erachem comilog, inc. - mde.state.md.us · erachem comilog, inc. baltimore facility (the permittee)...

ERACHEM COMILOG, INC. 610 PITTMAN ROAD BALTIMORE, MD 21226

PART 70 OPERATING PERMIT NO. 24-003-0056

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SECTION I SOURCE IDENTIFICATION ....................................................................4

1. DESCRIPTION OF FACILITY..............................................................................4 2. FACILITY INVENTORY LIST...............................................................................5

SECTION II GENERAL CONDITIONS ................................. .....................................10

1. DEFINITIONS....................................................................................................10 2. ACRONYMS......................................................................................................10 3. EFFECTIVE DATE ............................................................................................11 4. PERMIT EXPIRATION ......................................................................................11 5. PERMIT RENEWAL ..........................................................................................11 6. CONFIDENTIAL INFORMATION.......................................................................12 7. PERMIT ACTIONS ............................................................................................12 8. PERMIT AVAILABILITY.....................................................................................13 9. REOPENING THE PART 70 PERMIT FOR CAUSE BY THE EPA ....................13 10. TRANSFER OF PERMIT ...............................................................................13 11. REVISION OF PART 70 PERMITS – GENERAL CONDITIONS....................13 12. SIGNIFICANT PART 70 OPERATING PERMIT MODIFICATIONS................14 13. MINOR PERMIT MODIFICATIONS ...............................................................15 14. ADMINISTRATIVE PART 70 OPERATING PERMIT AMENDMENTS ...........18 15. OFF-PERMIT CHANGES TO THIS SOURCE ...............................................19 16. ON-PERMIT CHANGES TO SOURCES........................................................21 17. FEE PAYMENT .............................................................................................23 18. REQUIREMENTS FOR PERMITS-TO-CONSTRUCT AND APPROVALS.....23 19. CONSOLIDATION OF PROCEDURES FOR PUBLIC PARTICIPATION .......24 20. PROPERTY RIGHTS.....................................................................................24 21. SEVERABILITY .............................................................................................25 22. INSPECTION AND ENTRY ...........................................................................25 23. DUTY TO PROVIDE INFORMATION ............................................................25 24. COMPLIANCE REQUIREMENTS..................................................................26 25. CREDIBLE EVIDENCE..................................................................................26 26. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE ........................27 27. CIRCUMVENTION.........................................................................................27 28. PERMIT SHIELD ...........................................................................................27 29. ALTERNATE OPERATING SCENARIOS......................................................28

SECTION III PLANT WIDE CONDITIONS.............................. ................................29

1. PARTICULATE MATTER FROM CONSTRUCTION AND DEMOLITION ..........29 2. OPEN BURNING...............................................................................................29 3. AIR POLLUTION EPISODE...............................................................................29 4. REPORT OF EXCESS EMISSIONS AND DEVIATIONS...................................29 5. ACCIDENTAL RELEASE PROVISIONS............................................................30 6. GENERAL TESTING REQUIREMENTS............................................................31 7. EMISSIONS TEST METHODS..........................................................................31 8. EMISSIONS CERTIFICATION REPORT...........................................................31 9. COMPLIANCE CERTIFICATION REPORT .......................................................33 10. CERTIFICATION BY RESPONSIBLE OFFICIAL...........................................33 11. SAMPLING AND EMISSIONS TESTING RECORD KEEPING......................34 12. GENERAL RECORDKEEPING......................................................................34



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13. GENERAL CONFORMITY.............................................................................35 14. ASBESTOS PROVISIONS ............................................................................35 15. OZONE DEPLETING REGULATIONS...........................................................35 16. ACID RAIN PERMIT ......................................................................................36

SECTION IV PLANT SPECIFIC CONDITIONS.......................... .............................37

SECTION V INSIGNIFICANT ACTIVITIES ........................... .....................................97

SECTION VI STATE-ONLY ENFORCEABLE CONDITIONS .................. .............100



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SECTION I SOURCE IDENTIFICATION 1. DESCRIPTION OF FACILITY Erachem Comilog, Inc. Baltimore facility (the Permittee) is a manufacturer of inorganic, manganese based, chemical compounds such as Manganese Chloride, Manganese Nitrate, Manganese Dioxide, Manganous Oxide, Lithium Manganese Oxide, Manganous Manganic Oxide, Manganese Carbonate, Nitrided Ferromanganese (dismantled in 2013) and Nitrided Manganese in various purities, size, packaging and form. The facility is located in Anne Arundel county and its primary SIC code is 2819.

The registrations for the facility are: 5-0378 Boiler (backup) 5-0412 Boiler (primary) 6-0285 Waste Water Treatment System 6-0288 Manganese Ore Reduction 6-0721 Pilot Test Plant for High Surface Area MnO2 (The scrubber was removed

and the pilot plant is no longer active as of 2015) 7-0403 Manganese Chloride Solution (leaching) 7-0404 Multipurpose Plant (MnCO3, Mn3O4, and MnO2) 7-0405 Manganese Nitriding Process (dismantled in 2013) 7-0406 Manganese Nitrate Solution (very high purity) 7-0407 Manganese Chloride Prilling Process 7-0408 High Purity Manganese Oxides (MnO2 and MnO) process (aka. Nitrate

Plant) 7-0410 Manganese Chloride Flakes 7-0411 Catalytic Sulfur Trap Prilling and Reduction, Mn2O3 Calcining, Ozone

Decomposition Catalyst (ODC) and Lithiated Manganese Dioxide (LiMn2O4)

9-0416 Manganese Ore Storage Yard The Permittee operates two boilers to generate steam for general plant use. The 40 MMBTU/Hr Cleaver Brooks water tube is the primary unit (5-0412). The other boiler is a Cleaver Brooks fire tube boiler rated at 29 MMBTU/Hr and is used only as a backup to the first boiler during periods of mechanical repair or inspection.



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2. FACILITY INVENTORY LIST Emissions

Unit Number

ARMA Registration

Number

Emissions Unit Name and Description

Date of Installation

EU01 003-0056-5-0378 Fire Tube Boiler

One Cleaver Brooks boiler rated at 29MMBTU/hr fired by natural gas as the primary fuel and propane or No. 2 fuel oil as back-up during natural gas supply interruptions.

1971

EU02 003-0056-5-0412 Water Tube Boiler

One Cleaver Brooks boiler rated at 40 MMBTU/hr fired by natural gas as the primary fuel and propane or No. 2 fuel oil as back-up during natural gas supply interruptions.

1994

EU03 003-0056-6-0285 Wastewater Treatment Process

One lime storage silo equipped with a dust collector (bin vent)

1998M

EU04 003-0056-6-0288 Manganese Ore Reduction Process

One Shaft furnace rated at 12.6 MMBTU/hr fired by natural gas as the primary fuel and propane as back-up during natural gas supply interruptions. (EP6-0288A)

1983

One course MnO ball mill/classification unit equipped with a baghouse. (EP6-0288B). The baghouse is used for material recovery.

1962

One milled MnO bulk loading equipped with a baghouse (EP6-0288C). The baghouse is used for material recovery.

1962

EU05 003-0056-6-0721 High Surface Area Manganese Dioxide Pilot Process

One jacketed pan dryer controlled by a scrubber. (EP6-0721A)

1997 (no longer active as of 2015)

EU06 003-0056-7-0403 Manganese Chloride

Two hydrochloric acid holding tanks vents

1976M



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Emissions Unit

Number

ARMA Registration

Number



Solution Process manifolded together to form one vent. (EP7-0403A)

One evaporator for the manganese chloride solution process. (EP7-0403B)

1976M

Two leaching tanks vented to the venturi scrubber in the Manganese Chloride Flake Process (7-0410A). The venturi scrubber is used for material recovery.

1976M

EU07 003-0056-7-0404 Manganous Manganic Oxide (Mn3O4 PF), Manganese Carbonate (MnCO3 UF), and High Surface Area manganese Dioxide (MnO2-HSA) Production Process

One reactor for the production of Mn3O4 PF (EP7-404A), MnCO3 UF (EP7-404A) or MnO2-HSA controlled by a wet scrubber. (EP7-404D)

1982, 1998M

One MnO HP conveyor equipped with a baghouse. (EP7-404B). The baghouse is used for material recovery.

1982

One Aljet dryer rated at 1.4 MMBtu/hr fired by natural gas and is back-up by propane gas. The dryer is equipped with a baghouse (EP7-404C). The baghouse is used for material recovery.

1982

EU08 003-0056-7-0405 Manganese Nitride Production Process

One ferromanganese roll crusher and one sodium silicate blending screw equipped with a baghouse. (EP7-0405A)

1987 (dismantled as of 2013)

One tube loading station and unloading, screening, packaging equipped with a baghouse. (7-0405B)




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Emissions Unit

Number

ARMA Registration

Number



EU09 003-0056-7-0406 Manganese Nitrate Solution Process line

One (1) Manganese Nitrate Solution Process line

EU10 003-0056-7-0407 Manganese Chloride Prilling Process

Two Chemetals MnCl2 prills rotary dryers each rated at 1.8 MMBtu/hr fired by natural gas and is back-up by propane gas. Both dryers are controlled by a packed tower scrubber (EP7-407A). The scrubber is used for material recovery.

1975

One boildown tank controlled by one packed bed scrubber (EP7-407B). The scrubber is used for material recovery.

1975, 1996M

EU11 003-0056-7-0408 High Purity Manganese Oxides Process (Nitrate Plant)

Five rooftop ventilators for fugitive emissions each at 14000 cfm. (EP7-408A)

1972

One raw MnO2 ore dryer rated at 3.5 MMBTU/hr fired by natural gas and is back-up by propane gas or No.2 fuel oil. (EP7-408B)

1974

Two contact condensers controlled by one chemical scrubber (EP7-408C). The scrubber is used for material recovery.

1972

Three treatment tanks equipped with one dust collector (EP7-408D). The dust collector is used for material recovery.

1972, 1998M

One evaporator (EP7-408E) 1972 One MnO2-HP dryer rated

at 2.27 MMBTU/hr fired by 1972, 1998M



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Emissions Unit

Number

ARMA Registration

Number



natural gas and back up by propane gas or No.2 fuel oil equipped with a dust collector (EP7-408F). The dust collector is used for material recovery.

One horizontal roaster with two burners rated at 1.65 MMBTU/hr fired by natural gas and is back-up by propane gas or No.2 fuel oil. (EP7-408G)

1972

One ball mill/classification unit equipped with a baghouse (EP7-408H). The baghouse is used for material recovery.

1979

One air classifier equipped with a dust collector (EP7-408I). The baghouse is used for material recovery.

1998M

EU12 003-0056-7-0410 Manganese Chloride Flakes Processing Equipment

Two rotary drum dryers rated at 4.6 MMBTU/hr fired by natural gas and back up by propane gas. Dryers and MnCl2 packaging facility are controlled by a venturi scrubber. (EP7-410A). The scrubber is used for material recovery.

1976

EU13 003-0056-7-0411 CST & Mn2O3 Process

One Eirich (Sigma) mixer blender with hopper equipped with one baghouse. (EP7-411A/D; A and D represent different emissions when products change but both products share the same equipment and emission point)

1993, 1997M, 1998M

Two horizontal roaster/calciners rated at

1962, 1998M



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Emissions Unit

Number

ARMA Registration

Number



0.2 MMBTU/hr fired by natural gas and back up by propane gas. Each roaster/calciner is equipped with one baghouse (EP7-411B/E). The baghouse is used for material recovery.

One turbo-screen classifier equipped with one dust collector (EP7-411C). The baghouse is used for material recovery.

1998M

EU14 003-0056-9-0416 Raw MnO2 pile storage & material handling

Fugitive emissions (EP9-416-FUG)

1975



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SECTION II GENERAL CONDITIONS 1. DEFINITIONS [COMAR 26.11.01.01] and [COMAR 26.11.02.01] The words or terms in this Part 70 permit shall have the meanings

established under COMAR 26.11.01 and .02 unless otherwise stated in this permit.

2. ACRONYMS ARMA Air and Radiation Management Administration BACT Best Available Control Technology Btu British thermal unit CAA Clean Air Act CAM Compliance Assurance Monitoring CEM Continuous Emissions Monitor CFR Code of Federal Regulations CO Carbon Monoxide COMAR Code of Maryland Regulations EPA United States Environmental Protection Agency FR Federal Register gr grains HAP Hazardous Air Pollutant MACT Maximum Achievable Control Technology MDE Maryland Department of the Environment MVAC Motor Vehicle Air Conditioner NESHAPS National Emission Standards for Hazardous Air Pollutants NOx Nitrogen Oxides NSPS New Source Performance Standards NSR New Source Review OTR Ozone Transport Region PM Particulate Matter PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10

micrometers or less ppm parts per million ppb parts per billion PSD Prevention of Significant Deterioration PTC Permit to construct PTO Permit to operate (State) SIC Standard Industrial Classification SO2 Sulfur Dioxide TAP Toxic Air Pollutant



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tpy tons per year VE Visible Emissions VOC Volatile Organic Compounds 3. EFFECTIVE DATE The effective date of the conditions in this Part 70 permit is the date of

permit issuance, unless otherwise stated in the permit. 4. PERMIT EXPIRATION [COMAR 26.11.03.13B(2)] Upon expiration of this permit, the terms of the permit will automatically

continue to remain in effect until a new Part 70 permit is issued for this facility provided that the Permittee has submitted a timely and complete application and has paid applicable fees under COMAR 26.11.02.16.

Otherwise, upon expiration of this permit the right of the Permittee to

operate this facility is terminated. 5. PERMIT RENEWAL [COMAR 26.11.03.02B(3)] and [COMAR 26.11.03.02E] The Permittee shall submit to the Department a completed application for

renewal of this Part 70 permit at least 12 months before the expiration of the permit. Upon submitting a completed application, the Permittee may continue to operate this facility pending final action by the Department on the renewal.

The Permittee, upon becoming aware that any relevant facts were omitted

or incorrect information was submitted in the permit application, shall submit such supplementary facts or corrected information no later than 10 days after becoming aware that this occurred. The Permittee shall also provide additional information as necessary to address any requirements that become applicable to the facility after the date a completed application was submitted, but prior to the release of a draft permit. This information shall be submitted to the Department no later than 20 days after a new requirement has been adopted.



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6. CONFIDENTIAL INFORMATION [COMAR 26.11.02.02G] In accordance with the provisions of the State Government Article, Sec.

10-611 et seq., Annotated Code of Maryland, all information submitted in an application shall be considered part of the public record and available for inspection and copying, unless the Permittee claims that the information is confidential when it is submitted to the Department. At the time of the request for inspection or copying, the Department will make a determination with regard to the confidentiality of the information. The Permittee, when requesting confidentiality, shall identify the information in a manner specified by the Department and, when requested by the Department, promptly provide specific reasons supporting the claim of confidentiality. Information submitted to the Department without a request that the information be deemed confidential may be made available to the public. Subject to approval of the Department, the Permittee may provide a summary of confidential information that is suitable for public review. The content of this Part 70 permit is not subject to confidential treatment.

7. PERMIT ACTIONS [COMAR 26.11.03.06E(3)] and [COMAR 26.11.03.20(A)] This Part 70 permit may be revoked or reopened and revised for cause.

The filing of an application by the Permittee for a permit revision or renewal; or a notification of termination, planned changes or anticipated noncompliance by the facility, does not stay a term or condition of this permit.

The Department shall reopen and revise, or revoke the Permittee’s Part

70 permit under the following circumstances:

a. Additional requirements of the Clean Air Act become applicable to this facility and the remaining permit term is 3 years or more;

b. The Department or the EPA determines that this Part 70 permit

contains a material mistake, or is based on false or inaccurate information supplied by or on behalf of the Permittee;

c. The Department or the EPA determines that this Part 70 permit must

be revised or revoked to assure compliance with applicable requirements of the Clean Air Act; or



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d. Additional requirements become applicable to an affected source under the Federal Acid Rain Program.

8. PERMIT AVAILABILITY [COMAR 26.11.02.13G] The Permittee shall maintain this Part 70 permit in the vicinity of the facility

for which it was issued, unless it is not practical to do so, and make this permit immediately available to officials of the Department upon request.

9. REOPENING THE PART 70 PERMIT FOR CAUSE BY THE EP A [COMAR 26.11.03.20B] The EPA may terminate, modify, or revoke and reissue a permit for cause

as prescribed in 40 CFR §70.7(g) 10. TRANSFER OF PERMIT [COMAR 26.11.02.02E] The Permittee shall not transfer this Part 70 permit except as provided in

COMAR 26.11.03.15. 11. REVISION OF PART 70 PERMITS – GENERAL CONDITION S [COMAR 26.11.03.14] and [COMAR 26.11.03.06A(8)]

a. The Permittee shall submit an application to the Department to revise this Part 70 permit when required under COMAR 26.11.03.15 -.17.

b. When applying for a revision to a Part 70 permit, the Permittee shall

comply with the requirements of COMAR 26.11.03.02 and .03 except that the application for a revision need include only information listed that is related to the proposed change to the source and revision to the permit. This information shall be sufficient to evaluate the proposed change and to determine whether it will comply with all applicable requirements of the Clean Air Act.



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c. The Permittee may not change any provision of a compliance plan or schedule in a Part 70 permit as an administrative permit amendment or as a minor permit modification unless the change has been approved by the Department in writing.

d. A permit revision is not required for a change that is provided for in

this permit relating to approved economic incentives, marketable permits, emissions trading, and other similar programs.

12. SIGNIFICANT PART 70 OPERATING PERMIT MODIFICATI ONS [COMAR 26.11.03.17] The Permittee may apply to the Department to make a significant

modification to its Part 70 Permit as provided in COMAR 26.11.03.17 and in accordance with the following conditions:

a. A significant modification is a revision to the federally enforceable

provisions in the permit that does not qualify as an administrative permit amendment under COMAR 26.11.03.15 or a minor permit modification as defined under COMAR 26.11.03.16.

b. This permit does not preclude the Permittee from making changes,

consistent with the provisions of COMAR 26.11.03, that would make the permit or particular terms and conditions of the permit irrelevant, such as by shutting down or reducing the level of operation of a source or of an emissions unit within the source. Air pollution control equipment shall not be shut down or its level of operation reduced if doing so would violate any term of this permit.

c. Significant permit modifications are subject to all requirements of

COMAR 26.11.03 as they apply to permit issuance and renewal, including the requirements for applications, public participation, and review by affected states and EPA, except:

(1) An application need include only information pertaining to the

proposed change to the source and modification of this permit, including a description of the change and modification, and any new applicable requirements of the Clean Air Act that will apply if the change occurs;

(2) Public participation, and review by affected states and EPA, is

limited to only the application and those federally enforceable



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terms and conditions of the Part 70 permit that are affected by the significant permit modification.

d. As provided in COMAR 26.11.03.15B(5), an administrative permit

amendment may be used to make a change that would otherwise require a significant permit modification if procedures for enhanced preconstruction review of the change are followed that satisfy the requirements of 40 CFR 70.7(d)(1)(v).

e. Before making a change that qualifies as a significant permit

modification, the Permittee shall obtain all permits-to-construct and approvals required by COMAR 26.11.02.

f. The Permittee shall not make a significant permit modification that

results in a violation of any applicable requirement of the Clean Air Act.

g. The permit shield in COMAR 26.11.03.23 applies to a final significant

permit modification that has been issued by the Department, to the extent applicable under COMAR 26.11.03.23.

13. MINOR PERMIT MODIFICATIONS [COMAR 26.11.03.16] The Permittee may apply to the Department to make a minor modification

to the federally enforceable provisions of this Part 70 permit as provided in COMAR 26.11.03.16 and in accordance with the following conditions:

a. A minor permit modification is a Part 70 permit revision that:

(1) Does not result in a violation of any applicable requirement of

the Clean Air Act;

(2) Does not significantly revise existing federally enforceable monitoring, including test methods, reporting, record keeping, or compliance certification requirements except by:

(a) Adding new requirements,

(b) Eliminating the requirements if they are rendered

meaningless because the emissions to which the requirements apply will no longer occur, or



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(c) Changing from one approved test method for a pollutant and source category to another;

(3) Does not require or modify a:

(a) Case-by-case determination of a federally enforceable

emissions standard,

(b) Source specific determination for temporary sources of ambient impacts, or

(c) Visibility or increment analysis;

(4) Does not seek to establish or modify a federally enforceable

permit term or condition for which there is no corresponding underlying applicable requirement of the Clean Air Act, but that the Permittee has assumed to avoid an applicable requirement to which the source would otherwise be subject, including:

(a) A federally enforceable emissions standard applied to the

source pursuant to COMAR 26.11.02.03 to avoid classification as a Title I modification; and

(b) An alternative emissions standard applied to an emissions

unit pursuant to regulations promulgated under Section 112(i)(5) of the Clean Air Act

(5) Is not a Title I modification; and

(6) Is not required under COMAR 26.11.03.17 to be processed as a

significant modification to this Part 70 permit.

b. Application for a Minor Permit Modification The Permittee shall submit to the Department an application for a

minor permit modification that satisfies the requirements of COMAR 26.11.03.03 which includes the following:

(1) A description of the proposed change, the emissions resulting

from the change, and any new applicable requirements that will apply if the change is made;

(2) The proposed minor permit modification;



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(3) Certification by a responsible official, in accordance with COMAR 26.11.02.02F, that:

(a) The proposed change meets the criteria for a minor permit

modification, and

(b) The Permittee has obtained or applied for all required permits-to-construct required by COMAR 26.11.03.16 with respect to the proposed change;

(4) Completed forms for the Department to use to notify the EPA

and affected states, as required by COMAR 26.11.03.07-.12.

c. Permittee’s Ability to Make Change

(1) For changes proposed as minor permit modifications to this permit that will require the applicant to obtain a permit to construct, the permit to construct must be issued prior to the new change.

(2) During the period of time after the Permittee applies for a minor

modification but before the Department acts in accordance with COMAR 26.11.03.16F(2):

(a) The Permittee shall comply with applicable requirements of

the Clean Air Act related to the change and the permit terms and conditions described in the application for the minor modification.

(b) The Permittee is not required to comply with the terms and

conditions in the permit it seeks to modify. If the Permittee fails to comply with the terms and conditions in the application during this time, the terms and conditions of both this permit and the application for modification may be enforced against it.

d. The Permittee is subject to enforcement action if it is determined at

any time that a change made under COMAR 26.11.03.16 is not within the scope of this regulation.

e. Minor permit modification procedures may be used for Part 70 permit

modifications involving the use of economic incentives, marketable permits, emissions trading, and other similar approaches, but only to the extent that the minor permit modification procedures are explicitly provided for in regulations approved by the EPA as part of the



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Maryland SIP or in other applicable requirements of the Clean Air Act.

14. ADMINISTRATIVE PART 70 OPERATING PERMIT AMENDME NTS [COMAR 26.11.03.15] The Permittee may apply to the department to make an administrative

permit amendment as provided in COMAR 26.11.03.15 and in accordance with the following conditions:

a. An application for an administrative permit amendment shall:

(1) Be in writing;

(2) Include a statement certified by a responsible official that the

proposed amendment meets the criteria in COMAR 26.11.03.15 for an administrative permit amendment, and

(3) Identify those provisions of this part 70 permit for which the

amendment is requested, including the basis for the request.

b. An administrative permit amendment:

(1) Is a correction of a typographical error;

(2) Identifies a change in the name, address, or phone number of a person identified in this permit, or a similar administrative change involving the Permittee or other matters which are not directly related to the control of air pollution;

(3) requires more frequent monitoring or reporting by the Permittee;

(4) Allows for a change in ownership or operational control of a

source for which the Department determines that no other revision to the permit is necessary and is documented as per COMAR 26.11.03.15B(4);

(5) Incorporates into this permit the requirements from

preconstruction review permits or approvals issued by the Department in accordance with COMAR 26.11.03.15B(5), but only if it satisfies 40 CFR 70.7(d)(1)(v);



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(6) Incorporates any other type of change, as approved by the EPA, which is similar to those in COMAR 26.11.03.15B(1)—(4);

(7) Notwithstanding COMAR 26.11.03.15B(1)—(6), all modifications

to acid rain control provisions included in this Part 70 permit are governed by applicable requirements promulgated under Title IV of the Clean Air Act; or

(8) Incorporates any change to a term or condition specified as

State-only enforceable, if the Permittee has obtained all necessary permits-to-construct and approvals that apply to the change.

c. The Permittee may make the change addressed in the application for

an administrative amendment upon receipt by the Department of the application, if all permits-to-construct or approvals otherwise required by COMAR 26.11.02 prior to making the change have first been obtained from the Department.

d. The permit shield in COMAR 26.11.03.23 applies to administrative

permit amendments made under Section B(5) of COMAR 26.11.03.15 , but only after the Department takes final action to revise the permit.

e. The Permittee is subject to enforcement action if it is determined at

any time that a change made under COMAR 26.11.03.15 is not within the scope of this regulation.

15. OFF-PERMIT CHANGES TO THIS SOURCE [COMAR 26.11.03.19] The Permittee may make off-permit changes to this facility as provided in

COMAR 26.11.03.19 and in accordance with the following conditions:

a. The Permittee may make a change to this permitted facility that is not addressed or prohibited by the federally enforceable conditions of this Part 70 permit without obtaining a Part 70 permit revision if:

(1) The Permittee has obtained all permits and approvals required

by COMAR 26.11.02 and .03;

(2) The change is not subject to any requirements under Title IV of the Clean Air Act;



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(3) The change is not a Title I modification; and

(4) The change does not violate an applicable requirement of the

Clean Air Act or a federally enforceable term or condition of the permit.

b. For a change that qualifies under COMAR 26.11.03.19, the Permittee

shall provide contemporaneous written notice to the Department and the EPA, except for a change to an emissions unit or activity that is exempt from the Part 70 permit application, as provided in COMAR 26.11.03.04. This written notice shall describe the change, including the date it was made, any change in emissions, including the pollutants emitted, and any new applicable requirements of the Clean Air Act that apply as a result of the change.

c. Upon satisfying the requirements of COMAR 26.11.03.19, the

Permittee may make the proposed change.

d. The Permittee shall keep a record describing:

(1) Changes made at the facility that result in emissions of a regulated air pollutant subject to an applicable requirement of the Clean Air Act , but not otherwise regulated under this permit; and

(2) The emissions resulting from those changes.

e. Changes that qualify under COMAR 26.11.03.19 are not subject to

the requirements for Part 70 revisions.

f. The Permittee shall include each off-permit change under COMAR 26.11.03.19 in the application for renewal of the part 70 permit.

g. The permit shield in COMAR 26.11.03.23 does not apply to off-permit

changes made under COMAR 26.11.03.19.

h. The Permittee is subject to enforcement action if it is determined that an off-permit change made under COMAR 26.11.03.19 is not within the scope of this regulation.



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16. ON-PERMIT CHANGES TO SOURCES [COMAR 26.11.03.18] The Permittee may make on-permit changes that are allowed under

Section 502(b)(10) of the Clean Air Act as provided in COMAR 26.11.03.18 and in accordance with the following conditions:

a. The Permittee may make a change to this facility without obtaining a

revision to this Part 70 permit if:

(1) The change is not a Title I modification;

(2) The change does not result in emissions in excess of those expressly allowed under the federally enforceable provisions of the Part 70 permit for the permitted facility or for an emissions unit within the facility, whether expressed as a rate of emissions or in terms of total emissions;

(3) The Permittee has obtained all permits and approvals required

by COMAR 26.11.02 and .03;

(4) The change does not violate an applicable requirement of the Clean Air Act;

(5) The change does not violate a federally enforceable permit term

or condition related to monitoring, including test methods, record keeping, reporting, or compliance certification requirements;

(6) The change does not violate a federally enforceable permit term

or condition limiting hours of operation, work practices, fuel usage, raw material usage, or production levels if the term or condition has been established to limit emissions allowable under this permit;

(7) If applicable, the change does not modify a federally

enforceable provision of a compliance plan or schedule in this Part 70 permit unless the Department has approved the change in writing; and

(8) This permit does not expressly prohibit the change under

COMAR 26.11.03.18.



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b. The Permittee shall notify the Department and the EPA in writing of a proposed on-permit change under COMAR 26.11.03.18 not later than 7 days before the change is made. The written information shall include the following information:

(1) A description of the proposed change;

(2) The date on which the change is proposed to be made;

(3) Any change in emissions resulting from the change, including

the pollutants emitted;

(4) Any new applicable requirement of the Clean Air Act; and

(5) Any permit term or condition that would no longer apply.

c. The responsible official of this facility shall certify in accordance with COMAR 26.11.02.02F that the proposed change meets the criteria for the use of on-permit changes under COMAR 26.11.03.18.

d. The Permittee shall attach a copy of each notice required by

condition b. above to this Part 70 permit.

e. On-permit changes that qualify under COMAR 26.11.03.18 are not subject to the requirements for part 70 permit revisions.

f. Upon satisfying the requirements under COMAR 26.11.03.18, the

Permittee may make the proposed change.

g. The permit shield in COMAR 26.11.03.23 does not apply to on-permit changes under COMAR 26.11.03.18.

h. The Permittee is subject to enforcement action if it is determined that

an on-permit change made under COMAR 26.11.03.18 is not within the scope of the regulation or violates any requirement of the State air pollution control law.



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17. FEE PAYMENT [COMAR 26.11.02.16A(2) & (5)(b)]

a. The fee for this Part 70 permit is as prescribed in Regulation .19 of COMAR 26.11.02.

b. The fee is due on and shall be paid on or before each 12-month

anniversary date of the permit.

c. Failure to pay the annual permit fee constitutes cause for revocation of the permit by the Department.

18. REQUIREMENTS FOR PERMITS-TO-CONSTRUCT AND APPROVALS [COMAR 26.11.02.09.] The Permittee may not construct or modify or cause to be constructed or

modified any of the following sources without first obtaining, and having in current effect, the specified permits-to-construct and approvals:

a. New Source Review source, as defined in COMAR 26.11.01.01,

approval required, except for generating stations constructed by electric companies;

b. Prevention of Significant Deterioration source, as defined in COMAR

26.11.01.01, approval required, except for generating stations constructed by electric companies;

c. New Source Performance Standard source, as defined in COMAR

26.11.01.01, permit to construct required, except for generating stations constructed by electric companies;

d. National Emission Standards for Hazardous Air Pollutants source, as

defined in COMAR 26.11.01.01, permit to construct required, except for generating stations constructed by electric companies;

e. A stationary source of lead that discharges one ton per year or more

of lead or lead compounds measured as elemental lead, permit to construct required, except for generating stations constructed by electric companies;



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f. All stationary sources of air pollution, including installations and air pollution control equipment, except as listed in COMAR 26.11.02.10, permit to construct required;

g. In the event of a conflict between the applicability of (a.— e.) above

and an exemption listed in COMAR 26.11.02.10, the provision that requires a permit applies.

h. Approval of a PSD or NSR source by the Department does not

relieve the Permittee obtaining an approval from also obtaining all permits-to-construct required b y (c.— g.) above.

19. CONSOLIDATION OF PROCEDURES FOR PUBLIC PARTICIP ATION [COMAR 26.11.02.11C] and [COMAR 26.11.03.01K] The Permittee may request the Department to authorize special

procedures for the Permittee to apply simultaneously, to the extent possible, for a permit to construct and a revision to this permit.

These procedures may provide for combined public notices, informational

meetings, and public hearings for both permits but shall not adversely affect the rights of a person, including EPA and affected states, to obtain information about the application for a permit, to comment on an application, or to challenge a permit that is issued.

These procedures shall not alter any existing permit procedures or time

frames. 20. PROPERTY RIGHTS [COMAR 26.11.03.06E(4)] This Part 70 permit does not convey any property rights of any sort, or any

exclusive privileges.



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21. SEVERABILITY [COMAR 26.11.03.06A(5)] If any portion of this Part 70 permit is challenged, or any term or condition

deemed unenforceable, the remainder of the requirements of the permit continues to be valid.

22. INSPECTION AND ENTRY [COMAR 26.11.03.06G(3)] The Permittee shall allow employees and authorized representatives of

the Department, the EPA, and local environmental health agencies, upon presentation of credentials or other documents as may be required by law, to:

a. Enter at a reasonable time without delay and without prior notification

the Permittee’s property where a Part 70 source is located, emissions-related activity is conducted, or records required by this permit are kept;

b. Have access to and make copies of records required by the permit;

c. Inspect all emissions units within the facility subject to the permit and

all related monitoring systems, air pollution control equipment, and practices or operations regulated or required by the permit; and

d. Sample or monitor any substances or parameters at or related to the

emissions units at the facility for the purpose of determining compliance with the permit.

23. DUTY TO PROVIDE INFORMATION [COMAR 26.11.03.06E(5)] The Permittee shall furnish to the Department, within a reasonable time

specified by the Department, information requested in writing by the Department in order to determine whether the Permittee is in compliance with the federally enforceable conditions of this Part 70 permit, or whether cause exists for revising or revoking the permit. Upon request, the Permittee shall also furnish to the Department records required to be kept under the permit.



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For information claimed by the Permittee to be confidential and therefore

potentially not discloseable to the public, the Department may require the Permittee to provide a copy of the records directly to the EPA along with a claim of confidentiality.

The Permittee shall also furnish to the Department, within a reasonable

time specified by the Department, information or records requested in writing by the Department in order to determine if the Permittee is in compliance with the State-only enforceable conditions of this permit.

24. COMPLIANCE REQUIREMENTS [COMAR 26.11.03.06E(1)] and [COMAR 26.11.03.06A(11) ] and

[COMAR 26.11.02.05] The Permittee shall comply with the conditions of this Part 70 permit.

Noncompliance with the permit constitutes a violation of the Clean Air Act, and/or the Environment Article Title 2 of the Annotated Code of Maryland and may subject the Permittee to:

a. Enforcement action,

b. Permit revocation or revision,

c. Denial of the renewal of a Part 70 permit, or

d. Any combination of these actions.

The conditions in this Part 70 permit are enforceable by EPA and citizens

under the Clean Air Act except for the State-only enforceable conditions. Under Environment Article Section 2-609, Annotated Code of Maryland,

the Department may seek immediate injunctive relief against a person who violates this permit in such a manner as to cause a threat to human health or the environment.

25. CREDIBLE EVIDENCE Nothing in this permit shall be interpreted to preclude the use of credible

evidence to demonstrate noncompliance with any term of this permit.



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26. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE [COMAR 26.11.03.06E(2)] The need to halt or reduce activity in order to comply with the conditions of

this permit may not be used as a defense in an enforcement action. 27. CIRCUMVENTION [COMAR 26.11.01.06] The Permittee may not install or use any article, machine, equipment or

other contrivance, the use of which, without resulting in a reduction in the total weight of emissions, conceals or dilutes emissions which would otherwise constitute a violation of any applicable air pollution control regulation.

28. PERMIT SHIELD [COMAR 26.11.03.23] A permit shield as described in COMAR 26.11.03.23 shall apply only to

terms and conditions in this Part 70 permit that have been specifically identified as covered by the permit shield. Neither this permit nor COMAR 26.11.03.23 alters the following:

a. The emergency order provisions in Section 303 of the Clean Air Act,

including the authority of EPA under that section;

b. The liability of the Permittee for a violation of an applicable requirement of the Clean Air Act before or when this permit is issued or for a violation that continues after issuance;

c. The requirements of the Acid Rain Program, consistent with Section

408(a) of the Clean Air Act;

d. The ability of the Department or EPA to obtain information from a source pursuant to Maryland law and Section 114 of the Clean Air Act; or

e. The authority of the Department to enforce an applicable requirement

of the State air pollution control law that is not an applicable requirement of the Clean Air Act.



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29. ALTERNATE OPERATING SCENARIOS [COMAR 26.11.03.06A(9)] For all alternate operating scenarios approved by the Department and

contained within this permit, the Permittee, while changing from one approved scenario to another, shall contemporaneously record in a log maintained at the facility each scenario under which the emissions unit is operating and the date and time the scenario started and ended.



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SECTION III PLANT WIDE CONDITIONS 1. PARTICULATE MATTER FROM CONSTRUCTION AND DEMOLIT ION [COMAR 26.11.06.03D] The Permittee shall not cause or permit any building, its appurtenances, or

a road to be used, constructed, altered, repaired, or demolished without taking reasonable precautions to prevent particulate matter from becoming airborne.

2. OPEN BURNING [COMAR 26.11.07] Except as provided in COMAR 26.11.07.04, the Permittee shall not cause

or permit an open fire from June 1 through August 31 of any calendar year. Prior to any open burning, the Permittee shall request and receive approval from the Department.

3. AIR POLLUTION EPISODE [COMAR 26.11.05.04] When requested by the Department, the Permittee shall prepare in writing

standby emissions reduction plans, consistent with good industrial practice and safe operating procedures, for reducing emissions creating air pollution during periods of Alert, Warning, and Emergency of an air pollution episode.

4. REPORT OF EXCESS EMISSIONS AND DEVIATIONS [COMAR 26.11.01.07] and [COMAR 26.11.03.06C(7)] The Permittee shall comply with the following conditions for occurrences

of excess emissions and deviations from requirements of this permit, including those in Section VI – State-only Enforceable Conditions:

a. Report any deviation from permit requirements that could endanger

human health or the environment, by orally notifying the Department immediately upon discovery of the deviation;



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b. Promptly report all occurrences of excess emissions that are expected to last for one hour or longer by orally notifying the Department of the onset and termination of the occurrence;

c. When requested by the Department the Permittee shall report all

deviations from permit conditions, including those attributed to malfunctions as defined in COMAR 26.11.01.07A, within 5 days of the request by submitting a written description of the deviation to the Department. The written report shall include the cause, dates and times of the onset and termination of the deviation, and an account of all actions planned or taken to reduce, eliminate, and prevent recurrence of the deviation;

d. The Permittee shall submit to the Department semi-annual

monitoring reports that confirm that all required monitoring was performed, and that provide accounts of all deviations from permit requirements that occurred during the reporting periods. Reporting periods shall be January 1 through June 30 and July 1 through December 31, and reports shall be submitted within 30 days of the end of each reporting period. Each account of deviation shall include a description of the deviation, the dates and times of onset and termination, identification of the person who observed or discovered the deviation, causes and corrective actions taken, and actions taken to prevent recurrence. If no deviations from permit conditions occurred during a reporting period, the Permittee shall submit a written report that so states.

e. When requested by the Department, the Permittee shall submit a

written report to the Department within 10 days of receiving the request concerning an occurrence of excess emissions. The report shall contain the information required in COMAR 26.11.01.07D(2).

5. ACCIDENTAL RELEASE PROVISIONS [COMAR 26.11.03.03B(23)] and [40 CFR 68] Should the Permittee become subject to 40 CFR 68 during the term of this

permit, the Permittee shall submit risk management plans by the date specified in 40 CFR 68.150 and shall certify compliance with the requirements of 40 CFR 68 as part of the annual compliance certification as required by 40 CFR 70.



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The Permittee shall initiate a permit revision or reopening according to the procedures of 40 CFR 70.7 to incorporate appropriate permit conditions into the Permittee’s Part 70 permit.

6. GENERAL TESTING REQUIREMENTS [COMAR 26.11.01.04] The Department may require the Permittee to conduct, or have conducted,

testing to determine compliance with this Part 70 permit. The Department, at its option, may witness or conduct these tests. This testing shall be done at a reasonable time, and all information gathered during a testing operation shall be provided to the Department.

7. EMISSIONS TEST METHODS [COMAR 26.11.01.04] Compliance with the emissions standards and limitations in this Part 70

permit shall be determined by the test methods designated and described below or other test methods submitted to and approved by the Department.

Reference documents of the test methods approved by the Department

include the following:

a. 40 CFR 60, appendix A

b. 40 CFR 51, appendix M

c. The Department’s Technical Memorandum 91-01 “Test Methods and Equipment Specifications for Stationary Sources”, (January 1991), as amended through Supplement 3, (October 1, 1997)

8. EMISSIONS CERTIFICATION REPORT

[COMAR 26.11.01.05-1] and [COMAR 26.11.02.19C] and [COMAR 26.11.02.19D]

The Permittee shall certify actual annual emissions of regulated pollutants

from the facility on a calendar year basis.



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a. The certification shall be on forms obtained from the Department and submitted to the Department not later than April 1 of the year following the year for which the certification is required;

b. The individual making the certification shall certify that the

information is accurate to the individual’s best knowledge. The individual shall be:

(1) Familiar with each source for which the certifications forms are

submitted, and

(2) Responsible for the accuracy of the emissions information;

c. The Permittee shall maintain records necessary to support the emissions certification including the following information if applicable:

(1) The total amount of actual emissions of each regulated pollutant

and the total of all regulated pollutants;

(2) An explanation of the methods used to quantify the emissions and the operating schedules and production data that were used to determine emissions, including significant assumptions made;

(3) Amounts, types and analyses of all fuels used;

(4) Emissions data from continuous emissions monitors that are

required by this permit, including monitor calibration and malfunction information;

(5) Identification, description, and use records of all air pollution

control equipment and compliance monitoring equipment including:

(a) Significant maintenance performed, (b) Malfunctions and downtime, and (c) Episodes of reduced efficiency of all equipment;

(6) Limitations on source operation or any work practice standards

that significantly affect emissions; and

(7) Other relevant information as required by the Department.



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9. COMPLIANCE CERTIFICATION REPORT [COMAR 26.11.03.06G(6) and (7)] The Permittee shall submit to the Department and EPA Region III a report

certifying compliance with each term of this Part 70 permit including each applicable standard, emissions limitation, and work practice for the previous calendar year by April 1 of each year.

a. The compliance certification shall include:

(1) The identification of each term or condition of this permit which

is the basis of the certification;

(2) The compliance status;

(3) Whether the compliance was continuous or intermittent;

(4) The methods used for determining the compliance status of each source, currently and over the reporting period; and

(5) Any other information required to be reported to the Department

that is necessary to determine the compliance status of the Permittee with this permit.

b. The Permittee shall submit the compliance certification reports to the

Department and EPA simultaneously. 10. CERTIFICATION BY RESPONSIBLE OFFICIAL [COMAR 26.11.02.02F] All application forms, reports, and compliance certifications submitted

pursuant to this permit shall be certified by a responsible official as to truth, accuracy, and completeness. The Permittee shall expeditiously notify the Department of an appointment of a new responsible official.

The certification shall be in the following form: “I certify under penalty of law that this document and all attachments were

prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for



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gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.”

11. SAMPLING AND EMISSIONS TESTING RECORD KEEPING [COMAR 26.11.03.06C(5)] The Permittee shall gather and retain the following information when

sampling and testing for compliance demonstrations:

a. The location as specified in this permit, and the date and time that samples and measurements are taken;

b. All pertinent operating conditions existing at the time that samples

and measurements are taken;

c. The date that each analysis of a sample or emissions test is performed and the name of the person taking the sample or performing the emissions test;

d. The identity of the Permittee, individual, or other entity that performed

the analysis;

e. The analytical techniques and methods used; and

f. The results of each analysis. 12. GENERAL RECORDKEEPING [COMAR 26.11.03.06C(6)] The Permittee shall retain records of all monitoring data and information

that support the compliance certification for a period of five (5) years from the date that the monitoring, sample measurement, application, report or emissions test was completed or submitted to the Department.

These records and support information shall include:

a. All calibration and maintenance records;



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b. All original data collected from continuous monitoring instrumentation;

c. Records which support the annual emissions certification; and

d. Copies of all reports required by this permit.

13. GENERAL CONFORMITY [COMAR 26.11.26.09] The Permittee shall comply with the general conformity requirements of 40

CFR 93, Subpart B and COMAR 26.11.26.09. 14. ASBESTOS PROVISIONS [40 CFR 61, Subpart M] The Permittee shall comply with 40 CFR 61, Subpart M when conducting

any renovation or demolition activities at the facility. 15. OZONE DEPLETING REGULATIONS [40 CFR 82, Subpart F] The Permittee shall comply with the standards for recycling and emissions

reduction pursuant to 40 CFR 82, Subpart F, except as provided for MVACs in subpart B:

a. Persons opening appliances for maintenance, service, repair, or

disposal shall comply with the prohibitions and required practices pursuant to 40 CFR 82.154 and 82.156.

b. Equipment used during the maintenance, service, repair or disposal

of appliances shall comply with the standards for recycling and recovery equipment pursuant to 40 CFR 82.158.

c. Persons performing maintenance, service, repairs or disposal of

appliances shall be certified by an approved technician certification program pursuant to 40 CFR 82.161.



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d. Persons performing maintenance, service, repairs or disposal of appliances shall certify with the Administrator pursuant to 40 CFR 82.162.

e. Persons disposing of small appliances, MVACS, and MVAC-like

appliances as defined in 40 CFR 82.152, shall comply with record keeping requirements pursuant to 40 CFR 82.166.

f. Persons owning commercial or industrial process refrigeration

equipment shall comply with the leak repair requirements pursuant to 40 CFR 82.156.

g. Owners/operators of appliances normally containing 50 or more

pounds of refrigerant shall keep records of refrigerant purchased and added to such appliances pursuant to 40 CFR 82.166.

16. ACID RAIN PERMIT Not applicable



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SECTION IV PLANT SPECIFIC CONDITIONS This section provides tables that include the emissions standards, emissions limitations, and work practices applicable to each emissions unit located at this facility. The Permittee shall comply with all applicable emissions standards, emissions limitations and work practices included herein. The tables also include testing, monitoring, record keeping and reporting requirements specific to each emissions unit. In addition to the requirements included here in Section IV , the Permittee is also subject to the general testing, monitoring, record keeping and reporting requirements included in Section III – Plant Wide Conditions of this permit. Unless otherwise provided in the specific requirements for an emissions unit, the Permittee shall maintain at the facility for at least five (5) years, and shall make available to the Department upon request, all records that the Permittee is required under this section to establish. [Authority: COMAR 26.11.03.06C(5)(g)]

Table IV – 0 (General Provisions for Section IV) 0.0 General Provisions Within Plant Specific Requiremen ts:

This table provides generally applicable provisions with regard to requirements for observations for visible emissions, preparation of operations and maintenance plans, preparation of best management practice plans for unconfined sources, stack testing, record keeping and reporting. Provisions included in this table will be referenced in succeeding tables in this section when such provisions are applicable. Provisions in this table may also be superseded or modified by requirements in succeeding tables in this section. INDEX: 1.1 Observations For Visible Emissions 1.2 Operations and Maintenance Plans 1.3 Best Management Practices Plans For Unconfined Sources 1.4 Performance Test Protocols 1.5 Record Keeping and Reporting

0.1 Observations For Visible Emissions: Unless otherwise provided in the specific requirements for an affected emissions unit or emissions point, whenever the Permittee is required to perform an observation for visible emissions the following shall apply:

(A) Each required observation of an emissions point shall be

performed when the affected source of emissions is in operation. If the affected source of emissions does not operate



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Table IV – 0 (General Provisions for Section IV) within the period during which an observation would otherwise be required, the Permittee shall not be required to make an observation of the emissions point for that period.

(B) If the Permittee is required to observe an emissions point that is

common to more than one source of emissions, the Permittee shall make the required observation when at least one of the sources of emissions is in operation. If none of the affected sources of emissions operate within the period during which an observation would otherwise be required, the Permittee shall not be required to make an observation of the emissions point for that period.

(C) Observations shall be performed during daylight hours unless

the Permittee obtains from the Department written approval to conduct observations of properly lighted emissions points during non-daylight hours.

(D) Excepting observations for visible emissions from exhaust

stacks on fuel burning equipment, each required observation for visible emissions shall endure for at least one (1) minute unless a longer duration is specified in the Part 70 operating permit condition that requires the observation. Required observations for visible emissions from exhaust stacks on fuel burning equipment (e.g., boilers, thermal oil heaters) shall be performed in accordance with Method 9 and shall endure for at least 18 minutes unless a different duration is specified in the Part 70 permit condition that requires the observation.

(E) The Permittee shall make a written or printable electronic record

of each required observation for visible emissions, and each such record shall include identification of the observer, the date of the observation, the time at the start of the observation, the time at the end of the observation if the observation endures for more than 1 minute, and an account of the observer’s findings during performance of the observation.

[Authority: COMAR 26.11.03.06C] 0.2 Operations and Maintenance Plans:

Unless otherwise provided in the specific requirements for an emissions unit or plant, whenever the Permittee is required to develop and implement an operations and maintenance (O&M) plan, the plan shall include at minimum:



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Table IV – 0 (General Provisions for Section IV) (A) Information that is sufficient to demonstrate that air emissions

from each affected emissions unit can be expected to comply with all applicable standards and limits during periods of normal operation. Examples of types of information that could be included to support the required demonstrations would be design criteria, vendor specifications and performance guarantees, approved computer modeling studies, and results of testing programs in which approved test methods and procedures were utilized;

(B) Procedures that provide for proper operation and maintenance

(including preventive maintenance) of all affected emissions units and air pollution control equipment associated with the source;

(C) Provisions for periodic monitoring of operating parameters and

emissions as necessary to determine that affected emissions units and air pollution control equipment are functioning properly;

(D) Provisions for periodic inspections, to be conducted at least as

frequently as once per month, to determine whether responsible persons are complying with the provisions and procedures included in the required O&M plan;

(E) Descriptions of procedures to be followed and corrective actions

to be taken when inspections or monitoring information indicate that an emissions unit or pollution control device is not functioning properly; and

(F) Provisions for developing written or printable electronic records

that show whether prescribed operating, maintenance and monitoring procedures are consistently followed, and whether timely and appropriate corrective actions are taken when malfunctions occur.

[Authority: COMAR 26.11.03.06C]

0.3 Best Management Practices Plans For Unconfined Sources: Unless otherwise provided in the specific requirements for an emissions unit, whenever the Permittee is required to develop and implement a best management practices (BMP) plan for control of particulate emissions from an unconfined source, such plan shall identify all reasonable precautions to be implemented to prevent particulate matter from becoming airborne.



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Table IV – 0 (General Provisions for Section IV) Such reasonable precautions shall include: (1) Housekeeping measures to minimize excess dust, including (a) using

either an industrial vacuum system or manual sweeping to reduce the amount of dust; (b) at least once per month, removing dust from walls, ledges, and equipment using low pressure air or other means, and then sweeping or vacuuming the area; and (c) keeping exterior doors in the immediate affected areas shut except during normal ingress and egress, as practicable.

(2) Maintaining and operating all process equipment in accordance with

manufacturer's specifications and in a manner to minimize dust creation.

(3) Storing raw materials in closed containers, as practicable. (4) Keeping mixers covered when mixing is occurring except when

materials are added to the mixer. (5) For bulk loading processes where materials are loaded into trucks or

railcars, lessen fugitive emissions by reducing the distance between the loadout spout and the vehicle being loaded by using a device of any kind at the bulk loadout spout that minimizes the distance to the vehicle being loaded, or using any other means to minimize the distance between the loadout spout and the vehicle being loaded.

The BMP plan shall include provisions for periodic inspections, to be conducted at least once per month, to determine whether reasonable precautions identified in the plan are consistently employed. [Authority: COMAR 26.11.03.06C, COMAR 26.11.06.03C( 1), and COMAR 26.11.06.03C]

0.4 Performance Test Protocols: (A) Unless otherwise provided in the specific requirements for an

emissions unit or emissions point, when the Permittee is required to perform stack testing the Permittee shall submit to the Department for approval a stack test protocol that includes:

(1) the purpose of the stack testing; (2) a testing schedule that provides the projected dates

and times of testing;



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Table IV – 0 (General Provisions for Section IV) (3) an account of all test methods and procedures to be

employed during the testing program; (4) for the emissions source or sources to be tested, an

account of the operating conditions that will be extant during the testing program;

(5) for fuel burning sources, identification of the types of

fuels that will be burned during the testing periods; and (6) identification of operating data that will be collected

during the testing periods. (B) The required stack test protocol shall be submitted at least 30 days

prior to performance of any testing, and testing shall not be conducted before the Department provides approval of the protocol.

(C) Results of all required stack tests shall be submitted to the Department

in writing within 60 days of completion of the testing. [Authority: COMAR 26.11.03.06G]

0.5 Record Keeping and Reporting Requirements: (A) Unless otherwise provided in the specific requirements for an

emissions unit or emissions point, the Permittee shall maintain at the facility for at least five (5) years, and shall make available to the Department upon request, all records that the Permittee is required by this Part 70 operating permit to establish.

(B) Records required by this Part 70 operating permit shall be

maintained in a format that is acceptable to the Department. A format adopted by the Permittee shall be considered acceptable until the Department provides the Permittee with written notice otherwise.

(C) Unless otherwise specified in this Part 70 operating permit

required records shall be maintained either in writing or in a printable electronic form.

[Authority: COMAR 26.11.03.06C] Note: A permit shield shall cover the applicable requirements identified above for General Provisions within plant specific requirements



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Table IV – 1 1.0 Emissions Unit Number(s)

EU01: Fuel burning equipment – one backup boiler (#5-0378, 29 MMBTU/Hr). Since the boiler was installed before June 9, 1989, it is not subject to any NSPS, but is subject to 40 CFR 63, Subpart DDDDD.

1.1 Applicable Standards/Limits : A. Visible Emissions Limitations

COMAR 26.11.09.05A(2) which prohibits visible emissions other than water in an uncombined form.

Exceptions. COMAR 26.11.09.05A(3) establishes that Section A(2) does not apply to emissions during load changing, soot blowing, start-up, or adjustments or occasional cleaning of control equipment if: (a) the visible emissions are not greater than 40 percent opacity; and (b) the visible emissions do not occur for more than 6 consecutive minutes in any sixty minutes.

B. Control of Sulfur Oxides

COMAR 26.11.09.07A(2) which limits the sulfur content in distillate fuel oil to 0.3 percent by weight.

C. Control of NOx – NOx RACT Requirements 1. A person who owns or operates fuel-burning equipment with a rated

heat input capacity of 100 MMBtu per hour or less shall:

(a) Submit to the Department an identification of each affected installation, the rated heat input capacity of each installation, and the type of fuel burned in each;

(b) Perform a combustion analysis for each installation at least once

each year and optimize combustion based on the analysis; (c) Maintain the results of the combustion analysis at the site for at

least 5 years and make this data available to the Department and the EPA upon request;

(d) Once every 3 years, require each operator of the installation to

attend operator training programs on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and

(e) Prepare and maintain a record of training program attendance for



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Table IV – 1 each operator at the site, and make these records available to the Department upon request.

[Reference: COMAR 26.11.09.08E]

2. For the purposes of COMAR 26.11.09.08, the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation. [Reference: COMAR 26.11.09.08B(5)]

D. Operating Requirements

The boilers shall burn only natural gas or propane gas except during periods of gas curtailment or gas supply interruptions of any duration as defined in 40 CFR §63.7575. No. 2 fuel oil may be burned only during periods of gas curtailment or gas supply interruptions or for periodic testing of liquid fuel, maintenance, or operator training, not to exceed a combined total of 48 hours during any calendar year. [Authority: 40 CFR §63.7575]

E. Control of HAP No later than January 31, 2016 for EU01, the Permittee shall comply with the work practice requirements of 40 CFR 63, Subpart DDDDD [Authority: 40 CFR §63.7495(a) and (b)]

1.2 Testing Requirements : A. Visible Emissions Limitations

See monitoring, record keeping, and reporting requirements.

B. Control of Sulfur Oxides The Permittee shall determine the sulfur content of fuel oils burned in emissions unit EU01 by providing a certification of the sulfur content from the fuel supplier.

C. Control of NOx The Permittee shall perform a combustion analysis for each installation at least once each year and optimize combustion based on the analysis [COMAR 26.11.09.08E(2)].


See record keeping and reporting requirements.



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Table IV – 1 E. Control of HAP

1. The Permittee must have a one-time energy assessment performed by a qualified energy assessor no later than January 31, 2016. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements of 40 CFR 63, Subpart DDDDD, satisfies the energy assessment requirement. A facility that operates under an energy management program compatible with ISO 50001 that includes the affected units also satisfies the energy assessment requirement. The energy assessment must include the following with extent of the evaluation for items (1) through (5) appropriate for the on-site technical hours listed in 40 CFR §63.7575:

(a) A visual inspection of the boiler or process heater system.

(b) An evaluation of operating characteristics of the boiler or process

heater systems, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints.

(c) An inventory of major energy use systems consuming energy from

affected boilers and process heaters and which are under the control of the boiler/process heater owner/operator.

(d) A review of available architectural and engineering plans, facility

operation and maintenance procedures and logs, and fuel usage.

(e) A review of the facility's energy management practices and provide recommendations for improvements consistent with the definition of energy management practices, if identified.

(f) A list of cost-effective energy conservation measures that are within

the facility's control.

(g) A list of the energy savings potential of the energy conservation measures identified.

(h) A comprehensive report detailing the ways to improve efficiency,

the cost of specific improvements, benefits, and the time frame for recouping those investments.

[Authority: 40 CFR §63.7495(b), §63.7510(e) and Tab le 3, Item 4 to 40 CFR 63, Subpart DDDDD]



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Table IV – 1 2. The Permittee must complete an initial tune-up no later than January

31, 2016 EU01 boiler. If the boiler has not operated between January 31, 2013 and January 31, 2016, the Permittee must complete an initial tune-up no later than 30 days after the re-start of the affected unit. The Permittee shall conduct subsequent annual tune-ups no more than 13 months after the previous tune-up. Initial and subsequent annual tune-ups shall be conducted in accordance with the following requirements:

(1) As applicable, inspect the burner, and clean or replace any

components of the burner as necessary (the Permittee may delay the burner inspection until the next scheduled unit shutdown).

(2) Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available.

(3) Inspect the system controlling the air-to-fuel ratio, as applicable,

and ensure that it is correctly calibrated and functioning properly (the Permittee may delay the inspection until the next scheduled unit shutdown).

(4) Optimize total emissions of CO. This optimization should be

consistent with the manufacturer's specifications.

(5) Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer.

(6) Maintain on-site and submit, if requested by the Department, an

annual report containing the following information:

(a) The concentrations of CO in the effluent stream in parts per million by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler or process heater;

(b) A description of any corrective actions taken as a part of the tune-up; and

(c) The type and amount of fuel used over the 12 months prior to the

tune-up, but only if the unit was physically and legally capable of



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Table IV – 1 using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel used by each unit.

(7) If the boiler is not operating on the required date for a tune-up, the

tune-up must be conducted within 30 calendar days of startup. [Authority: 40 CFR §63.7495(b), §63.7510(e), (g) an d (j), §63.7515(d), §63.7540(a)(10) and (a)(13), and Table 3, Item 3 to 40 CFR 63, Subpart DDDDD]

1.3 Monitoring Requirements:

A. Visible Emissions Limitations

The Permittee shall:

(a) Properly operate and maintain the boiler; and

(b) Verify no visible emissions when burning No. 2 fuel oil. The Permittee shall conduct a visible emissions observation of the exhaust gases from the boiler exhaust stack for a 6 minutes period once for each 168 hours that the boiler burns No. 2 fuel oil or at a minimum of once per year and shall record the results of each observation. [Authority: COMAR 26.11.03.06C]

If the emissions in the exhaust gases are visible, the Permittee shall perform the following:

(1) Inspect all process and/or control equipment that may affect visible

emissions; [COMAR 26.11.03.06C]

(2) Perform all necessary repairs and/or adjustments to processes or control equipment within 48 hours, so that visible emissions in the exhaust gases are eliminated; [COMAR 26.11.03.06C]

(3) Document, in writing, the results of the inspections and the repairs

and/or adjustments made to the processes and/or control equipment; [COMAR 26.11.03.06C] and

(4) If visible emissions have not been eliminated within 48 hours, the

Permittee shall perform a Method 9 observation once daily for an 18 minute period until corrective actions have eliminated the visible emissions. [COMAR 26.11.03.06C]

(c) The Permittee shall establish in writing, revise as necessary and



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Table IV – 1 implement an operations and maintenance (O&M) plan developed and implemented in accordance with Section 0.2 of Table IV-0 of this Part 70 operating permit. [Authority: COMAR 26.11.03.06C]

B. Control of Sulfur Oxides The Permittee shall obtain a certification from the fuel supplier that includes the following information: (a) the name of the oil supplier; (b) a statement from the oil supplier that the oil complies with the specifications included in the definition of distillate oil under COMAR 26.11.09.01; and (c) the sulfur content of the oil [COMAR 26.11.03.06C].

C. Control of NOx

(1) The Permittee shall submit to the Department an identification of the boiler, the rated heat input capacity, and the type of fuel burned in the boiler [COMAR 26.11.09.08E(1)].

(2) the Permittee shall at least once every 3 years require each operator of the emissions unit to attend an operator training program on combustion optimization that is sponsored by the Department, the EPA or equipment vendors. In accordance with COMAR 26.11.09.08B(5)(a), the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation. [Authority: COMAR 26.11.09.08E(4) and COMAR 26.11.09.08B(5)(a)]



E. Control of HAP At all times, the Permittee must operate and maintain the boilers, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Department that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. [Authority: 40 CFR §63.7500(a)(3)]

1.4 Record Keeping Requirements : NOTE: Except as otherwise provided in this part, all records must be maintained for a period of 5 years [COMAR 26.11.03.06.C(5)(g)].



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Table IV – 1 A. Visible Emissions Limitations

The Permittee shall Maintain a log of visible emissions observations performed and make it available to the Department’s representative upon request. [COMAR 26.11.03.06C]


(1) The Permittee shall maintain records of fuel supplier’s certification

and shall make records available to the Department upon request [COMAR 26.11.03.06C].

(2) Maintain a record of the hours that No. 2 fuel oil is burned. [COMAR

26.11.03.06C] C. Control of NOx

(1) The Permittee shall maintain the results of the combustion analysis at the site for at least two years and make this data available to the Department and the EPA upon request [COMAR 26.11.09.08E(3)].

(2) The Permittee shall prepare and maintain a record of training

program attendance for each operator at the site, and make these records available to the Department upon request [COMAR 26.11.09.08E(5)].

(3) Maintain a record of the maintenance performed that relates to

combustion performance. [COMAR 26.11.03.06C]

(4) Maintain an operation manual and prevention maintenance plan on site. [COMAR 26.11.03.06C]

(5) The Permittee shall maintain on site for at least 5 years, and shall make available to the Department upon request, records of monthly and annual fuel use. [Authority: COMAR 26.11.03.06C and COMAR 26.11.09.08K(3)]


(1) The Permittee shall maintain a copy of the interruptible natural gas service contract that the Permittee is required by this Part 70 operating permit to maintain with a utility company under the jurisdiction of the Maryland Public Service Commission. [Authority: COMAR 26.11.03.06C]



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Table IV – 1

(2) The Permittee shall maintain records of all periods during which the Permittee's natural gas service was interrupted or curtailed. [Authority: COMAR 26.11.03.06C]

(3) The Permittee shall maintain records of all fuels burned in the boilers during periods when natural gas was available, and records of all fuels burned in the boilers when natural gas service was interrupted or curtailed. [Authority: COMAR 26.11.03.06C]

E. Control of HAP

(1) The Permittee shall maintain a copy of each notification and report that the Permittee submitted to comply with 40 CFR 63, Subpart DDDDD, including all documentation supporting any Initial Notification or Notification of Compliance Status or semiannual compliance report that the Permittee submitted, according to the requirements in 40 CFR §63.10(b)(2)(xiv).

(2) The Permittee shall keep records of compliance demonstrations and performance evaluations as required in 40 CFR §63.10(b)(2)(viii).

(3) The Permittee shall keep records of the total hours per calendar year that alternative fuel (No. 2 or No. 6 oil) is burned and the total hours per calendar year that the unit operated during periods of gas curtailment or gas supply emergencies.

(4) Records must be in a form suitable and readily available for expeditious review, according to 40 CFR §63.10(b)(1).

(5) As specified in 40 CFR §63.10(b)(1), the Permittee must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record.

(6) The Permittee must keep each record on site, or they must be accessible from on site (for example, through a computer network), for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to 40 CFR §63.10(b)(1). The Permittee can keep the records off site for the remaining 3 years.

[Authority: 40 CFR §63.7555(a) and (h), and 40 CFR §63.7560(a), (b), and (c)]

1.5 Reporting Requirements : A. Visible Emissions Limitations

The Permittee shall report incidents of visible emissions in accordance with permit condition 4, Section III, Plant Wide Conditions, “Report of Excess Emissions and Deviations”.



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Table IV – 1 B. Control of Sulfur Oxides

The Permittee shall report fuel supplier certification to the Department upon request [Authority: COMAR 26.11.09.07C].

C. Control of NOx

See record keeping requirements D. Operating Requirements

The Permittee shall submit required fuel records to the Department upon request. [Authority: COMAR 26.11.03.06C]

E. Control of HAP (1) The Permittee must submit to the Department all of the notifications

in 40 CFR §§63.7(b) and (c), 63.8(e), (f)(4) and (6), and 63.9(b) through (h) that apply to the Permittee by the dates specified. [Authority: 40 CFR §63.7545(a)]

(2) The Permittee must submit a Notification of Compliance Status according to 40 CFR §63.9(h)(2)(ii) before the close of business on the 60th day following the completion of all initial compliance demonstrations for all boilers according to 40 CFR §63.10(d)(2). The Notification of Compliance Status report must contain all the following information:

(a) A description of the affected unit(s) including identification of

which subcategories the unit is in, the design heat input capacity of the unit, description of the fuel(s) burned, and justification for the selection of fuel(s) burned during the compliance demonstration.

(b) A signed certification that the Permittee has met all applicable work practice standards.

(c) If the Permittee had a deviation from any work practice standard,

the Permittee must also submit a description of the deviation, the duration of the deviation, and the corrective action taken in the Notification of Compliance Status report.

(d) In addition to the information required in §63.9(h)(2), the

notification of compliance status must include the following certification(s) of compliance, as applicable, and signed by a responsible official:



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Table IV – 1

(i) “This facility complies with the required initial tune-up according to the procedures in 40 CFR §63.7540(a)(10)(i) through (vi).”

(ii) “This facility has had an energy assessment performed according to 40 CFR §63.7530(e).”

(iii) Except for units that burn only natural gas, refinery gas, or

other gas 1 fuel, or units that qualify for a statutory exemption as provided in section 129(g)(1) of the Clean Air Act, include the following: “No secondary materials that are solid waste were combusted in any affected unit.”

[Authority: 40 CFR §63.7545(e)]

(3) If the Permittee intends to use a fuel other than natural gas to fire the affected unit during a period of natural gas curtailment or supply interruption, as defined in 40 CFR §63.7575, the Permittee must submit a notification of alternative fuel use within 48 hours of the declaration of each period of natural gas curtailment or supply interruption, as defined in 40 CFR §63.7575. The notification must include the following information:

(a) Company name and address.

(b) Identification of the affected unit.

(c) Reason the Permittee is unable to use natural gas or equivalent fuel, including the date when the natural gas curtailment was declared or the natural gas supply interruption began.

(d) Type of alternative fuel that the Permittee intends to use.

(e) Dates when the alternative fuel use is expected to begin and end.

(4) The Permittee shall submit annual compliance reports to the Department. The first compliance report must cover the period beginning on January 31, 2016 and ending on December 31, 2016. The first compliance report must be postmarked or submitted no later than January 31, 2017. Each subsequent compliance report must cover the annual periods from January 1 to December 31. Each subsequent compliance report must be postmarked or submitted no later than January 31 following the end of the annual period. Each compliance report must contain the following information:



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Table IV – 1 (a) Company and Facility name and address.

(b) Process unit information, emissions limitations, and operating

parameter limitations.

(c) Date of report and beginning and ending dates of the reporting period.

(d) The total operating time during the reporting period.

(e) Include the date of the most recent tune-up for each unit subject

to only the requirement to conduct an annual tune-up according to 40 CFR §63.7540(a)(10). Include the date of the most recent burner inspection if it was not done annually and was delayed until the next scheduled or unscheduled unit shutdown.

(5) The Permittee shall submit the initial and annual compliance reports

to the EPA electronically using CEDRI that is accessed through the EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to 40 CFR 63, Subpart DDDDD is not available in CEDRI at the time that the report is due the report the Permittee must submit the report to EPA Region III at the appropriate address listed in 40 CFR §63.13.

[Authority: 40 CFR §63.7530(d), (e), and (f), §63.7 545(e) and (f), §63.7550(a) through (e) and (h), and Table 9 to 40 CFR 63, Subpart DDDDD]

Note: A permit shield shall cover the applicable requirements identified above for the emission units EU01.


EU02: Fuel burning equipment – one primary boiler (#5-0412, 40 MMBTU/Hr) installed after June 9, 1989. This emission unit includes one 40 million BTU/hr Cleaver-brooks fire tube boiler. The boiler is natural gas fired. Propane gas and No. 2 fuel oil are the back-up fuels during the interruptions of natural gas. Since the boiler was installed in 1994 (after June 9, 1989), it is subject to NSPS Subpart Dc and NESHAP Subpart DDDDD.



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Table IV – 2 2.1 Applicable Standards/Limits :


COMAR 26.11.09.05A(2) which prohibits visible emissions other than water in an uncombined form.


40 CFR §60.43c(c) and (d) - Except during periods of start up, shut down, or malfunction, when the Permittee is burning fuel oil in an NSPS boiler the Permittee shall operate the unit so that the opacity of any exhaust gases does not exceed 20 percent on a 6-minute average, except for one (1) 6-minute period per hour of not more than 27 percent. [Reference: 40 CFR §60.43c(c) and (d)].

Compliance with the “No Visible Emissions” requirement of COMAR 26.11.09.05A(2) will be used to show compliance with this NSPS standard.


COMAR 26.11.09.07A(2)(b) which limits the sulfur content in distillate fuel oil to 0.3 percent by weight. 40 CFR §60.42c(d) establishes that compliance with the SO2 standard for affected units may be demonstrated by use of fuel oil with a sulfur content that does not exceed 0.5 percent by weight. Compliance with COMAR 26.11.09.07A(2)(b), which requires 0.3 % sulfur content by weight, will be used to demonstrate compliance with this NSPS standard.

C. Control of NOx – NOx RACT Requirements

1. A person who owns or operates fuel-burning equipment with a rated

heat input capacity of 100 MMBtu per hour or less shall:

(a) Submit to the Department an identification of each affected installation, the rated heat input capacity of each installation, and



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Table IV – 2 the type of fuel burned in each;

(b) Perform a combustion analysis for each installation at least once

each year and optimize combustion based on the analysis; (c) Maintain the results of the combustion analysis at the site for at

least 5 years and make this data available to the Department and the EPA upon request;

(d) Once every 3 years, require each operator of the installation to

attend operator training programs on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and

(e) Prepare and maintain a record of training program attendance for

each operator at the site, and make these records available to the Department upon request.

[Reference: COMAR 26.11.09.08E]

2. For the purposes of COMAR 26.11.09.08, the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation. [Reference: COMAR 26.11.09.08B(5)]


The boilers shall burn only natural gas except during periods of gas curtailment or gas supply interruptions of any duration as defined in 40 CFR §63.7575. No. 2 oil may be burned only during periods of gas curtailment or gas supply interruptions or for periodic testing of liquid fuel, maintenance, or operator training, not to exceed a combined total of 48 hours during any calendar year. [Authority: 40 CFR §63.7575]

E. Control of HAP No later than January 31, 2016, the Permittee shall comply with the work practice requirements of 40 CFR 63, Subpart DDDDD [Authority: 40 CFR §63.7495(a) and (b)]

2.2 Testing Requirements : A. Visible Emissions Limitations

See monitoring, record keeping, and reporting requirements.



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Table IV – 2 B. Control of Sulfur Oxides

(1) For distillate oil-fired NSPS affected facilities with heat input capacities between 10 and 100 MMBtu/hr, compliance with the emission limits, or fuel oil sulfur limits may be determined based on a certification from the fuel supplier, as described under 40CFR60.48c(f), as applicable. [Reference 40CFR60.42c(h)(1)]

(2) For any No. 2 fuel oil fired in the boilers, the performance test to determine compliance status with regard to the applicable SO2 standard shall consist of the certification from the fuel supplier, as described in 40 CFR §60.48c(f)(1). [Authority: 40 CFR §60.44c(h)]

C. Control of NOx

The Permittee shall perform a combustion analysis for each installation at least once each year and optimize combustion based on the analysis [COMAR 26.11.09.08E(2)].



E. Control of HAP (1) The Permittee must have a one-time energy assessment performed

by a qualified energy assessor no later than January 31, 2016. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements of 40 CFR 63, Subpart DDDDD, satisfies the energy assessment requirement. A facility that operates under an energy management program compatible with ISO 50001 that includes the affected units also satisfies the energy assessment requirement. The energy assessment must include the following with extent of the evaluation for items (1) through (5) appropriate for the on-site technical hours listed in 40 CFR §63.7575:

(i) A visual inspection of the boiler or process heater system.

(ii) An evaluation of operating characteristics of the boiler or process

heater systems, specifications of energy using systems, operating and maintenance procedures, and unusual operating constraints.

(iii) An inventory of major energy use systems consuming energy

from affected boilers and process heaters and which are under



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Table IV – 2 the control of the boiler/process heater owner/operator.

(iv) A review of available architectural and engineering plans, facility

operation and maintenance procedures and logs, and fuel usage.

(v) A review of the facility's energy management practices and provide recommendations for improvements consistent with the definition of energy management practices, if identified.

(vi) A list of cost-effective energy conservation measures that are within the facility's control.

(vii) A list of the energy savings potential of the energy conservation measures identified.

(viii) A comprehensive report detailing the ways to improve

efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments.

[Authority: 40 CFR §63.7495(b), §63.7510(e) and Tab le 3, Item 4 to 40 CFR 63, Subpart DDDDD]

(2) The Permittee must complete an initial tune-up no later than January

31, 2016 for the boiler. If the boiler has not operated between January 31, 2013 and January 31, 2016, the Permittee must complete an initial tune-up no later than 30 days after the re-start of the affected unit. For each boiler, the Permittee shall conduct subsequent annual tune-ups no more than 13 months after the previous tune-up. Initial and subsequent annual tune-ups shall be conducted in accordance with the following requirements:

(a) As applicable, inspect the burner, and clean or replace any

components of the burner as necessary (the Permittee may delay the burner inspection until the next scheduled unit shutdown).

(b) Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available.

(c) Inspect the system controlling the air-to-fuel ratio, as applicable,

and ensure that it is correctly calibrated and functioning properly (the Permittee may delay the inspection until the next scheduled unit shutdown).

(d) Optimize total emissions of CO. This optimization should be



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Table IV – 2 consistent with the manufacturer's specifications, if available, and with any NOX requirement to which the unit is subject.

(e) Measure the concentrations in the effluent stream of CO in parts

per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer.

(f) Maintain on-site and submit, if requested by the Department, an

annual report containing the following information: (i) The concentrations of CO in the effluent stream in parts per

million by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler or process heater;

(ii) A description of any corrective actions taken as a part of the tune-up; and

(iii) The type and amount of fuel used over the 12 months prior to

the tune-up, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel used by each unit.

(g) If the boiler is not operating on the required date for a tune-up, the

tune-up must be conducted within 30 calendar days of startup. [Authority: 40 CFR §63.7495(b), §63.7510(e), (g) an d (j), §63.7515(d), §63.7540(a)(10) and (a)(13), and Table 3, Item 3 to 40 CFR 63, Subpart DDDDD

2.3 Monitoring Requirements: A. Visible Emissions Limitations

The Permittee shall: (1) The Permittee shall establish in writing, revise as necessary and

implement an operations and maintenance (O&M) plan developed and implemented in accordance with Section 0.2 of Table IV-0 of this Part 70 operating permit. [Authority: COMAR 26.11.03.06C]

(2) The Permittee shall submit to the Department for approval a written site-specific monitoring plan that includes procedures and criteria for



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Table IV – 2 establishing and monitoring specific parameters for the boilers indicative of compliance with the opacity standard. For testing performed as part of this site-specific monitoring plan, the Department may require as an alternative to the notification and reporting requirements specified in 40 CFR §§60.8 and 60.11 that the Permittee submit any deviations with the excess emissions report required under 40 CFR §60.48c(c). [Authority: 40 CFR §60.47c(f)(3)] Such site-specific monitoring plan may be included in the O&M plan required under paragraph (1) of this Section.

(3) The Permittee shall conduct a visible emissions observation of the exhaust gases from each boiler exhaust stack for a 6 minutes period once for each 168 hours that the boiler burns No. 2 fuel oil or at a minimum of once per year and shall record the results of each observation. [Authority: COMAR 26.11.03.06C]

If the emissions in the exhaust gases are visible, the Permittee shall perform the following:

(a) Inspect all process and/or control equipment that may affect visible


(b) Perform all necessary repairs and/or adjustments to processes or control equipment within 48 hours, so that visible emissions in the exhaust gases are eliminated; [COMAR 26.11.03.06C] and

(c) Document, in writing, the results of the inspections and the repairs

and/or adjustments made to the processes and/or control equipment. [COMAR 26.11.03.06C]

(d) If visible emissions have not been eliminated within 48 hours, the



The Permittee shall obtain a certification from the fuel supplier indicating that the oil complies with the limitation on the sulfur content of the fuel oil [40CFR 60.44c(h)]. The supplier certification shall include the following information 40CFR60.48c(f)(1):

(1) The name of the oil supplier;



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Table IV – 2 (2) A statement from the oil supplier that the oil complies with the

specifications under the definition of distillate oil in 40CFR60.41c; and

(3) The sulfur content or maximum sulfur content of the oil.

C. Control of NOx (1) The Permittee shall submit to the Department an identification of the

boiler, the rated heat input capacity, and the type of fuel burned in the boiler [COMAR 26.11.09.08E(1)].

(2) the Permittee shall at least once every 3 years require each operator of the emissions unit to attend an operator training program on combustion optimization that is sponsored by the Department, the EPA or equipment vendors. In accordance with COMAR 26.11.09.08B(5)(a), the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation. [Authority: COMAR 26.11.09.08E(4) and COMAR 26.11.09.08B(5)(a)]



E. Control of HAP At all times, the Permittee must operate and maintain the boilers, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Department that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. [Authority: 40 CFR §63.7500(a)(3)]

2.4 Record Keeping Requirements : NOTE: Except as otherwise provided in this part, all records must be maintained for a period of 5 years [COMAR 26.11.03.06.C(5)(g)]. A. Visible Emissions Limitations

The Permittee shall maintain a log of visible emissions observations



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Table IV – 2 performed and make it available to the Department’s representative upon request. [COMAR 26.11.03.06C]


(1) The Permittee shall maintain records of fuel supplier’s certification and shall make records available to the Department upon request [40CFR 60.48c(e)].

(2) For No. 2 fuel oil combusted in any of the boilers, fuel oil supplier certification that includes the following information: (a) the name of the oil supplier; (b) a statement from the oil supplier that the oil complies with the specifications under the definition of distillate oil in 40 CFR §60.41c; and (c) the sulfur content or maximum sulfur content of the oil. [Authority: 40 CFR §60.48c(f)(1)]

(3) The Permittee shall maintain a record of the hours that No. 2 fuel oil

is burned. [COMAR 26.11.03.06C]

C. Control of NOx

(1) The Permittee shall maintain the results of the combustion analysis at the site for at least two years and make this data available to the Department and the EPA upon request [COMAR 26.11.09.08E(3)].

(2) The Permittee shall prepare and maintain a record of training

program attendance for each operator at the site, and make these records available to the Department upon request [COMAR 26.11.09.08E(5)].

(3) Maintain a record of the maintenance performed that relates to

combustion performance. [COMAR 26.11.03.06C]

(4) Maintain an operation manual and prevention maintenance plan on site. [COMAR 26.11.03.06C]

(5) The Permittee shall maintain on site for at least 5 years, and shall make available to the Department upon request, records of monthly and annual fuel use. [Authority: 40 CFR §60.48c(g)(2), COMAR 26.11.03.06C and COMAR 26.11.09.08K(3)]


(1) The Permittee shall maintain a copy of the interruptible natural gas



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Table IV – 2 service contract that the Permittee is required by this Part 70 operating permit to maintain with a utility company under the jurisdiction of the Maryland Public Service Commission. [Authority: COMAR 26.11.03.06C]

(2) The Permittee shall maintain records of all periods during which the Permittee's natural gas service was interrupted or curtailed. [Authority: COMAR 26.11.03.06C]

(3) The Permittee shall maintain records of all fuels burned in the boilers during periods when natural gas was available, and records of all fuels burned in the boilers when natural gas service was interrupted or curtailed. [Authority: COMAR 26.11.03.06C]

E. Control of HAP

The Permittee shall comply with the following record keeping requirements: (1) The Permittee shall maintain a copy of each notification and report

that the Permittee submitted to comply with 40 CFR 63, Subpart DDDDD, including all documentation supporting any Initial Notification or Notification of Compliance Status or semiannual compliance report that the Permittee submitted, according to the requirements in 40 CFR §63.10(b)(2)(xiv).

(2) The Permittee shall keep records of compliance demonstrations and performance evaluations as required in 40 CFR §63.10(b)(2)(viii)

(3) The Permittee shall keep records of the total hours per calendar year

that alternative fuel (No. 2 or No. 6 oil) is burned and the total hours per calendar year that the unit operated during periods of gas curtailment or gas supply emergencies.

(4) Records must be in a form suitable and readily available for

expeditious review, according to 40 CFR §63.10(b)(1).

(5) As specified in 40 CFR §63.10(b)(1), the Permittee must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record.

(6) The Permittee must keep each record on site, or they must be

accessible from on site (for example, through a computer network), for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to 40



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Table IV – 2 CFR §63.10(b)(1). The Permittee can keep the records off site for the remaining 3 years.

[Authority: 40 CFR §63.7555(a) and (h), and 40 CFR §63.7560(a), (b), and (c)]

2.5 Reporting Requirements : A. Visible Emissions Limitations

The Permittee shall report incidents of visible emissions in accordance with permit condition 4, Section III, Plant Wide Conditions, “Report of Excess Emissions and Deviations”.


In accordance with 40 CFR §60.48c(c), (d) and (e), the Permittee shall submit reports to the Department that include the following information for the boilers:

(1) Calendar dates covered in the reporting period. [Authority: 40 CFR

§60.48c(e)(1)]

(2) For No. 6 fuel oil to be burned in the boilers, each 30-day average sulfur content (weight percent) calculated during the reporting period, ending with the last 30-day period; reasons for any noncompliance with the standard; and a description of corrective action taken. [Authority: 40 CFR §60.48c(b) and §60.48c(e)(2)]

(3) Excess emission reports for any excess emissions from the boilers

during the reporting period. [Authority: 40 CFR §60.48c(c)]

(4) Fuel supplier certification records as described under 40 CFR §60.48c(f)(1) and (f)(2) and a certified statement signed by the Permittee that the records of fuel supplier certifications submitted represent all of the fuel combusted during the reporting period. [Authority: 40 CFR §60.48c(e)(11)]

(5) The reporting period for the reporting required under 40 CFR §60.48c is each six (6) month period. All reports shall be submitted to the Department and shall be postmarked by the 30th day following the end of the reporting period. [Authority: 40 CFR §60.48c(j)]

C. Control of NOx

See record keeping requirements



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Table IV – 2


The Permittee shall submit required fuel records to the Department upon request. [Authority: COMAR 26.11.03.06C]

E. Control of HAP (1) The Permittee must submit to the Department all of the notifications

in 40 CFR §§63.7(b) and (c), 63.8(e), (f)(4) and (6), and 63.9(b) through (h) that apply to the Permittee by the dates specified. [Authority: 40 CFR §63.7545(a)]

(2) The Permittee must submit a Notification of Compliance Status according to 40 CFR §63.9(h)(2)(ii) before the close of business on the 60th day following the completion of all initial compliance demonstrations for all boilers according to 40 CFR §63.10(d)(2). The Notification of Compliance Status report must contain all the following information: (a) A description of the affected unit(s) including identification of

which subcategories the unit is in, the design heat input capacity of the unit, description of the fuel(s) burned, and justification for the selection of fuel(s) burned during the compliance demonstration.

(b) A signed certification that the Permittee has met all applicable work practice standards.

(c) If the Permittee had a deviation from any work practice standard,

the Permittee must also submit a description of the deviation, the duration of the deviation, and the corrective action taken in the Notification of Compliance Status report.

(d) In addition to the information required in §63.9(h)(2), the

notification of compliance status must include the following certification(s) of compliance, as applicable, and signed by a responsible official:

(i) “This facility complies with the required initial tune-up

according to the procedures in 40 CFR §63.7540(a)(10)(i) through (vi).”



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Table IV – 2 (ii) “This facility has had an energy assessment performed

according to 40 CFR §63.7530(e).”

(iii) Except for units that burn only natural gas, refinery gas, or other gas 1 fuel, or units that qualify for a statutory exemption as provided in section 129(g)(1) of the Clean Air Act, include the following: “No secondary materials that are solid waste were combusted in any affected unit.”

[Authority: 40 CFR §63.7545(e)]

(3) If the Permittee intends to use a fuel other than natural gas to fire the affected unit during a period of natural gas curtailment or supply interruption, as defined in 40 CFR §63.7575, the Permittee must submit a notification of alternative fuel use within 48 hours of the declaration of each period of natural gas curtailment or supply interruption, as defined in 40 CFR §63.7575. The notification must include the following information: (a) Company name and address.

(b) Identification of the affected unit.

(c) Reason the Permittee is unable to use natural gas or equivalent

fuel, including the date when the natural gas curtailment was declared or the natural gas supply interruption began.

(d) Type of alternative fuel that the Permittee intends to use.

(e) Dates when the alternative fuel use is expected to begin and end.

(4) The Permittee shall submit annual compliance reports to the

Department. The first compliance report must cover the period beginning on January 31, 2016 and ending on December 31, 2016. The first compliance report must be postmarked or submitted no later than January 31, 2017. Each subsequent compliance report must cover the annual periods from January 1 to December 31. Each subsequent compliance report must be postmarked or submitted no later than January 31 following the end of the annual period. Each compliance report must contain the following information:

(a) Company and Facility name and address.

(b) Process unit information, emissions limitations, and operating

parameter limitations.



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Table IV – 2

(c) Date of report and beginning and ending dates of the reporting period.

(d) The total operating time during the reporting period.

(e) Include the date of the most recent tune-up for each unit subject

to only the requirement to conduct an annual tune-up according to 40 CFR §63.7540(a)(10). Include the date of the most recent burner inspection if it was not done annually and was delayed until the next scheduled or unscheduled unit shutdown.

(5) The Permittee shall submit the initial and annual compliance reports

to the EPA electronically using CEDRI that is accessed through the EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to 40 CFR 63, Subpart DDDDD is not available in CEDRI at the time that the report is due the report the Permittee must submit the report to EPA Region III at the appropriate address listed in 40 CFR §63.13. [Authority: 40 CFR §63.7530(d), (e), and (f), §63.7 545(e) and (f), §63.7550(a) through (e) and (h), and Table 9 to 40 CFR 63, Subpart DDDDD]



EU03: Wastewater Treatment Process (6-0285) One lime storage silo equipped with a dust collector


COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in an uncombined form from any installation or building. However, this limitation does not apply to emissions during start-up and process modifications or adjustments, or occasional cleaning of control equipment, which are not greater than 40 percent opacity for a period of not more than 6 consecutive minutes in any 60 minutes [COMAR 26.11.06.02 A (2)].



of 100

Table IV – 3 B. Control of Particulate

COMAR 26.11.06.03B(2) which limits particulate matter emissions to 0.03 grains per standard cubic foot of dry exhaust gas.

C. Operating Requirements

The exhaust gases from the lime storage silo shall vent through the dust collector before discharging to the atmosphere to meet particulate matter and visible emission limits [Emission Point (EP) 6-0285A; Permit to construct 02-6-0285M issued April 21, 1998].

3.2 Testing Requirements : A. See monitoring, record keeping, and reporting requirements. B. See monitoring, record keeping, and reporting requirements. C. See reporting requirements.

3.3 Monitoring Requirements: A. & B.

The Permittee shall conduct a visible emissions observation of the exhaust gases from each emission point at least once per week when hydrated lime is unloading from truck to the lime storage silo and shall record the results of each observation. If the emissions in the exhaust gases are visible, the Permittee shall perform the following:

(1) Inspect all process and/or control equipment that may affect visible emissions; [COMAR 26.11.03.06C];

(2) Perform all necessary repairs and/or adjustments to processes or

control equipment within 48 hours, so that visible emissions in the exhaust gases are eliminated; [COMAR 26.11.03.06C]





C. See reporting requirements.



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Table IV – 3 3.4 Record Keeping Requirements :

B. & B. The Permittee shall maintain a record of each visible emission check required in 3.3 Monitoring Requirements on site for a period of no less than five (5) years. Said record shall include the date, time, name of emission unit, the applicable visible emissions requirement, the results of the check, what action(s), if any, was/were taken, and the name of the observer. [COMAR 26.11.03.06C] C. See reporting requirements.

3.5 Reporting Requirements : A., B., & C. The Permittee shall report excess emissions and deviations in accordance with Section III, Condition 4 “Report of Excess Emissions and Deviations”. [COMAR 26.11.03.06C].


Table IV – 4

4.0 Emissions Unit Number(s) EU04: Manganese Ore Reduction Process (6-0288) (1) One Shaft furnace rated at 12.6 MMBTU/hr fired by natural gas as the

primary fuel and back up by propane during natural gas supply interruptions (EP6-0288A);

(2) One course MnO ball mill/classification unit equipped with a baghouse (EP6-0288B); and

(3) One milled MnO bulk loading equipped with a baghouse. (EP6-0288C).


COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in an uncombined form. However, this limitation does not apply to emissions during start-up and process modifications or adjustments, or occasional cleaning of control equipment, which are not greater than 40 percent opacity for a period of not more than 6 consecutive minutes in any 60 minutes [COMAR 26.11.06.02 A (2)].



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Table IV – 4 B. Control of Particulate


C. Control of Nitrogen Oxides

(1) The Permittee shall maintain good operating practices for the Shaft furnace as recommended by the equipment vendor to minimize NOx emissions [COMAR 26.11.09.08J(1)].

(2) The Permittee shall prepare and implement a written in-house training

program for all operators of the Shaft furnace that include instruction on good operating and maintenance practices for the particular installation [COMAR 26.11.09.08J(2)].

(3) For the purposes of COMAR 26.11.09.08, the equipment operator to

be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation. [Reference: COMAR 26.11.09.08B(5)]


(1) The exhaust gas streams from the milling and bulk loading processes shall vent through the dust collectors (EP6-288BC) prior to discharging to the atmosphere to meet particulate matter and visible emission limits [Permit to Construct 02-6-288 M issued April 30, 1992].

(2) The pressure drop across the dust collector (EP6-288C) shall be

maintained at a minimum of 3 inches water gauge, when the plant is operating, unless the Permittee demonstrates, to the satisfaction of the Department, that the process can be operated at a lower pressure drop to meet particulate matter and visible emission requirements [Permit to Construct 02-6-288 M issued April 30, 1992].

(3) The Permittee shall only burn natural gas with propane gas as back-

up during periods of interrupted gas service unless the Permittee applies for and receives an approval or permit from the Department to burn alternate fuels [Authority: COMAR 26.11.02.09A].

4.2 Testing Requirements : A. & B. See monitoring, record keeping, and reporting requirements.



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Table IV – 4 C. & D. See record keeping and reporting requirements.

4.3 Monitoring Requirements: A. The Permittee shall conduct a visible emissions observation of the

exhaust gases from each emission point at least daily and shall record the results of each observation. If the emissions in the exhaust gases are visible, the Permittee shall perform the following: (1) Inspect all process and/or control equipment that may affect visible







B. (1) The Permittee shall develop and maintain a preventive maintenance

plan for each dust collector (baghouse) that describes the maintenance activity and time schedule for completing each activity. The Permittee shall perform maintenance activities within the time frames established in the plan and shall maintain a log with records of the dates and description of the maintenance that was performed. [COMAR 26.11.03.06C]

(2) The pressure drop across the baghouses in bulk loading and Ball mill shall be monitored and recorded daily during operation [EP6-288C; Permit to Construct 02-6-288 M issued April 30, 1992; COMAR 26.11.03.06C].

(3) The pressure drop across the mill dust collector (EP6-288B) shall be

between 3” and 10” inches water gauge under normal operation. If the indicator reading falls beyond the normal range, the Permittee shall conduct a visible emissions observation within 24 hours and perform all necessary repairs and/or adjustments to processes or control equipment within 72 hours, so that pressure drops are



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Table IV – 4 corrected. [COMAR 26.11.03.06C]

(4) The pressure drop across the bulk loading dust collector (EP6-288C)

shall be between 3” and 10” inches water gauge under normal operation. If the indicator reading falls beyond the normal range, the Permittee shall conduct a visible emissions observation within 24 hours and perform all necessary repairs and/or adjustments to processes or control equipment within 72 hours, so that pressure drops are corrected. [COMAR 26.11.03.06C]

C. See record keeping and reporting requirements. D. See record keeping, and reporting requirements.

4.4 Record Keeping Requirements : A. B. & D.

(1) Records of the following operating data shall be kept at the site for at least five (5) years and shall be made available to the Department upon request:

(a) Monthly records of material usage for each registered process;

(b) Pressure drop records for the baghouses used in ball mill and bulk loading; and

(c) Records of each visible emission check required in the monitoring

section. Said record shall include the date, time, name of emission unit, the applicable visible emissions requirement, the results of the check, what action(s), if any, was/were taken, and the name of the observer [COAMR 26.11.03.06C].

(2) The Permittee shall maintain a copy of the preventive maintenance

plan, records of the dates and maintenance activities performed, records of control device malfunctions and corrective actions taken to bring into proper operation. The Permittee shall keep the above records for at least 5 years and make them available to the Department upon request [COMAR 26.11.03.06C].

C.

(1) The Permittee shall maintain operator training attendance records for the Shaft furnace for each operator at the site for at least 2 years and make these records available to the Department upon request [COMAR 26.11.09.08J(5)].



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Table IV – 4 (2) The Permittee shall maintain and make available to the Department,

upon request, the written in-house operator training program for the Shaft furnace [COMAR 26.11.09.08J(3)].

4.5 Reporting Requirements : A., B., C., and D. The Permittee shall report excess emissions and deviations in accordance with Section III, Condition 4 “Report of Excess Emissions and Deviations”. [COMAR 26.11.03.06C]



EU05: High Surface Area Manganese Dioxide Pilot Process (6-0721) One jacketed pan dryer controlled by a scrubber (EP6-0721A). Please note: The scrubber was removed and the pilot plant is no longer active as of 2015. The Permittee shall apply and obtain an air quality permit or approval before restoring this process line. [COMAR 26.11.02.09 A (2)]


EU06: Manganese Chloride Solution Process (7-0403)

(1) Two hydrochloric acid holding tanks vents manifolded together to form one vent. (EP7-0403A);

(2) One evaporator for the manganese chloride solution process. (EP7-

0403B); and

(3) Two leaching tanks vented to the venturi scrubber in the Manganese Chloride Flake Process (7-0410A) in Emission Unit EU12. (Please see the monitoring, record keeping, and reporting requirements in EU12.)




of 100

Table IV – 6 COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in an uncombined form from any installation or building. However, this limitation does not apply to emissions during start-up and process modifications or adjustments, or occasional cleaning of control equipment, which are not greater than 40 percent opacity for a period of not more than 6 consecutive minutes in any 60 minutes [COMAR 26.11.06.02 A (2)].

B. Operating Requirements

The exhaust gas from the two leaching tanks shall vent through the venturi scrubber prior to discharging to the atmosphere to meet particulate matter and visible emission limits as well as any air toxics screening level [EP7-410A; COMAR 26.11.03.06C].



exhaust gases from each emission point at least monthly and shall record the results of each observation. If the emissions in the exhaust gases are visible, the Permittee shall perform the following: (1) Inspect all process and/or control equipment that may affect visible


(2) Perform all necessary repairs and/or adjustments to processes or control equipment within 48 hours, so that visible emissions in the exhaust gases are eliminated; [COMAR 26.11.03.06C] and





B. The monitoring requirements for scrubber stack EP7-410A are listed in

Emission Unit EU12.



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Table IV – 6 6.4 Record Keeping Requirements :

A. The Permittee shall maintain a record of each visible emission check

required in the monitoring section on site for a period of no less than five (5) years. Said record shall include the date, time, name of emission unit, the applicable visible emissions requirement, the results of the check, what action(s), if any, was/were taken, and the name of the observer. [COMAR 26.11.03.06C]

B. The record keeping requirements for scrubber stack EP7-410A are listed

in Emission Unit EU12. 6.5 Reporting Requirements :

A. & B. The Permittee shall report excess emissions in accordance with Section III, Condition 4 “Report of Excess Emissions and Deviations”. [COMAR 26.11.03.06C]



EU07: Manganous Manganic Oxide (Mn3O4 PF), Manganese Carbonate

(MnCO3 UF), and High Surface Area manganese Dioxide (MnO2-HSA) Production Process (Multipurpose Plant; 7-404)

(1) One reactor for the production of Mn3O4 PF (EP7-404A), MnCO3 UF

(EP7-404A) or MnO2-HSA controlled by a wet scrubber. (EP7-404D).

(2) One MnO HP conveyor equipped with a baghouse. (EP7-404B).

(3) One Aljet dryer rated at 1.4 MMBtu/hr fired by natural gas and back up by propane gas. The dryer is equipped with a baghouse (EP7-404C).


COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in an uncombined form from any installation or building. However, this limitation does not apply to emissions during start-up and process modifications or adjustments, or occasional cleaning of control equipment, which are not greater than 40 percent opacity for a period of



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Table IV – 7 not more than 6 consecutive minutes in any 60 minutes [COMAR 26.11.06.02 A (2)].

B. Control of Particulate



(1) The Permittee shall maintain good operating practices for Aljet dryer as recommended by the equipment vendor to minimize NOx emissions [COMAR 26.11.09.08J(1)].

(2) The Permittee shall prepare and implement a written in-house training

program for all operators of the Aljet dryer that include instruction on good operating and maintenance practices for the Aljet dryer [COMAR 26.11.09.08J(2)].

(3) For the purposes of COMAR 26.11.09.08, the equipment operator to

be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation. [Reference: COMAR 26.11.09.08B(5)]


(1) The exhaust gases from the MnO HP conveyor shall vent through a baghouse (EP7-404B) prior to discharging to the atmosphere to meet particulate matter and visible emission limits [COMAR 26.11.03.06C].

(2) The exhaust gases from the Aljet dryer shall vent through a

baghouse (EP7-404C) prior to discharging to the atmosphere to meet particulate matter and visible emission limits [COMAR 26.11.03.06C].

(3) The exhaust gases from the reactor (agitated tank) and centrifuges

shall vent through a wet scrubber prior to discharging to the atmosphere to meet particulate matter and visible emission [EP7-404D; Permit to construct 02-7-0404 M issued December 15, 1998].

(4) The Permittee shall only burn natural gas with propane gas as back-

up during periods of interrupted gas service unless the Permittee applies for and receives an approval or permit from the Department to burn alternate fuels [COMAR 26.11.02.09A].



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Table IV – 7 7.2 Testing Requirements :

A. & B. See monitoring, record keeping, and reporting requirements. C. & D. See record keeping and reporting requirements.


exhaust gases from the scrubber (EP7-404D) and dust collectors (EP7-404B&C) at least daily when in operation and shall record the results of each observation. If the emissions in the exhaust gases are visible, the Permittee shall perform the following:




(3) Document, in writing, the results of the inspections and the repairs and/or

adjustments made to the processes and/or control equipment. [COMAR 26.11.03.06C]


Permittee shall perform a Method 9 observation once daily for an 18-minute period until corrective actions have eliminated the visible emissions. [COMAR 26.11.03.06C]

B.

(1) The Permittee shall develop and maintain a preventive maintenance plan for each control device (baghouses and scrubber) that describes the maintenance activity and time schedule for completing each activity. The Permittee shall perform maintenance activities within the time frames established in the plan and shall maintain a log with records of the dates and description of the maintenance that was performed. [COMAR 26.11.03.06C]

(2) The Permittee shall monitor and record the following data in a logbook

at least once a day: (a) the pH of the scrubbing solution; and (b) the flow rate of the scrubbing solution entering the scrubber [EP7-404D; Permit to construct 02-7-0404 M issued December 15, 1998].



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Table IV – 7

(3) The pressure drop across the baghouse for Alijet dryer (EP7-0404C) shall be monitored and recorded daily when in operation. [COMAR 26.11.03.06C]

(4) The pressure drop across the baghouse for Alijet dryer (EP7-0404C)

shall be between 3” and 10” inches water gauge under normal operation. If the indicator reading falls beyond the normal range, the Permittee shall conduct a visible emissions observation within 24 hours and perform all necessary repairs and/or adjustments to processes or control equipment within 72 hours, so that pressure drops are corrected. [COMAR 26.11.03.06C]

C. & D.

See record keeping and reporting requirements. 7.4 Record Keeping Requirements :

The Permittee shall maintain the following records on site for a period of no less than five (5) years and shall be made available to the Department upon request: A. Records of each visible emission check required in the monitoring

section. Said record shall include the date, time, name of emission unit, the applicable visible emissions requirement, the results of the check, what action(s), if any, was/were taken, and the name of the observer. [COAMR 26.11.03.06C]

B.

(1) Records of the flow rate and pH of the scrubber liquid [EP7-404D; Permit to construct 02-7-0404 M issued December 15, 1998].



(3) Records of pressure drop across the baghouse for Alijet dryer (EP7-

0404C). [COMAR 26.11.03.06C] C.

(1) The Permittee shall maintain operator training attendance records for



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Table IV – 7 each Aljet dryer operator at the site for at least 2 years and make these records available to the Department upon request [COMAR 26.11.09.08J(5)].

(2) The Permittee shall maintain and make available to the Department,

upon request, the written in-house operator training program for Aljet dryer [COMAR 26.11.09.08J(3)].

D. The Permittee shall maintain records of normal and backup fuel usages


7.5 Reporting Requirements : A., B., C., and D. The Permittee shall report excess emissions in accordance with Section III, Condition 4 “Report of Excess Emissions and Deviations”. [COMAR 26.11.03.06C]



EU08: Manganese Nitride Production Process (7-0405) including (1) One ferromanganese roll crusher and one sodium silicate blending

screw equipped with a baghouse (EP7-0405A) and

(2) One tube loading station and unloading, screening, packaging equipped with a baghouse (7-0405B).

Please note: This process line was dismantled in 2013. The Permittee shall apply and obtain an air quality permit or approval before restoring this process line. [COMAR 26.11.02.09 A (2)]



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Table IV – 9

9.0 Emissions Unit Number(s) EU09: Manganese Nitrate Solution Process line (7-0406) Since this process is used to process inorganic materials in solution form, there are no significant air emissions from this process. It has been considered as an insignificant activity in the Section V - Insignificant Activities.


EU10: Manganese Chloride Prilling Process (7-0407) (1) Two Chemetals MnCl2 prills rotary dryers each rated at 1.8 MMBtu/hr

fired by natural gas and back up by propane gas. Both dryers are controlled by a packed tower scrubber (EP7-407A).

(2) One boildown tank controlled by one packed bed scrubber (EP7-

407B). 10.1 Applicable Standards/Limits :






(1) The Permittee shall maintain good operating practices for the rotary dryers as recommended by the equipment vendor to minimize NOx emissions [COMAR 26.11.09.08J(1)].



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Table IV – 10 (2) The Permittee shall prepare and implement a written in-house

training program for all operators of the rotary dryers that include instruction on good operating and maintenance practices for the particular installation [COMAR 26.11.09.08J(2)].

(3) The Permittee shall burn only gas in each rotary dryer, where gas is

available, during the period May 1 through September 30 of each year [COMAR 26.11.09.08J(4)].

(4) For the purposes of COMAR 26.11.09.08, the equipment operator

to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation. [Reference: COMAR 26.11.09.08B(5)]


(1) The Permittee shall only burn natural gas with propane gas as back-up during periods of interrupted gas service unless the Permittee applies for and receives an approval or permit from the Department to burn alternate fuels [COMAR 26.11.02.09A].

(2) The exhaust gas from the rotary dryers shall vent through the

scrubber prior to discharging to the atmosphere to meet particulate matter and visible emission limits [EP7-407A; COAMR 26.11.03.06C].

(3) The exhaust gas from the Boil Down tank shall vent through the

scrubber prior to discharging to the atmosphere to meet particulate matter and visible emission limits [EP7-407B; COAMR 26.11.03.06C].

10.2 Testing Requirements : A. & B. See monitoring, record keeping, and reporting requirements. C. & D. See record keeping and reporting requirements.

10.3 Monitoring Requirements: A.

The Permittee shall conduct a visible emissions observation of the exhaust gases from the packed bed scrubbers (EP7-407A&B) at least daily when in operation and shall record the results of each observation. If the emissions in the exhaust gases are visible, the



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Table IV – 10 Permittee shall perform the following:





and/or adjustments made to the processes and/or control equipment; and [COMAR 26.11.03.06C]



B.

(1) The Permittee shall develop and maintain a preventive maintenance plan for each control device (scrubber) that describes the maintenance activity and time schedule for completing each activity. The Permittee shall perform maintenance activities within the time frames established in the plan and shall maintain a log with records of the dates and description of the maintenance that was performed. [COMAR 26.11.03.06C]

(2) The Permittee shall monitor and record the following data in a

logbook at least once a day: (a) the pressure difference of the exhaust gases entering and leaving the scrubber; and (b) the flow rate of the scrubbing solution entering the scrubber [EP7-407A; COMAR 26.11.03.06C].

(3) The Permittee shall monitor and record the following data in a

logbook at least once a day: (a) the pH of the scrubbing solution; and (b) the flow rate of the scrubbing solution entering the scrubber [EP7-407B; Permit to construct 02-7-0407 M issued November 26, 1996].

C. & D.


A. The Permittee shall maintain the following records on site for a period

of no less than five (5) years and shall be made available to the



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Table IV – 10 Department upon request::

(1) Monthly records of material usage for the Manganese Chloride

Prilling Process;

(2) a record of each visible emission check required in the monitoring section. Said record shall include the date, time, name of emission unit, the applicable visible emissions requirement, the results of the check, what action(s), if any, was/were taken, and the name of the observer [COMAR 26.11.03.06C];

B.

(1) The Permittee shall maintain the following records on site for a period of no less than five (5) years and shall be made available to the Department upon request::

(a) Daily records of the flow rate of the scrubber liquid and pressure

difference of the exhaust gases entering and leaving the scrubber [EP7-407A; COMAR 26.11.03.06C]; and

(b) Daily records of the flow rate and pH of the scrubber liquid [EP7-

407B; Permit to construct 02-7-0407 M issued November 26, 1996].



C.

(1) The Permittee shall maintain each rotary dryer operator training attendance records for each operator at the site for at least 2 years and make these records available to the Department upon request [COMAR 26.11.09.08J(5)].


upon request, the written in-house operator training program for rotary dryers [COMAR 26.11.09.08J(3)].





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Table IV – 10

10.5

Reporting Requirements : A., B., C., and D. The Permittee shall report excess emissions in accordance with Section III, Condition 4 “Report of Excess Emissions and Deviations”. [COMAR 26.11.03.06C]

Note: A permit shield shall cover the applicable requirements identified above for the emission unit EU10.


EU11: High Purity Manganese Oxides Process (7-0408; Nitrate Plant)

(1) Five rooftop ventilators for fugitive emissions each at 14000 cfm (EP7-

408A).

(2) One raw MnO2 ore dryer rated at 3.5 MMBTU/hr fired by natural gas and back up by propane gas or No.2 fuel oil. The dryer is equipped with one dust collector (EP7-408B).

(3) One leach tank equipped with two contact condensers controlled by

one chemical scrubber (EP7-408C). (4) Three treatment tanks equipped with one dust collector (EP7-408D). (5) One evaporator (EP7-408E). (6) One MnO2-HP dryer rated at 2.27 MMBTU/hr fired by natural gas and

back up by propane gas or No.2 fuel oil. The dryer is equipped with a dust collector (EP7-408F).

(7) One horizontal roaster with two burners rated at 1.65 MMBTU/hr each

fired by natural gas and back up by propane gas or No.2 fuel oil. The dryer is equipped with one dust collector (EP7-408G).

(8) One ball mill/classification unit equipped with a dust collector (EP7-

408H). (9) One air classifier equipped with a dust collector (EP7-408I).



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Table IV – 11






(1) The Permittee shall maintain good operating practices for the raw MnO2 ore dryer, MnO2-HP dryer, and horizontal roaster as recommended by the equipment vendor to minimize NOx emissions [COMAR 26.11.09.08J(1)].

(2) The Permittee shall prepare and implement a written in-house

training program for all operators of the raw MnO2 ore dryer, MnO2-HP dryer, and horizontal roaster that include instruction on good operating and maintenance practices for the this particular installation [COMAR 26.11.09.08J(2)].

(3) The Permittee shall burn only gas in the raw MnO2 ore dryer, MnO2-

HP dryer, and horizontal roaster, where gas is available, during the period May 1 through September 30 of each year [COMAR 26.11.09.08J(4)].




(1) The exhaust gases from the raw MnO2 ore dryer shall vent through



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Table IV – 11 a dust collector (EP7-408B) prior to discharging to the atmosphere to meet particulate matter and visible emission limits [COMAR 26.11.03.06C].

(2) The exhaust gases from the contact condensers shall vent through a chemical scrubber (EP7-408C) prior to discharging to the atmosphere to meet particulate matter and visible emission limits [COMAR 26.11.03.06C].

(3) The exhaust gases from the treatment tanks shall vent through a

dust collector (EP7-408D) prior to discharging to the atmosphere to meet particulate matter and visible emission limits [COMAR 26.11.03.06C].

(4) The exhaust gases from the MnO2-HP dryer shall vent through a

dust collector (EP7-408F) prior to discharging to the atmosphere to meet particulate matter and visible emission limits [COMAR 26.11.03.06C].

(5) The exhaust gases from the horizontal roaster shall vent through a

dust collector (EP7-408G) prior to discharging to the atmosphere to meet particulate matter and visible emission limits [COMAR 26.11.03.06C].

(6) The exhaust gases from the ball mill/classification unit shall vent

through a dust collector (EP7-408H) prior to discharging to the atmosphere to meet particulate matter and visible emission limits [COMAR 26.11.03.06C].

(7) The Permittee shall only burn natural gas with propane gas or No. 2 fuel oil as back-up during periods of interrupted gas service unless the Permittee applies for and receives an approval or permit from the Department to burn alternate fuels [Authority: COMAR 26.11.02.09A].

(8) The exhaust gases from the air classifier and vibrating screener

shall vent through a cartridge dust collector (EP7-408I) before discharging to the atmosphere to meet particulate matter and visible emission limits [Permit to construct 02-7-0408 M issued July 6, 1998].




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Table IV – 11 C. & D. See record keeping and reporting requirements.


exhaust gases from the dust collectors (EP7-408B, D, F, I, G, and H) at least daily when in operation for manganese compound particulate related emission and shall record the results of each observation. If the emissions in the exhaust gases are visible, the Permittee shall perform the following:








B.

(1) The Permittee shall monitor and record daily the pressure drop across the baghouse (EP7-408B, D, and F) when in operation [COMAR 26.11.03.06C].

(2) The Permittee shall develop and maintain a preventive maintenance

plan for each dust collector (or called scrubber) that describes the maintenance activity and time schedule for completing each activity. The Permittee shall perform maintenance activities within the time frames established in the plan and shall maintain a log with records of the dates and description of the maintenance that was performed. [COMAR 26.11.03.06C]

C. See record keeping and reporting requirements. D. See record keeping and reporting requirements.



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Table IV – 11

11.4 Record Keeping Requirements : A. The Permittee shall maintain the following records on site for a period

of no less than five (5) years and shall be made available to the Department upon request::

(1) Monthly records of material usage for the High Purity Manganese

Oxides Process; and

(2) a record of each visible emission check required in the monitoring section. Said record shall include the date, time, name of emission unit, the applicable visible emissions requirement, the results of the check, what action(s), if any, was/were taken, and the name of the observer. [COMAR 26.11.03.06C]

B. The Permittee shall maintain the following records on site for a period of

no less than five (5) years and shall be made available to the Department upon request::

(1) Daily records of the pressure drop across the baghouse (EP7-408B,

D, and F) when in operation [COMAR 26.11.03.06C]; and (2) a copy of the preventive maintenance plan, records of the dates and

maintenance activities performed, records of control device malfunctions and corrective actions taken to bring into proper operation. [COMAR 26.11.03.06C].

C.

(1) The Permittee shall maintain operator training attendance records for each operator of the raw MnO2 ore dryer, MnO2-HP dryer, and horizontal roaster at the site for at least 2 years and make these records available to the Department upon request [COMAR 26.11.09.08J(5)].


upon request, the written in-house operator training program for the raw MnO2 ore dryer, MnO2-HP dryer, and horizontal roaster [COMAR 26.11.09.08J(3)].





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Table IV – 11




EU12: Manganese Chloride Flakes Production Process (7-0410) Two rotary drum dryers rated at 4.6 MMBTU/hr fired by natural and back-up by propane gas. Both dryers and one MnCl2 packaging facility are controlled by a venturi scrubber with a mist eliminator (EP7-410A).






(1) The Permittee shall maintain good operating practices for two rotary dryers as recommended by the equipment vendor to minimize NOx emissions [COMAR 26.11.09.08J(1)].


training program for all operators of two rotary dryers that include



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Table IV – 12 instruction on good operating and maintenance practices for the particular installation [COMAR 26.11.09.08J(2)].

(3) The Permittee shall burn only gas in two rotary dryers, where gas is

available, during the period May 1 through September 30 of each year [COMAR 26.11.09.08J(4)].





(2) The exhaust gas steams from the rotary drum dryers and packing

process shall vent through the scrubber prior to discharging to the atmosphere to meet particulate matter and visible emission limits [EP7-410A; COMAR 26.11.03.06C].

12.2 Testing Requirements : A. See monitoring, record keeping, and reporting requirements. B.

(1) The Permittee shall conduct a stack emission test for Particulate Matters, Manganese compounds, and Visible Emission once every five year for the stack EP7-410A. [COAMR 26.11.03.06C].

(2) During the stack testing period for compliance determination, the plant shall operate at not less than 90 % of its rated capacity.

(3) The Permittee shall submit the test protocol to the Department for review and approval at least 30 days prior to the emission test.

(4) The Permittee shall submit the test report to the Department within

60 days after the emission test. C. See record keeping and reporting requirements. D. See record keeping and reporting requirements.



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Table IV – 12


exhaust gases from the venturi scrubber (EP7-410A) at least daily when in operation and shall record the results of each observation. If the emissions in the exhaust gases are visible, the Permittee shall perform the following:








B.

(1) The Permittee shall develop and maintain a preventive maintenance plan for each dust collector (or scrubber) that describes the maintenance activity and time schedule for completing each activity. The Permittee shall perform maintenance activities within the time frames established in the plan and shall maintain a log with records of the dates and description of the maintenance that was performed. [COMAR 26.11.03.06C]

(2) The Company shall monitor and record the following data in a

logbook at least once a day when in operation: (a) the flow rate of the scrubbing solution entering the scrubber; and (b) the pressure difference of the exhaust gases entering and leaving the venturi scrubber. [EP7-410A; COMAR 26.11.03.06C]

C. See record keeping and reporting requirements. D. See record keeping and reporting requirements.



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Table IV – 12

12.4 Record Keeping Requirements : A.

The Permittee shall maintain the following records on site for a period of no less than five (5) years and shall be made available to the Department upon request:

(1) Monthly records of material usage for the Manganese Chloride

Flakes Production Process;

(2) a record of each visible emission check required in the monitoring section. Said record shall include the date, time, name of emission unit, the applicable visible emissions requirement, the results of the check, what action(s), if any, was/were taken, and the name of the observer [COMAR 26.11.03.06C];

B.

(1) The Permittee shall maintain the records of daily records of the flow rate of the scrubber solution and pressure difference of the exhaust gases entering and leaving the venturi scrubber [EP7-410A] on site for a period of no less than five (5) years and shall be made available to the Department upon request. [COMAR 26.11.03.06C]



C.

(1) The Permittee shall maintain operator training attendance records of the two rotary dryers for each operator at the site for at least 2 years and make these records available to the Department upon request [COMAR 26.11.09.08J(5)].


upon request, the written in-house operator training program for two rotary dryers [COMAR 26.11.09.08J(3)].





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Table IV – 12

12.5 Reporting Requirements : A, B, C, and D. The Permittee shall report excess emissions in accordance with Section III, Condition 4 “Report of Excess Emissions and Deviations”. [COMAR 26.11.03.06C]



EU13: CST & Mn2O3 Process (7-0411) for CST prilling and reduction,

manganese sesquioxide calcination, and lithium manganese oxide productions.

(1) One Eirich (Sigma) mixer blender with hopper equipped with one

baghouse (EP7-411A/D; A and D represent different emissions when production changes but both products share the same equipment and emission point).

(2) Two horizontal roaster/calciners rated at 0.2 MMBTU/hr fired by

natural gas and back up by propane gas or No 2 fuel oil. Each roaster/calciner is equipped with one baghouse (EP7-411B/E).

(3) One turbo-screen classifier equipped with one dust collector (EP7-

411C). 13.1 Applicable Standards/Limits :


COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in an uncombined form from any installation or building. However, this limitation does not apply to emissions during start-up and process modifications or adjustments, or occasional cleaning of control equipment, which are not greater than 40 percent opacity for a period of not more than 6 consecutive minutes in any 60 minutes [COMAR 26.11.06.02 A (2)].


COMAR 26.11.06.03B(2) which limits particulate matter emissions to



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Table IV – 13 0.03 grains per standard cubic foot of dry exhaust gas.


(1) The Permittee shall maintain good operating practices for the horizontal roaster/calciners as recommended by the equipment vendor to minimize NOx emissions [COMAR 26.11.09.08J(1)].


training program for all operators of the horizontal roaster/calciners that include instruction on good operating and maintenance practices for the particular installation [COMAR 26.11.09.08J(2)].

(3) The Permittee shall burn only gas in the horizontal roaster/calciners,

where gas is available, during the period May 1 through September 30 of each year [COMAR 26.11.09.08J(4)].




(1) The Permittee shall maintain and operate all installations with potential to cause air pollution, and any associated air pollution control equipment, in such a manner as to ensure full and continuous compliance with all applicable regulations [COMAR 26.11.03.06C].

(2) The Permittee shall only burn natural gas with propane gas or No. 2 fuel oil as back-up during periods of interrupted gas service unless the Permittee applies for and receives an approval or permit from the Department to burn alternate fuels [COMAR 26.11.02.09A].

(3) The exhaust gases from the mixer blender/hopper shall vent

through the dust collector before discharging to the atmosphere to meet particulate matter and visible emission limits [EP7-411A/D; Permit to construct 02-7-0411 M issued January 7, 1997 and October 7, 1998].

(4) The exhaust gases from the horizontal roaster/calciner shall vent

through the dust collectors before discharging to the atmosphere to meet particulate matter and visible emission limits [EP7-411B/E;



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Table IV – 13 Permit to construct 02-7-0411 M issued October 7, 1998].

(5) The exhaust gases from the turbo-screen classifier shall vent

through the dust collector before discharging to the atmosphere to meet particulate matter and visible emission limits [EP7-411C; Permit to construct 02-7-0411 M issued February 5, 1998].

13.2 Testing Requirements : A. & B. See monitoring, record keeping, and reporting requirements. C. & D. See record keeping and reporting requirements.


exhaust gases from the dust collectors (EP7-411A/D, B, C, and E) at least daily when in operation and shall record the results of each observation. If the emissions in the exhaust gases are visible, the Permittee shall perform the following:








B. The Permittee shall develop and maintain a preventive maintenance plan

for each dust collector (or called baghouse) that describes the maintenance activity and time schedule for completing each activity. The Permittee shall perform maintenance activities within the time frames established in the plan and shall maintain a log with records of the dates and description of the maintenance that was performed. [COMAR 26.11.03.06C]



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Table IV – 13 C. & D.


A. Records of the following operating data shall be kept at the site for at

least five (5) years and shall be made available to the Department upon request:

(1) Monthly records of material usage for the CST prilling and reduction, manganese sesquioxide calcination, and lithium manganese oxide production processes; and

(2) Records of each visible emission check required in the monitoring

section. Said record shall include the date, time, name of emission unit, the applicable visible emissions requirement, the results of the check, what action(s), if any, was/were taken, and the name of the observer [COAMR 26.11.03.06C].

B. The Permittee shall maintain a copy of the preventive maintenance


C.

(1) The Permittee shall maintain operator training attendance records of the horizontal roaster/calciners for each operator at the site for at least 2 years and make these records available to the Department upon request [COMAR 26.11.09.08J(5)].

(2) The Permittee shall maintain and make available to the Department, upon request, the written in-house operator training program for the horizontal roaster/calciners [COMAR 26.11.09.08J(3)].






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EU14: Raw MnO2 pile storage (9-0416) and material handling Fugitive emissions (EP9-416-FUG)

14.1 Applicable Standards/Limits : A. Control of Particulate

(1) COMAR 26.11.06.03C which prohibits emissions from an unconfined source without taking reasonable precautions to prevent particulate matter from becoming airborne.

(2) COMAR 26.11.06.03D which require that reasonable precautions

be taken to prevent any particulate matter from becoming airborne as a result of material being handled, transported, or stored.

B. Operating Requirements

(1) The Permittee shall spray water on unpaved roadways or sweep paved roadways as frequently as necessary or use other alternatives to control fugitive particulate emissions [COMAR 26.11.06.03D].

(2) The Manganese Ore Storage pile shall be covered with a tarp at all

times except when material is being added to or removed from the stockpile [COMAR 26.11.06.03D].

14.2 Testing Requirements :

A. See reporting requirements. B. See record keeping and reporting requirements.

14.3 Monitoring Requirements: A. See reporting requirements. B. See record keeping and reporting requirements.

14.4 Record Keeping Requirements : A. See reporting requirements.



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Table IV – 14 B. Records of logs of the date and time, and any other pertinent

information on roadway fugitive particulates control activities shall be kept at the site for at least five (5) years and shall be made available to the Department upon request [COMAR 26.11.03.06C].

14.5 Reporting Requirements : A. & B. The Permittee shall report excess emissions in accordance with Section III, Condition 4 “Report of Excess Emissions and Deviations”. [COMAR 26.11.03.06C]




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SECTION V INSIGNIFICANT ACTIVITIES This section provides a list of insignificant emissions units that were reported in the Title V permit application. The applicable Clean Air Act requirements, if any, are listed below the insignificant activity. (1) No. 13 Fuel burning equipment using gaseous fuels or no. 1 or no. 2

fuel oil, and having a heat input less than 1,000,000 Btu (1.06 gigajoules) per hour;

The above fuel burning units are subject to the following

requirements: COMAR 26.11.09.05A(2), which establishes that the Permittee

may not cause or permit the discharge of emissions from any fuel burning equipment, other than water in an uncombined form, which is visible to human observers.

Exceptions: COMAR 26.11.09.05A(2) does not apply to

emissions during load changing, soot blowing, start-up, or adjustments or occasional cleaning of control equipment if:

(e) The visible emissions are not greater than 40

percent opacity; and

(f) The visible emissions do not occur for more than 6 consecutive minutes in any sixty minute period.

COMAR 26.11.09.07A(2)(b), which establishes that the

Permittee may not burn, sell, or make available for sale any distillate fuel with a sulfur content by weight in excess of 0.3 percent.

(2) No. 1 Stationary internal combustion engines with an output less than

500 brake horsepower (373 kilowatts) and which are not used to generate electricity for sale or for peak or load shaving;

The stationary internal combustion engine is subject to the following requirements:

(A) COMAR 26.11.09.05E(2), Emissions During Idle Mode:

The Permittee may not cause or permit the discharge of emissions from any engine, operating at idle, greater than 10 percent opacity.



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(B) COMAR 26.11.09.05E(3), Emissions During Operating

Mode: The Permittee may not cause or permit the discharge of emissions from any engine, operating at other than idle conditions, greater than 40 percent opacity.

(C) Exceptions:

(i) COMAR 26.11.09.05E(2) does not apply for a period

of 2 consecutive minutes after a period of idling of 15 consecutive minutes for the purpose of clearing the exhaust system.

(ii) COMAR 26.11.09.05E(2) does not apply to emissions

resulting directly from cold engine start-up and warm-up for the following maximum periods:

(a) Engines that are idled continuously when not in

service: 30 minutes (b) all other engines: 15 minutes.

(iii) COMAR 26.11.09.05E(2) & (3) do not apply while

maintenance, repair or testing is being performed by qualified mechanics.

(D) COMAR 26.11.36.03A(1), which establishes that the

Permittee may not operate an emergency generator except for emergencies, testing and maintenance purposes.

(E) COMAR 26.11.36.03A(5), which establishes that the

Permittee may not operate an emergency generator for testing and engine maintenance purposes between 12:01 a.m. and 2:00 p.m. on any day on which the Department forecasts that the air quality will be a code orange, code red, or code purple unless the engine fails a test and engine maintenance and a re-test are necessary.

(3) �� Space heaters utilizing direct heat transfer and used solely for comfort heat;

(4) �� Brazing, soldering, or welding equipment, and cutting torches related to manufacturing and construction activities that emit HAP metals and not directly related to plant maintenance, upkeep and repair or maintenance shop activities;



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(5) Containers, reservoirs, or tanks used exclusively for:

(a) �� Storage of butane, propane, or liquefied petroleum, or natural gas;

(b) No. 1 Storage of lubricating oils;

(c) No. 1 Storage of Numbers 1, 2, 4, 5, and 6 fuel oil and aviation

jet engine fuel; and

(d) No. 2 Storage of motor vehicle gasoline and having individual tank capacities of 2,000 gallons (7.6 cubic meters) or less.

(6) �� Non-contact water (i.e., water that has not been in direct contact with process fluids) cooling towers except as regulated under Section 112 of the Clean Air Act;

(7) �� Comfort air conditioning subject to requirements of Title VI of the Clean Air Act;

(8) �� Natural draft hoods or natural draft ventilators that exhaust air pollutants into the ambient air from manufacturing/industrial or commercial processes;

(9) �� Laboratory fume hoods and vents.

(10) Any other emissions unit at the facility which is not subject to an applicable requirement of the Clean Air Act (list and describe):

No. 1 Manganese Nitrate Solution Process line (7-0406). There is no

significant emission unit in this inorganic solution process.



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SECTION VI STATE-ONLY ENFORCEABLE CONDITIONS The Permittee is subject to the following State-only enforceable requirements: 1. Applicable Regulations:

(A) COMAR 26.11.06.08 and 26.11.06.09, which generally prohibit the discharge of emissions beyond the property line in such a manner that a nuisance or air pollution is created.

(B) COMAR 26.11.15.05, which requires that the Permittee implement

“Best Available Control Technology for Toxics” (T – BACT) to control emissions of toxic air pollutants.

(C) COMAR 26.11.15.06, which prohibits the discharge of toxic air

pollutants to the extent that such emissions will unreasonably endanger human health

2. Operating Conditions:

Air pollution Control devices used for each process line to meet particulate

matter and visible emission limits are sufficient to comply with T-BACT requirements and the appropriate screening levels.

3. Testing and Monitoring:

The Compliance demonstration for criteria pollutants should be sufficient for air toxic pollutants.

4. Record Keeping and Reporting: The Permittee shall submit to the Department, by April 1 of each year during

the term of this permit, a written certification of the results of an analysis of emissions of toxic air pollutants from the Permittee’s facility during the previous calendar year. The analysis shall include either:

(a) a statement that previously submitted compliance demonstrations for

emissions of toxic air pollutants remain valid; or (b) a revised compliance demonstration, developed in accordance with

requirements included under COMAR 26.11.15 & 16, that accounts for changes in operations, analytical methods, emissions determinations, or other factors that have invalidated previous demonstrations.

ERACHEM COMILOG, INC. PERMIT NO. 24-003-0056

PART 70 OPERATING PERMIT FACT SHEET

Page 1 of 50

BACKGROUND Erachem Comilog, Inc. Baltimore facility (the Permittee) is a manufacturer of inorganic, manganese based, chemical compounds such as Manganese Chloride, Manganese Nitrate, Manganese Dioxide, Manganous Oxide, Lithium Manganese Oxide, Manganous Manganic Oxide, Manganese Carbonate, Nitrided Ferromanganese (dismantled in 2013) and Nitrided Manganese in various purities, size, packaging and form. The facility is located in Anne Arundel county and its primary SIC code is 2819. The registrations for the facility are: 5-0378 Boiler (backup) 5-0412 Boiler (primary) 6-0285 Waste Water Treatment System 6-0288 Manganese Ore Reduction 6-0721 Pilot Test Plant for High Surface Area MnO2 (The scrubber was removed

and the pilot plant is no longer active as of 2015) 7-0403 Manganese Chloride Solution (leaching) 7-0404 Multipurpose Plant (MnCO3, Mn3O4, and MnO2) 7-0405 Manganese Nitriding Process (dismantled as of 2013) 7-0406 Manganese Nitrate Solution (very high purity) 7-0407 Manganese Chloride Prilling Process 7-0408 High Purity Manganese Oxides (MnO2 and MnO) process (aka. Nitrate

Plant) 7-0410 Manganese Chloride Flakes 7-0411 Catalytic Sulfur Trap Prilling and Reduction, Mn2O3 Calcining, Ozone

Decomposition Catalyst (ODC) and Lithiated Manganese Dioxide (LiMn2O4)

9-0416 Manganese Ore Storage Yard The Permittee operates two boilers to generate steam for general plant use. The 40 MMBTU/Hr Cleaver Brooks water tube is the primary unit (5-0412). The other boiler is a Cleaver Brooks fire tube boiler rated at 29 MMBTU/Hr and is used only as a backup to the first boiler during periods of mechanical repair or inspection. There is no Permit modification since last issuance of Part 70 Operating Permit dated on February 1, 2011. The following table summarizes the actual emissions from Erachem Comilog, Inc. Baltimore facility based on its Annual Emission Certification Reports:



Page 2 of 50

Table 1: Actual Emissions Year NOx

(TPY) SOx

(TPY) PM10 (TPY)

CO (TPY)

VOC (TPY)

Total HAP

(TPY) 2010 10.2 0.06 5.3 242.1 0.3 2.9 2011 12.0 0.08 5.8 261.4 0.4 3.2 2012 11.7 0.07 6.8 257.9 0.4 3.9 2013 12.2 0.07 7.9 302.7 0.4 4.8 2014 10.6 0.05 7.5 276.3 0.3 4.5 The major source threshold for triggering Title V permitting requirements is 10 tons per year (TPY) for individual HAP, 25 TPY for total HAP, 25 TPY for NOx and/or 100 TPY for other criteria pollutants. Since the actual emissions of CO and potential emissions of NOx and HAP from the facility are greater than the major source threshold, the Permittee is required to obtain a Part 70 permit under COMAR 26.11.03.01. The Part 70 permit application from the Company was received by the Department on March 16, 2015. An administrative completeness review was conducted and the application was deemed to be complete. The completeness determination letter was sent to the Company on April 2, 2015 granting the facility an application shield. NSPS Applicability The Company operates one (1) primary boiler (#5-0412, 40 MMBTU/Hr) and one (1) backup boiler (#5-0378, 29 MMBTU/Hr). The backup boiler was installed before June 9, 1989 and is not subject to NSPS Subpart Dc – Standards of Performance for Small Industrial – Commercial – Industrial Steam Generating Unit. The primary boiler was installed after June 9, 1989, and is subject to NSPS Subpart Dc – Standards of Performance for Small Industrial – Commercial – Industrial Steam Generating Unit. NESHAP Applicability 40 CFR 63, Subpart XXX - National Emission Standards for Hazardous Air Pollutants for Ferroalloys Production; Ferromanganese and Silicomanganese, located in a major source of Hazardous Air Pollutants (HAPS): Since the only affected facility, the ferromanganese roll crusher and one sodium silicate blending screw, was dismantled in 2013, the plant is no longer subject to 40 CFR 63, Subpart XXX. 40 CFR 63, Subpart DDDDD - Industrial, Commercial, and Institutional Boilers and Process Heaters located in major HAPS source: Both natural gas fired boilers are subject to 40 CFR 63, Subpart DDDDD.



Page 3 of 50

CAM Applicability Compliance Assurance Monitoring (CAM), as specified in 40 CFR, Part 64, applies to any emission unit at a Title V major source that meets all of the following criteria: A. The emission unit is subject to a federally enforceable emission limit or

standard for a regulated pollutant; B. The emission unit uses a control device to achieve compliance with any

such emission limitation or standard; and C. The emission unit has the potential to emit pre-control device emissions of

the applicable regulated air pollutant that are equal to or greater than 100 percent of the amount, in tons per year required for a source to be classified as a major source and must not otherwise be exempt from CAM.

Most of bag filters and scrubbers used in the facility are considered as inherent process equipment for product recovery. In addition, the particulate matter loading into each bag filter or scrubber is below the major source threshold for particulate matter emissions. therefore the facility is not subject to the CAM rule (40 CFR 64). Although the CO emission of the Shaft furnace (EP6-0288A) exceeds 100 tons per year, it is not equipped with a CO control device. Therefore, the facility is not subject to the CAM rule. GREENHOUSE GAS (GHG) EMISSIONS There are no greenhouse gas related Clean Air Act requirements applicable to Erachem Comilog. Erachem Comilog has not triggered Prevention of Significant Determination (PSD) requirements for GHG emissions; therefore, no applicable GHG Clean Air Act requirements for the facility. EMISSION UNIT IDENTIFICATION Erachem Comilog, Inc. Baltimore facility has identified the following emission units as being subject to Title V permitting requirements and having applicable requirements. Table 2: Emission Unit Identification Emissions

Unit Number

ARMA Registration

Number



EU01 003-0056-5-0378 Fire Tube Boiler

One Cleaver Brooks boiler rated at 29MMBTU/hr fired by natural gas as the

1971



Page 4 of 50

Emissions Unit

Number

ARMA Registration

Number



primary fuel and propane or No. 2 fuel oil as back-up during natural gas supply interruptions.

EU02 003-0056-5-0412 Water Tube Boiler

One Cleaver Brooks boiler rated at 40 MMBTU/hr fired by natural gas as the primary fuel and propane or No. 2 fuel oil as back-up during natural gas supply interruptions.

1994

EU03 003-0056-6-0285 Wastewater Treatment Process

One lime storage silo equipped with a dust collector (bin vent)

1998M

EU04 003-0056-6-0288 Manganese Ore Reduction Process

One Shaft furnace rated at 12.6 MMBTU/hr fired by natural gas as the primary fuel and propane as back-up during natural gas supply interruptions. (EP6-0288A)

1983

One course MnO ball mill/classification unit equipped with a baghouse. (EP6-0288B). The baghouse is used for material recovery.

1962

One milled MnO bulk loading equipped with a baghouse (EP6-0288C). The baghouse is used for material recovery.

1962

EU05 003-0056-6-0721 High Surface Area Manganese Dioxide Pilot Process

One jacketed pan dryer controlled by a scrubber. (EP6-0721A)

1997 (no longer active as of 2015)

EU06 003-0056-7-0403 Manganese Chloride Solution Process

Two hydrochloric acid holding tanks vents manifolded together to form one vent. (EP7-0403A)

1976M

One evaporator for the manganese chloride

1976M



Page 5 of 50

Emissions Unit

Number

ARMA Registration

Number



solution process. (EP7-0403B)

Two leaching tanks vented to the venturi scrubber in the Manganese Chloride Flake Process (7-0410A). The venturi scrubber is used for material recovery.

1976M

EU07 003-0056-7-0404 Manganous Manganic Oxide (Mn3O4 PF), Manganese Carbonate (MnCO3 UF), and High Surface Area manganese Dioxide (MnO2-HSA) Production Process

One reactor for the production of Mn3O4 PF (EP7-404A), MnCO3 UF (EP7-404A) or MnO2-HSA controlled by a wet scrubber. (EP7-404D)

1982, 1998M

One MnO HP conveyor equipped with a baghouse. (EP7-404B). The baghouse is used for material recovery.

1982

One Aljet dryer rated at 1.4 MMBtu/hr fired by natural gas and is back-up by propane gas. The dryer is equipped with a baghouse (EP7-404C). The baghouse is used for material recovery.

1982

EU08 003-0056-7-0405 Manganese Nitride Production Process

One ferromanganese roll crusher and one sodium silicate blending screw equipped with a baghouse. (EP7-0405A)


One tube loading station and unloading, screening, packaging equipped with a baghouse. (7-0405B)


EU09 003-0056-7-0406 Manganese Nitrate Solution Process line

One (1) Manganese Nitrate Solution Process line



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Emissions Unit

Number

ARMA Registration

Number



EU10 003-0056-7-0407 Manganese Chloride Prilling Process

Two Chemetals MnCl2 prills rotary dryers each rated at 1.8 MMBtu/hr fired by natural gas and is back-up by propane gas. Both dryers are controlled by a packed tower scrubber (EP7-407A). The scrubber is used for material recovery.

1975

One boildown tank controlled by one packed bed scrubber (EP7-407B). The scrubber is used for material recovery.

1975, 1996M

EU11 003-0056-7-0408 High Purity Manganese Oxides Process (Nitrate Plant)

Five rooftop ventilators for fugitive emissions each at 14000 cfm. (EP7-408A)

1972

One raw MnO2 ore dryer rated at 3.5 MMBTU/hr fired by natural gas and is back-up by propane gas or No.2 fuel oil. (EP7-408B)

1974

Two contact condensers controlled by one chemical scrubber (EP7-408C). The scrubber is used for material recovery.

1972

Three treatment tanks equipped with one dust collector (EP7-408D). The dust collector is used for material recovery.

1972, 1998M

One evaporator (EP7-408E) 1972 One MnO2-HP dryer rated

at 2.27 MMBTU/hr fired by natural gas and back up by propane gas or No.2 fuel oil equipped with a dust

1972, 1998M



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Emissions Unit

Number

ARMA Registration

Number



collector (EP7-408F). The dust collector is used for material recovery.

One horizontal roaster with two burners rated at 1.65 MMBTU/hr fired by natural gas and is back-up by propane gas or No.2 fuel oil. (EP7-408G)

1972

One ball mill/classification unit equipped with a baghouse (EP7-408H). The baghouse is used for material recovery.

1979

One air classifier equipped with a dust collector (EP7-408I). The baghouse is used for material recovery.

1998M

EU12 003-0056-7-0410 Manganese Chloride Flakes Processing Equipment

Two rotary drum dryers rated at 4.6 MMBTU/hr fired by natural gas and back up by propane gas. Dryers and MnCl2 packaging facility are controlled by a venturi scrubber. (EP7-410A). The scrubber is used for material recovery.

1976

EU13 003-0056-7-0411 CST & Mn2O3 Process

One Eirich (Sigma) mixer blender with hopper equipped with one baghouse. (EP7-411A/D; A and D represent different emissions when products change but both products share the same equipment and emission point)

1993, 1997M, 1998M

Two horizontal roaster/calciners rated at 0.2 MMBTU/hr fired by natural gas and back up by propane gas. Each

1962, 1998M



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Emissions Unit

Number

ARMA Registration

Number



roaster/calciner is equipped with one baghouse (EP7-411B/E). The baghouse is used for material recovery.

One turbo-screen classifier equipped with one dust collector (EP7-411C). The baghouse is used for material recovery.

1998M

EU14 003-0056-9-0416 Raw MnO2 pile storage & material handling

Fugitive emissions (EP9-416-FUG)

1975

AN OVERVIEW OF THE PART 70 PERMIT The Fact Sheet is an informational document. If there are any discrepancies between the Fact Sheet and the Part 70 permit, the Part 70 permit is the enforceable document. Section I of the Part 70 Permit contains a brief description of the facility and an inventory list of the emissions units for which applicable requirements are identified in Section IV of the permit. Section II of the Part 70 Permit contains the general requirements that relate to administrative permit actions. This section includes the procedures for renewing, amending, reopening, and transferring permits, the relationship to permits to construct and approvals, and the general duty to provide information and to comply with all applicable requirements. Section III of the Part 70 Permit contains the general requirements for testing, record keeping and reporting; and requirements that affect the facility as a whole, such as open burning, air pollution episodes, particulate matter from construction and demolition activities, asbestos provisions, ozone depleting substance provisions, general conformity, and acid rain permit. This section includes the requirement to report excess emissions and deviations, to submit an annual emissions certification report and an annual compliance certification report, and results of sampling and testing. Section IV of the Part 70 Permit identifies the emissions standards, emissions limitations, operational limitations, and work practices applicable to each emissions unit located at the facility. For each standard, limitation, and work



Page 9 of 50

practice, the permit identifies the basis upon which the Permittee will demonstrate compliance. The basis will include testing, monitoring, record keeping, and reporting requirements. The demonstration may include one or more of these methods. Section V of the Part 70 Permit contains a list of insignificant activities. These activities emit very small quantities of regulated air pollutants and do not require a permit to construct or registration with the Department. For insignificant activities that are subject to a requirement under the Clean Air Act, the requirement is listed under the activity. Section VI of the Part 70 Permit contains State-only enforceable requirements. Section VI identifies requirements that are not based on the Clean Air Act, but solely on Maryland air pollution regulations. These requirements generally relate to the prevention of nuisances and implementation of Maryland's Air Toxics Program. REGULATORY REVIEW/TECHNICAL REVIEW/COMPLIANCE METHODOLOGY

Table IV – 0 (General Provisions for Section IV) 0.0 General Provisions Within Plant Specific Requiremen ts:

This table provides generally applicable provisions with regard to requirements for observations for visible emissions, preparation of operations and maintenance plans, preparation of best management practice plans for unconfined sources, stack testing, record keeping and reporting. Provisions included in this table will be referenced in succeeding tables in this section when such provisions are applicable. Provisions in this table may also be superseded or modified by requirements in succeeding tables in this section. INDEX: 1.1 Observations For Visible Emissions 1.2 Operations and Maintenance Plans 1.3 Best Management Practices Plans For Unconfined Sources 1.4 Performance Test Protocols 1.5 Record Keeping and Reporting

0.1 Observations For Visible Emissions: Unless otherwise provided in the specific requirements for an affected emissions unit or emissions point, whenever the Permittee is required to perform an observation for visible emissions the following shall apply:



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Table IV – 0 (General Provisions for Section IV) (A) Each required observation of an emissions point shall be

performed when the affected source of emissions is in operation. If the affected source of emissions does not operate within the period during which an observation would otherwise be required, the Permittee shall not be required to make an observation of the emissions point for that period.

(B) If the Permittee is required to observe an emissions point that is

common to more than one source of emissions, the Permittee shall make the required observation when at least one of the sources of emissions is in operation. If none of the affected sources of emissions operate within the period during which an observation would otherwise be required, the Permittee shall not be required to make an observation of the emissions point for that period.

(C) Observations shall be performed during daylight hours unless

the Permittee obtains from the Department written approval to conduct observations of properly lighted emissions points during non-daylight hours.

(D) Excepting observations for visible emissions from exhaust

stacks on fuel burning equipment, each required observation for visible emissions shall endure for at least one (1) minute unless a longer duration is specified in the Part 70 operating permit condition that requires the observation. Required observations for visible emissions from exhaust stacks on fuel burning equipment (e.g., boilers, thermal oil heaters) shall be performed in accordance with Method 9 and shall endure for at least 18 minutes unless a different duration is specified in the Part 70 permit condition that requires the observation.

(E) The Permittee shall make a written or printable electronic record

of each required observation for visible emissions, and each such record shall include identification of the observer, the date of the observation, the time at the start of the observation, the time at the end of the observation if the observation endures for more than 1 minute, and an account of the observer’s findings during performance of the observation.

[Authority: COMAR 26.11.03.06C] 0.2 Operations and Maintenance Plans:

Unless otherwise provided in the specific requirements for an emissions unit or plant, whenever the Permittee is required to develop and implement an



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Table IV – 0 (General Provisions for Section IV) operations and maintenance (O&M) plan, the plan shall include at minimum: (A) Information that is sufficient to demonstrate that air emissions

from each affected emissions unit can be expected to comply with all applicable standards and limits during periods of normal operation. Examples of types of information that could be included to support the required demonstrations would be design criteria, vendor specifications and performance guarantees, approved computer modeling studies, and results of testing programs in which approved test methods and procedures were utilized;

(B) Procedures that provide for proper operation and maintenance

(including preventive maintenance) of all affected emissions units and air pollution control equipment associated with the source;

(C) Provisions for periodic monitoring of operating parameters and

emissions as necessary to determine that affected emissions units and air pollution control equipment are functioning properly;

(D) Provisions for periodic inspections, to be conducted at least as

frequently as once per month, to determine whether responsible persons are complying with the provisions and procedures included in the required O&M plan;

(E) Descriptions of procedures to be followed and corrective actions

to be taken when inspections or monitoring information indicate that an emissions unit or pollution control device is not functioning properly; and

(F) Provisions for developing written or printable electronic records

that show whether prescribed operating, maintenance and monitoring procedures are consistently followed, and whether timely and appropriate corrective actions are taken when malfunctions occur.

[Authority: COMAR 26.11.03.06C] 0.3 Best Management Practices Plans For Unconfined Sources:

Unless otherwise provided in the specific requirements for an emissions unit, whenever the Permittee is required to develop and implement a best management practices (BMP) plan for control of particulate emissions from an unconfined source, such plan shall identify all reasonable precautions to



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Table IV – 0 (General Provisions for Section IV) be implemented to prevent particulate matter from becoming airborne. Such reasonable precautions shall include: (1) Housekeeping measures to minimize excess dust, including (a) using

either an industrial vacuum system or manual sweeping to reduce the amount of dust; (b) at least once per month, removing dust from walls, ledges, and equipment using low pressure air or other means, and then sweeping or vacuuming the area; and (c) keeping exterior doors in the immediate affected areas shut except during normal ingress and egress, as practicable.

(2) Maintaining and operating all process equipment in accordance with

manufacturer's specifications and in a manner to minimize dust creation.

(3) Storing raw materials in closed containers, as practicable. (4) Keeping mixers covered when mixing is occurring except when

materials are added to the mixer. (5) For bulk loading processes where materials are loaded into trucks or

railcars, lessen fugitive emissions by reducing the distance between the loadout spout and the vehicle being loaded by using a device of any kind at the bulk loadout spout that minimizes the distance to the vehicle being loaded, or using any other means to minimize the distance between the loadout spout and the vehicle being loaded.

The BMP plan shall include provisions for periodic inspections, to be conducted at least once per month, to determine whether reasonable precautions identified in the plan are consistently employed. [Authority: COMAR 26.11.03.06C, COMAR 26.11.06.03C( 1), and COMAR 26.11.06.03C]

0.4 Performance Test Protocols: (A) Unless otherwise provided in the specific requirements for an

emissions unit or emissions point, when the Permittee is required to perform stack testing the Permittee shall submit to the Department for approval a stack test protocol that includes:

(1) the purpose of the stack testing; (2) a testing schedule that provides the projected dates

and times of testing;



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Table IV – 0 (General Provisions for Section IV) (3) an account of all test methods and procedures to be

employed during the testing program; (4) for the emissions source or sources to be tested, an

account of the operating conditions that will be extant during the testing program;

(5) for fuel burning sources, identification of the types of

fuels that will be burned during the testing periods; and (6) identification of operating data that will be collected

during the testing periods. (B) The required stack test protocol shall be submitted at least 30 days

prior to performance of any testing, and testing shall not be conducted before the Department provides approval of the protocol.

(C) Results of all required stack tests shall be submitted to the Department

in writing within 60 days of completion of the testing. [Authority: COMAR 26.11.03.06G]

0.5 Record Keeping and Reporting Requirements: (A) Unless otherwise provided in the specific requirements for an

emissions unit or emissions point, the Permittee shall maintain at the facility for at least five (5) years, and shall make available to the Department upon request, all records that the Permittee is required by this Part 70 operating permit to establish.

(B) Records required by this Part 70 operating permit shall be

maintained in a format that is acceptable to the Department. A format adopted by the Permittee shall be considered acceptable until the Department provides the Permittee with written notice otherwise.

(C) Unless otherwise specified in this Part 70 operating permit

required records shall be maintained either in writing or in a printable electronic form.

[Authority: COMAR 26.11.03.06C]



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Emission Unit EU01 (5-0378)

Fuel burning equipment – one backup boiler (#5-0378, 29 MMBTU/Hr) installed 1971. The boiler is natural gas fired. Propane gas and No.2 fuel oil are alternative fuels during natural gas supply interruptions. The unit is operated as a back-up during periods of mechanical repair or inspection of the primary boiler (EU02; 5-0412). This unit was installed before June 9, 1989 and is not subject to NSPS Subpart Dc – Standards of Performance for Small Industrial – Commercial – Industrial Steam Generating Unit. The emissions unit is subject to 40 CFR 63, Subpart DDDDD (NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters operated at facilities that are major sources of HAP). The final NESHAP rule was promulgated on January 31, 2013. Existing boilers (boilers constructed June 4, 2010 or earlier) must comply with the NESHAP no later than January 31, 2016. The emission units is not subject to Compliance Assurance Monitoring (CAM) requirements because it is not equipped with an air pollution control device. Applicable Requirements: A. Visible Emissions Limitations

• COMAR 26.11.09.05A(2) which prohibits visible emissions other than water in an uncombined form.


Compliance with Visible Emissions Standards The Permittee shall properly operate and maintain the boiler; and verify that there are no visible emissions when burning No. 2 fuel oil. The Permittee shall conduct a visible emissions observation of exhaust gases from each emission point for a 6-minute period once for each 168 hours that the boiler burns oil.

The Permittee shall perform the following, if emissions are visible: a. Inspect all process and/or control equipment that may affect visible

emissions;



Page 15 of 50

b. Perform all necessary repairs and/or adjustments to processes or control

equipment within 48 hours, so that visible emissions in the exhaust gases are eliminated;

c. Document, in writing, the results of the inspections and the repairs and/or

adjustments made to the processes and/or control equipment; and

d. If visible emissions have not been eliminated within 48 hours, the Permittee shall perform a Method 9 observation once daily for an 18 minute period until corrective actions have eliminated the visible emissions.

The Permittee shall establish in writing, revise as necessary and implement an operations and maintenance (O&M) plan developed and implemented in accordance with Section 0.2 of Table IV-0 of this Part 70 operating permit. [Authority: COMAR 26.11.03.06C] The Permittee shall maintain a log of maintenance performed that relates to combustion performance. The Permittee shall report incidents of visible emissions in accordance with permit condition 4 of Section III, Plant Wide Conditions, "Report of Excess Emissions and Deviations". The basis for these monitoring, record keeping, and reporting requirements is the Department's authority to create periodic monitoring requirements, COMAR 26.11.03.06C.

Rationale for Periodic Monitoring Strategy The boiler burns natural gas as a primary fuel with distillate as a back up fuel only when natural gas or propane are unavailable. All of the boilers are required to be operated and maintained in accordance with an O&M plan. Properly operated and maintained boilers will rarely cause visible emissions when burning natural gas or No. 2 fuel oil. The Permittee is required to maintain on site an operations manual, a preventative maintenance plan, and records of maintenance performed that relate to combustion performance. Visible emissions will most likely occur when burning No. 2 fuel oil during periods of interrupted gas service. The Permittee is required to perform a visible emissions observation of the exhaust gases from the boiler stack for a 6-minute period, once per 168 hours that fuel oil is burned. The Permittee is required to maintain a record of the results of the observations and number of hours that No. 2 fuel oil is burned.



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B. Control of Sulfur Oxides • COMAR 26.11.09.07A(2)(b) which limits the sulfur content of distillate fuel oil

to 0.3% by weight. Compliance with Sulfur Limitation The Permittee shall obtain a certification from the fuel supplier indicating that the oil complies with the limitation on the sulfur content of fuel oil. The Permittee shall retain fuel supplier certifications of sulfur content in fuel. The Permittee shall report fuel supplier certifications of sulfur content in fuel to the Department upon request. The basis for these monitoring, record keeping, and reporting requirements is the department's authority to create periodic monitoring requirements, COMAR 26.11.03.06C.

Rationale for Periodic Monitoring Strategy The fuel supplier certifications of sulfur content in fuel will be used to demonstrate the compliance of the requirement of COMAR 26.11.09.07A(2)(b).

C. Control of NOx

• COMAR 26.11.09.08E, Requirement for Fuel Burning Equipment with Rated

Heat Input Capacity of 100 MMBtu/hour or Less, which requires the Permittee to:

(a) Submit to the Department an identification of the boiler, the rated heat

input capacity, and the type of fuel burned in the boiler; (b) Perform a combustion analysis for each installation at least once each

year and optimize combustion based on the analysis;

(c) Maintain the results of the combustion analysis at the site for at least two years and make this data available to the Department and the EPA upon request;

(d) Once every 3 years, require each operator of the installation to attend

operator training programs on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and

(e) Prepare and maintain a record of training program attendance for each

operator at the site, and make these records available to the Department upon request.



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• For the purposes of COMAR 26.11.09.08, the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation. [Reference: COMAR 26.11.09.08B(5)] Compliance Demonstration and Rationale for Periodic Monitoring Strategy COMAR 26.11.09.08E outlines the specific monitoring, record keeping, and reporting requirements necessary to demonstrate compliance. These requirements include periodic combustion analyses and training programs. No additional periodic monitoring is necessary to demonstrate compliance.

D. Operating Requirements • The boilers shall burn only natural gas except during periods of gas

curtailment or gas supply interruptions of any duration as defined in 40 CFR §63.7575. No. 2 oil may be burned only during periods of gas curtailment or gas supply interruptions or for periodic testing of liquid fuel, maintenance, or operator training, not to exceed a combined total of 48 hours during any calendar year. [Authority: 40 CFR §63.7575]

Compliance Demonstration and Rationale for Record Keeping and Reporting Requirements Only

The boiler is considered natural gas boiler with respect to the boiler NESHAP, 40 CFR 63, Subpart DDDDD. To comply with the requirement the Permittee shall:

• maintain a copy of the interruptible natural gas service contract that the

Permittee is required by the Part 70 operating permit to maintain with a utility company under the jurisdiction of the Maryland Public Service Commission;

• maintain records of all periods during which the Permittee's natural gas

service was interrupted or curtailed; and

• maintain records of all fuels burned in the boilers during periods when natural gas was available, and records of all fuels burned in the boilers when natural gas service was interrupted or curtailed.

The applicable requirement limits the types of fuels that may be burned and when the fuels may be burned in the emissions units. Records of utility contracts, periods of when natural gas was interrupted or curtailed, and fuel usage are sufficient to demonstrate compliance. The records must also be made available to the Department upon request for compliance review.



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A. Control of HAP • No later than January 31, 2016, the Permittee shall comply with the work

practice requirements of 40 CFR 63, Subpart DDDDD [Authority: 40 CFR §63.7495(a) and (b)]

Compliance Demonstration and Rationale for Periodic Monitoring Strategy To comply with the requirements of 40 CFR 63, Subpart DDDDD for boilers greater than 10 MMBtu/hr that burn natural gas (and fuel oil only as a back up during gas curtailment or supply interruption), the Permittee must conduct a one-time energy assessment for the existing boiler, initial and subsequent tune-ups of all boilers (existing and new). The Permittee must conduct the assessment and tune-ups using the procedures prescribed in Subpart DDDDD and submit initial and subsequent annual reports. The Permittee must also keep records of when gas supply is curtailed or interrupted and when alternative fuels are used. Subpart DDDDD outlines all of the specific initial and continuous compliance demonstration requirements for the assessment and tune-ups. No additional periodic monitoring is required.

Emission Units EU02 (5-0412)

Fuel burning equipment – one primary boiler (#5-0412, 40 MMBTU/Hr) installed after June 9, 1989. This emission unit includes one 40 million BTU/hr Cleaver-brooks fire tube boiler. The boiler is natural gas fired. Propane gas and No. 2 fuel oil are the back-up fuels during the interruptions of natural gas. The unit is the primary unit for steam generating. This unit was installed after June 9, 1989 and is subject to NSPS Subpart Dc – Standards of Performance for Small Industrial – Commercial – Industrial Steam Generating Unit. Applicable Requirements: A. Visible Emissions Limitations • COMAR 26.11.09.05A(2) which prohibits visible emissions other than water in

an uncombined form.




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• 40 CFR §60.43c(c) and (d) - Except during periods of start up, shut down, or malfunction, when the Permittee is burning fuel oil in an NSPS boiler the Permittee shall operate the unit so that the opacity of any exhaust gases does not exceed 20 percent on a 6-minute average, except for one (1) 6-minute period per hour of not more than 27 percent. [Reference: 40 CFR §60.43c(c) and (d)]. Compliance with the “No Visible Emissions” requirement of COMAR 26.11.09.05A(2) will be used to show compliance with this NSPS standard.

Compliance with Visible Emissions The Permittee shall properly operate and maintain the boiler; and verify that there are no visible emissions when burning No. 2 fuel oil. The Permittee shall conduct a visible emissions observation of exhaust gases from each emission point for a 6-minute period once for each 168 hours that the boiler burns oil.

The Permittee shall perform the following, if emissions are visible:

a. Inspect all process and/or control equipment that may affect visible

emissions; b. Perform all necessary adjustments and/or repairs to the boiler within 48

hours, so that visible emissions are eliminated; c. Document in writing the results of the inspections, adjustments and/or

repairs to the boiler; and d. After 48 hours, if the required adjustments and/or repairs had not

eliminated the visible emissions, perform Method 9 observations once daily for 18 minutes until corrective actions have eliminated the visible emissions.

The Permittee shall establish in writing, revise as necessary and implement an operations and maintenance (O&M) plan developed and implemented in accordance with Section 0.2 of Table IV-0 of this Part 70 operating permit. [Authority: COMAR 26.11.03.06C] The Permittee shall submit to the Department for approval a written site-specific monitoring plan that includes procedures and criteria for establishing and monitoring specific parameters for the boilers indicative of compliance with the opacity standard. For testing performed as part of this site-specific monitoring plan, the Department may require as an alternative to the notification and reporting requirements specified in 40 CFR §§60.8 and 60.11 that the Permittee submit any deviations with the excess emissions report required under 40 CFR §60.48c(c). [Authority: 40 CFR §60.47c(f)(3)] Such site-specific monitoring plan may be included in the required O&M plan. The Permittee shall maintain a log of maintenance performed that relates to combustion performance. The Permittee shall report incidents of visible



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emissions in accordance with permit condition 4 of Section III, Plant Wide Conditions, "Report of Excess Emissions and Deviations". The basis for these monitoring, record keeping, and reporting requirements is the Department's authority to create periodic monitoring requirements, COMAR 26.11.03.06C.

For NSPS boiler: Installations that burn oil with a sulfur content that does not exceed 0.5 percent by weight are not subject to the particulate emissions limit established in 40 CFR 60, Subpart Dc. [Reference: 40 CFR §60.43c(e)(4)]

Rationale for Periodic Monitoring Strategy The boiler burns natural gas as a primary fuel with distillate oil as a back up fuel only when natural gas is unavailable. All of the boilers are required to be operated and maintained in accordance with an O&M plan. Properly operated and maintained boilers will rarely cause visible emissions when burning natural gas or No. 2 fuel oil. The Permittee is required to maintain on site an operations manual, a preventative maintenance plan, and records of maintenance performed that relate to combustion performance. Visible emissions will most likely occur when burning No. 2 fuel oil during periods of interrupted gas service. The Permittee is required to perform a visible emission observation of the exhaust gases from the boiler stack for a 6-minute period, once each 168 hours that fuel oil is burned. The Permittee is required to maintain a record of the results of the observations and number of hours that No. 2 fuel oil is burned.


• The Permittee shall not burn, sell, or make available for sale any distillate fuel oil with sulfur content in excess of 0.3 percent by weight. [Reference: COMAR 26.11.09.07A(2)(b)]

• 40 CFR §60.42c(d) establishes that compliance with the SO2 standard for affected units may be demonstrated by use of fuel oil with a sulfur content that does not exceed 0.5 percent by weight. Compliance with COMAR 26.11.09.07A(2)(b), which requires 0.3 % sulfur content by weight, will be used to demonstrate compliance with this NSPS standard.

Compliance with this requirement also provides compliance with the emissions standard for sulfur dioxide (SO2) established under 40 CFR §60.42c for the NSPS boilers when those boilers are burning distillate fuel oil. Specifically, 40 CFR §60.42c(d) establishes that compliance with the SO2 standard for affected units may be demonstrated by use of fuel oil with a sulfur content that does not exceed 0.5 percent by weight.



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Compliance with Sulfur Dioxide Standards For distillate oil-fired NSPS affected facilities with heat input capacities between 10 and 100 MMBtu/hr, compliance with the emission limits, or fuel oil sulfur limits may be determined based on a certification from the fuel supplier, as described under 40CFR60.48c(f), as applicable [Reference 40CFR60.42c(h)(1)]. The Permittee shall obtain a certification from the fuel supplier indicating that the oil complies with the limitation on the sulfur content of fuel oil [Authority: 40 CFR 60.44c(h)]. The supplier certification shall include the following information [Reference: 40CFR60.48c(f)(1)]:

(a) The name of the oil supplier; (b) A statement from the oil supplier that the oil complies with the

specifications under the definition of distillate oil in 40CFR60.41c; and (c) The sulfur content or maximum sulfur content of the oil.

The owner or operator of each affected facility subject to the fuel oil sulfur limits under 40CFR60.42c(d) shall keep records and submit reports to the Department. In addition to records of fuel supplier certifications, the report shall include a certified statement signed by the owner or operator of the affected facility that the records of fuel supplier certifications submitted represent all of the fuel combusted during the reporting period [References: 40CFR60.48c(d) & (e)(11); COMAR 26.11.09.07C]. The reporting period for the reporting required under 40 CFR §60.48c is each six (6) month period. All reports shall be submitted to the Department and shall be postmarked by the 30th day following the end of the reporting period. [Reference: 40 CFR §60.48c(j)] The Permittee shall maintain a record of the hours that No. 2 fuel oil is burned. [COMAR 26.11.03.06C] Rationale for Periodic Monitoring Strategy This boiler is subject to NSPS (40 CFR 60 Subpart Dc) sulfur content in fuel oil requirements. The methodology for the compliance demonstration is based on the NSPS monitoring, record keeping, and reporting requirements for sulfur in fuel oil.

This boiler is subject to following Federal New Source Performance Standards (NSPS) for Small Industrial-commercial-institutional Steam Generating Units with a heat input capacity less than 100 million Btu/hour but greater than 10 million Btu/hour for which construction began after June 9, 1989, 40 CFR 60, Subpart Dc:



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� 40 CFR 60.43c which limits visible emissions to 20 percent opacity

� 40 CFR 60.42c which limits sulfur content in the fuel oil to 0.5 wt %

Compliance with the “No Visible Emissions” requirement of COMAR 26.11.09.05A(2) will be used as a demonstration of compliance with the NSPS 20 percent opacity standard.

Subpart Dc was revised in 2009 to require Method 9 or a site specific plan per 40 CFR 60.47c(g) for affected facility. The VE observations required by the Title V permit satisfy this requirement.

The demonstration of compliance with COMAR 26.11.09.07A, which requires 0.3 % sulfur content by weight, as well as the NSPS limitation of 0.5 % will be based on the NSPS monitoring, record keeping, and reporting requirements for sulfur content in fuel oil.

C. Control of NOx • COMAR 26.11.09.08E, Requirement for Fuel Burning Equipment with Rated

Heat Input Capacity of 100 MMBtu/hour or Less, which requires the Permittee to:

(a) Submit to the Department an identification of the boiler, the rated heat

input capacity, and the type of fuel burned in the boiler; (b) Perform a combustion analysis for each installation at least once each

year and optimize combustion based on the analysis;

(c) Maintain the results of the combustion analysis at the site for at least two years and make this data available to the Department and the EPA upon request;

(d) Once every 3 years, require each operator of the installation to attend

operator training programs on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and

(e) Prepare and maintain a record of training program attendance for each

operator at the site, and make these records available to the Department upon request.

• For the purposes of COMAR 26.11.09.08, the equipment operator to be

trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation. [Reference: COMAR 26.11.09.08B(5)]



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Compliance Demonstration and Rationale for Periodic Monitoring Strategy COMAR 26.11.09.08E outlines the specific monitoring, record keeping, and reporting requirements necessary to demonstrate compliance. These requirements include periodic combustion analyses and training programs. No additional periodic monitoring is necessary to demonstrate compliance.

• The Permittee shall only burn Natural Gas with No. 2 Fuel Oil or propane gas

as backup unless the Permittee applies for and receives an approval or permit from the Department to burn an alternate fuel. [COMAR 26.11.02.09A]

Compliance Demonstration and Rationale for Periodic Monitoring Strategy

The Permittee is required to submit an annual emissions certification report (permit condition 8 of Section III, Plant Wide Conditions "Emissions Certification Report). The annual certification report must contain the type, quantities, and analyses of all fuels burned. No additional requirements are needed to show compliance with this operational limitation.

D. Operating Requirements • The boilers shall burn only natural gas except during periods of gas

curtailment or gas supply interruptions of any duration as defined in 40 CFR §63.7575. No. 2 oil may be burned only during periods of gas curtailment or gas supply interruptions or for periodic testing of liquid fuel, maintenance, or operator training, not to exceed a combined total of 48 hours during any calendar year. [Authority: 40 CFR §63.7575]

Compliance Demonstration and Rationale for Record Keeping and Reporting Requirements Only

The boiler is considered natural gas boiler with respect to the boiler NESHAP, 40 CFR 63, Subpart DDDDD. To comply with the requirement the Permittee shall:

• maintain a copy of the interruptible natural gas service contract that the

Permittee is required by the Part 70 operating permit to maintain with a utility company under the jurisdiction of the Maryland Public Service Commission;

• maintain records of all periods during which the Permittee's natural gas

service was interrupted or curtailed; and

• maintain records of all fuels burned in the boilers during periods when natural gas was available, and records of all fuels burned in the boilers when natural gas service was interrupted or curtailed.



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The applicable requirement limits the types of fuels that may be burned and when the fuels may be burned in the emissions units. Records of utility contracts, periods of when natural gas was interrupted or curtailed, and fuel usage are sufficient to demonstrate compliance. The records must also be made available to the Department upon request for compliance review. E. Control of HAP • No later than January 31, 2016, the Permittee shall comply with the work

practice requirements of 40 CFR 63, Subpart DDDDD [Authority: 40 CFR §63.7495(a) and (b)]

Compliance Demonstration and Rationale for Periodic Monitoring Strategy To comply with the requirements of 40 CFR 63, Subpart DDDDD for boilers greater than 10 MMBtu/hr that burn natural gas (and fuel oil only as a back up during gas curtailment or supply interruption), the Permittee must conduct a one-time energy assessment for the existing boiler, initial and subsequent tune-ups of all boilers (existing and new). The Permittee must conduct the assessment and tune-ups using the procedures prescribed in Subpart DDDDD and submit initial and subsequent annual reports. The Permittee must also keep records of when gas supply is curtailed or interrupted and when alternative fuels are used. Subpart DDDDD outlines all of the specific initial and continuous compliance demonstration requirements for the assessment and tune-ups. No additional periodic monitoring is required.

Emission Units EU03 (6-0285) Wastewater Treatment Process consisting of one emission point: One lime storage silo equipped with a dust collector (bin vent; EP6-0285) to control exhaust gases from the silo. Applicable Requirements:

1. COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in

an uncombined form from any installation or building. However, this limitation does not apply to emissions during start-up and process modifications or adjustments, or occasional cleaning of control equipment, which are not greater than 40 percent opacity for a period of not more than 6 consecutive minutes in any 60 minutes [COMAR 26.11.06.02 A (2)].

2. COMAR 26.11.06.03B(2) which limits particulate matter emissions to 0.03

grains per standard cubic foot of dry exhaust gas.

Compliance with Visible Emissions and Particulate Matter Standards



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The Permittee shall conduct a visible emissions observation of the exhaust gases from each emission point at least once per week when lime is unloading from the truck to the storage tank and shall record the results of each observation.

If emissions in the exhaust gases are visible, the Permittee shall perform the following: a. inspect all process and/or control equipment that may affect visible

emissions; b. Perform all necessary repairs and/or adjustments to processes or control

equipment within 48 hours, so that visible emissions in the exhaust gases are eliminated;

c. Document, in writing, the results of the inspections and the repairs and/or adjustments made to the processes and/or control equipment; and

d. If visible emissions have not been eliminated within 48 hours, the Permittee shall perform a Method 9 observation once daily for an 18 minute period until corrective actions have eliminated the visible emissions.

Rationale for Periodic Monitoring Strategy The Company currently unloads hydrated lime from the truck to the storage tank once per week. It usually takes one hour to complete the unloading. The required visible emission observation once per week during unloading will reveal any malfunction or lack of maintenance of the process and/or control equipment that would cause visible emissions. (If any leakages from the filter bag, the white lime powder will be instantly visible and there will be much powder covering the surfaces of the building and ground.)

The Permittee shall report incidences of visible emissions in accordance with permit condition 4, Section III, “Report of Excess Emissions and Deviations.”

Emission Units EU04 (6-0288) Manganese Ore Reduction Process consisting of the following emission points: (1) One Shaft furnace rated at 12.6 MMBTU/hr fired by natural gas as the

primary fuel and back up by propane during natural gas supply interruptions (EP6-0288A);

(2) One course MnO ball mill/classification unit equipped with a baghouse (EP6-0288B); and



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(3) One milled MnO bulk loading equipped with a baghouse. (EP6-0288C). Applicable Requirements: 1. COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in

an uncombined form. However, this limitation does not apply to emissions during start-up and process modifications or adjustments, or occasional cleaning of control equipment, which are not greater than 40 percent opacity for a period of not more than 6 consecutive minutes in any 60 minutes [COMAR 26.11.06.02 A (2)].




a. Except as otherwise provided in this part, the Permittee shall conduct a visible emissions observation of the exhaust gases from each baghouse stack (EP6-0288B and C) at least daily for the manganese (a hazardous air pollutant) particulate emissions and shall record the results of each observation. If emissions in the exhaust gases are visible, the Permittee shall perform the following: (1) inspect all process and/or control equipment that may affect visible

emissions; (2) perform all necessary repairs and/or adjustments to all processes and/or

control equipment within 48 hours, so that visible emissions in the exhaust gases are eliminated;

(3) document, in writing, the results of the inspections and the repairs and/or adjustments made to the processes and/or control equipment; and

(4) if visible emissions have not been eliminated within 48 hours, the Permittee shall perform a Method 9 observation once daily for an 18-minute period until corrective actions have eliminated the visible emissions.

b. The Permittee shall develop and maintain a preventive maintenance plan

for each dust collector (or called baghouse in this emission unit) that describes the maintenance activity and time schedule for completing each activity. The Permittee shall record the dates and maintenance activities performed, dust collector malfunctions, and the corrective actions taken to bring into proper operation.

c. The pressure drop across the mill dust collector (EP6-288B) shall be

between 3” and 10” inches water gauge under normal operation. If the



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indicator reading falls beyond the normal range, the Permittee shall conduct a visible emissions observation within 24 hours and perform all necessary repairs and/or adjustments to processes or control equipment within 72 hours, so that pressure drops are corrected. [COMAR 26.11.03.06C]

d. The pressure drop across the bulk loading dust collector (EP6-288C) shall

be between 3” and 10” inches water gauge under normal operation. If the indicator reading falls beyond the normal range, the Permittee shall conduct a visible emissions observation within 24 hours and perform all necessary repairs and/or adjustments to processes or control equipment within 72 hours, so that pressure drops are corrected. [Permit to Construct 02-6-288 M issued April 30, 1992; COMAR 26.11.03.06C]

e. The Permittee shall only burn natural gas with propane gas as back-up

during periods of interrupted gas service unless the Permittee applies for and receives an approval or permit from the Department to burn alternate fuels [COMAR 26.11.02.09A].

The Shaft furnace (EP-6-0288A) is fueled by natural gas and propane gas as back-up. The furnace is expected to be in compliance with PM and VE standards under normal operation. Rationale for Periodic Monitoring Strategy

The baghouse is designed to achieve an emissions rate of less than 0.03 gr/dscf. If the baghouse is properly maintained, it will continue to achieve its designed efficiency and will not have visible emissions. The visible emission observation and monitoring of pressure drop across the dust collectors required will reveal any malfunction or lack of maintenance of the control equipment.

3. COMAR 26.11.09.08J, Requirement for Industrial Furnaces and Other Miscellaneous Installations that Cause Emissions of NOx, which requires the Permittee to:

a. Maintain good operating practices for the Shaft furnace as recommended by

the equipment vendor to minimize NOx emissions; b. Prepare and implement a written in-house training program for all operators

of the Shaft furnace that include instruction on good operating and maintenance practices for the particular installation;

c. Maintain and make available to the Department, upon request, the written in-

house operator training program for the Shaft furnace; and



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d. Maintain operator training attendance records of the Shaft furnace for each

operator at the site for at least 2 years and make these records available to the Department upon request.

For the purposes of COMAR 26.11.09.08, the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation. [Reference: COMAR 26.11.09.08B(5)] Compliance Demonstration and Rationale for Periodic Monitoring Strategy COMAR 26.11.09.08J outlines the specific monitoring, record keeping, and reporting requirements necessary to demonstrate compliance. These requirements include good operating practices and training programs. No additional periodic monitoring is necessary to demonstrate compliance.

Emission Units EU05 (6-0721) High Surface Area Manganese Dioxide Pilot Process consisting of one emission point: One jacketed pan dryer controlled by a scrubber (EP6-0721A). The scrubber was removed and the pilot process is no longer active as of 2015. The Permittee is required to apply and obtain a permit or approval before restoring this process line. [COMAR 26.11.02.09] Emission Units EU06 (7-0403) Manganese Chloride Solution Process consists of the following emission points: (1) Two hydrochloric acid holding tanks vents manifolded together to form one

vent. (EP7-0403A; displacement and breathing losses);

(2) One evaporator for the manganese chloride solution process. (EP7-0403B; no control device); and

(3) Two leaching tanks vented to the venturi scrubber in the Manganese Chloride

Flake Process (7-0410A) in Emission Unit EU12. (Please see the monitoring, record keeping, and reporting requirements in EU12)

Applicable Requirements: COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in an uncombined form from any installation or building. However, this limitation does



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not apply to emissions during start-up and process modifications or adjustments, or occasional cleaning of control equipment, which are not greater than 40 percent opacity for a period of not more than 6 consecutive minutes in any 60 minutes [COMAR 26.11.06.02 A (2)].

Compliance with Visible Emissions Standards

The exhaust gases from two hydrochloric acid holding tanks breathing vents (EP7-0403A) contains small amount of HCl (max. 230 lbs/yr) and no particulate. The exhaust gases from the evaporator for the manganese chloride solution process (EP7-0403B) contained steam and very small amount of HCl (max. 75 lbs/yr). Therefore, no PM standard is required for both emission points. The exhaust gases from the leaching tanks are vented through the venturi scrubber in the Manganese Chloride Flake Process (7-0410A) prior to discharging to the atmosphere. All the requirements are also listed under EU12.

The Permittee shall conduct a visible emissions observation of the exhaust gases from EP7-0403A and EP7-0403B at least monthly and shall record the results of each observation.

If emissions in the exhaust gases are visible, the Permittee shall perform the following: a. inspect all process and/or control equipment that may affect visible

emissions; b. perform all necessary repairs and/or adjustments to all processes and/or


c. document, in writing, the results of the inspections and the repairs and/or adjustments made to the processes and/or control equipment; and

d. if visible emissions have not been eliminated within 48 hours, the Permittee shall perform a Method 9 observation once daily for an 18-minute period until corrective actions have eliminated the visible emissions.

The Permittee shall maintain a record of each visible emission check required in the monitoring section on site for a period of no less than five (5) years. Said record shall include the date, time, name of emission unit, the applicable visible emissions requirement, the results of the check, what action(s), if any, was/were taken, and the name of the observer. The requirements for scrubber (EP7-410A) are listed in EU12.



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The Permittee shall report incidences of visible emissions in accordance with permit condition 4, Section III, “Report of Excess Emissions and Deviations.” Rationale for Periodic Monitoring Strategy The exhaust gases from two hydrochloric acid holding tanks (EP7-0403A) and one evaporator for the manganese chloride solution process. (EP7-0403B) are expected to meet the PM and VE requirement under normal operation. The monthly visual inspection serves periodic monitoring purpose. If emissions in the exhaust gases are visible, the Permittee shall inspect all process and/or control equipment that may affect visible emissions and perform all necessary repairs and/or adjustments to all processes and/or control equipment within 48 hours. If visible emissions have not been eliminated within 48 hours, the Permittee shall perform a Method 9 observation once daily for an 18-minute period until corrective actions have eliminated the visible emissions. The Permittee shall document, in writing, the results of the inspections and the repairs and/or adjustments made to the processes and/or control equipment. The monitoring, investigation and correction plan, record keeping, and reporting are expected to demonstrate compliance through periodic monitoring.

Emission Units EU07 (7-0404) Manganous Manganic Oxide (Mn3O4 PF), Manganese Carbonate (MnCO3 UF), and High Surface Area manganese Dioxide (MnO2-HSA) Production Process (Multipurpose Plant). The process includes the following emission points: (1) One reactor for the production of Mn3O4 PF (EP7-404A), MnCO3 UF (EP7-

404A) or MnO2-HSA controlled by a wet scrubber. (EP7-404D).

(2) One MnO HP conveyor equipped with a baghouse. (EP7-404B).

(3) One Aljet dryer rated at 1.4 MMBtu/hr fired by natural gas and back up by propane gas. The dryer is equipped with a baghouse (EP7-404C).

Applicable Requirements: 1. COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in

an uncombined form from any installation or building. However, this limitation does not apply to emissions during start-up and process modifications or adjustments, or occasional cleaning of control equipment, which are not



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greater than 40 percent opacity for a period of not more than 6 consecutive minutes in any 60 minutes [COMAR 26.11.06.02 A (2)].




a. Except as otherwise provided in this part, the Permittee shall conduct a visible emissions observation of the exhaust gases from the scrubber (EP7-404D) and baghouse (EP7-404B&C) stacks at least daily and shall record the results of each observation. If emissions in the exhaust gases are visible, the Permittee shall perform the following: (1) inspect all process and/or control equipment that may affect visible

emissions;

(2) perform all necessary repairs and/or adjustments to all processes and/or control equipment within 48 hours, so that visible emissions in the exhaust gases are eliminated;

(3) document, in writing, the results of the inspections and the repairs and/or

adjustments made to the processes and/or control equipment; and



b. The Permittee shall develop and maintain a preventive maintenance plan

for each control device (baghouses and scrubber in this emission unit) that describes the maintenance activity and time schedule for completing each activity. The Permittee shall perform maintenance activities within the time frames established in the plan and shall record the dates and maintenance activities performed, dust collector malfunctions, and the corrective actions taken to bring into proper operation.

c. The Permittee shall also meet the following requirements:



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at least once a day: (a) the pH of the scrubbing solution; and (b) the flow rate of the scrubbing solution entering the scrubber [EP7-404D; Permit to construct 02-7-0404 M issued December 15, 1998].

(3) The Permittee shall monitor and record the pressure drop across the

baghouse (EP7-404C) at least once a day [COMAR 26.11.03.06].

Rationale for Periodic Monitoring Strategy

Visible emission observation and a preventive maintenance plan are required for each control device (baghouses and scrubber) in this emission unit. Additional monitoring and record keeping for pH and flow rate are required for scrubber (EP7-404D). Monitoring and record keeping for pressure drop have been added for dust collector (EP7-404C). The dust collector for conveying system (EP7-404B) handles coarse material and emits less particulate thus no additional requirement was added.

If the control device is properly maintained, it will continue to achieve its designed efficiency and will not have visible emissions. The visible emission observation required will reveal any malfunction or lack of maintenance of the control equipment.

3. COMAR 26.11.09.08J, Requirement for Industrial Furnaces and Other

Miscellaneous Installations that Cause Emissions of NOx, which requires the Permittee to:

a. Maintain good operating practices for the Aljet dryer as recommended by


of the Aljet dryer that include instruction on good operating and maintenance practices for the particular installation;


house operator training program for the Aljet dryer;

d. Burn only gas in the Aljet dryer, where gas is available, during the period May 1 through September 30 of each year; and



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e. Maintain operator training attendance records of the Aljet dryer for each operator at the site for at least 2 years and make these records available to the Department upon request.


Emission Units EU08 (7-0405) Manganese Nitride Production Process consists of the following emission points: (1) One ferromanganese roll crusher and one sodium silicate blending screw

equipped with a baghouse (EP7-0405A).

(2) One tube loading station and unloading, screening, packaging equipped with a baghouse (7-0405B).

This process line was dismantled in 2013. The Permittee is required to apply and obtain a permit or approval before restoring this process line. [COMAR 26.11.02.09] Emission Units EU09 (7-0406) Manganese Nitrate Solution Process. Since this process is used to process inorganic materials in solution form, there are no significant air emissions from this process. It has been considered as an insignificant activity in the Section V - Insignificant Activities. Emission Units EU10 (7-0407) Manganese Chloride Prilling Process consists of the following emission points: (1) Two Chemetals MnCl2 prills rotary dryers each rated at 1.8 MMBtu/hr fired by

natural gas. The dryers use propane gas as back up. Both dryers are controlled by one packed tower scrubber (EP7-407A).



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(2) One boildown tank controlled by one packed bed scrubber (EP7-407B). Applicable Requirements: 1. COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in





a. The Permittee shall conduct a visible emissions observation of the exhaust gases from the scrubber stacks (EP7-407A&B) at least daily for the manganese (a hazardous air pollutant) particulate emissions and shall record the results of each observation. If emissions in the exhaust gases are visible, the Permittee shall perform the following: (1) inspect all process and/or control equipment that may affect visible






b. The Permittee shall also meet the following requirements to ensure

compliance with Visible Emissions and Particulate Matter Standards:

(1) The Permittee shall only burn natural gas with propane gas or No. 2 fuel oil as back-up during periods of interrupted gas service unless the



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Permittee applies for and receives an approval or permit from the Department to burn alternate fuels [COMAR 26.11.02.09A].


at least once a day for the emission control of Mn particulates: (a) the pressure difference of the exhaust gases entering and leaving the scrubber; and (b) the flow rate of the scrubbing solution entering the scrubber [EP7-407A; COMAR 26.11.03.06].


at least once a day for the emission control of HCl: (a) the pH of the scrubbing solution; and (b) the flow rate of the scrubbing solution entering the scrubber [EP7-407B; Permit to construct 02-7-0407 M issued November 26, 1996].

c. The Permittee shall develop and maintain a preventive maintenance plan

for each control device (scrubber in this emission unit) that describes the maintenance activity and time schedule for completing each activity. The Permittee shall record the dates and maintenance activities performed, dust collector malfunctions, and the corrective actions taken to bring into proper operation.


If the control device is properly maintained, it will continue to achieve its designed efficiency and will not have visible emissions. The visible emission observation required will reveal any malfunction or lack of maintenance of the control equipment.



a. Maintain good operating practices for two rotary dryers as

recommended by the equipment vendor to minimize NOx emissions;

b. Prepare and implement a written in-house training program for all operators of two rotary dryers that include instruction on good operating and maintenance practices for the particular installation;

c. Maintain and make available to the Department, upon request, the

written in-house operator training program for two rotary dryers;

d. Burn only gas in two rotary dryers, where gas is available, during the period May 1 through September 30 of each year; and



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e. Maintain operator training attendance records of two rotary dryers for

each operator at the site for at least 2 years and make these records available to the Department upon request.


Emission Units EU11 (7-0408) High Purity Manganese Oxides Process consists of the following emission points: (1) Five rooftop ventilators for fugitive emissions each at 14000 cfm (EP7-408A);

(2) One raw MnO2 ore dryer rated at 3.5 MMBTU/hr fired by natural gas and back

up by propane gas or No.2 fuel oil. The dryer is equipped with one dust collector (EP7-408B);

(3) Two contact condensers controlled by one chemical scrubber (EP7-408C); (4) Three treatment tanks equipped with one dust collector (EP7-408D); (5) One evaporator (EP7-408E); (6) One MnO2-HP dryer rated at 2.27 MMBTU/hr fired by natural gas and back up

by propane gas or No.2 fuel oil. The dryer is equipped with a dust collector (EP7-408F);

(7) One horizontal roaster with two burners rated at 1.65 MMBTU/hr each fired by

natural gas and back up by propane gas or No.2 fuel oil. The roaster is equipped with one dust collector (EP7-408G);

(8) One ball mill/classification unit equipped with a dust collector (EP7-408H);

and (9) One air classifier equipped with a dust collector (EP7-408I).



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Applicable Requirements: 1. COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in



grains per standard cubic foot of dry exhaust gas. Compliance with Visible Emissions and Particulate Matter Standards

a. The Permittee shall conduct a visible emissions observation of the exhaust

gases from the dust collector stacks (EP7-408B, D, F, I, G, and H) at least daily for the manganese (a hazardous air pollutant) particulate emissions and shall record the results of each observation. If emissions in the exhaust gases are visible, the Permittee shall perform the following: (1) inspect all process and/or control equipment that may affect visible




(4) If visible emissions have not been eliminated within 48 hours, the Permittee shall perform a Method 9 observation once daily for an 18-minute period until corrective actions have eliminated the visible emissions.







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(2) The Permittee shall monitor and record daily the pressure drop across the baghouse (EP7-408B, D, and F) when in operation [COMAR 26.11.03.06C].

c. The Permittee shall develop and maintain for each control device a

preventive maintenance plan that describes the maintenance activity and time schedule for completing each activity. The Permittee shall perform maintenance activities within the time frames established in the plan and shall record the dates and maintenance activities performed, dust collector malfunctions, and the corrective actions taken to bring into proper operation.


The baghouse is designed to achieve an emissions rate of less than 0.03 gr/dscf. If the baghouse is properly maintained, it will continue to achieve its designed efficiency and will not have visible emissions. The visible emission observation required will reveal any malfunction or lack of maintenance of the control equipment.

The potential to emit Mn related PM from EP7-408B, D, and F is significant. Daily monitoring of the pressure drop across those baghouses will give additional safeguard for the smooth operation of large dust collectors.

3. COMAR 26.11.09.08J, Requirement for Industrial Furnaces and Other Miscellaneous Installations that Cause Emissions of NOx, which requires the Permittee to:

a. Maintain good operating practices for the raw MnO2 ore dryer, MnO2-HP

dryer, and horizontal roaster as recommended by the equipment vendor to minimize NOx emissions;

b. Prepare and implement a written in-house training program for all operators

of the raw MnO2 ore dryer, MnO2-HP dryer, and horizontal roaster that include instruction on good operating and maintenance practices for the particular installation;


house operator training program for the raw MnO2 ore dryer, MnO2-HP dryer, and horizontal roaster;

d. Burn only gas in the raw MnO2 ore dryer, MnO2-HP dryer, and horizontal

roaster, where gas is available, during the period May 1 through September 30 of each year; and



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e. Maintain operator training attendance records of the raw MnO2 ore dryer,

MnO2-HP dryer, and horizontal roaster for each operator at the site for at least 2 years and make these records available to the Department upon request.


Emission Units EU12 (7-0410) Manganese Chloride Flakes Process consists of the following emission points: Two rotary drum dryers rated at 4.6 MMBTU/hr are fired by natural gas. Propane gas is the back-up fuel. Both dryers and one MnCl2 packaging facility are controlled by one venturi scrubber with a mist eliminator (EP7-410A). Applicable Requirements: 1. COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in





a. Except as otherwise provided in this part, the Permittee shall conduct a visible emissions observation of the exhaust gases from the scrubber stack (EP7-410A) at least daily for the manganese (a hazardous air pollutant) particulate emission and shall record the results of each observation.



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If emissions in the exhaust gases are visible, the Permittee shall perform the following: (1) inspect all process and/or control equipment that may affect visible








The Permittee shall only burn natural gas with propane gas as back-up during periods of interrupted gas service unless the Permittee applies for and receives an approval or permit from the Department to burn alternate fuels [COMAR 26.11.02.09A].

c. The Permittee shall develop and maintain a preventive maintenance plan for each dust collector (scrubber in this emission unit) that describes the maintenance activity and time schedule for completing each activity. The Permittee shall record the dates and maintenance activities performed, dust collector malfunctions, and the corrective actions taken to bring into proper operation. [COMAR 26.11.03.06C]

d. The Permittee shall conduct a stack emission test for Particulate Matters,

Manganese compounds, and Visible Emission once every five year for the stack EP7-410A. [COMAR 26.11.03.06C]

e. The Permittee shall monitor and record the following data in a logbook at

least once a day: (a) the pressure difference of the exhaust gases entering and leaving the venturi scrubber; and (b) the flow rate of the scrubbing solution entering the venturi scrubber [EP7-410A; COMAR 26.11.03.06].


The potential to emit Manganese compounds for the stack EP7-410A is significant. To safeguard the operation of process and its control device, the



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Permittee will monitor and record: (a) the pressure difference of the exhaust gases entering and leaving the venturi scrubber; and (b) the flow rate of the scrubbing solution entering the venturi scrubber. A stack test once every five year will help the Permittee to get the best operational parameters and actual emission rates. The preventive maintenance plan, when properly executed, ensures the emission units continue to achieve its designed efficiency and will not have visible emissions. The visible emission observation required will reveal any malfunction or lack of maintenance of the control equipment.



a. Maintain good operating practices for two rotary dryers as recommended by


of two rotary dryers that include instruction on good operating and maintenance practices for the particular installation;


house operator training program for two rotary dryers;

d. Burn only gas in two rotary dryers, where gas is available, during the period May 1 through September 30 of each year; and

e. Maintain operator training attendance records of two rotary dryers for each

operator at the site for at least 2 years and make these records available to the Department upon request.




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Emission Units EU13 (7-0411) CST & Mn2O3 Process (7-0411) for CST prilling and reduction, manganese sesquioxide calcination, and lithium manganese oxide productions consists of the following emission points: (1) One Eirich (Sigma) mixer blender with hopper equipped with one baghouse

(EP7-411A/D; A and D represent different emissions when production changes but both products share the same equipment and emission point);

(2) Two horizontal roaster/calciners rated at 0.2 MMBTU/hr fired by natural gas and back up by propane gas or No 2 fuel oil. Each roaster/calciner is equipped with one baghouse (EP7-411B/E); and

(3) One turbo-screen classifier equipped with one dust collector (EP7-411C). Applicable Requirements: 1. COMAR 26.11.06.02C(2) which prohibits visible emissions other than water in





a. The Permittee shall conduct a visible emissions observation of the exhaust gases from the dust collector stacks (EP7-411A/D, B, C, and E) at least daily for the manganese (a hazardous air pollutant) particulate emissions and shall record the results of each observation. If emissions in the exhaust gases are visible, the Permittee shall perform the following: (1) inspect all process and/or control equipment that may affect visible






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(2) The Permittee shall develop and maintain a preventive maintenance

plan for each dust collector (baghouse in this emission unit) that describes the maintenance activity and time schedule for completing each activity. The Permittee shall record the dates and maintenance activities performed, dust collector malfunctions, and the corrective actions taken to bring into proper operation.


The dust collector is designed to achieve an emissions rate of less than 0.03 gr/dscf. If the dust collector is properly maintained, it will continue to achieve its designed efficiency and will not have visible emissions. The visible emission observation required will reveal any malfunction or lack of maintenance of the control equipment.


Miscellaneous Installations that Cause Emissions of NOx, which requires for the Permittee to:

a. Maintain good operating practices for the horizontal roaster/calciners as

recommended by the equipment vendor to minimize NOx emissions; b. Prepare and implement a written in-house training program for all operators

of the horizontal roaster/calciners that include instruction on good operating and maintenance practices for the particular installation;


house operator training program for the horizontal roaster/calciners;



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d. Burn only gas in the horizontal roaster/calciners, where gas is available, during the period May 1 through September 30 of each year; and

e. Maintain operator training attendance records of the horizonal

roaster/calciners for each operator at the site for at least 2 years and make these records available to the Department upon request.


Emission Units EU14 (9-0416) Raw MnO2 pile storage and material handling Applicable Requirements: 1. COMAR 26.11.06.03C which prohibits emissions from an unconfined source

without taking reasonable precautions to prevent particulate matter from becoming airborne.

2. COMAR 26.11.06.03D which require that reasonable precautions be taken to

prevent any particulate matter from becoming airborne as a result of material being handled, transported, or stored.


The Permittee shall meet the following requirements to comply with VE and PM standards for unconfined sources:

1. The Permittee shall spray water on unpaved roadways or sweep paved

roadways as frequently as necessary or use other alternatives to control fugitive particulate emissions and keep records of roadway fugitive particulates control activities for at least five (5) years and made them available to the Department upon request [COMAR 26.11.06.03D]; and



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2. The Manganese Ore Storage pile shall be covered with a tarp at all times except when material is being added to or removed from the stockpile [COMAR 26.11.06.03D].

Rationale for Periodic Monitoring Strategy:

There is no control device for this emission unit. However, by implementing good house keeping practices such as: (1) spraying water on unpaved roadways or sweep paved roadways as frequently as necessary or use other alternatives to control fugitive particulate emissions; (2) keeping records of roadway fugitive particulates control activities; and (3) covering the Manganese Ore Storage pile with a tarp at all times except when material is being added to or removed from the stockpile, the Permittee will be able to demonstrate compliance with the requirements of Visible Emissions and Particulate Matter.

COMPLIANCE SCHEDULE The Erachem Comilog, Inc. Baltimore facility is currently in compliance with all applicable air quality regulations. TITLE IV – ACID RAIN Not Applicable TITLE VI – OZONE DEPLETING SUBSTANCES The Permittee is not subject to Title VI requirements. SECTION 112(r) – ACCIDENTAL RELEASE The Erachem Comilog, Inc. Baltimore facility handles hydrochloric acid (37% or greater concentration) and propane gas but those are less than threshold quantities for accidental release prevention requirement and is not subject to the requirements under Section 112(r) - Accidental Release. However, should the Permittee become subject to 40 CFR Part 68 during the term of this permit, the Permittee shall submit risk management plans by the date specified in 40 CFR Part 68.150 and shall certify compliance with the requirements of 40 CFR Part 68 as part of the annual compliance certification as required by 40 CFR Part 70.



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PERMIT SHIELD The Permittee requested that a permit shield be expressly included in the Permittee’s Part 70 permit. Permit shields are granted on an emission unit by emission unit basis. If an emission unit is covered by a permit shield, a permit shield statement will follow the emission unit table in Section IV - Plant Specific Conditions of the permit. In this case, a permit shield was granted for each emission unit covered by the permit. INSIGNIFICANT ACTIVITIES This section provides a list of insignificant emissions units that were reported in the Title V permit application. The applicable Clean Air Act requirements, if any, are listed below the insignificant activity. (1) No. 13 Fuel burning equipment using gaseous fuels or no. 1 or no. 2

fuel oil, and having a heat input less than 1,000,000 Btu (1.06 gigajoules) per hour;

The above fuel burning units are subject to the following

requirements: COMAR 26.11.09.05A(2), which establishes that the Permittee

may not cause or permit the discharge of emissions from any fuel burning equipment, other than water in an uncombined form, which is visible to human observers.

Exceptions: COMAR 26.11.09.05A(2) does not apply to

emissions during load changing, soot blowing, start-up, or adjustments or occasional cleaning of control equipment if:

(a) The visible emissions are not greater than 40

percent opacity; and

(b) The visible emissions do not occur for more than 6 consecutive minutes in any sixty minute period.

COMAR 26.11.09.07A(2)(b), which establishes that the

Permittee may not burn, sell, or make available for sale any distillate fuel with a sulfur content by weight in excess of 0.3 percent.



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(2) No. 1 Stationary internal combustion engines with an output less than 500 brake horsepower (373 kilowatts) and which are not used to generate electricity for sale or for peak or load shaving;

The stationary internal combustion engine is subject to the following requirements:

(A) COMAR 26.11.09.05E(2), Emissions During Idle Mode:

The Permittee may not cause or permit the discharge of emissions from any engine, operating at idle, greater than 10 percent opacity.

(B) COMAR 26.11.09.05E(3), Emissions During Operating

Mode: The Permittee may not cause or permit the discharge of emissions from any engine, operating at other than idle conditions, greater than 40 percent opacity.

(C) Exceptions:

(i) COMAR 26.11.09.05E(2) does not apply for a period

of 2 consecutive minutes after a period of idling of 15 consecutive minutes for the purpose of clearing the exhaust system.

(ii) COMAR 26.11.09.05E(2) does not apply to emissions

resulting directly from cold engine start-up and warm-up for the following maximum periods:

(a) Engines that are idled continuously when not in

service: 30 minutes (b) all other engines: 15 minutes.

(iii) COMAR 26.11.09.05E(2) & (3) do not apply while

maintenance, repair or testing is being performed by qualified mechanics.

(D) COMAR 26.11.36.03A(1), which establishes that the

Permittee may not operate an emergency generator except for emergencies, testing and maintenance purposes.

(E) COMAR 26.11.36.03A(5), which establishes that the

Permittee may not operate an emergency generator for testing and engine maintenance purposes between 12:01 a.m. and 2:00 p.m. on any day on which the Department forecasts that the air quality will be a code orange, code



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red, or code purple unless the engine fails a test and engine maintenance and a re-test are necessary.

(3) �� Space heaters utilizing direct heat transfer and used solely for comfort heat;

(4) �� Brazing, soldering, or welding equipment, and cutting torches related to manufacturing and construction activities that emit HAP metals and not directly related to plant maintenance, upkeep and repair or maintenance shop activities;

(5) Containers, reservoirs, or tanks used exclusively for:

(a) �� Storage of butane, propane, or liquefied petroleum, or natural gas;

(b) No. 1 Storage of lubricating oils;

(c) No. 1 Storage of Numbers 1, 2, 4, 5, and 6 fuel oil and aviation

jet engine fuel; and

(d) No. 2 Storage of motor vehicle gasoline and having individual tank capacities of 2,000 gallons (7.6 cubic meters) or less.

(6) �� Non-contact water (i.e., water that has not been in direct contact with process fluids) cooling towers except as regulated under Section 112 of the Clean Air Act;

(7) �� Comfort air conditioning subject to requirements of Title VI of the Clean Air Act;

(8) �� Natural draft hoods or natural draft ventilators that exhaust air pollutants into the ambient air from manufacturing/industrial or commercial processes;

(9) �� Laboratory fume hoods and vents.

(10) Any other emissions unit at the facility which is not subject to an applicable requirement of the Clean Air Act (list and describe):



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No. 1 Manganese Nitrate Solution Process line (7-0406). There is no significant emission unit in this inorganic solution process.

STATE ONLY ENFORCEABLE REQUIREMENTS This section of the permit contain state-only enforceable requirements. The requirements in this section will not be enforced by the U.S. Environmental Protection Agency. The requirements in this section are not subject to COMAR 26.11.03 10 - Public Petitions for Review to EPA Regarding Part 70 Permits. The Permittee is subject to the following State-only enforceable requirements:

1. Applicable Regulations:

(A) COMAR 26.11.06.08 and 26.11.06.09, which generally prohibit the discharge of emissions beyond the property line in such a manner that a nuisance or air pollution is created.

(B) COMAR 26.11.15.05, which requires that the Permittee implement

“Best Available Control Technology for Toxics” (T – BACT) to control emissions of toxic air pollutants.

(C) COMAR 26.11.15.06, which prohibits the discharge of toxic air

pollutants to the extent that such emissions will unreasonably endanger human health

2. Operating Conditions:

Air pollution Control devices used for each process line to meet particulate

matter and visible emission limits are sufficient to comply with T-BACT requirements and the appropriate screening levels.

3. Testing and Monitoring:

The Compliance demonstration for criteria pollutants should be sufficient for air toxic pollutants.

4. Record Keeping and Reporting: The Permittee shall submit to the Department, by April 1 of each year during

the term of this permit, a written certification of the results of an analysis of emissions of toxic air pollutants from the Permittee’s facility during the previous calendar year. The analysis shall include either:



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(a) a statement that previously submitted compliance demonstrations for emissions of toxic air pollutants remain valid; or

(b) a revised compliance demonstration, developed in accordance with

requirements included under COMAR 26.11.15 & 16, that accounts for changes in operations, analytical methods, emissions determinations, or other factors that have invalidated previous demonstrations.

erachem comilog, inc. - mde.state.md.us · erachem comilog, inc. baltimore facility (the permittee)...

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