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AMIGOS DEL RO GUAYNABO, INC.

CAMBIO
CIUDADANOS EN DEFENSA DEL AMBIENTE
COMIT BASURA CERO ARECIBO
MADRES DE NEGRO DE ARECIBO
SIERRA CLUB DE PUERTO RICO

April 9, 2017

Mr. John Filippelli, Director


USEPA Region 2
Clean Air and Sustainability Division
290 Broadway
New York, NY 10007-1866
Filippelli.John@epa.gov

Re: Energy Answers Arecibo, LLCs Request for Prevention of Significant Deterioration
Permit Extension

Dear Director Filippelli:

We are writing on behalf of the organizations listed above in response to the March 21, 2017
request made by Energy Answers Arecibo, LLC (Energy Answers) for a second extension of
its existing Prevention of Significant Deterioration (PSD) permit (Attachment 1). 1 We
understand that your office is set to determine on April 10, 2017 whether to grant Energy
Answers second extension request. We strongly oppose any extension because an extension at
this juncture would lock in permit requirements that are based on years-old analyses and
standards that are likely insufficiently protective of public health and the environment.
Moreover, Energy Answers request for a second extension is fraught with inaccuracies and
incomplete information, which obviate any likelihood that this is one of the rare circumstances
where a permittees justification, absent a substantive re-analysis and update of PSD
requirements, is sufficient to support a second extension. 2

Energy Answers presently holds a PSD permit for its proposed municipal waste incinerator
project in Arecibo, Puerto Rico. It applied for the permit in February 2011 and EPA
subsequently granted the final permit on April 10, 2014. Pursuant to the Clean Air Act and
EPAs implementing regulations, the permit was set to expire within 18 months if Energy
Answers had not commenced construction of the project consistent with 40 C.F.R. 52.21(r)(2).
However, on October 1, 2015, consistent with its authority under section 52.21(r)(2), EPA
Region 2 granted an 18-month extension of the PSD permit (Attachment 2). In granting this
1
Despite making several requests to EPA for the March 21 letter from Energy Answers, we
received a copy only at 3:42 PM on Friday April 7, 2017.
2
EPA, Guidance on Extension of Prevention of Significant Deterioration (PSD) Permits under
40 CFR 52.21(r)(2), at 5 (Jan. 31, 2014) (PSD Extension Guidance).

1
extension, the Region noted that in the event that Energy Answers does not commence
construction by April 10, 2017, Region 2 is not inclined to grant another extension.

Pursuant to EPAs PSD Extension Guidance, a second extension request should include a
substantive re-analysis and update of PSD requirements including Best Available Control
Technology (BACT), air quality impacts analysis (AQIA), and PSD increment consumption
analysis. Here, Energy Answers second extension request does not include a substantive re-
analysis and update of PSD requirements. Rather, Energy Answers dismisses the likelihood of
any relevant updated technology, suggesting that BACT has not changed for Municipal Waste
Combustor Units. Even if this were true, Energy Answers cursory review ignores the numerous
other processes for which BACT applies at the facility, including 1) Ash Handling System and
Storage Silos; 2) Emergency Diesel Generator; 3) Emergency Diesel Fire Pump; and 4) the Wet
Cooling Tower. 3 Together, EPAs online RACT/BACT/LAER Clearinghouse lists over 70
permits for these processes issued after the April 2014 Arecibo permit. A thorough analysis of
the 2014 Arecibo permit is therefore necessary to ensure that its requirements for all processes
continue to meet BACT standards. See In the Matter of the Proposed Operating Permit Issued
by the Commonwealth of Kentucky, Div. of Air Quality to Thoroughbred Generating Co., L.L.C.
for the Operation of Thoroughbred Generating Station, PERMIT V-02-001, 2007 WL 7356891
(E.P.A. Oct. 18, 2007) (Thoroughbred) (A BACT reanalysis is required in all permit
extension requests, as in an application for a new PSD permit.).

Similarly, the Clean Air Act requires a showing that a newly constructed facility will not cause,
or contribute to, air pollution in excess of any . . . national ambient air quality standard in any air
quality control region . . . . 4 Nevertheless, Energy Answers fails to mention several significant
regulatory changes since 2014 that impact its PSD obligations. For example, in 2015, EPA
revised the National Ambient Air Quality Standards for ozone in order to better protect public
health and the environment. 5 EPA also recently revised its guidelines for modeling ozone and
fine particulate matter air quality impacts using EPAs AERMOD modeling program. 6 In fact,
the AERMOD program has been updated at least 8 times since Energy Answers first submitted
its PSD application in February 2011, and at least 2 of those updates have occurred after the
issuance of the Arecibo PSD Permit in April 2014. 7 These changes necessarily alter the analysis
for determining compliance with the Clean Air Acts PSD requirements for ozone and its
precursors, fine particulate matter, and other pollutants whose modeling is required in the PSD

3
RACT/BACT/LAER Clearinghouse Report for the Energy Answers Arecibo Puerto Rico
Renewable Energy Project (Attachment 3).
4
42 U.S.C. 7475(a)(3).
5
National Ambient Air Quality Standards for Ozone; Final Rule, 80 Fed. Reg. 65,292 (Oct. 26,
2015).
6
Revisions to the Guideline on Air Quality Models: Enhancements to the AERMOD Dispersion
Modeling System and Incorporation of Approaches To Address Ozone and Fine Particulate
Matter, 82 Fed. Reg. 5,182 (Jan. 17, 2017).
7
See https://www.epa.gov/scram/air-quality-dispersion-modeling-preferred-and-recommended-
models.

2
analysis. Granting the second extension that Energy Answers seeks here would therefore fly in
the face [of] the technology forcing nature of PSD, allowing the permit applicant to move
forward with a project with an outdated technology analysis. Thoroughbred.

Moreover, contrary to the purported justification set forth in its request for a second extension,
the ongoing USDA Rural Utilities Service (RUS) NEPA review process does not prevent
Energy Answers from commencing construction within the meaning of 40 C.F.R. 52.21(r)(2).
Energy Answers claim that NEPA prohibits the company from commencing construction relies
solely on 7 C.F.R. 1794.15, 8 a regulatory provision that was removed from the Code of Federal
Regulations more than a year ago and no longer exists. See 81 Fed. Reg. 11,029 (March 2,
2016). EPAs PSD regulations allow an owner or operator to commence construction by
caus[ing] to begin such construction or by entering into binding agreements or contractual
obligations, which cannot be cancelled or modified without substantial loss to the owner or
operator, to undertake a program of actual construction of the source to be completed within a
reasonable time. Id. 52.21(b)(9)(i),(ii). Energy Answers points to no existing NEPA
provision or regulation that would prevent it from undertaking such actions.

Ultimately, Energy Answers second permit extension request is made necessary because the
project is economically unsound. The only way Energy Answers can secure financing is through
a taxpayer-backed loan from the RUS under the Rural Electrification Act, as amended. 9 While
poor economics and an inability to secure financing to commence construction may justify an
initial 18-month extension, these financial considerations do not outweigh the benefits of
conducting an updated substantive review of the PSD requirements after 36 months from the
initial permit issuance date. 10 These benefits, which relate to ensuring that the PSD permit
reflects the most up-to-date technology and air quality considerations, 11 redound to local
communities. 12

8
Attachment 1 at 1 (underlining the quoted text of 7 C.F.R. 1794.15).
9
Despite Energy Answers suggestion otherwise, RUSs ongoing National Environmental Policy
Act (NEPA) review does not justify extending the PSD permit. The NEPA review is being
undertaken by a federal agency that has been asked to financially support the project because the
economics of the project make it too risky for private investors. It would make little sense as a
matter of policy to allow Energy Answers to proceed with outdated PSD requirements simply
because Energy Answers chose to embark on a financially risky venture that necessitates reliance
on taxpayer subsidized financing.
10
PSD Extension Guidance at 56.
11
See id. at 6 (EPA believes that it is more likely that technology and air quality considerations
will become outdated when construction does not begin until 36 months or longer after the EPA
has taken final action to issue a PSD permit.).
12
Energy Answers request for a second extension argues that there is a need for the incinerator
project. We refer EPA to our comments to RUSs Draft EIS and Final EIS, both of which refute
Energy Answers arguments with regard to the purported purpose and need for the project. See
https://goo.gl/To6f6o and https://goo.gl/s7coEt.

3
In this case, the local communities that would be affected by this proposed project
communities that are overwhelmingly minority, low-income, and already burdened by
environmental pollutionhave made it exceedingly clear over many years that they are deeply
concerned about the incinerators impacts on their health and environment. Under these
circumstances, and in light of the potential changes in BACT, the updated ozone NAAQS,
updated AERMOD, and revised guidelines for modeling ozone and fine particulate matter, it is
incumbent on EPA to deny Energy Answers request for a second extension of its PSD permit.

Sincerely,

Hannah Chang Kenneth Rumelt Pedro Saade Llorens


Jonathan Smith Vermont Law School University of Puerto Rico
Earthjustice Envtl. & Natural Res. Law Clinic School of Law Environmental
hchang@earthjustice.org krumelt@vermontlaw.edu Law Clinic
212-845-7382 802-831-1031 pedrosaade5@gmail.com
787-999-9573

cc: Hon. Luis V. Gutirrez (via email with attachments)


Member of Congress

Ariel Iglesias, Deputy Director (via email with attachments)


Clean Air and Sustainability Division
U.S. EPA Region 2

Carmen Guerrero, Director (via email with attachments)


Caribbean Environmental Protection Division
U.S. EPA Region 2

4
Attachment 1
March 21, 2017

John Filippelli, Director


USEPA Region 2
Clean Air and Sustainability Division
290 Broadway
New York, NY 10007-1866

Subject: Energy Answers Arecibo, LLC


Request for Prevention of Significant Deterioration Air Permit Limited Extension

Dear Director Filippelli:

Energy Answers Arecibo, LLC (EAA) has been working diligently to commence construction of the
Arecibo Resource Recovery Facility (Arecibo RRF, or the Project) by the April 10, 2017 extended
Prevention of Significant Deterioration (PSD) permit Effective Date deadline; however, as discussed
below, EAA has experienced significant procedural and financial impediments that continue to restrict
our practical ability to commence construction of the Project, as this is defined under PSD regulations.
Although we continue to work towards beginning construction as soon as possible, and in advance of
the permitted deadline, we are requesting a limited extension of the current deadline for commencing
construction. We are making this request as a practical matter, considering the uncertain timing of the
completion of the necessary procedural steps for securing federal funding, which are steps that are
beyond EAAs control, yet directly influence the timeline by which EAA will be able to embark on a
program of continuous construction of the project.

At this time, we are prohibited from commencing a program of continuous construction due to the
onsite construction restrictions associated with the National Environmental Policy Act (NEPA)
Environmental Impact Statement (EIS) review, which is currently being conducted by the USDA Rural
Utilities Service (RUS). This process commenced on November 28, 2014 (28 months ago), with the
publication in the Federal Register of a Notice of Intent to prepare a Draft EIS, and has advanced slowly,
but steadily since that time, with the Final EIS being issued for public review and comment on February
22, 2017. Due to the Limitations on Actions During the NEPA process stipulated in 7 CFR Section
1794.15, which states that until RUS concludes its environmental review process, the applicant shall
take no action concerning the proposed action which would have an adverse environmental impact or
limit the choice of reasonable alternatives being considered in the environmental review process, the
work that can be conducted on the project site prior to the issuance of the RUS Record of Decision
(ROD) and without putting the Project at the risk of becoming ineligible to participate in the RUS loan
program, is consequently very limited.

The declining economic climate in Puerto Rico, due to the well documented ongoing economic crisis and
below-investment-grade credit ratings of Puerto Ricos debt and that of the Puerto Rico Electric Power
Authority (PREPA), has limited the sources of funding available to projects of the size and complexity of
Energy Answers Arecibo, LLC
SAN JUAN: The Atrium Business Center Suite 229 530 Constitution Avenue San Juan PR 00901-2304 Phone: 787 289-7804
NEW YORK: 79 North Pearl Street Albany NY 12207 Phone: 518 434 1227 Fax: 518 436 6343
Page: 2
Letter - Director Filippelli
USEPA Region 2
March 21, 2017

the Arecibo RRF, and made it necessary for EAA to pursue a federal loan through RUS. The RUS loan
program remains one of the few, if not only, potential sources of debt available to this Project under the
current economic conditions. These circumstances have presented a significant and extraordinary
financial impediment to proceeding with project financing and construction as originally expected. EAA
is now in a position wherein commencing on site construction prior to the issuance of a ROD would put
the RUS loan at risk, and consequently, put the entire project at risk. As of the date of this letter, the
ROD has yet to be issued.

Additionally, the NEPA onsite construction restriction is preventing the Project from commencing and
completing the tasks needed to activate one of the previously approved and currently effective local
environmental permits. Specifically, the Project must complete limited demolition activities on the
Project site and on the adjacent property in order to receive its previously approved Conditional Letter
of Map Revision (CLOMR) from FEMA. The issuance of the FEMA CLOMR, is a prerequisite condition to
the Puerto Rico Planning Board Siting Consultation. With the issuance of the FEMA CLOMR, all Project
federal and local permits necessary to commence construction will be approved, issued, effective and
active.

The negotiation of the Project's Engineering Procurement and Construction (EPC) contract, which
provides a program of continuous construction through the completion of the Project, is in an advanced
stage, and execution of a final agreement is expected within the next few weeks. Although most of the
terms and conditions of the EPC contract were negotiated years ago, the fact that this is a fixed price
contract with a guaranteed in-service date, means that the EPC contractor assumes substantial risk with
regards to the accuracy of both the price and schedule set in the contract. Consequently, to ensure that
all critical contract cost and schedule elements are accurate and current, the EPC contractor seeks to
complete the contract as near to the start of construction as possible, thus tying the execution of the
EPC contract to the ability to commence construction.

It is important to note that prior to the onset of the economic and fiscal crisis facing Puerto Rico and the
associated extraordinary financing impediments, EAA was prohibited from commencing construction,
and was required to seek an extension due to the legal challenges filed against the Projects PSD permit.
The legal challenges were not resolved until June 2016, only after the successful defense of the PSD
Permit at the DC Circuit Court of Appeals concluded and the request for an en banc reconsideration was
denied.

With respect to the proposed emissions control equipment technologies, pollution prevention
measures, and good engineering practices, which together constitute the Best Available Control
Technology (BACT) for the Project, this combined control system remains the most effective BACT
controls for the Project. In advance of this request, our project team reviewed the EPA
RACT/BACT/LAER Clearinghouse (RBLC) database and other industry sources, for the issuance of PSD
permits after the Arecibo RRF Permit was issued. This exercise confirmed that there is no evidence of
advancements in air pollution control technologies or regulatory standards that would indicate that
BACT for large scale Municipal Waste Combustion (MWC) units would be any different from what is
specified in the Arecibo RRF PSD Permit. In fact, the RBLC database continues to indicate that the
Arecibo RRF is the most recent PSD project and BACT determination for the large MWC source category.
In addition, it was confirmed with the Energy Recovery Council that there have been no new or modified
large MWCs or waste-to-energy facilities permitted since the Arecibo RRF PSD permit was issued, which
Page: 3
Letter - Director Filippelli
USEPA Region 2
March 21, 2017

further supports the fact that the BACT controls specified in the Arecibo RRF PSD permit continue to be
current and effective for minimizing emissions of regulated air pollutants from large MWCs.

Also, it is important to note that the RUS NEPA EIS review, which incorporates the PSD permit as part of
the document, has undergone a rigorous review process, which has included a Scoping meeting held on
January 28, 2015, a Draft EIS (DEIS) public hearing held on August 20, 2015, which was accompanied by
an extended public comment period of 97 days, which was further extended by 11 days to
accommodate a request by Regional Administrator Enck. In addition to these public participation
opportunities, the RUS FEIS underwent a 30-day public comment period that ended on March 6, 2017,
within approximately two weeks of the submittal of this letter. During the DEIS review, there were no
comments on the BACT controls or PSD permit conditions that brought into question whether they
represent the most current and effective emission control methods or technologies.

It is the Projects intention to commence limited test pile/foundation work prior to the April 10, 2017
permit Expiration Date and execute the EPC Contract as quickly as possible, also likely before the April
10, 2017 Expiration Date. Upon the issuance of a favorable RUS ROD, the Project will commence the
essential demolition work necessary to activate the Projects local construction permits. In summary, the
Project intends to follow the milestone target schedule detailed below:

Project Milestones Target Date Delayed Date


EPC Contract Executed March 31, 2017
Commencement of Phase I work (FEMA Onsite work and test piles) April 7, 2017
RUS ROD Issued April 14, 2017 April 28, 2017
FEMA CLOMR Issued June 16, 2017 July 7, 2017
RUS Loan Commitment Letter Issued July 14, 2017 August 4, 2017
Commencement of Phase II work (Fill & Foundation Work) July 21, 2017 August 18, 2017
EPA Notification of Construction Start July 28, 2017 September 1, 2017

Finally, although it is outside of the scope of the specific governing regulations, it is our hope that your
evaluation of our request takes into consideration the fact that:
20 of Puerto Rico's 28 landfills are not, and cannot, meet Sub-Title D regulations,
The average age of Puerto Rico Electric Power Authoritys generating facilities is over 45 years, with
many of these facilities needing renovations and/or fuel conversions to effectively meet EPA
emission standards,
Puerto Ricos recycling rate has remained below 15% for approximately 20 years and less than 5% of
the energy generated in Puerto Rico is renewable energy, and finally,
Puerto Rico is going through a historic economic crisis.

And know that the proposed Arecibo RRF will:

Provide fully compliant solid waste management capacity for over 20% of the MSW generated in
Puerto Rico,
Add greatly needed renewable energy generation capacity to PREPA,
Provide a major net reduction in GHG generation and will recover over 200 tons per day of
recyclable metals that would otherwise be lost to landfills, and
Page: 4
Letter - Director Filippelli
USEPA Region 2
March 21, 2017

Be the largest single economic development project in Puerto Ricos Fiscal Plan, providing thousands
of construction jobs and hundreds of permanent jobs.

As our record shows, we have been working diligently since the issuance of the PSD permit and have
spent over $20 million obtaining all of the necessary contracts and approvals necessary to commence
construction. We were hopeful that we would have been able to commence construction prior to the
April 10, 2017 deadline, but the need for the federal loan program due to the economic climate in
Puerto Rico and the slow pace of the NEPA EIS review, have made meeting that date less certain at this
time. EAA continues to work toward reaching the commencement of construction as soon as practical.
Notwithstanding the uncertainty related to the timing of the RUS ROD and the conclusion of the NEPA
process, we expect that construction will commence within no more than five (5) months from the April
10, 2017 deadline. Therefore, we respectfully request a five (5) month extension to the Effective Date
deadline for the commencement of construction of the Project.

Should you have any questions or require additional information, please contact me directly at your
earliest convenience.

Sincerely,

Mark J. Green
Vice President
Energy Answers Arecibo, LLC
Attachment 2
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 2
290 BROADWAY
NEWYORK, NY 10007-1866

OCT - 1 2015

Mr. Patrick Mahoney


President
Energy Answers, LLC
79 North Pearl Street
Albany, New York 12207

Re: Prevention of Significant Deterioration (PSD) of Air Quality


Request for a PSD Permit Extension for the Energy Answers Arecibo Puerto Rico
Renewable Energy Project

Dear Mr. Mahoney:

EPA is in receipt of your letters dated July 26, 2015 and August 14, 2015 requesting an
extension of the final PSD permit for the proposed Energy Answers Arecibo, LLC (Energy
Answers) facility. We have reviewed the information you provided, considered nationally issued
guidance on PSD permit extensions, and determined that an extension of 18 months is warranted
in this case.

Background

On April 10, 2014, EPA Region 2 issued a final and effective PSD permit decision for
construction of the Energy Answers Arecibo Puerto Rico Renewable Energy Project. EPA
regulations at 40 CFR 52.21 (r) (2) provide that the permit will become invalid if construction is
not commenced within 18 months of your receipt of the final permit decision. Given the April
10, 2014 permit issuance date, and your receipt of the permit on that date, the 18-month period
will end on October 10, 2015. However, 40 CFR 52.21 (r) (2) also provides that EPA may
extend the 18-month period for commencement of construction upon a satisfactory showing that
an extension is justified.

Following issuance of the final PSD permit decision for Energy Answers, Sierra Club de Puerto
Rico, et al. , filed a petition for judicial review on July 16, 2014 in the D.C. Circuit Court. While
no specific condition of the PSD permit was challenged, the petitioners argue that when EPA
granted the PSD permit, it erroneously concluded that nonattainment New Source Review did
not apply. The case has already been fully briefed but the Court has not yet scheduled oral
argument.

Discussion

EPA's interpretation of the permit extension provision of 40 CFR 52.2 l(r) (2) is discussed in
EPA' s Memorandum dated January 31 , 2014, titled "Guidance on Extension of Prevention of

Internet Address (URL) http://www.epa.gov


Recycled/Recyclable Printed with Vegetable 011 Based Inks on Recycled Paper (Minimum 50"/o Po1tconsumer content)
Significant Deterioration (PSD) Permits under 40 CFR 52.21(r) (2)" (Extension Memorandum).
This Memorandum clarifies what EPA considers adequate justification for such an extension and
indicates that a request for extension should be evaluated on a case-by-case basis. However, for
first-time PSD permit extension requests, the Memorandum specifically cites ongoing litigation
and "inability to secure financial resources necessary to commence construction," as relevant
factors in determining whether adequate justification has been provided. The memorandum also
references "significant or unusual economic impediments (including inability to secure financial
resources necessary to commence construction)" as relevant factors that may justify a first-time
extension.

Your August 14, 2015 letter indicates that the ongoing litigation "precludes the completion of
financing and release of construction funds for the Project' and "precludes the execution of the
design-build construction contract." We are mindful of the fact that the D.C. Circuit case might
not be decided until as late as next summer and recognize, as your August 14, 2015 letter notes,
the time necessary to complete the financing after a decision. Your August 14, 2015 letter also
references, among other factors, the impact of Puerto Rico ' s economic situation on the project
which has required your company to adopt new strategies for financial viability including a
request for the use of a federally-backed loan program from the United States Department of
Agriculture Rural Utilities Service that requires an Environmental Impact Statement. These
details, along with others in your letter, provide adequate justification under the Extension
Memorandum for a permit extension without any revisions or reconsideration of the substantive
conditions of the permit. Therefore, EPA is extending the Energy Answers PSD permit for an
additional 18-month period, until April 10, 201 7.

The Memorandum encourages the permitting authority to notify the public once it has issued the
permit extension, particularly where there has been significant public interest in the permit.
Given the large number of commenters on the Energy Answers PSD permit, Region 2 will be
posting this decision to extend the Energy Answers PSD permit on its website and placing notice
of this decision in a local newspaper.

In conclusion, EPA has determined that Energy Answers has provided adequate justification for
its request for an 18-month extension, consistent with what EPA has described a,s an adequate
justification in the Extension Memorandum. Therefore, EPA extends the effective date of the
Energy Answers ' PSD permit until April 10, 2017. Please note that this action does not alter the
substantive PSD permit conditions found in Enclosure I and the Enclosure II-General Permit
Conditions which were included with the April 10, 2014 PSD permit. Also note that in the event
that Energy Answers does not commence construction by April 10, 2017, Region 2 is not
inclined to grant another extension. As observed by EPA in the Extension Memorandum, "it is
significantly more likely that technology and air quality considerations will become outdated
when construction does not begin until 36 months or longer" after the final PSD permit is issued.
If you have any questions regarding this letter, please call me at (212) 637-3736 or Steven Riva,
Chief, Permitting Section, Air Programs Branch, at (212) 637-4074.

Sincerely,

/A/;,
John Filippelli, Director
Clean Air and Sustainability Division

cc: Luis Sierra, Puerto Rico Environmental Quality Board


Jose Font, EPA Region 2, Caribbean Environmental Protection Division
Attachment 3
COMPREHENSIVE REPORT
Report Date:04/07/2017
Facility Information
RBLC ID: PR-0009 (final) Date
Determination
Last Updated: 05/05/2016
Corporate/Company ENERGY ANSWERS ARECIBO, LLC Permit Number: R2-PSD 1
Name:
Facility Name: ENERGY ANSWERS ARECIBO PUERTO RICO RENEWABLE ENERGY PROJECT Permit Date: 04/10/2014 (actual)
Facility Contact: MARK GREEN (347)-351-5248 FRS Number: FRL-9911-10-Region 2
Facility Description: Energy Answers Arecibo is a new resource recovery facility capable of producing up to 77 SIC Code: 4953
megawatts (MW) of electrical power while combusting municipal solid waste, as the primary fuel.
Permit Type: A: New/Greenfield Facility NAICS Code: 221119
Permit URL:
EPA Region: 2 COUNTRY: USA
Facility County: ARECIBO
Facility State: PR
Facility ZIP Code:
Permit Issued By: EPA REGION II (Agency Name)
MR. FRANK JON(Agency Contact) (212)637-4085 jon.frank@epa.gov
Other Agency Contact Ms. Viorica Petriman
Info: petriman.viorica@epa.gov
Permit Notes: This is a PSD permit for a new/greenfield facility.
Affected Boundaries: Boundary Type: Class 1 Area State: Boundary: Distance:
INTL BORDER US/Canada Border > 250 km
Facility-wide Emissions: Pollutant Name: Facility-wide Emissions Increase:
Carbon Monoxide 357.0000 (Tons/Year)
Nitrogen Oxides (NOx) 352.0000 (Tons/Year)
Particulate Matter (PM) 51.7000 (Tons/Year)
Sulfur Oxides (SOx) 260.0000 (Tons/Year)
Volatile Organic Compounds (VOC) 52.4000 (Tons/Year)

Process/Pollutant Information
PROCESS Two Identical Municipal Solid Waste Combustors Units
PROCESS Two Identical Municipal Solid Waste Combustors Units
NAME:
Process Type: 21.400 (Municipal Waste Combustion)
Primary Fuel: municipal solid waste
Throughput: 2106.00 tons per day
Process Two identical municipal solid waste (MSW) combustors units (i.e., spreader-stoker boilers) designed to combust 2,106 tons per day (tpd), combined, of
Notes: refuse-derived fuel (RDF) as the primary fuel. RDF is shredded MSW with most of the metal content removed. Each boiler is rated at a maximum of 550
MMBTU/hr. The supplementary fuels permitted to be combusted, to substitute for a portion of RDF are tire-derived fuel, auto-shredder residue, and
processed urban wood waste. The warm up and shutdown fuel is ultra low sulfur distillate fuel oil No.2.

POLLUTANT NAME: Nitrogen Oxides (NOx)


CAS Number: 10102
Test Method: Other
Other Test Method: EPA Method 19
Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1: 45.0000 PPMVD@7%O2 24-HOUR DAILY ARITHMETIC AVERAGE
Emission Limit 2: 43.8900 LB/H 1-HOUR AVERAGE
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Regenerative Selective Catalytic Reduction System
Est. % Efficiency: 77.000
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: No
Pollutant/Compliance Notes: The NOx limits of 45 ppmvd@7%O2 and 43.89 lb/hr do not apply during warm up periods. The NOx BACT
limit during warmup is 480 lb/ 7 hours warmup event. The facility will use CEMS to measure NOx emissions.

POLLUTANT NAME: Carbon Monoxide


CAS Number: 630-08-0
Test Method: EPA/OAR Mthd 10
Pollutant Group(s): ( InOrganic Compounds )
Emission Limit 1: 75.0000 PPMVD@7%O2 24-HOUR DAILY ARITHMETIC AVERAGE
Emission Limit 2: 44.5300 LB/H 1-HR AVERAGE
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Oxidation Catalyst. The Regenerative Selective Catalytic Reduction System has two modules: an Selective
Catalytic Reduction System moduel, for NOx emissions control; and an Oxidation Catalyst module, for CO and
VOC emissions control.
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes: The 75 ppmvd @7%O2 and the 44.53 lb/hr limits do not apply during warmup periods.The limit for the warmup
periods is 228 lb of CO/7 hours warmup event. The facility will use CEMS to measure CO emissions.

POLLUTANT NAME: Volatile Organic Compounds (VOC)


CAS Number: VOC
Test Method: Other
Other Test Method: EPA Method 25 A
Pollutant Group(s): ( Volatile Organic Compounds (VOC) )
Emission Limit 1: 7.0000 PPMVD@7%O2 AVERAGE OF THREE 1-HOUR TEST RUNS
Emission Limit 2: 6.5600 LB/H 1 HOUR AVERAGE
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Oxidation Catalyst
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes: The VOC are expresse as propane.

POLLUTANT NAME: Sulfur Dioxide (SO2)


CAS Number: 7446-09-5
Test Method: Other
Other Test Method: EPA Method 19
Pollutant Group(s): ( InOrganic Compounds , Oxides of Sulfur (SOx) )
Emission Limit 1: 24.0000 PPMVD @7%O2 24-HOUR DAILY GEOMETRIC AVERAGE
Emission Limit 2: 32.5900 LB/H 1-HOUR AVERAGE
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Turbosorp Circulating Dry Scrubber and Fabric Filter System
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes: The facility will use CEMS to measure SO2 emissions at the inlet of the Turbosorp Circualting Dry Scrubber
amd at the stack

POLLUTANT NAME: Hydrochloric Acid


CAS Number: 7647-01-0
Test Method: EPA/OAR Mthd 26
Pollutant Group(s): ( Acid Gasses/Mist , Hazardous Air Pollutants (HAP) , InOrganic Compounds , Particulate Matter (PM) )
Emission Limit 1: 20.0000 PPMVD@7%O2 AVERAGE OF THREE 1-HOUR TEST RUNS
Emission Limit 2: 15.4800 LB/H 1-HOUR AVERAGE
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Turbosorp Circulating Dry Scrubber and Fabric Filters
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes: Hydrochloric Acid (HCL) is Muncipal Waste Combustor Acid Gas, along with SO2 emissions. The facility is
required to use CEMS for HCL emissions, in case EPA promulgates HCL CEMS performance specifications
before the end of calendar year 2014.
POLLUTANT NAME: Particulate matter, filterable (FPM)
CAS Number: PM
Test Method: EPA/OAR Mthd 5
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 10.0000 MG/DSCM@7%O2 AVERAGE OF THREE 1-HOUR TEST RUNS
Emission Limit 2: 5.1000 LB/H 1-HR AVERAGE
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Fabric Filters
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes: PM are also a surrogate for municipal waste combustor metals. Opacity of emissions from the municipal waste
combustors is limited to 10%(based on 6-minute average). The permit requires the use of continuous opacity
monitoring system (COM).

POLLUTANT NAME: Particulate matter, total < 10 (TPM10)


CAS Number: PM
Test Method: EPA/OAR Mthd 201A and OTM 28
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 24.0000 MG/DSCM@7%O2 AVERAGE OF THREE 1-HOUR TEST RUNS
Emission Limit 2: 12.2300 LB/H 1-HOUR AVERAGE
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Fabric Filters
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes: The PM10 limits account for both filterable and condensable fractions.
POLLUTANT NAME: Particulate matter, total < 2.5 (TPM2.5)
CAS Number: PM
Test Method: EPA/OAR OTM 27 and Mthd 202
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 22.0000 MG/DSCM@7%O2 AVERAGE OF THREE 1-HOUR TEST RUNS
Emission Limit 2: 11.2100 LB/H 1-HOUR AVERAGE
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Fabric Filters
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Dioxins & Furans


CAS Number: SEQ. 128
Test Method: EPA/OAR Mthd 23
Pollutant Group(s): ( Dioxens , Hazardous Air Pollutants (HAP) , Organic Compounds (all) , Volatile Organic Compounds (VOC) )
Emission Limit 1: 10.0000 NG/DSCM@7%O2 AVG. OF 3 TEST RUNS; MINIM. 4 HR/RUN
Emission Limit 2: LB/H 1-HOUR AVERAGE
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Turbosorp circulating dry scrubber, Activated carbon injection system, and Fabric Filter system
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:
POLLUTANT NAME: Sulfuric Acid (mist, vapors, etc)
CAS Number: 7664-93-9
Test Method: EPA/OAR Mthd 8
Pollutant Group(s): ( InOrganic Compounds , Particulate Matter (PM) )
Emission Limit 1: 1.0000 PPMVD@7%O2 AVERAGE OF THREE 1-HR TEST RUNS
Emission Limit 2: 2.0800 LB/H 1-HOUR AVERAGE
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Turbosorp circulating dry scrubber and Fabric Filters
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Fluorides, Total


CAS Number: 16984-48-8
Test Method: EPA/OAR Mthd 13A
Pollutant Group(s): ( InOrganic Compounds )
Emission Limit 1: 3.2000 PPMVD@7%O2 AVERAGE OF THREE 1-HOUR TEST RUNS
Emission Limit 2: 1.3600 LB/H 1-HOUR AVERAGE
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Turbosorp circulating dry scrubber and Fabric Filters
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes: Fluorides are measured as hydrogen fluoride
POLLUTANT NAME: Ammonia (NH3)
CAS Number: 7664-41-7
Test Method: EPA/OAR Cond. Test Mthd 027
Pollutant Group(s): ( InOrganic Compounds )
Emission Limit 1: 10.0000 PPMVD@7%O2 24-HR DAILY ARITHMETIC AVERAGE
Emission Limit 2: 3.6000 LB/H 1-HOUR AVERAGE
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes: Emission of Ammonia represent ammonia slip, which result from the RSCR that uses ammonia solution as a
reagent while reducing NOx emissions. Ammonia may be a precursor for PM2.5 emissions.

POLLUTANT NAME: Carbon Dioxide Equivalent (CO2e)


CAS Number: CO2e
Test Method: Other
Other Test Method: CEMS for Carbon dioxide emissions
Pollutant Group(s): ( Greenhouse Gasses (GHG) )
Emission Limit 1: 0.2900 LB CO2E/ LB OF STEAM 30-DAY ROLLING AVERAGE
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (P) Thermal efficiency of 13.25 MMBTU/MWh based on 30-day rolling average
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Compliance Verified: Unknown
Pollutant/Compliance Notes: The CO2e emission limit accounts for,both, biogenic an non-biogenic CO2.

Process/Pollutant Information
PROCESS Ash Handling System and Storage Silos
NAME:
Process Type: 21.400 (Municipal Waste Combustion)
Primary Fuel:
Throughput: 0
Process Notes: Ash Handling System comprises of bottom ash handling and conveying system, bottom ash storage and conveying system, bottom ash processing
activities, fly ash conveying, storage silo, conditioning and loading system. Storage silos comprise of carbon handling system and storage silo, and lime
handling and storage silo.

POLLUTANT NAME: Particulate matter, filterable (FPM)


CAS Number: PM
Test Method: Unspecified
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0170 MG/DSCM
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Fabric Filters
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes: The 0.017 mg/dscm PM limit applies also for PM10 and PM2.5. Note that PM, PM10 and PM2.5 shall only
account for filterable PM. There is no performance test required for PM, PM10 or PM2.5. Opacity of emissions
for the Ash Handling System and Storage Silos shall not exceed 5% (based on 6 minute average). Performance
test for opacity using EPA Method 9 is required on a monthly basis.
Process/Pollutant Information
PROCESS NAME: Emergency Diesel Generator
Process Type: 17.110 (Fuel Oil (ASTM # 1,2, includes kerosene, aviation, diesel fuel))
Primary Fuel: ULSD Fuel oil # 2
Throughput: 0
Process Notes: Emergency Generator is rated at 670 BHP and is limited to 500 hr per year (emergency and testing and maintenance, combined)

POLLUTANT NAME: Nitrogen Oxides (NOx)


CAS Number: 10102
Test Method: Unspecified
Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1: 2.8500 G/B-HP-H
Emission Limit 2: 4.2000 LB/H
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Carbon Monoxide


CAS Number: 630-08-0
Test Method: Unspecified
Pollutant Group(s): ( InOrganic Compounds )
Emission Limit 1: 2.6000 G/BHP-H
Emission Limit 2: 3.8600 LB/H
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Volatile Organic Compounds (VOC)


CAS Number: VOC
Test Method: Unspecified
Pollutant Group(s): ( Volatile Organic Compounds (VOC) )
Emission Limit 1: 0.1500 G/B-HP-H
Emission Limit 2: 0.2200 LB/H
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, filterable (FPM)


CAS Number: PM
Test Method: Unspecified
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.1500 G/B-HP-H
Emission Limit 2: 0.2200 LB/H
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, total < 10 (TPM10)


CAS Number: PM
Test Method: Unspecified
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.1500 G/B-HP-H
Emission Limit 2: 0.2200 LB/H
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, total < 2.5 (TPM2.5)


CAS Number: PM
Test Method: Unspecified
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.1500 G/B-HP-H
Emission Limit 2: 0.2200 LB/H
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Sulfur Dioxide (SO2)


CAS Number: 7446-09-5
Test Method: Unspecified
Pollutant Group(s): ( InOrganic Compounds , Oxides of Sulfur (SOx) )
Emission Limit 1: 0.0060 LB/H
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Carbon Dioxide Equivalent (CO2e)


CAS Number: CO2e
Test Method: Unspecified
Pollutant Group(s): ( Greenhouse Gasses (GHG) )
Emission Limit 1: 183.0000 T/YR
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

Process/Pollutant Information
PROCESS NAME: Emergency Diesel Fire Pump
Process Type: 17.210 (Fuel Oil (ASTM # 1,2, includes kerosene, aviation, diesel fuel))
Primary Fuel: ULSD Fuel Oil #2
Throughput: 0
Process Notes: The Emergency Fire Pump is rated at 335 BHP and limited to 500 hr/yr (emergency operations and testing and maintenance, combined).

POLLUTANT NAME: Nitrogen Oxides (NOx)


CAS Number: 10102
Test Method: Unspecified
Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) )
Emission Limit 1: 2.8500 G/B-HP-H
Emission Limit 2: 2.1000 LB/H
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Carbon Monoxide


CAS Number: 630-08-0
Test Method: Unspecified
Pollutant Group(s): ( InOrganic Compounds )
Emission Limit 1: 2.6000 G/B-HP-H
Emission Limit 2: 1.9300 LB/H
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Volatile Organic Compounds (VOC)


CAS Number: VOC
Test Method: Unspecified
Pollutant Group(s): ( Volatile Organic Compounds (VOC) )
Emission Limit 1: 0.1500 G/B-HP-H
Emission Limit 2: 0.1100 LB/H
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, total < 10 (TPM10)


CAS Number: PM
Test Method: Unspecified
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.1500 G/B-HP-H
Emission Limit 2: 0.1100 LB/H
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, filterable (FPM)


CAS Number: PM
Test Method: Unspecified
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.1500 G/B-HP-H
Emission Limit 2: 0.1100 LB/H
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes: Opacity of emissions from the emergency diesel fire pump's stack shall not exceed 20% except for one period of
no more than six (6) minutes in any sixty (60) minute interval when opacity shall not exceed 27%. The opacity
shall be measured annually by using EPA Method 9.
POLLUTANT NAME: Particulate matter, total < 2.5 (TPM2.5)
CAS Number: PM
Test Method: Unspecified
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.1500 G/B-HP-H
Emission Limit 2: 0.1100 LB/H
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Sulfur Dioxide (SO2)


CAS Number: 7446-09-5
Test Method: Unspecified
Pollutant Group(s): ( InOrganic Compounds , Oxides of Sulfur (SOx) )
Emission Limit 1: 0.0030 LB/H
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:
POLLUTANT NAME: Carbon Dioxide Equivalent (CO2e)
CAS Number: CO2e
Test Method: Unspecified
Pollutant Group(s): ( Greenhouse Gasses (GHG) )
Emission Limit 1: 91.3000 T/YR
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (N)
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

Process/Pollutant Information
PROCESS Wet Cooling Tower
NAME:
Process Type: 99.999 (Other Miscellaneous Sources)
Primary Fuel:
Throughput: 0
Process Notes: A"Four-Cell" mechanical draft wet cooling tower, with maximum total circulating flow ater rate of no more than 65,150 gallons per minute; Total
disolved solids content less than 16,100 ppm by weight.

POLLUTANT NAME: Particulate matter, filterable (FPM)


CAS Number: PM
Test Method: Unspecified
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 2.4800 LB/H 24-HOUR DAILY AVERAGE
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Dirft Eliminator designed to limit circulating water flow drift loss to 0.0005% or less.
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, filterable < 10 (FPM10)


CAS Number: PM
Test Method: Unspecified
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 1.3000 LB/H 24-HOUR DAILY AVERAGE
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Drift Eliminator designed to limit circulating water flow drift loss to 0.0005% or less.
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, filterable < 2.5 (FPM2.5)


CAS Number: PM
Test Method: Unspecified
Pollutant Group(s): ( Particulate Matter (PM) )
Emission Limit 1: 0.0050 LB/H 24-HOUR DAILY AVERAGE
Emission Limit 2:
Standard Emission:
Did factors, other then air pollution technology considerations influence the BACT decisions: U
Case-by-Case Basis: BACT-PSD
Other Applicable Requirements:
Control Method: (A) Drift Eliminator designed to limit circulating water flow drift loss to 0.0005% or less.
Est. % Efficiency:
Cost Effectiveness: 0 $/ton
Incremental Cost Effectiveness: 0 $/ton
Compliance Verified: Unknown
Pollutant/Compliance Notes:

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