ML24331A070

BWXT Nuclear Operations Group, Inc., State Air Permit Modification

ML24331A070
Person / Time
Site:	BWX Technologies
Issue date:	11/21/2024
From:	Freudenberger R BWXT
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
24-068
Download: ML24331A070 (1)

Text

BWX Technologies, Inc.

November 21, 2024 24-068 ATTN: Document Control Desk Director, Office of Nuclear Material Safety & Safeguards U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

License No. SNM-42, Docket 70-27

Subject:

State Air Permit Modification

Dear Sir or Madam:

In accordance with Chapter 1, General Information, Section 1.5.9 of the SNM-42 License Application, BWXT Nuclear Operations Group, Inc. Lynchburg (BWXT NOG-L) is required to inform the Nuclear Regulatory Commission (NRC) when the state permitting agency issues violations or modifies the requirements of the State issued National Pollution Discharge Elimination System (NPDES) permit or air quality permit. As a result of a permit modification, an updated air permit was recently issued to BWXT NOG-L. A copy of the permit, which was received by BWXT NOG-L on November 6, 2024, is included as an enclosure to this letter.

If you have questions or require additional information, please contact Daniel Ashworth, Manager of Licensing and Safety Analysis, at dlashworth@bwxt.com or 434-522-5472 Sincerely,

-:::::!t.~

Manager, Environment, Safety, Health & Safeguards BWXT Nuclear Operations Group, Inc. - Lynchburg Enclosure cc:

NRC, James Downs, Sr. Project Inspector NRC, Region II NRC, Resident Inspector BWXT Nuclear Operations Group, Inc PO Box 785 Lynchburg, VA 24505 USA t: + 1.434 522.6000 www.bwxt.com People Strong INNOVATION DRIVEN >

BWXT Nucle;:ir Operations Group, Inc.

P.O. Box 785 Lynchburg, VA 24505 USA t:

• 1.434.522.6000 www.bwxt.com ENCLOSURE People Strong INNOVATION DRIVEN >

Commonwealth of Virginia VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY Travis A. Voyles Secretary of Natural and Historic Resources Mr. James J. Bittner Vice President and General Manager BWXT Nuclear Operations Group, Inc.

P.O. Box 785 Lynchburg, VA 24505 j jbittner@bwxt.com

Dear Mr. Bittner:

www.deq.virginia.gov November 6, 2024 Michael S. Rolband, PE, PWD, PWS Emeritus Director Location: Campbell County Registration No.: 30260 Attached is a minor amendment to your new source review permit approval dated November 23, 2021 to construct and operate a nuclear component and fuel production facility in accordance with the provisions of the Virginia Regulations for the Control and Abatement of Air -Pollution.

Also attached is a minor amendment to your state operating permit dated November 23, 2021.

This amended permit document supersedes your combined minor NSR/Statc Operating permit document dated November 23, 2021.

The Department of Environmental Quality (DEQ) deemed the application complete on August 20, 2024 and has determined that the application meets the requirements of 9V AC5-80-1280 A, B and C for a minor amendment to a new source review permit and 9V AC5-80-980 A, B, and C for a minor amendment to a state operating permit.

This permit document contains legally enforceable conditions. Failure to comply may result in a Notice of Violation and/or civil charges. Please read all permit conditions carefully.

This pem1it approval to construct and operate shall not relieve BWXT Nuclear Operations Group, Inc. of the responsibility to comply with all other local, state, and federal permit regulations.

The Regulations as contained in Title 9 of the Virginia Administrative Code 5-170-200 provide that you may request a formal hearing from this case decision by filing a petition with the DEQ within 30 days after this case decision notice was mailed or delivered to you. Please consult the relevant regulations for additional requirements for such requests.

Mr. James J. Bittner November 6, 2024 Page 2 As provided by Rule 2A:2 of the Supreme Court of Virginia, you have 30 days from the date you actually received this permit or the date on which it was mailed to you, whichever occurred first, within which to initiate an appeal of this decision by filing a Notice of Appeal with:

Director Department of Environmental Quality P. 0. Box 1105 Richmond, VA 23218 If this permit was delivered to you by mail, three days are added to the thirty-day peri_od in which to file an appeal. Please refer to Part Two A of the Rules of the Supreme Court of Virginia for information on the required content of the Notice of Appeal and for additional requirements governing appeals from decisions of administrative agencies.

If you have any questions concerning this permit, please contact the Blue Ridge Regional Office at (540) 562-6700.

Sincerely, for Robert J. Weld, Regional Director Virginia Department of Environmental Quality 540-562-6870 robert. weld@deq. virginia. gov Blue Ridge Regional Office 901 Russell Drive, Salem, VA 540-562-6700

Attachment:

Permit cc:

Adam Dean, DEQ BRRO Air Permit Writer (electronic)

Nicole Wright, DEQ BRRO Air Compliance (electronic)

Margaret Wagner, DEQ BRRO Air Compliance Manager (electronic)

Todd Nash, BWXT Nuclear Operations Group, Inc., wtnash@bwxt.com

Commonwealth of Virginia VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY Travis A. Voyles Secretary of Natural and Historic Resources www.deq.virginia.gov Michael S. Rolband, PE, PWD, PWS Emeritus Director ST A TIO NARY SOURCE PERMIT TO CONSTRUCT AND OPERA TE STATIONARY SOURCE PERMIT TO OPERATE This permit document supersedes your permit document dated November 23, 2021.

In compliance with the Federal Clean Air Act and the Commonwealth of Virginia Regulations for the Control and Abatement of Air Pollution, BWXT Nuclear Operations Group Inc.

1570 Mt. Athos Road Lynchburg, VA 24504 Registration No.: 30260 is authorized to construct and operate located at two Vertical Tube Furnaces, one Centorr Finishing Furnace, and one TRISO Coating Furnace 1570 Mt. Athos Road, Lynchburg, VA 24504 in accordance with the Conditions of this permit document.

Approved on November 6, 2024.

for Robert J. Weld, Regional Director Blue Ridge Regional Office Virginia Department of Environmental Quality Permit consists of 13 pages.

Permit Conditions 1 to 40.

INTRODUCTION BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 Page 2 This permit document is based on and combines permit terms and conditions in accordance with 9VAC5-80-1255 from the following permit approvals and the respective permit applications:

State Operating Permit (SOP) amendment dated November 6, 2024 based on the permit application dated June 12, 2024, including supplemental information dated June 14, 2024, June 27, 2024, July 15, 2024, August 14, 2024, August 16, 2024, and August 20, 2024; Minor New Source Review (mNSR) amendment dated November 6, 2024 based on the permit application dated June 12, 2024, including supplemental information dated June 14, 2024, June 27, 2024, July 15, 2024, August 14, 2024, August 16, 2024, and August 20, 2024; State operating permit approval and minor new source review approval dated November 23, 2021, based on the permit application dated July 23, 2021.

State operating permit approval dated June 4, 2007 based on the applications dated March 22, 2007, and August 12, 2002, and including amendment information dated November 2, 2006, August 29, 2002, August 28, 2002, and September 11, 1995.

Any changes in the permit application specifications or any existing facilities which alter the impact of the facility on air quality may require a permit. Failure to obtain such a permit prior to construction may result in enforcement action. In addition, this facility may be subject to additional applicable requirements not listed in this permit document.

Words or tem1s used in this permit document shall have meanings as provided in 9VAC5-10-10 of the State Air Pollution Control Board Regulations for the Control and Abatement of Air Pollution. The regulatory reference or authority for each condition is listed in parentheses ()

after each condition. The enabling permit program, or permit programs is provided below each permit condition in the regulatory authority parenthetical as follows: 9V ACS-80-850 for Article 5, 9V AC5-80-l 180 for Article 6, 9V AC5-80-l 985 for Article 8, and 9V AC5-80-2050 for Article

9. The most recent effective date for a term or condition is listed in brackets [ ]. When identical conditions for one or more emission units are combined, the effective date listed in this permit does not alter the prior effective date(s) for any such conditions as issued in a previous permit action. In accordance with 9V AC5 l 120F, any condition not marked as state-only enforceable (SOE) is state and federally enforceable.

Annual requirements to fulfill legal obligations to maintain current stationary source emissions data will necessitate a prompt response by the permittee to requests by the Department of Environmental Quality (DEQ) for information to include, as appropriate: process and production data; changes in control equipment; and operating schedules. Such requests for information from the DEQ will either be in writing or by personal contact.

The availability of information submitted to the DEQ or the Board will be governed by applicable provisions of the Freedom of Information Act, §§ 2.2-3700 through 2.2-3714 of the

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 Page 3 Code of Virginia, § 10.1-1314 (addressing information provided to the DEQ) of the Code of Virginia, and 9VAC5-l 70-60 of the State Air Pollution Control Board Regulations. Information provided to federal officials is subject to appropriate federal law and regulations governing confidentiality of such information.

Equipment List - Equipment at this facility covered by this pern1it document consists of:

Permitted Equipment:

Reference No.

Equipment Description Rated Capacity Referenced Federal Requirements EU-12A-3A &

Two ThermCraft Vertical Tube Finishing EU-12A-3B Furnaces EU-13A-2 One Centorr Finishing Furnace 6 inch finishing EU-14A-11 TRISO Coating Furnace 4200 g/hr MTS Feed Specifications included in the above table is for informational purposes only and does not fonn enforceable terms or conditions of the permit.

PROCESS REQUIRMENTS I.

Emission Controls - HCl emissions from the two Vertical Tube Finishing Furnaces and Centorr Finishing Furnace (EU-12A-3A, EU-12A-3B, and EU-13A-2) shall be controlled by a packed column scrubber (PC-13A-5), adsorber (PC-13A-12), and a HEPA filter (PC-13A-3). The scrubber, adsorber, and filter shall be provided with adequate access for inspection and shall be in operation when the furnaces are operating.

(9V ACS-60-320 and 9VAC5-80-850) [June 4, 2007]

2.

Monitoring Devices - The scrubber (PC-13A-5) shall be equipped with devices to continuously measure the scrubber liquid flow rate and differential pressure drop across the scrubber. Each monitoring device shall be installed, maintained, calibrated and operated in accordance with approved procedures which shall include, as a minimum, the manufacturer's written requirements or recommendations. Each monitoring device shall be provided with adequate access for inspection and shall be in operation when the finishing furnaces are operating.

(9VAC5-80-l 180, 9VAC5-80-890, and 9VAC5-60-320) [June 4, 2007]

3.

Emission Controls - Hydrogen Chloride emissions from the TRISO Coating Furnace (EU-14A-11) shall be controlled by a Wet Scrubber (PC-14A-6) and Dry Scrubber (PC-14A-7).

The Wet Scrubber and Dry Scrubber shall be provided with adequate access for inspection and shall be in operation when the TRISO Coating Furnace is operating.

(9VAC5-80-850) [November 6, 2024]

4.

Control Efficiency -The Wet Scrubber (PC-14A-6) and Dry Scrubber (PC-14A-7) shall achieve a control efficiency for Hydrogen Chloride (HCl) of no less than 99.25 percent, to

be demonstrated by a DEQ-approved performance test.

(9VAC5-80-850) [November 6, 2024]

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 Page4

5.

Monitoring Devices -The Wet Scrubber (PC-14A-6) controlling the TRISO Coating Furnace (EU-14A-11) shall be equipped with devices to continuously measure the liquid flow rate and the differential pressure drop across the Wet Scrubber. The permittee shall establish a normal operating range for the flow rate and differential pressure drop across the Wet Scrubber, based on manufacturer's recommendations, developed from observations recorded from the monitoring devices during normal operation, performance test data and/or other DEQ approved methods.

(9V ACS-80-890) [November 23, 2021]

6.

Monitoring Devices - The Dry Scrubber (PC-14A-7) controlling the TRISO Coating Furnace (EU-14A-1 l) shall be equipped with devices to continuously measure the differential pressure drop across the Dry Scrubber. The pennittee shall establish a normal operating range for the differential pressure drop across the Dry Scrubber, based on manufacturer's recommendations, developed from observations recorded from the monitoring devices during normal operation, performance test data and/or other DEQ approved methods. The pern1ittee shall maintain written documentation of this range. Each monitoring device shall be provided with adequate access for inspection and shall be in operation when the Dry Scrubber is operating. The permittee shall also maintain records of the manufacturer's recommendations for filtration media replacement and records of actual filtration media replacement.

(9VAC5-80-850) [November 6, 2024]

7.

Monitoring Devices - The Dry Scrubber (PC-14A-7) controlling the TRI SO Coating Furnace (EU-14A-11) shall be equipped with devices to continuously measure the gas stream temperature across the Dry Scrubber. The permittee shall establish a normal operating range for the gas stream temperature across the Dry Scrubber, based on manufacturer's recommendations, developed from observations recorded from the monitoring devices during normal operation, performance test data and/or other DEQ approved methods. The permittee shall maintain written documentation of this range. Each monitoring device shall be installed, maintained, calibrated and operated in accordance with approved procedures which shall include, as a minimum, the manufacturer's written requirements or recommendations. Each monitoring device shall be provided with adequate access for inspection and shall be in operation when the Dry Scrubber is operating.

(9VAC5-80-850) [November 6, 2024]

8.

Monitoring Devices -The TRISO Coating Furnace (EU-14A-1 l) shall be operated as a closed system while flowing methyltrichlorosilane gas (MTS), with only Argon and Hydrogen gas being introduced to the furnace. The furnace shall be equipped with gas supply mass flow controllers on the Argon and Hydrogen gas that is being introduced into the furnace. The permittee shall establish a normal operating range for the combined gas flow rate (Argon plus Hydrogen) through the Dry Scrubber, based on manufacturer's recommendations, developed from observations recorded from the monitoring devices

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 Page 5 during nonnal operation, performance test data and/or other DEQ approved methods. The permittee shall maintain written documentation of this range. Each monitoring device shall be installed, maintained, calibrated and operated in accordance with approved procedures which shall include, as a minimum, the manufacturer's written requirements or recommendations. Each monitoring device shall be provided with adequate access for inspection and shall be in operation when the Dry Scrubber is operating.

(9VAC5-80-850) [November 6, 2024]

9.

Monitoring Device Observation - To ensure good performance, the control monitoring devices used to continuously measure the liquid flow rate and the differential pressure drop on the Wet Scrubber and the differential pressure drop across the Dry Scrubber shall be observed by the permittee with a frequency of not less than once per shift when the scrubbers are in operation. The permittee shall keep a log of the observations or continuously record measurements from the Wet Scrubber (PC-14A-6) and Dry Scrubber (PC-14A-7) controlling the TRISO Coating Furnace (EU-14A-11 ).

(9VAC5-80-890) [November 6, 2024]

10. Monitoring Device Observation - To ensure good performance, the monitoring devices used to continuously measure the gas stream temperature in the Dry Scrubber (PC-14A-7) shall be observed by the permittee with a frequency of not less than once per 15 minutes when the scrubber is in operation. The permittee shall keep a log of the observations or continuously record measurements from the Dry Scrubber (PC-14A-7) controlling the TRISO Coating Furnace (EU-14A-l l).

(9VAC5-80-890) [November 6, 2024]

11. Monitoring Device Observation - To ensure good performance, the control monitoring devices used to continuously measure the gas flow rate of Argon and Hydrogen through the furnace, and subsequently the Dry Scrubber (PC-14A-7), shall be observed by the permittee with a frequency of not less than once per shift when the scrubber is in operation. The permittee shall keep a log of the observations or continuously record measurements from the Dry Scrubber (PC-14A-7) controlling the TRISO Coating Furnace (EU-14A-l l).

(9VAC5-80-890) [November 6, 2024]

OPERA TING LIMITS

12. Throughput - The throughput of methyltrichlorosilane (MTS) fed to the TRISO Coating Furnace (EU-14A-11) shall not exceed 2,400 grams/hr calculated monthly as the sum of each consecutive 12-month period. Compliance for the consecutive 12-month period shall be demonstrated monthly by adding the total for the most recently completed calendar month to the individual monthly totals for the preceding 11 months.

(9VAC5-80-850) [November 23, 2021]

EMISSION LIMITS BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 Page 6

13. Process Emission Limits - Emissions from the operation of each of the two Vertical Tube Finishing Furnaces (EU-12A-3A and EU-12A-3B) shall not exceed the limits specified below:

Hydrogen Chloride 0.01 lbs/hr (each)

(9VAC5-80-1180 and 9VAC5-80-850) [June 4, 2007]

14. Process Emission Limits - Emissions from the operation of the Centorr Finishing Furnace (EU-13A-2) shall not exceed the limits specified below:

Hydrogen Chloride 0.05 lbs/hr (9V AC5-80-1180 and 9V AC5-80-850) [June 4, 2007]

15. Process Emission Limits - Emissions from the operation of the TRISO Coating Furnace (EU-14-A 11) shall not exceed the limits specified below:

Hydrogen Chloride 0.05 lbs/hr (9VAC5-80-850 and 9VAC5-60-320) [November 23, 2021]

16. Visible Emission Limit - Visible emissions from the two Vertical Tube Finishing Furnaces (EU-12A-3A, EU-12A-3B), Centorr Finishing Furnace (EU-13A-2) and TRISO Coating Furnace (EU-14-Al 1) shall not exceed 5 percent opacity as determined by the EPA Method 9 (reference 40 CFR 60, Appendix A). This condition applies at all times except during startup, shutdown, and malfunction.

(9V AC5-80-850 and 9VAC5-50-260) [November 23, 2021]

RECORDS

17. On Site Records - The permittee shall maintain records of emission data and operating parameters as necessary to demonstrate compliance with this permit. The content and format of such records shall be arranged with the Blue Ridge Regional Office. These records shall include, but are not limited to:

a.

Annual consumption of chlorine (in tons) in the two Vertical Tube Finishing Furnaces and Centorr Finishing Furnace (EU-12A-3A, EU-12A-3B, and EU-13A-2), calculated monthly as the sum of each consecutive 12-month period. Compliance for the consecutive 12-month period shall be demonstrated monthly by adding the total for the most recently completed calendar month to the individual monthly totals for the preceding 11 months. [June 4, 2007]

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 Page 7

b.

Annual emissions of hydrogen chloride (in tons) from the two Vertical Tube Finishing Furnaces and Centorr Finishing Furnace (EU-12A-3A, EU-12A-3B, and EU-13A-2),

calculated monthly as the sum of each consecutive 12-month period. Compliance for the consecutive 12-month period shall be demonstrated monthly by adding the total for the most recently completed calendar month to the individual monthly totals for the preceding 11 months. [June 4, 2007]

c.

Records verifying the control efficiency of the Wet Scrubber (PC-14A-6) and Dry Scrubber (PC-14A-7) controls required by Condition 4. [November 6, 2024]

d.

Operation and control device monitoring records for the Wet Scrubber (PC-14A-6) and Dry Scrubber (PC-14A-7) as required in Conditions 5, 6, and 9. [November 6, 2024]

e.

Operation and control device monitoring records for the Dry Scrubber (PC-14A-7) controls required in Condition 10. [November 6, 2024]

f.

Operation and control device monitoring records for the gas supply mass flow controllers required in Condition 11. [November 6, 2024]

g.

Hourly throughput (in grams) of methyltrichlorosilane (MTS) used in the TRISO Coating Furnace (EU-14A-11) to verify compliance with the throughput limitation in Condition 12. [November 23, 2021]

h.

Hourly emissions calculations for hydrogen chloride (HCl) from the TRISO Coating Furnace (EU-14A-11), using calculation methods approved by the Blue Ridge Regional Office to verify compliance with the lb/hr emissions limitation in Condition

15. [November 23, 2021]

1.

Perforn1ance test results. [November 23, 2021]

J.

Scheduled and unscheduled maintenance and operator training. [November 23, 2021]

These records shall be available for inspection by the DEQ and shall be current for the most recent five years.

(9V AC5-80-l 180 and 9V AC5-80-850)

18. Emission Testing - The two Vertical Tube Finishing Furnaces (EU-12A-3A, EU-12A-3B),

Centorr Finishing Furnace (EU-13A-2) and TRISO Coating Furnace (EU-14-Al I) shall be constructed so as to allow for emissions testing upon reasonable notice at any time, using appropriate methods. Sampling ports shall be provided when requested at the appropriate locations and safe sampling platforms and access shall be provided.

(9VAC5-80-880 and 9VAC5-80-850) [November 6, 2024]

GENERAL CONDITIONS BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 Page 8

19. Permit Suspension/Revocation - This permit may be suspended or revoked if the permittee:

a.

Knowingly makes material misstatements in the permit application or any amendments to it;

b.

Fails to comply with the conditions of this permit;

c.

Fails to comply with any emission standards applicable to a permitted emissions unit;

d.

Causes emissions from the stationary source which result in violations of, or interfere with the attainment and maintenance of, any ambient air quality standard; or

e.

Fails to operate in conformance with any applicable control strategy, including any emission standards or emissions limitations, in the State Implementation Plan in effect at the time an application for this permit is submitted.

(9VAC5-80-1210 G and 9VAC5-80-1010)

20. Right of Entry - The permittee shall allow authorized local, state, and federal representatives, upon the presentation of credentials:

a.

To enter upon the permittee's premises on which the facility is located or in which any records are required to be kept under the terms and conditions of this permit;

b.

To have access to and copy at reasonable times any records required to be kept under the terms and conditions of this permit or the State Air Pollution Control Board Regulations;

c.

To inspect at reasonable times any facility, equipment, or process subject to the terms and conditions of this permit or the State Air Pollution Control Board Regulations; and

d.

To sample or test at reasonable times.

For purposes of this condition, the time for inspection shall be deemed reasonable during regular business hours or whenever the facility is in operation. Nothing contained herein shall make an inspection time unreasonable during an emergency.

(9V ACS-170-130, 9V ACS-80-1180 and 9V ACS-80-850) 21. Maintenance/Operating Procedures - At all times, including periods of start-up, shutdown, and malfunction, the permittee shall, to the extent practicable, maintain and

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 operate the affected source, including associated air pollution control equipment, in a manner consistent with good air pollution control practices for minimizing emissions.

Page 9 The permittee shall take the following measures in order to minimize the duration and frequency of excess emissions, with respect to air pollution control equipment and process equipment which affect such emissions:

a.

Develop a maintenance schedule and maintain records of all scheduled and non-scheduled maintenance.

b.

Maintain an inventory of spare parts.

c.

Have available written operating procedures for equipment. These procedures shall be based on the manufacturer's recommendations, at a minimum.

d.

Train operators in the proper operation of all such equipment and familiarize the operators with the written operating procedures, prior to their first operation of such equipment. The permittee shall maintain records of the training provided including the names of trainees, the date of training and the nature of the training.

Records of maintenance and training shall be maintained on site for a period of five years and shall be made available to DEQ personnel upon request.

(9V ACS-50-20 E, 9V ACS-80-1180 and 9V ACS-80-850)

22. Record of Malfunctions - The permittee shall maintain records of the occurrence and duration of any bypass, malfunction, shutdown or failure of the facility or its associated air pollution control equipment that results in excess emissions for more than one hour.

Records shall include the date, time, duration, description ( emission unit, pollutant affected, cause), corrective action, preventive measures taken and name of person generating the record.

(9V ACS-20-180 J and 9V ACS-80-850)

23. Notification for Facility or Control Equipment Malfunction - The permittee shall furnish notification to the Blue Ridge Regional Office of malfunctions of the affected facility or related air pollution control equipment that may cause excess emissions for more than one hour. Such notification shall be made no later than four daytime business hours after the malfunction is discovered. The permittee shall provide a written statement giving all pertinent facts, including the estimated duration of the breakdown, within 14 days of discovery of the malfunction. When the condition causing the failure or malfunction has been corrected and the equipment is again in operation, the permittee shall notify the Blue Ridge Regional Office.

(9V ACS-20-180 C, 9V ACS-80-1180 and 9V ACS-80-850)

24. Violation of Ambient Air Quality Standard - The permittee shall, upon request of the DEQ, reduce the level of operation or shut down a facility, as necessary to avoid violating

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 Page 10 any primary ambient air quality standard and shall not return to normal operation until such time as the ambient air quality standard will not be violated.

(9V AC5-20-l 80 I, 9V AC5-80-1180 and 9V AC5-80-850)

25. Change of Ownership - In the case of a transfer of ownership of a stationary source, the new owner shall abide by any current permit issued to the previous owner. The new owner shall notify the Blue Ridge Regional Office of the change of ownership within 30 days of the transfer.

(9VAC5-80-1240 and 9VAC5-80-940)

26. Permit Copy - The permittee shall keep a copy of this permit on the premises of the facility to which it applies.

(9V AC5-80-1180 and 9V AC5-80-860 D)

STATE ONLY ENFORCEABLE (SOE) REQUIREMENTS The following terms and conditions are included in this permit to implement the requirements of 9V AC5-40-130 et seq., 9V AC5-50-130 et seq., 9V AC5-60-200 et seq. and/or 9V AC5-60-300 et seq. and are enforceable only by the Virginia Air Pollution Control Board. Neither their inclusion in this permit nor any resulting public comment period make these terms federally enforceable.

PROCESS REQUIREMENTS

27. SOE - Emission Controls - Hydrogen Chloride emissions from the TRISO Coating Furnace (EU-14A-11) shall be controlled by a Wet Scrubber (PC-14A-6) and Dry Scrubber (PC-14A-7). The Wet Scrubber and Dry Scrubber shall be provided with adequate access for inspection and shall be in operation when the TRISO Coating Furnace is operating.

(9VAC5-60-320, 9VAC5-80-l 120F) [November 6, 2024]

28. SOE - Control Efficiency - The Wet Scrubber (PC-l 4A-6) and Dry Scrubber (PC-l 4A-7) shall achieve a control efficiency for Hydrogen Chloride (HCl) of no less than 99.25 percent, to be demonstrated by a DEQ-approved performance test.

(9VAC5-60-320, 9VAC5-80-1120F) [November 6, 2024]

29. SOE - Monitoring Devices -The Wet Scrubber (PC-14A-6) controlling the TRISO Coating Furnace (EU-14A-11) shall be equipped with devices to continuously measure the liquid flow rate and the differential pressure drop across the Wet Scrubber. The permittee shall establish a normal operating range for the flow rate and differential pressure drop the Wet Scrubber, based on manufacturer's recommendations, developed from observations recorded from the monitoring devices during normal operation, performance test data and/or other DEQ approved methods.

(9VAC5-80-1120F) [November 23, 2021]

30. SOE - Monitoring Devices-The Dry Scrubber (PC-14A-7) controlling the TRISO Coating Furnace (EU-14A-11) shall be equipped with devices to continuously measure the

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 Page 11 differential pressure drop across the Dry Scrubber. The permittee shall establish a normal operating range for the differential pressure drop across the Dry Scrubber, based on manufacturer's recommendations, developed from observations recorded from the monitoring devices during normal operation, performance test data and/or other DEQ approved methods. The permittee shall maintain written documentation of this range. Each monitoring device shall be provided with adequate access for inspection and shall be in operation when the Dry Scrubber is operating. The permittee shall maintain records of the manufacturer's recommendations for filtration media replacement and records of actual filtration media replacement.

(9VAC5-80-1120F) [November 6, 2024]

31. SOE - Monitoring Devices - The Dry Scrubber (PC-14A-7) controlling the TRISO Coating Furnace (EU-14A-11) shall be equipped with devices to continuously measure the gas stream temperature across the Dry Scrubber. The permittee shall establish a norn1al operating range for the gas stream temperature across the Dry Scrubber, based on manufacturer's recommendations, developed from observations recorded from the monitoring devices during normal operation, performance test data and/or other DEQ approved methods. The permittee shall maintain written documentation of this range. Each monitoring device shall be installed, maintained, calibrated and operated in accordance with approved procedures which shall include, as a minimum, the manufacturer's written requirements or recommendations. Each monitoring device shall be provided with adequate access for inspection and shall be in operation when the Dry Scrubber is operating.

(9VAC5-80-l 120F) [November 6, 2024]

32. SOE-Monitoring Devices-The TRISO Coating Furnace (EU-14A-11) shall be operated as a closed system while flowing methyltrichlorosilane gas (MTS), with only Argon and Hydrogen gas being introduced to the furnace. The furnace shall be equipped with gas supply mass flow controllers on the Argon and Hydrogen gas that is being introduced into the furnace. The permittee shall establish a normal operating range for the combined gas flow (Argon plus Hydrogen) rate through the Dry Scrubber, based on manufacturer's recommendations, developed from observations recorded from the monitoring devices during normal operation, performance test data and/or other DEQ approved methods. The permittee shall maintain written documentation of this range. Each monitoring device shall be installed, maintained, calibrated and operated in accordance with approved procedures which shall include, as a minimum, the manufacturer's written requirements or recommendations. Each monitoring device shall be provided with adequate access for inspection and shall be in operation when the Dry Scrubber is operating.

(9VAC5-80-1120F) [November 6, 2024]

33. SOE - Monitoring Device Observation - To ensure good performance, the control monitoring devices used to continuously measure the liquid flow rate and the differential pressure drop across the Wet Scrubber and the differential pressure drop across the Dry Scrubber shall be observed by the permittee with a frequency of not less than once per shift when the scrubbers are in operation. The permittee shall keep a log of the observations or

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 Page 12 continuously record measurements from the Wet Scrubber (PC-14A-6) and Dry Scrubber (PC-14A-7) controlling the TRISO Coating Furnace (EU-14A-11).

(9VAC5-80-1120F) [November 6, 2024]

34. Monitoring Device Observation - To ensure good performance, the monitoring devices used to continuously measure the gas stream temperature in the Dry Scrubber (PC-14A-7) shall be observed by the permittee with a frequency of not less than once per 15 minutes when the scrubber is in operation. The pennittee shall keep a log of the observations or continuously record measurements from the Dry Scrubber (PC-14A-7) controlling the TRISO Coating Furnace (EU-14A-11).

(9VAC5-80-l 120F) [November 6, 2024]

35. Monitoring Device Observation - To ensure good performance, the control monitoring devices used to continuously measure the gas flow rate of Argon and Hydrogen through the Dry Scrubber (PC-l 4A-7) shall be observed by the permittee with a frequency of not less than once per shift when the scrubber is in operation. The permittee shall keep a log of the observations or continuously record measurements from the Dry Scrubber (PC-14A-7) controlling the TRISO Coating Furnace (EU-14A-l l).

(9VAC5-80-l 120F) [November 6, 2024]

OPERA TING LIMITS

36. SOE-Throughput -The throughput of methyltrichlorosilane (MTS) fed to the TRISO Coating Furnace (EU-14A-l 1) shall not exceed 2,400 grams/hr calculated monthly as the sum of each consecutive 12-month period. Compliance for the consecutive 12-month period shall be demonstrated monthly by adding the total for the most recently completed calendar month to the individual monthly totals for the preceding 11 months.

(9VAC5-80-ll20F) [November 23, 2021]

EMISSION LIMITS

37. SOE-Process Emission Limits - Emissions from the operation of the TRISO Coating Furnace (EU-14-A 11) shall not exceed the limits specified below:

Hydrogen Chloride 0.05 lbs/hr (9VAC5-60-320, 9VAC5-80-l 120F) [November 6, 2024]

38. SOE - Visible Emission Limit - Visible emissions from the TRISO Coating Furnace (EU-14A-l 1) shall not exceed 5 percent opacity as detennined by the EPA Method 9 (reference 40 CFR 60, Appendix A).

(9VAC5-80-1120F) [November 6, 2024]

RECORDS BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 Page 13

39. SOE - On Site Records - The permittee shall maintain records of emission data and operating parameters as necessary to demonstrate compliance with this permit. The content and format of such records shall be arranged with the Blue Ridge Regional Office. These records shall include, but are not limited to:

a.

Records verifying the control efficiency of the Wet Scrubber (PC-14A-6) and Dry Scrubber (PC-14A-7) controls required by Condition 28.

b.

Operation and control device monitoring records for the Wet Scrubber (PC-14A-6) and Dry Scrubber (PC-14A-7) as required in Conditions 29, 30, and 33.

c.

Operation and control device monitoring records for the Dry Scrubber (PC-14A-7) controls required in Condition 34.

d.

Operation and control device monitoring records for the gas supply mass flow controllers required in Condition 35.

e.

Hourly throughput (in grams) of methyltrichlorosilane (MTS) used in the TRISO Coating Furnace (EU-14A-l 1) to verify compliance with the throughput limitation in Condition 36.

f.

Hourly emissions calculations for hydrogen chloride (HCl) from the TRISO Coating Furnace (EU-l 4A-l l ), using calculation methods approved by the Blue Ridge Regional Office to verify compliance with the lb/hr emissions limitation in Condition

37.

g.

Performance test results.

h.

Scheduled and unscheduled maintenance and operator training.

These records shall be available for inspection by the Blue Ridge Regional Office and shall be current for the most recent five years.

(9VAC5-80-l 120F) [November 6, 2024]

INITIAL COMPLIANCE DETERMINATION

40. SOE - Performance Test - Initial performance tests shall be conducted for HCl from the Wet Scrubber and Dry Scrubber stack to determine compliance with the emission limits and control efficiency requirements contained in Conditions 28 and 37. The test shall be performed within 60 days after achieving the maximum production rate at which the facility will be operated but in no event later than 180 days after start-up of the permitted facility.

The details of the test shall be arranged with the Blue Ridge Regional Office. The permittee shall submit a test protocol at least 30 days prior to testing. One copy of the test

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 6, 2024 results shall be submitted to the Blue Ridge Regional Office within 60 days after test completion and shall conform to the test report format enclosed with this permit.

(9VAC5-50-30 and 9VAC5-80-1200) [November 6, 2024]

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