction of Emission of Odors, 1 O CSR 10-6.165

• Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin, 10 CSR 10-6.170

• Restriction of Emission of Visible Air Contaminants, 10 CSR 10-6.220

SPECIFIC REQUIREMENTS

• New Source Performance Regulations, 10 CSR 10-6.070 , Standards of Performance for Stationary Spark Ignition Internal

Combustion Engines, 40 CFR Part 60, Subpart JJJJ

• MACT Regulations, 10 CSR 10-6.075 , National Emission Standards for Hazardous Air Pollutants for Stationary

Reciprocating Internal Combustion Engines, 40 CFR Part 63, Subpart zzzz

STAFF RECOMMENDATION

On the basis of this review conducted in accordance with Section (5), Missouri State Rule 10 CSR 10-6.060, Construction Permits Required, it is recommended that this permit be granted with special conditions.

- 9 -

PERMIT DOCUMENTS

The following documents are incorporated by reference into this permit:

• The Application for Authority to Construct form, dated June 20, 2018, received June 26, 2018, designating US Army IMCOM - Directorate of Training {IDT) as the owner and operator of the installation.

- 10 -

APPENDIX A

Abbreviations and Acronyms

% .............. percent

~F .............. degrees Fahrenheit acfm .......... actual cubic feet per minute

BACT ....... Best Available Control Technology

BMPs ........ Best Management Practices

Btu ............ British thermal unit

CAM ........ Compliance Assurance Monitoring

CAS ...... .... Chemical Abstracts Service

CEMS ...... Continuous Emission Monitor System

CFR .......... Code of Federal Regulations

CO ............ carbon monoxide

C02 ........... carbon dioxide

C02e ......... carbon dioxide equivalent

COMS ...... Continuous Opacity Monitoring System

CSR .......... Code of State Regulations dscf ........... dry standard cubic feet

EIQ ........... Emission Inventory Questionnaire

EP ............. Emission Point

EPA .......... Environmental Protection Agency

EU ............ Emission Unit fps ............. feet per second ft ............... feet

GACT ...... Generally Available Control Technology

GHG ......... Greenhouse Gas gpm .......... gallons per minute gr .............. grams

GWP ........ Global Warming Potential

HAP .......... Hazardous Air Pollutant hr .............. hour hp ............. horsepower lb ............... pound lbs/hr ........ pounds per hour

MACT ...... Maximum Achievable Control Technology µ.g/m3 ........ micrograms per cubic meter m/s ............ meters per second

- 11 -

Mgal ......... 1,000 gallons

MW .......... megawatt

MHDR. ..... maximum hourly design rate

MMBtu .... Million British thermal units

MMCF ..... million cubic feet

MSDS ....... Material Safety Data Sheet

NAAQS .... National Ambient Air Quality Standards

NESHAPs National Emissions Standards for Hazardous Air Po 11 utan ts

NO, ........... nitrogen oxides

NSPS ........ New Source Performance Standards

NSR .......... New Source Review

PM ............ particulate matter

PM2.5 ......... particulate matter less than 2.5 microns in aerodynamic diameter

PMrn ......... particulate matter less than IO microns in aerodynamic diameter ppm .......... parts per million

PSD ........... Prevention of Significant Deterioration

PTE .......... potential to emit

RAeT ....... Reasonable Available Control Technology

RAL .......... Risk Assessment Level sec .......... Source Classification Code scfm .......... standard cubic feet per minute

SOS ........... Safety Data Sheet

SIC. ........... Standard Industrial Classification

SIP ............ State Implementation Plan

SMAL ....... Screening Model Action Levels

SO, ............ sulfur oxides

S02 ............ sulfur dioxide

SSM .......... Startup, Shutdown & Malfunction tph ............ tons per hour tpy ............. tons per year

VMT ......... vehicle miles traveled voe ......... Volatile Organic Compound