ML21347A368

Bwx Technologies, Inc., State Air Permit Modification

ML21347A368
Person / Time
Site:	BWX Technologies
Issue date:	12/03/2021
From:	Freudenberger R BWXT, BWXT
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
21-066
Download: ML21347A368 (16)

Text

BW BWX Technologies, Inc.

December 3, 2021 21-066 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) facility 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 23, 2021, is included as an enclosure to this letter.

If you have questions or require additional information, please contact Chris Terry, Manager of

• Licensing and Safety Analysis, at ctterry@bwxt.com or 434-522-5202.

Sincerely, Richard J. reudenberger 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.

People Strong P.O. Box 785 Lynchburg, VA 24505 USA t: +1.434.522.6000 www.bwxt.com INNOVATION DRIVEN >

ENCLOSURE People Strong BWXT Nuclear Operations Group, Inc.

P.O. Box 785 Lynchburg, VA 24505 USA t: +1.434.522.6000 www.bwxt.com INNOVATION DRIVEN >

COM MON WEA LTH of VIRGINIA Ann F. Jennings Secretary of Natural and DEPARTMENT OF ENVIRONMENTAL QUALITY David K. Paylor Historic Resources Director Blue Ridge Regional Office 901 Russell Drive, Salem, VA 24153 RobertJ. Weld Regional Director (540) 562-6700; Fax (804) 698-4178 www.deq.virginia.gov November 23, 2021 Mr. Jim Bittner Vice President and General Manager BWXT Nuclear Operations Group, Inc.

1570 Mt. Athos Road Lynchburg, VA 24504 Location: Campbell County Registration No.: 30260

Dear Mr. Bittner,

Attached is a permit to construct and operate a project at a nuclear component and fuel production facility in accordance with the provisions of the Virginia State Air Pollutio n Control Board Regulations for the Control and Abatement of Air Pollution.

In the course of evaluating the application and arriving at a final decision to approve the project, the Department of Environmental Quality (DEQ) deemed the application complete on July 29, 2021.

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

The Board's 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 Board 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. Jim Bittner November 23, 2021 Page2 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:

David K. Paylor, 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 period 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 Blake Apo at 540-598-0456 or blake.apo@deq.virginia.gov.

Sincerely,

/?ad ?f"'*J.-

for Robert J. Weld Regional Director

Attachment:

Permit cc: Nicole Wright, DEQ BRRO Air Compliance Inspector (electronic)

Jim Bittner Gjbittner@bwxt.com)

Vincent St. Angelo (vjstangelo@bwxt.com)

COMM( )NWEAL TH of VIRGINIA Ann Jennings David K. Paylor Secretary of Natural and DEPARTMEN T OF ENVIRONMENTAL QUALITY Director Historic Resources Blue Ridge Regional Office Robert J. Weld

90) Russell Drive, Salem, VA 24153 Regional Director (540)562-6700;Fax(804)698-4178 www.deq.virginia.gov STATIONARY SOURCE PERMIT TO CONSTRUCT AND OPERATE STATIONAR Y SOURCE PERMIT TO OPERATE This permit supersedes your permit dated June 4, 2007.

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 operate two Vertical Tube Furnaces, one Centorr Finishing Furnace, and on~ TRISO Coating Furnace located at 1570 Mt Athos Road, Lynchburg, VA 24504 in accordance with the Conditions of this permit.

Approved on November 23, 2021.

for Robert J. Weld

• Regional Director, Department of Environmental Quality Permit consists of 11 pages.

Permit Conditions 1 to 32

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 23, 2021 Page2 INTRODU CTION This permit approval is based on and combines permit terms and conditions in accordance with 9VAC5 1255 from the following permit approvals and the respective permit applications:

e State operating permit approval and minor new source review approval dated November 23, 2021, based on the permit application dated July 23, 2021.

e 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 enforcemen t action. In addition, this facility may be subject to additional applicable requiremen ts not listed in this permit.

Words or terms used in this permit 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 most recent effective date for a term or condition is listed in brackets [ ]. When identical conditions on approval for an emission unit or 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 approval. In accordance with 9VAC5 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 DEQ or the Board 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 Code of Virginia,§ 10.1-1314 (addressing information provided to the Board) of the Code of Virginia, and 9VAC5-170 -60 of the State Air Pollution Control Board Regulations. Information provided to federal officials is subject to appropriate federal law and regulations governing confidential ity of such information.

Equipment List - Equipment at this facility covered by this permit consists of:

E:qmpme.nt to bC e ons trUCtd e :

Refere111ce No. Equipment Description Rated Capacity Delegated Federal Requirements EU-1_4A-ll TRISO Coating Furnace 4200 g/hr MTS Feed

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 23, 2021 Page3 Other Permitted E ui ment:

Reference No. Equipment Description Rated Capacity Delegated Federal Re uirements EU-12A-3A & Two ThennCraft Vertical Tube Finishing EU-12A-3B Furnaces EU-13A-2 One Centorr Finishin Furnace 6 inch finishin Specifications included in the above tables are for infonnational purposes only and do not form enforceable terms or conditions of the permit.

PROCESSREOUIRMENTS

1. Emission Controls - HCI 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.

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

2. Monitori ng 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.

(9VACS-80-1180, 9VAC5-80-890, and 9VAC5-60-320) [June 4, 2007]

3. Emission Controls - Hydrogen Chloride emissions from the TRISO Coating Furnace (EU-14A-1 l) shall be controlled by a Wet Scrubber (PC-14A-6). The Wet 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 23, 2021]

4. Control Efficiency- The Wet Scrubber (PC-14A-6) shall achieve a control efficiency for Hydrogen Chloride (HCl) ofno less than 99.25 percent, to be demonstrated by a DEQ-approved performance test.

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

5. Monitoring Devices -The Wet Scrubber (PC-14A-6) controlling the TRISO Coating Furnace (EU-14A -ll) 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

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 23, 2021 Page4 recorded from the monitoring devices during normal operation, performance test data and/or other DEQ approved methods.

(9VAC5-80-890) [November 23, 2021]

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

(9VAC5-80-890) [November 23, 2021]

OPERA TING LIMIT S

7. Throu ghput- The throughput ofmethyltrichlorosilane (MTS) fed to the TRISO Furnace (EU-14 A-l l) shall not exceed 2,400 grams/hr calculated monthl y as Coating I the sum of each consecutive 12-month period. Compliance for the consecutive 12-month period shall be demonstrated monthl y 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]

EMISS ION LIMIT S

8. Process Emissi on 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 Chlorid e 0.01 lbs/hr (each)

(9VAC5-80-l 180 and 9VAC5-80-850) [June 4, 2007]

9. Process Emissi on Limits - Emissions from the operation of the Centorr Finishi ng Furnace (EU-13A-2) shall not exceed the limits specified below:

Hydrogen Chloride 0.05 lbs/hr (9VAC5-80-1180 and 9VAC5-80-850) [June 4, 2007]

10. Process Emission Limits -Emiss ions 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]

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 23, 2021 Page5

11. 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.

(9VAC5-80-850 and 9VAC5-50-260 1) [November 23, 2021]

RECORDS

12. 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]

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) controls required by Condition 4. [November 23, 2021]

d. Operation and control device monitoring records for the Wet Scrubber (PC-14A-6) as required in Conditions 5 and 6. [November 23, 2021]

e. 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 7. [November 23, 2021]

£ Hourly emissions calculations for hydrogen chloride (HCI) 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

10. [November 23, 2021]

1 BACT citation only applies to EU-12A-3A, EU-12A-3B and EU-13A-2 as indicated from previous permit actions.

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 23, 2021 Page6

g. Performance test results. [November 23, 2021]

h. 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.

(9VAC5-80-1180 and 9VAC5-80-850)

13. 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 1) 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) [November23, 2021]

GENERAL CONDITIONS

14. Permit Invalidation -The portions of this permit to.construct the TRISO Coating Furnace shall become invalid, unless an extension is granted by the DEQ, if:

a.* A program of continuous construction is not commenced within 18 months from the date of this permit.

b. A program of construction is discontinued for a period of 18 months or more, or is not completed within a reasonable time, except for a DEQ approved period between phases of the phased construction of a new stationary source or project.

(9VAC5-80-1210)

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

a. Knowingly makes material misstatements in the pennit 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.

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 23, 2021 Page7

f. Fails to comply with the applicable provisions of Articles 6, 8, and 9 of 9VAC5 Chapter 80.

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

16. 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 tenns 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.

(9VACS-170-130, 9VACS-80-1180 and 9VACS-80-850)

17. Maintenance/Operating Procedures - At all times, including periods of start-up, shutdown, and malfunction, the permittee shall, to the extent practicable, maintain and operate the affected source, including associated air pollution control equipment, in a manner consistent with good air pollution control practices for minimizing emissions.

The pennittee 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.

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 23, 2021 Page 8

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 pennittee shall maintain records of the training provided including the names of trainees, the date of training and the nature of the training.

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

(9VAC5-50-20 E, 9VAC5-80-118 0 and 9VACS-80-850)

18. 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.

(9VAC5-20-18 0 J and 9VACS-80-85 0)

19. Notificatio n for Facility or Control Equipment Malfunction -The pennittee shall furnish notification to the Blue Ridge Regional Office of malfunction s 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.

(9VAC5-20-18 0 C, 9VACS-80-1180 and 9VACS-80-850)

20. 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 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.

(9VAC5-20-18 0 I, 9VACS-80-11 80 and 9VACS-80-850)

21. Change of Ownership - In the case of a transfer of ownership of a stationary source, the new owner shall abide by any current minor NSR 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 940)

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

(9VACS-80-11 80 and 9VAC5 860 D)

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 23, 2021.

Page9 STATE ONLY ENFORCEABLE (SOE) REQUIREMENTS The following terms and conditions are included in this permit to implement the requirements of 9VAC5-40-130 et seq., 9VAC5-50-130 et seq., 9VAC5-60-200 et seq. and/or 9VAC5-60-300 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.

PROCESSREOUIRMENTS

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

(9VAC5-60-320, 9VAC5-80-1120F and 9VAC5-80-l 180) [November 23, 2021]

. 24; SOE-Con trol Efficiency -The Wet Scrubber (PC-14A-6) 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 -l 120F and 9VAC5-80-1180) [November 23, 2021]

25. 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 pennittee 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 nonnal operation, performanc e test data and/or other DEQ approved methods.

(9VAC5-80-1120F and 9VAC5-80-1180) [November 23, 2021]

26. 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 shall be observed by the pennittee with a frequency of not less than once per

. day. The permittee shall keep a log of the observations or continuously record measurements from the Wet Scrubber (PC-14A-6) controlling the TRISO Coating Furn.ace (EU-14A-11).

(9VAC5-80-1120F and 9VAC5-80-1180) [November 23, 2021]

OPERATING LIMITS

27. SOE -Through put- 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.

(9VAC5-80-1120F and 9VAC5 l 180) [November 23, 2021]

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 23, 2021 Page 10 EMISSIO N LIMITS

28. SOE- Process Emission Limits - Emissions from the operation of the TRISO Coating Furnace (EU-14-A l 1) shall not exceed the limits specified below:,

Hydrogen Chloride 0.05 lbs/hr (9VAC5-60-320, 9VAC5-80-1120F and 9VAC5-80-l 180) [November 23, 2021]

29. SOE - Visible Emission Limit - Visible emissions from the TRISO Coating Furnace (EU-14A-11) shall not exceed 5 percent opacity as determined by the EPA Method 9 (reference 40 CFR 60, Appendix A).

(9VAC5-80-1120F and 9VACS-80-1180) [November 23, 2021]

RECORDS

30. 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) controls required by Condition 23.

b. Operation and control device monitoring records for the Wet Scrubber (PC-14A-6) as required in Conditions 25 and 26.

c. Hourly throughput (in grams) ofmethyltrichlorosilane (MTS) used in the TRISO Coating Furnace (EU-14A-11) to verify compliance with the throughput limitation in Condition 27.

d. Hourly emissions calculations for hydrogen chloride (HCI) 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 28.

e. Performance test results.

f. 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 and 9VAC5-80-1180) [November 23, 2021]

BWXT Nuclear Operations Group Inc.

Registration Number: 30260 November 23, 2021 Page 11 INITIAL COMPLIANCE DETERMINATION

31. SOE - Performance Test - Initial performance tests shall be conducted for HCI from the Wet Scrubber stack to determine compliance with the emission limits and control efficiency requirements contained in Conditions 24 and 28. 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 pennitted 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 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 23, 2021]

NOTIFICATIONS

32. SOE -Initial Notifications -The pennittee shall furnish written notification to the Blue Ridge Regional Office of:

a. The actual date on which construction of the TRISO Coating Furnace (EU-14A-11) commenced within 30 days after such date.

b. The anticipated start-up date of the TRISO Coating Furnace (EU-14A-11) postmarked not more than 60 days nor less than 30 days prior to such date.

c. The actual start-up date of the TRISO Coating Furnace (EU-14A-1 l) within 15 days after such date.

(9VAC5-80-1120F and 9VAC5-80-l 180) [November 23, 2021]

SOURCE TESTING REPORT FORMAT Report Cover

1. Plant name and location

2. Units tested at source (indicate Ref. No. used by source in permit or registration)

3. Test Dates.

4. Tester; name, address and report date Certification

1. Signed by team leader/certified observer (include certification date)

2. Signed by responsible company official

3. *Signed by reviewer Copy of approved test protocol Summary

1. Reason for testing

2. Test dates

3. Identification of unit tested & the maximum rated capacity

4. *For each emission unit, a table showing:

a. Operating rate

b. Test Methods

c. Pollutants tested

d. Test results for each run and the run average

e. Pollutant standard or limit

5. Summarized process and control equipment data for each run and the average, as required by the test protocol

6. A statement that test was conducted in accordance with the test protocol or identification & discussion of deviations, including the likely impact on results

7. Any other important information Source Operation

1. Description of process and control devices

2. Process and control equipment flow diagram

3. Sampling port location and dimensioned cross section Attached protocol includes: sketch of stack (elevation view) showing sampling port locations, upstream and downstream flow disturbances and their distances from ports; and a sketch of stack (plan view) showing sampling ports, ducts entering the stack and stack diameter or dimensions Test Results

1. Detailed test results for each run

2. *Sample calculations

3. *Description of collected samples, to include audits when applicable Appendix

1. *Raw production data

2. *Raw field data

3. *Laboratory reports

4. *Chain of custody records for lab samples

5. *Calibration procedures and results

6. Project participants and titles

7. Observers' names (industry and agency)

8. Related correspondence

9. Standard procedures

• Not applicable to visible emission evaluations