ML061390265

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Massachusetts Department of Environmental Protection 50% Facility Emission Cap Approval Letter, Dated July 18, 2005
ML061390265
Person / Time
Site: Pilgrim
Issue date: 07/18/2005
From: Winkler J
State of MA, Dept of Environmental Protection
To: Bethay S
Entergy Nuclear Operations, Office of New Reactors
ALICIA WILLIAMSON 301-415-1878
Shared Package
ML061380814 List:
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Download: ML061390265 (8)


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I COMMONWEALTH OF MASSACHUSErTS ExECUTIvE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE 20 RIVERSIDE DRIVE, LAKEVILLE, MA 02347 508-946-2700 MITT ROMNEY Governor ELLEN ROY HERZFELDER Secretary KERRY HEALEY Lieutenant Governor ROBERT W. GOLLEDGE, Jr.

Commissioner July 18, 2005 Stephan Bethay Entergy Nuclear Operations, Inc.

Pilgrim Station 600 Rocky Hill Road Plymouth, Massachusetts 02360 Re:

50% Facility Emission Cap Approval FMF Classification: SM450 FMFNo. 130314 Source No. 1200163

Dear Mr. Bethay:

Enclosed for your files is a copy of your facility's BWPAQ Emissions Notification Form as processed by the Department, in response to your letter dated June 1, 2005 you requested an emissions cap of 50% of all applicable emission thresholds as defined in the following Table 1.

TABLE 1 - Annual Pollutant Emission Limits' (tons per 12-month period2)

VOC I NOx I

sox I

CO I PM10 I HAP(single) I HAP(total) 25 l

25 l

50 l

50 l

50 l

5 l

12.5 Notes: 1-As stipulated in 310 CMR 7.02(11)(e) 2-Rolling 12-month period 310 CMR 7.02(11) details specific record keeping and reporting requirements of an owner/operator electing to limit their facility's potential and actual emissions through this regulation. Operation under this facility wide emission cap does not relax or eliminate any emissions limitation(s), or recordkeeping requirement(s) established by regulation or previously issued source specific plan approval(s) or emission control plan(s). In addition, it does not eliminate the preconstruction plans review requirements of 310 CMR 7.02(1).

This Information Is available In alternate format. Call Donald M. Gomes, ADA Coordinator at 617-5561057. TDD Service - I1800-298.2207.

DEP on the World Wide Web: http:I/wwwvmass.gov/dep C

Printed on Recycled Paper

Entergy Nclear Operations, Inc.

Pilgram Station 50% Facility Emission Cap Approval 07/18/05 Page 2 of 2 Should you have any questions, please contact the Laura Patriarca at (508) 946-2829.

Very truly yours, John K. Winkler, Chief Permit Section Bureau of Waste Prevention Enclosure ecc:

Bob Boisselle, DEP/BWP-Boston Gregg Hunt, DEP/BWP-SERO Laura Patriarca, DEP/BWP-SERO Charlie Kitson, DEP/BWP-SERO

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t Massachusetts Department of Environmental Protection Bureau of Waste Prevention -Air Quality 50% or 25%

BWP AQ Emissions Notification Facility Emission Cap l Facility Information

1. Provide the following Information:

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/f 01 9 Notification Statement

1. Provide the Information required for the following notification statement

'1 hereby nabty DEP that this facility will operate in accora dance with the general requirements of 310 CMR 7.02(15) hd -

under the facility wide emission cap (check one):

1310 CMR 7.02(15(e) (50% cap) or O 310 CMR 7.02(15)(f) (25% cap) in lieu of restricted emissions status or operating permit approval or other facility-wide cap where applicable.

RES approval:

2. Facility wide emissions summary:

Actual Tons Per Year (p"o previous calendar year)

Emissions Particulate

0.

VA 6 PM1 0 sOx

,.as

8. e1 3 NOx r.Ia 4op Z v t

Lo co

?<8 I N/A Number de or operating permit:

4VS60C I As 1 a3. 1198 Number 14 date 7 or other facility-wide cap approval:

MIA C

Number do F

Lead J4iMSACHUSEUS DEPARTMENT OF ENVIRONMENTAL PROTICTION A,e 2/,e_/P5.-

U Certification I certify that I have personally examined the foregoing and am familiar with the Information contained In this document and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the Information Is true, accurate, and complete. I am aware that there are significant penalties for submitting false Information, Including possible fines and Imprisonment.

Signed under the pains and penalties of perjury:

MKtAicme I A.

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z-i ftirtNawe TMe

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I For DEP Use only Facility wide emissions cap:

o 25%ff5%

o 259/450%

Rev. 10196 Page 1 of 1

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COMMONWEALTH OF MASSACHUSETTS ExEcuTrIvE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE 20 RIVERSIDE DRIVE, LAKEVILLE, MA 02347 508-946-2700 MITT ROMNEY STEPHEN R. PRITCHARD Governor Secretary KERRY HEALEY ROBERT W. GOLLEDGE, Jr.

Lieutenant Governor Commissioner July 19,2005 Stephen Bethay Entergy Nuclear Operations, Inc.

Pilgrim Station 600 Rocky Hill Road Plymouth, Massachusetts 02360 RE:

OPERATING PERMIT-APPROVAL REVOCATION-Source Number: 1200163 Application Number: 4V95061 Transmittal Number: 108018 OPERATING PERMIT RENEWAL APPLICATION TERMINATION Application Number 4V02035 Transmittal Number W031836 AT:

Entergy Nuclear Operations, Inc.

Pilgrim Station 600 Rocky Hill Road Plymouth, MA 02360

Dear Mr. Bethay:

The Department of Environmental Protection, Bureau of Waste Prevention, is in receipt of your letter dated June 1, 2005, concerning the Operating Permit (Application No. 4V95061, Transmittal Number 108018) issued by the Department on April 23, 2003, to Entergy Nuclear Operations, Inc., Pilgrim Station, located at 600 Rocky Hill Road, Plymouth, Massachusetts.

The June 1, 2005 letter, which included a BWP AQ Emissions Notification form, requested that Operating Permit Application No. 4V95061, Transmittal No. 108018, be rescinded upon processing of the 50% facility emission cap notification form.

This Information Is available In alternate format. Call Donald M. Gemes, ADA Coordinator at 617-SS&1057. TDD Service 00.298-2207.

DEP on the World Wide Web: http:l/lww.mass.gov/dep

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Printed on Recycled Paper

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Entergy Nuclear Operations, Inc.

07/19/05 REVOCATION Application No. 4V95061 07/19/05 TERMINATION Application No. 4V02035 Page 2 of 2 On July 18, 2005, the Department issued a letter acknowledging receipt of the BWP AQ Emissions Notification form submitted in accordance with 310 CMR 7.02(1 1). The July 18, 2005, 50% Facility Emission Cap Approval established annual emission limitations, on a rolling 12-month period, which restricts the facility to below OP applicability thresholds as stated in 310 CMR 7.00:

Appendix C(2)(a)1.

The Department herein notifies Entergy Nuclear Operations, Inc. that the Operating Permit (Application No. 4V95061, Transmittal Number 108018) issued by the Department on April 23, 2003, to Entergy Nuclear Operations, Inc. for the Pilgrim Station is rescinded. In addition, the Department review of the pending Operating Permit Renewal application (Application No.

4V02035, Transmittal No. W031836) is terminated.

Should you have any questions relative to this matter, please contact Charlie Kitson at the Regional Office at (508) 946-2733.

Very truly yours, K inkler, Chief Permit Section Bureau of Waste Prevention ecc:

Ida McDonnell, EPA Region 1 Karen Regas, DEP/BWP-Boston Yi Tian, DEP/BWP-Boston Gregg Hunt, DEP/BWP-SERO Laura Patriaca, DEP/BWP-SERO Charlie Kitson, DEP/BWP-SERO Mark Poudrier, DEP/BWP-SERO

310 CMR 7.02 - U Plan Approval And Emission Limitations Page 1 of 3 (11) U 50% or 25% Facility Emission Cap Notification.

(11)(a) General.

(11)(a)1. 310 CMR 7.02(11) is an alternative means for an owner or operator to establish an emission cap on a facility's federal potential to emit. An owner or operator complying with 310 CMR 7.02(11) will no longer be subject to the restrictions established in the facility's RES granted pursuant to 310 CMR 7.02(9), or the requirements pursuant to 310 CMR 7.00: Appendix C after the Department has returned to the owner or operator a copy of the processed notification form.

(11)(a)2. Failure to comply with the emission cap set forth at 310 CMR 7.02(11)(e) or (f) means that an owner or operator is subject to all previously applicable requirements, including but not limited to, 42 U.S.C. 7401, §112 (Title I), §501 (Title V) and 40 CFR 52.21, or 310 CMR 7.18 (only where applicability is determined by the facility's potential to emit), 310 CMR 7.19, 310 CMR 7.00: Appendix A and/or 310 CMR 7.00: Appendix C.

(11)(a)3. Applicability of § 112 (Title III) may be avoided pursuant to 310 CMR 7.02(11) only where the owner or operator complies with 310 CMR 7.02(11) prior to the first substantive requirement of the applicable MACT standard.

The first compliance date is defined as the date an owner or operator must comply with an emission limitation or other substantive regulatory requirement.

(11)(b) Duty to Comply. Operation under 310 CMR 7.02(11) does not relax or eliminate any emission limitation(s), or recordkeeping requirement(s) established by regulation or previously issued source specific plan approval(s) or emission control plan(s). Annual emission limitations established by regulation or source specific plan approval or emission control plan, may not be less stringent than the emission limitations established at 310 CMR 7.02(1 1)(e) and (f).

(11)(c) Plan Approval. Notwithstanding 310 CMR 7.02(1 1)(a), an owner or operator is subject to preconstruction, plan approval pursuant to 310 CMR 7.02(1) for future construction, substantial reconstruction or alteration at the facility.

(11)(d) Application Requirements. An owner or operator relecting to comply with 310 CMR 7.02(11) shall notify the Department on forms provided by the Department, of his/her intentions to operate under one of the emission caps established at 310 CMR 7.02(11)(e) or (f), and that the facility's actual emissions in the prior calendar year were equal to or less than the emission cap. This facility wide emission cap shall remain in effect until the owner or operator notifies the Department.

(11)(e) 50% Cap Requirements. For owners or operators electing 50% emission cap, in every 12-month period (rolling 12-month), the potential and actual emissions of the facility shall be less than or equal to the following limitations:

(11)(e)1. 25 tons per year of VOC or NOx, or 50 tons per year of any other regulated air pollutant; (11)(e)2. 5 tons per year of a single HAP; (11)(e)3. 12.5 tons per year of any combination of HAPs; and (11)(e)4. 50% of any lesser threshold for a single HAP that the EPA may establish by rule.

(11)(f) 25% Cap Requirements. For owners or operators electing 25% emission cap, in every, 12-month period (roiling 12-month), the potential and actual emissions of the facility shall be less than or equal to the following limitations:

(11)(fO1. 15 tons per year of VOC or NOx, or 25 tons per year of any other regulated air pollutant; (11)(f)2. 2.5 tons per year of a single HAP; http://www.regscan.con/cgi-bin/rsget.cgi?db=maenvr&doc=007400LM.HTM 4/12/2006

310 CNM 7.02 - U Plan Approval And Emission Limitations Page 2 of 3 (11)(f)3. 6.25 tons per year of any combination of HAPs, and (11)(f)4. 25% of any lesser threshold for a single HAP that the EPA may establish by rule.

(11)(g) Eligible Restrictions. The owner or operator may take into account the operation of air pollution control equipment when calculating the facility's potential emissions, if the equipment is required by Federal or State regulations, or operated in accordance with 310 CMR 7.02(1) or 7.03, or an emission control plan issued pursuant to 310 CMR 7.18 or 310 CMR 7.19.

(11)(h) Record Keeping. The owner or operator electing to operate under one of the emission caps established at 310 CMR 7.02(11)(e) or (f), shall establish and maintain records of actual emissions. Such information shall be summarized in a monthly log, maintained on site for five years, be made available to the Department or EPA staff upon request, and contain the following items where applicable:

(11)(h)1. Coating or Solvent Usage.

(11)(h)1.a. A list of process related coatings, solvents, inks and adhesives in use. This list shall include: information on the VOC and HAPs content in lbs per gallon as applied; (11)(h)1.b. A description of production equipment including type, make and model; maximum design process rate or throughput; control device(s) type and description (if any); and a description of the coating/solvent application/drying method(s) employed; (11)(h)1.c. A monthly log of the gallons consumed of each production solvent (including solvents used in clean-up and surface preparation), coating, ink and adhesive used; (11)(h)1.d. All purchase orders, invoices, and other documents to support information in the monthly log; and (11)(h)1.e. The emissions of VOC from any coating used in small amounts are exempt from the emission limitations provided the amount of all coatings exempted does not exceed 55 gallons on a rolling 12 month period. A list of coatings used in small amounts shall be established and records of the consumption of these coatings shall be maintained.

(11)(h)2. Organic Liquid Storage.

(11)(h)2.a. A monthly log identifying the liquid stored and monthly throughput; (11)(h)2.b. Information on the tank design and specifications including control equipment; and (11)(h)2.c. The emissions of VOC from any coating used in small amounts are exempt from the emission limitations provided the amount of all coatings exempted does not exceed 55 gallons on a rolling 12 month period. A list of coatings used in small amounts shall be established and records of the consumption of these coatings shall be maintained.

(11)(h)3. Fuel Utilization Facility.

(11)(h)3.a. Information on equipment type, make and model, maximum power input/output, minimum operating temperature and capacity, control equipment and all source test information; (11)(h)3.b. A monthly log of hours of operation, fuel type, fuel usage in gallons or tons as appropriate, fuel heating value, percent sulfur for fuel oil and coal; and http://www.regscan.com/cgi-bin/rsget.cgi?db=maenvr&doc=007400LM.HTM 4/12/2006

310 CMR 7.02 -U Plan Approval And Emission Limitations

,,0 Page 3 of 3 (11)(h)3.c. All purchase orders, invoices, and other documents to support information in the monthly log.

(11)(h)4. Air Pollution Control Equipment.

(11)(h)4.a. Information on equipment type and description, make and model, and emission units served by the control unit:

(11)(h)4.b. Information on equipment design including where applicable: pollutants(s) controlled; control effectiveness; maximum design or rated capacity; inlet and outlet temperatures, and concentrations for each pollutant controlled; catalyst data (type, material, life, volume, space velocity, ammonia injection rate and temperature);

baghouse data (design, cleaning method, fabric material, flow rate, air/cloth ratio); electrostatic precipitator data (number of fields, cleaning method, and power input); scrubber data (type, design, sorbent type, pressure drop); other design data as appropriate; all source test information; and (11)(h)4.c. A monthly log of hours of operation including notation of any control equipment breakdowns, upsets, repairs, maintenance and any other deviations from design parameters.

(11)(h)5. Not Otherwise Classified Process.

(11)(h)5.a. Information on the process and equipment including the following: equipment type, description, make and model, maximum design process rate or throughput, control device(s) type and description (if any);

(11)(h)5.b. Any additional information requested in writing by the Department; (11)(h)5.c. A monthly log of operating hours, each raw material used and its amount; and (11)(h)5.d. Purchase orders, invoices, and other documents to support information in the monthly log.

(11)(h)5.d.(i) Reporting. In order to document compliance and maintain an emissions inventory, the Department may require reporting from any owner or operator of a facility with an emissions cap established at 310 CMR 7:02(1 1)(e) or (f).

[MR 1035, Effective 9/23/05; MR 1038, Effective 11/4/05]

RegScan Citation: MAR3IO_7_02 02006 RegScan, Inc.

http://www.regscan.coni/cgi-bin/rsget.cgi?db=maenvr&doc=007400LM.HTM 4/12/2006