ML22054A188
| ML22054A188 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 02/23/2022 |
| From: | State of SC, Dept of Health & Environmental Control |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML22054A185 | List: |
| References | |
| SOP-1900-0050 | |
| Download: ML22054A188 (12) | |
Text
STATEMENT OF BASIS Page 1 of 12 BAQ Air Permitting Division Company Name:
Permit Number:
Westinghouse Electric Company LLC SOP-1900-0050 Permit Writer:
Date:
Austin Goode DRAFT DATE APPLICATION RECEIVED:
December 4, 2017; Updated May 30, 2019 DATE OF LAST INSPECTION:
August 29, 2017 - No violations of permit conditions or applicable regulations were observed during the inspection.
FACILITY DESCRIPTION Westinghouse Electric Company LLC fabricates nuclear fuel assemblies containing low-enriched (<5% U-235) uranium oxide fuel for use in commercial light-water nuclear powered reactors.
PROJECT DESCRIPTION The facility requested the renewal of their state operating permit. Additionally, c/p-CD is being incorporated.
Construction Permit CD was for the replacement of the scrubber 1030 shell.
A temporary Boiler was installed at the facility on February 2nd, 2018 and was planned to be on site until new permanent Boilers were installed. Temporary Boilers are exempt from permitting as long as the equipment is on site for less than 1 calendar year. The temporary Boiler exceeded this 1-year limit for exemption from permitting and has been introduced to the permit as part of this project.
The scrubbers have historically been considered inherent to the process and listed as pieces of equipment.
Westinghouse submitted a justification for the inherency of the scrubbers, with the exception of plating room scrubber S-4025, which was determined to not be inherent, based on EPAs most recent guidance (Merit Energy Letter). The Department has reviewed the justification and concurs with the conclusion.
As part of this renewal, the Emission Unit and Equipment IDs have been changed and organized to better reflect operations at the facility. All of the equipment in the previous permit was listed with its own Emission Unit ID. As part of this renewal, operations at the facility have been grouped into six separate Emission Unit IDs (EU 01 and EU-22-26) to more clearly illustrate closely related equipment. The previous Emission Unit IDs 02-21 have been marked VOID.
This is not due to the equipment being removed from the facility but is a result of the reorganization of existing equipment; with the exception of the emergency generators (Emission Unit IDs 05-08) which were previously removed from the permit due to them being considered exempt equipment.
The following table maps the previous Emission Unit IDs, emission unit description, and the new Emission Unit ID.
Previous Emission Unit ID Previous Emission Unit Description New Emission Unit Description New Emission Unit ID 01 2.51 million Btu/hr natural gas fired Industrial Incinerator Incinerator 01 04 8.3 million Btu/hr natural gas/No. 2 fuel oil fired Boiler Boilers 22 09 Calciner #1: A 0.57 million Btu/hr natural gas fired North American Model NA-4424-0 Conversion 24 10 Calciner #2: A 0.57 million Btu/hr natural gas fired North American Model NA-4424-0
STATEMENT OF BASIS Page 2 of 12 BAQ Air Permitting Division Company Name:
Permit Number:
Westinghouse Electric Company LLC SOP-1900-0050 Permit Writer:
Date:
Austin Goode DRAFT Previous Emission Unit ID Previous Emission Unit Description New Emission Unit Description New Emission Unit ID 11 Calciner #3: A 0.57 million Btu/hr natural gas fired North American Model NA-4424-0 12 Calciner #4: A 0.57 million Btu/hr natural gas fired North American Model NA-4424-0 13 Calciner #5: A 0.57 million Btu/hr natural gas fired North American Model NA-4424-0 14 Conversion System #1. Includes a ammonium diuranate high energy venture cyclone (Heil 724) and HEPA filters 15,16 ADU Scrap Recovery & ADU On-Line Scrubber S-1030 System (A & B). Includes KCH-Hedron V packed tower scrubber and HEPA filter 17 Ammonia Fume Scrubber. Includes KCH-Phaser IV packed tower scrubber with HEPA filters 18 ADU/Waste Recovery Waterglass Scrubber Exhaust. Includes KCH Hedron-packed tower scrubber Waterglass 25 19 Plating Room Scrubber Exhaust. Includes Heil 760 packed horizontal baffle scrubber Plating 23 20 Uranium Recovery/Solvent Extraction.
Includes Harrington horizontal packed baffle venture scrubber with cyclone scrubber and HEPA filters Solvent Extraction 26 In the previous permit, there was no difference between the Emission Unit IDs and the Equipment IDs of sources at the facility. As part of this permit, each of these sources has been assigned a new Equipment ID as part of the reorganization of the permit. In the previous permit, for some processes, only the final equipment (i.e., exhausts to the atmosphere) was listed, instead of the whole process. Because all equipment is listed on this renewal, there are some sources which did not appear on previous permits; although, no new sources have been added.
Previous Equipment ID Equipment Description New Equipment ID Emission Unit ID 21 - Incinerator 01 2.51 Million BTU/hr natural gas fired Incinerator 01-1 Emission Unit 22 - Boilers 04 8.3 Million BTU/hr natural gas / No. 2 fuel oil fired Boiler 22-1 Emission Unit 23 - Plating Plating Tanks 23-1 Emission Unit 24 - Conversion
STATEMENT OF BASIS Page 3 of 12 BAQ Air Permitting Division Company Name:
Permit Number:
Westinghouse Electric Company LLC SOP-1900-0050 Permit Writer:
Date:
Austin Goode DRAFT Previous Equipment ID Equipment Description New Equipment ID 09 0.57 Million BTU/hr Natural gas fired Calciner #1 24-1 10 0.57 Million BTU/hr Natural gas fired Calciner #2 24-2 11 0.57 Million BTU/hr Natural gas fired Calciner #3 24-3 12 0.57 Million BTU/hr Natural gas fired Calciner #4 24-4 13 0.57 Million BTU/hr Natural gas fired Calciner #5 24-5 Conversion Area 24-6 15,16 ADU Scrap Recovery & ADU On-Line Scrubber System.
Includes KCH-Hedron V packed tower scrubber and divergent HEPA filter houses S-1030 Non-ammonia service vessels, URRS, and Solvent Extraction (SOLX) 24-7 14 Conversion system that includes two ammonium diuranate high energy venture cyclones (Heil 724) operating in parallel and divergent HEPA filter houses S-2A, S-2B Ammonia Fume Ventilation System 24-8 17 Ammonia Fume Scrubber S-1008 Emission Unit 25 - Waterglass Ammonium Hydroxide Storage Tanks 25-1 (2) Ammonia Stills 25-1 Waterglass Process 25-1 18 Waterglass (ADU Waste Recovery) Scrubber Exhaust. Includes KCH-Hedron packed tower scrubber S-1190 Emission Unit 26 - Solvent Extraction Safe Geometry Dissolver Process 26-1 20 Solvent Extraction Scrubber S-958 This operating permit renewal also includes the rollover of construction permit 1900-0050-CD. This construction permit involved the modification of scrubber S-1030. The scrubber body was replaced as the current body was reaching the end of its operational life. Changes made to the body of the scrubber are not expected to impact emissions estimates from the source.
CHANGES SINCE LAST OP ISSUANCE A construction permit (c/p-CC) has been issued to replace the three existing boilers (Previous Equipment IDs 02, 03, and 04) with two new 24.5 MMBTU/hr Boilers. This construction permit has not yet been rolled in. Once the new Boilers are in place and operational, the facility should submit an application to modify their operating permit.
Equipment IDs 02 and 03 (Boilers #1 and #2) have been removed from the facility and will not be included in the renewed permit.
Since 2007, there have been several minor modifications to sources listed in this permit and exempt sources at the facility. The following table details these changes.
STATEMENT OF BASIS Page 4 of 12 BAQ Air Permitting Division Company Name:
Permit Number:
Westinghouse Electric Company LLC SOP-1900-0050 Permit Writer:
Date:
Austin Goode DRAFT Date of Change Equipment /
Control Device ID Description 2007 S-1008 Replacement of existing S-1008 system with a new KCH 4300 ft3/min system; Removal of old heater and replacement with in-line heater Replacement of 14 ductwork with 18 ductwork on discharge side of scrubber 2008 S-1008 Installation of a vacuum break for each Q-tank to prevent back flow into the scrubber 2008 S-1190 Refurbishment of existing scrubber Installation of more efficient spray nozzles Installation of an access door for packing Addition of an extra Mist Eliminator 2008 S-1030 Relocation of scrap cage filter press from roof filter system 7A to S-1030 2008 S-1030 Installation of Double Demister 2009 S-1030 Removal of a manual block valve and automatic control valve for addition of ammonia for pH adjustment 2009 S-2A/S-2B Replacement of filters houses 1A and 1B with new filter houses consisting of pre-filters, intermediate filters, and HEPA filters with the same efficiency of filters being replaced.
2012 S-4025 Installation of a new hood over plating room hot rinse tank which ties into scrubber S-4025 2013 S-2A/S-2B Replacement of 3 banks of cartridge filter housings with 3 banks of bag filter housings 2013 S-1190 Mechanical replacement of scrubber with similar unit.
2014 S-1190 Decrease of fan rotational speed to operate in a more stable area of equipment performance curve. Adjustment will have no effect on flow rate or scrubber ventilation performance.
2/11/2016 S-4025 Like for Like replacement of the Plating Room Scrubber 9/7/2016 S-1030 Continuous bleed off Transition of spray nozzles to inlet Continuous pH monitoring & future control capability Installation of internal packing baskets 11/30/2016 S-1030 Redirection of ventilation ducts on the sifters from S-2010 to FL-150 Torit 11/15/2016 S-958 Air gap added to process water supply for S-958 1/9/2017 S-1030 Changed impeller on pump 1030A and 1030B from 11.625 to 13 SOURCE TEST/EMISSION STUDIES REQUIREMENTS The facility will conduct the following source tests for compliance.
STATEMENT OF BASIS Page 5 of 12 BAQ Air Permitting Division Company Name:
Permit Number:
Westinghouse Electric Company LLC SOP-1900-0050 Permit Writer:
Date:
Austin Goode DRAFT SOURCE TESTS Source Pollutant Frequency Regulation Incinerator (01)
PM Initial: 180 days; Every 2 years thereafter, unless an alternative method is approved Std. 3,Section VIII Incinerator (01)
SO2, NOx, CO, VOCs Initial: 180 days; subsequent periodic testing may be required 62.1,Section II.J.2 (Demonstrate actual emissions are below estimates)
S-4025 HF, HNO3, HCl, H2SO4, Nickel,
- Cadmium, Phosphorus Initial: 180 days; subsequent periodic testing may be required 62.1,Section II.J.2 (Demonstrate actual emissions are below estimates)
S-10301, S-2A/S-2B, S-1008, S-1190, S-958 HF, NOX, HNO3 Initial: 180 days; subsequent periodic testing may be required 62.1,Section II.J.2 (Demonstrate actual emissions are below estimates) 1Scrubber S-1030 had initial testing required in c/p-CD. Will not have to repeat for OP renewal if already conducted.
SPECIAL CONDITIONS In previous operating permits, the facility was not required to monitor operational parameters. Parametric monitoring is being established with this permit.
EMISSIONS As part of this renewal, an engineering study was performed on the scrubbers to help in the estimation of emission rates. To account for natural variance in emissions, safety factors were used when determining potential emissions.
With the issuance of this permit, the facility will be required to conduct source testing to verify actual emission rates are below the potential emission rates. Below is a table of sources and pollutants whose emissions were subject to a safety factor.
Source Pollutant Safety Factor (Emissions Test Result Multiplied by X)
S-4025 Scrubber Antimony 5
Arsenic Beryllium Cadmium Chromium Cobalt Manganese Nickel Phosphorus Selenium
STATEMENT OF BASIS Page 6 of 12 BAQ Air Permitting Division Company Name:
Permit Number:
Westinghouse Electric Company LLC SOP-1900-0050 Permit Writer:
Date:
Austin Goode DRAFT Source Pollutant Safety Factor (Emissions Test Result Multiplied by X)
Hydrogen Flouride Nitric Acid Hydrochloric Acid Sulfuric Acid Lead S-1030 Scrubber Hydrogen Flouride 5
Nitric Acid 5
NOX 3
S-958 Scrubber Hydrogen Flouride 5
Nitric Acid NOX 2
S-1190 Scrubber Hydrogen Flouride 5
Nitric Acid S-2A/2B Scrubber Hydrogen Flouride 5
Nitric Acid S-1008 Scrubber Hydrogen Flouride 5
Nitric Acid The incinerators at nuclear facilities such as Westinghouse are unique designs. Emissions were estimated using AP-42 emission factors from Chapter 2.1 - Refuse Combustion, Table 2.1-12, Uncontrolled Emission Factors for Refuse Combustors, Industrial/Commercial Multiple Chamber Combustors.
FACILITY WIDE EMISSIONS Pollutant Uncontrolled Controlled PTE TPY TPY TPY PM 9.627 9.627 PM10 9.627 9.627 PM2.5 9.216 9.216 SO2 3.106 3.106 NOX 50.475 50.475 CO 25.233 25.233 VOC 4.268 4.268 Pb 4.4E-04 4.4E-04 HNO3 (T) (CAS #: 7697-37-2) 2.57 2.57 HF (H) (CAS #: 7664-39-3) 0.304 0.304 HCl (H)(T) (CAS #: 7647-01-0) 0.395 0.395 H2SO4 (T) (CAS #: 7664-93-9) 0.624 0.624 Highest Single HAP Perchloroethylene (H)(T)
(CAS #: 127-18-4) 3.72 3.72
STATEMENT OF BASIS Page 7 of 12 BAQ Air Permitting Division Company Name:
Permit Number:
Westinghouse Electric Company LLC SOP-1900-0050 Permit Writer:
Date:
Austin Goode DRAFT FACILITY WIDE EMISSIONS Pollutant Uncontrolled Controlled PTE TPY TPY TPY Hexane (H)(T)(V)(CAS #110-54-3) 0.38 0.38 Arsenic (T) (CAS #: 7440-38-2) 4.63E-03 4.63E-03 Cadmium (T) (CAS #: 7440-43-9) 2.97E-05 2.97E-05 Chromium (T) (CAS #: 7440-47-3) 3.29E-05 3.29E-05 Mercury (T) (CAS #: 7439-97-6) 2.41E-03 2.41E-03 Nickel (T) (CAS #: 7440-02-0) 5.65E-05 5.65E-05 Lead (CAS # 7439-92-1) 2.86E-04 2.86E-04 Tetrachlorinated dibenzo-p-dioxin (H)(T)(V)
(CAS # 1746-01-6) 6.82E-08 6.82E-08 Total HAP Emissions 4.18 4.18 1Ammonia is neither a Hazardous Air Pollutant under federal regulations, nor a Toxic Air Pollutant under state regulations. It is listed here for information purposes only.
OPERATING PERMIT STATUS This facility operates under State Minor Source Operating Permit 1900-0050; issued on March 5, 2008; effective on March 5, 2008; expired on February 28, 2018. The renewal request was received December 4, 2017. Westinghouse may continue operation, under the terms and conditions of the expired permit, until such time as the renewal request is acted upon.
RADIONUCLIDES Some of the scrubbers have HEPA filters on their exhaust. These are present for control of radionuclides and not particulate matter. Non-radionuclide PM is not expected from the scrubber exhaust.
EPA does not currently have any, Clean Air Act, regulations on the release of radionuclides to the ambient air from facilities licensed by the Nuclear Regulatory Commission; although radionuclides are listed as a Hazardous Air Pollutant under Section 112 of the Clean Air Act.
NESHAPS (Part 61): The 1990 amendments allowed EPA to eliminate regulatory duplication with the NRC where the EPA can determine that the NRC program provides protection of the public health equivalent to that required by the CAA. Regarding this type of facility, other than commercial nuclear reactors, EPA rescinded the Part 61 NESHAP requirements for radionuclides in a final rule published in the 12/30/96 Federal Register. For a full explanation and history, see 61 FR 68972.
Title V: Radionuclides are excluded from the 10/25 TPY definition of major source under Title V (SC Regulation 61-62.70.1(r); equiv. 40 CFR 70.2). Instead, the regulation states that for radionuclides, major source shall have the meaning specified by the Administrator by rule. As verified with EPAs regional permitting contact, to date, EPA has not promulgated a major source definition for radionuclides.
NESHAPS (Part 63): The definition of major source in Part 63 has an exclusion from 10/25 for radionuclides, similar to Title V. See §63.2.
STATEMENT OF BASIS Page 8 of 12 BAQ Air Permitting Division Company Name:
Permit Number:
Westinghouse Electric Company LLC SOP-1900-0050 Permit Writer:
Date:
Austin Goode DRAFT REGULATORY APPLICABILITY REVIEW Regulations Comments/Periodic Monitoring RequirementsSection II.E - Synthetic Minor Not applicable. The facility does not have any synthetic minor limits and has not requested any limits as part of this renewal.
Standard No. 1 Applicable. The Boiler at this facility (Equipment ID 04) and the five Calciners (Equipment ID 24-1 through 24-5; combustion exhaust) are fuel burning sources subject to this standard. This standard will apply opacity, PM, and SO2 emission limitations.
There will be a 20% limit to opacity from these sources at all times except for periods of sootblowing. During periods of sootblowing, the 20% limit can be exceeded, but for no more than 6 minutes in a one hour period or 24 minutes in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. During these periods, the opacity limitation will be 60%.
Please see the Standard No. 1 Allowable table below. No monitoring is necessary.
Standard No. 3 (state only)
Applicable. Although used for material recovery, the incinerator is not considered a furnace as the material that it is recovering does not undergoing any type of reaction; unlike the other named furnace sources (cement kilns, lime kilns, etc.).
The material is recovered by the reduction and destruction of the other, combustible material.
The on-site Incinerator (EQP 01) will burn combustible materials from other processes and will be subject to this standard. This source will be subject to a 20%
opacity limitation, as well as a 0.5 lb / Million BTU limit on PM emissions.
In accordance with Standard No. 3,Section VIII, periodic tests will be required to be performed on the industrial incinerator. These tests will be scheduled every two years.
This regulation also requires training for all Incinerator Operators as outlined in Section IX.C of this standard. Previously, the facility was required to maintain the content of the training program and a list of trained personnel on site and made available upon request. This information will be required to be submitted to the Department within 30 days of the issuance of the permit.
A condition was added to the permit specifying the type of materials that may be combusted, and explicitly excluding waste classified as hazardous.
Standard No. 4 Applicable. Emission Units 23-26 are subject to a 20% Opacity limitation because the equipment or associated control devices have been modified or replaced since December 31, 1985.
STATEMENT OF BASIS Page 9 of 12 BAQ Air Permitting Division Company Name:
Permit Number:
Westinghouse Electric Company LLC SOP-1900-0050 Permit Writer:
Date:
Austin Goode DRAFT REGULATORY APPLICABILITY REVIEW Regulations Comments/Periodic Monitoring Requirements For Emission Unit 24, only the process emissions portion is submit to this standard. Emission Units 23, 24, 25, and 26 do not produce PM emissions. As such, there will be no associated PM emission limit for these sources.
In the previous permit, the opacity limits stemming from Standard 4 regulation varied between pieces of equipment. However, as all of the equipment exhausts through a scrubber system and all of the scrubber systems have been modified since 1985, all equipment is now subject to the 20% opacity limit.
Standard No. 5 Not applicable. This facility has VOC emissions, but the facility is not one of the listed subject source categories.
Standard No. 5.2 Not applicable. The combustion sources at this facility were constructed prior to the effective date of this regulation and none of those sources have been re-located or had their burner assemblies replaced since the effective date of this Standard.
Standard No. 7 Not applicable. This facility does not meet the definition of a major source.
61-62.6 Not applicable. Facility does not produce fugitive dust emissions.
40 CFR 60 and 61-62.60 Applicable.
Subpart Dc - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units: Not applicable. This standard applies to steam generating units for which construction, modification, or reconstruction was commenced after June 9, 1989. The Boiler #3 (Equip ID 22-1) was constructed in 1975 and has not been modified after the effective date of this regulation.
Subpart E - Standards of Performance for Incinerators: Not applicable. The loading rate for this incinerator is below the 50 tons/day applicability threshold.
Subpart G - Standards of Performance for Nitric Acid Plants: Not applicable.
This standard applies to facilities which contain a nitric acid production unit. A nitric acid production unit is defined as any facility producing weak nitric acid. This facility uses and emits nitric acid as part of their process but does not produce the nitric acid being emitted.
Subpart Ga - Standards of performance for Nitric Acid Plants for which Construction, Reconstruction, or Modification commenced after October 14, 2011: Not applicable. This standard applies to facilities which contain a nitric acid production unit. A nitric acid production unit is defined as any facility producing weak nitric acid. This facility uses and emits nitric acid as part of their process but does not produce the nitric acid being emitted.
Subpart UUU - Standards of Performance for Calciners and Dryers in Mineral Industries: Not applicable. This standard applies to calciners and dryers at a
STATEMENT OF BASIS Page 10 of 12 BAQ Air Permitting Division Company Name:
Permit Number:
Westinghouse Electric Company LLC SOP-1900-0050 Permit Writer:
Date:
Austin Goode DRAFT REGULATORY APPLICABILITY REVIEW Regulations Comments/Periodic Monitoring Requirements Mineral Processing Plant. This facility does not meet the definition of a Mineral Processing Plant because it does not process or produce any of the listed materials in the definition for such a plant.
Subpart CCCC - Standards of Performance for Commercial and Industrial Solid Waste Incineration Units: Not applicable. The Incinerator at this facility was constructed in 1973 and was last modified in 2018. However, the incinerator combusts waste for the primary purpose of recovering metals (Uranium). Because of this, it meets the definition of a materials recovery unit and is exempt from the requirements of this subpart.
Subpart DDDD - Emissions Guidelines and Compliance Times for Commercial and Industrial Solid Waste Incineration Units: Not applicable. This facility does not meet the definition of a solid waste incineration unit. The on-site incinerator (Equipment ID 01) combusts waste for the primary purpose of recovering metals (Uranium). This means the unit is considered a materials recovery unit and is not included in the definition of Solid Waste Incineration Unit.
Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines: Applicable. This standard applies to facilities which operate stationary compression ignition internal combustion engines. The facility operates eight (8) Emergency Generators on site. Seven of these generators were installed prior to June 12, 2006, and are not subject to this standard. One (1) 50 kW Emergency Generator was installed in 2011 and will be subject to the requirements of this standard.
40 CFR 61 and 61-62.61 Not applicable. The facility is not one of the listed subject source categories.
Subpart I - National Emission Standards for Radionuclide Emissions from Federal Facilities other than Nuclear Regulatory Commission Licensees and not covered by Subpart H: Not applicable. This subpart applies to facilities owned or operated by any Federal agency other than the Department of Energy and not licensed by the Nuclear Regulatory commission. This facility is not owned or operated by a Federal Agency.
STATEMENT OF BASIS Page 11 of 12 BAQ Air Permitting Division Company Name:
Permit Number:
Westinghouse Electric Company LLC SOP-1900-0050 Permit Writer:
Date:
Austin Goode DRAFT REGULATORY APPLICABILITY REVIEW Regulations Comments/Periodic Monitoring Requirements 40 CFR 63 and 61-62.63 Applicable.
Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines: Applicable. This standard applies to facilities which operate a stationary reciprocating internal combustion engine. The facility operates eight (8) Emergency Generators on site.
Subpart JJJJJJ - National Emission Standards For Hazardous Air Pollutants For Industrial, Commercial, and Institutional Boilers Area Sources: Not applicable. Boilers at this facility are not subject to this subpart because they meet the definition of a gas fired boiler, as defined in this subpart, as they only burn No. 2 fuel oil during periods of natural gas curtailment. A condition addressing potential applicability should operations at the facility exceed the established No. 2 Fuel Oil testing allowances is included in the permit.
61-62.68 Applicable. This facility stores subject chemicals (aqueous ammonia above 20%
conc.) above the threshold quantities. A Risk Management Plan was submitted to the US EPA on June 18, 1999 and was approved on July 2nd, 1999.
40 CFR 64 (CAM)
Not applicable. The facility does not meet the definition of a major source.
Standard No. 1 Allowable Equipment ID PM Allowable (lb/hr)
SO2 Allowable (lb/hr)
Uncontrolled Emissions Controlled Emissions PM (lb/hr)
SO2 (lb/hr)
PM (lb/hr)
SO2 (lb/hr)
Emission Unit ID 22 - Boilers 22-1 4.98 19.09 0.3441 7.41 22-2 8.718 33.419 0.191 0.015 Emission Unit ID 24 - Conversion 24-1 0.342 1.311 4.2E-03 3.0E-04 24-2 0.342 1.311 4.2E-03 3.0E-04 24-3 0.342 1.311 4.2E-03 3.0E-04 24-4 0.342 1.311 4.2E-03 3.0E-04 24-5 0.342 1.311 4.2E-03 3.0E-04 AMBIENT AIR STANDARDS REVIEW Regulations Comments/Periodic Monitoring Requirements Standard No. 2 Applicable. Facility has demonstrated compliance through modeling. See modeling summary dated July 11, 2019.
Standard No. 7.c Not applicable. Not applicable. Facility does not meet the definition of a major source.
Standard No. 8 (state only)
Applicable. Facility has demonstrated compliance through modeling. See modeling summary dated July 11, 2019.
STATEMENT OF BASIS Page 12 of 12 BAQ Air Permitting Division Company Name:
Permit Number:
Westinghouse Electric Company LLC SOP-1900-0050 Permit Writer:
Date:
Austin Goode DRAFT PUBLIC NOTICE This State Operating Permit will undergo a 30-day public notice period in accordance with SC Regulation 61-62.1,Section II.N. This permit was placed in The State on September 12, 2019. The comment period was open from September 12, 2019 to October 11, 2019 and was placed on the BAQ website during that time period.
SUMMARY
AND CONCLUSIONS It has been determined that this source, if operated in accordance with the submitted application, will meet all applicable requirements and emission standards.