indiana department of environmental managementpermits.air.idem.in.gov/37069f.pdf · 08/04/2014 ·...

Indiana Department of Environmental Management We Protect Hoosiers and Our Environment.

100 N. Senate Avenue • Indianapolis, IN 46204

(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov

Michael R. Pence Carol S. Comer Governor Commissioner

An Equal Opportunity Employer

Recycled Paper

To: Interested Parties Date: May 26, 2016 From: Matthew Stuckey, Chief Permits Branch Office of Air Quality Source Name: Indiana Army National Guard Combined Support Maintenance Shop #2 Permit Level: Exemption Permit Number: 081-37069-00074 Source Location: Building 630, Camp Atterbury Edinburg, Indiana Type of Action Taken: Initial Permit

Notice of Decision: Approval

Please be advised that on behalf of the Commissioner of the Department of Environmental Management, I have issued a decision regarding the matter referenced above. Pursuant to 326 IAC 2, this approval was effective immediately upon submittal of the application. The final decision is available on the IDEM website at: http://www.in.gov/apps/idem/caats/ To view the document, select Search option 3, then enter permit 37069. If you would like to request a paper copy of the permit document, please contact IDEM’s central file room:

Indiana Government Center North, Room 1201 100 North Senate Avenue, MC 50-07 Indianapolis, IN 46204 Phone: 1-800-451-6027 (ext. 4-0965) Fax (317) 232-8659

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If you wish to challenge this decision, IC 4-21.5-3-7 requires that you file a petition for administrative review. This petition may include a request for stay of effectiveness and must be submitted to the Office of Environmental Adjudication, 100 North Senate Avenue, Government Center North, Suite N 501E, Indianapolis, IN 46204, within eighteen (18) calendar days from the mailing of this notice. The filing of a petition for administrative review is complete on the earliest of the following dates that apply to the filing: (1) the date the document is delivered to the Office of Environmental Adjudication (OEA); (2) the date of the postmark on the envelope containing the document, if the document is mailed to

OEA by U.S. mail; or (3) The date on which the document is deposited with a private carrier, as shown by receipt issued

by the carrier, if the document is sent to the OEA by private carrier. The petition must include facts demonstrating that you are either the applicant, a person aggrieved or adversely affected by the decision or otherwise entitled to review by law. Please identify the permit, decision, or other order for which you seek review by permit number, name of the applicant, location, date of this notice and all of the following: (1) the name and address of the person making the request; (2) the interest of the person making the request; (3) identification of any persons represented by the person making the request; (4) the reasons, with particularity, for the request; (5) the issues, with particularity, proposed for considerations at any hearing; and (6) identification of the terms and conditions which, in the judgment of the person making the

request, would be appropriate in the case in question to satisfy the requirements of the law governing documents of the type issued by the Commissioner.

If you have technical questions regarding the enclosed documents, please contact the Office of Air Quality, Permits Branch at (317) 233-0178. Callers from within Indiana may call toll-free at 1-800-451-6027, ext. 3-0178.

Enclosures Decision Permit Amdendment 4/8/14

Department of Environmental Management Office of Air Quality

Technical Support Document (TSD) for an Exemption

Source Description and Location

Source Name: Indiana Army National Guard Combined Support

Maintenance Shop #2 Source Location: Building 630, Camp Atterbury, Edinburg, IN 46124 County: Johnson SIC Code: 7538 (General Automotive Repair Shops) Exemption No.: E081-37069-00074 Permit Reviewer: Brooke Haldeman On April 13, 2016, the Office of Air Quality (OAQ) received an application from Indiana (IN) Army National Guard Combined Support Maintenance Shop #2 related to the inclusion of new emission units and the continued operation of an existing stationary general automotive repair shop.

Source Definition The Indiana Army and Air National Guard (National Guard) operates Camp Atterbury; Camp Atterbury is under the control of the Camp Commander. The CSMS is under the control of the Indiana Guard’s Director of Logistics. Both the Camp Commander and the Director of Logistics report to the Indiana Guard’s Adjutant General. The plants are both owned and controlled by the Indiana Guard. They meet the first element of the source definition therefore they will be considered one (1) source, as defined by 326 IAC 2-7-1(22). In order to consider both plants as one single source, all three of the following criteria must be met: (1) The plants must have common ownership/control; (2) The plants must have the same SIC code; and (3) The plants must be located on contiguous or adjacent properties. The SIC Code Manual of 1987 sets out how to determine the proper SIC Code for each type of business. More information about SIC Codes is available at http://www.osha.gov/pls/imis/sic_manual.html on the Internet. IDEM, OAQ is aware of the U.S. EPA’s August 2, 1996 memorandum, Major Source Determinations for Military Installations under the Air Toxics, New Source Review, and Title V Operating Permit Programs of the Clean Air Act (the DOD memo). The DOD memo is available at http://www.epa.gov/region07/air/title5/t5memos/dodguid.pdf on the Internet. The DOD memo is not binding on IDEM but it does provide guidance, as the term “major source” in the Title V program is almost identical to the term “source” in 326 IAC 1-2-73. The DOD memo states that, historically, all activities at a military installation have been grouped under the two-digit SIC Code 97, for the major group National Security and International Affairs. The DOD memo states that using the two-digit Sic Code 97 for all activities at a military installation may inappropriately aggregate activities that would not be grouped together at nonmilitary facilities. The memo suggests that plants at military installations may be assigned appropriate two-digit SIC Codes as if they were not located at military installations (see DOD memo, pages 3 to 4). Using the DOD memo approach, Camp Atterbury, as a military installation, would still have the two-digit SIC Code 97, for the major group National Security and International Affairs. The CSMS, however, which does maintenance on vehicles, would have the two-digit SIC Code 75, for the major group Automotive Repair, Services and Parking. Therefore, the plants do not have the same two-digit SIC Code. A plant is a support facility to another plant if it dedicates 50% or more of its output to another plant. The

Indiana Army National Guard Combined Support Maintenance Shop #2 Page 2 of 13 Edinburgh, Indiana TSD for Exemption No. E081-37069-00074 Brooke Haldeman CSMS does the highest level of vehicle maintenance, supporting maintenance shops for several Indiana Guard locations around the state. It supplies less than 35% of its total output to Camp Atterbury. Since the CSMS and Camp Atterbury do not have a support relationship and have different two-digit SIC Codes, they do not meet the second part of the source definition. The CSMS is located on the same property as the rest of Camp Atterbury; therefore, the third element of the source definition is met. Since Camp Atterbury and the CSMS do not meet all three parts of the source definition, IDEM, OAQ has determined that they are not part of the same source. This determination was initially made under Exemption No. E081-34559-00074, issued on August 15, 2014.

Existing Approvals The source has been operating under Exemption No. E081-34559-00074 issued on August 15, 2014.

County Attainment Status The source is located in Johnson County.

Pollutant Designation SO2 Better than national standards. CO Unclassifiable or attainment effective November 15, 1990. O3 Unclassifiable or attainment effective July 20, 2012, for the 2008 8-hour ozone standard.1

PM2.5 Attainment effective July 11, 2013, for the annual PM2.5 standard. PM2.5 Unclassifiable or attainment effective December 13, 2009, for the 24-hour PM2.5 standard. PM10 Unclassifiable effective November 15, 1990. NO2 Cannot be classified or better than national standards. Pb Unclassifiable or attainment effective December 31, 2011.

1Unclassifiable or attainment effective October 18, 2000, for the 1-hour ozone standard which was revoked effective June 15, 2005.

(a) Ozone Standards

Volatile organic compounds (VOC) and Nitrogen Oxides (NOx) are regulated under the Clean Air Act (CAA) for the purposes of attaining and maintaining the National Ambient Air Quality Standards (NAAQS) for ozone. Therefore, VOC and NOx emissions are considered when evaluating the rule applicability relating to ozone. Johnson County has been designated as attainment or unclassifiable for ozone. Therefore, VOC and NOx emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

(b) PM2.5

Johnson County has been classified as attainment for PM2.5. Therefore, direct PM2.5, SO2, and NOx emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

(c) Other Criteria Pollutants

Johnson County has been classified as attainment or unclassifiable in Indiana for all other polutants. Therefore, these emissions were reviewed pursuant to the requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2.

Indiana Army National Guard Combined Support Maintenance Shop #2 Page 3 of 13 Edinburgh, Indiana TSD for Exemption No. E081-37069-00074 Brooke Haldeman

Fugitive Emissions The fugitive emissions of criteria pollutants and hazardous air pollutants are counted toward the determination of 326 IAC 2-1.1-3 (Exemptions) applicability.

Background and Description of Emission Units and Pollution Control Equipment The Office of Air Quality (OAQ) has reviewed an application, submitted by Indiana Army National Guard Combined Support Maintenance Shop #2 on April 13, 2016, relating to the inclusion of three (3) furnace units, one (1) water heater, and fifteen (15) heaters into the source's Exemption. The units are currently permitted under Camp Atterberry's MSOP permit No. M181-31782-00042, issued on May 17, 2013. These units are located within the buildings operated by the Indiana Army National Guard Combined Support Maintenance Shop #2. Since Camp Atterbury and the Combined Support Maintenance Shop have been determined to not be part of the same source, the units are being included in the appropriate source's air approval. Additionally, the source name has been updated to reflect that it is an Indiana Army National Guard facility. The source consists of the following existing emission units and pollution control equipment: (a) Abrasive blasting gloveboxes, used for cleaning automobile parts during equipment maintenance

and repair and for paint removal and preparing equipment for spot welding, consisting of:

(1) Building 630 abrasive blasting glovebox, identified as AB01, constructed in 1997, with a maximum capacity of 25 pounds of boiler slag per year, using filter bags as controls.

(2) Building 630 abrasive blasting glovebox, identified as AB02, constructed in 1997, with a

maximum capacity of 25 pounds of boiler slag per year, using filter bags as controls. Note: Abrasive blasting gloveboxes are located in vehicle repair areas and are used for

maintenance purposes.

(b) Degreasing operations, used to clean weapons following range qualification and automotive parts, consisting of:

(1) Building 630 System One, parts washer degreaser, identified as DG01, constructed in

1997, with a maximum capacity of 30 gallons and maximum usage of 10.00 gallons per year.

(2) Building 630 Recycle-Kleen, parts washer degreaser, identified as DG02, constructed in

2010, with a maximum capacity of 20 gallons and a maximum usage of 6.70 gallons per year.

(c) High Volume Low Pressure (HVLP) Surface coating operations, including:

(1) Building 630 paint spray booth, identified as SPB01, conducting manual and spray painting touch-up of motor vehicle and mobile equipment parts, constructed in 1988, with a maximum capacity of 1.0 gallon per week, with a filter wall for particulate control, exhausting to stacks S630a and S630b.

(d) Welding and torch cutting operations, including:

(1) Building 630 MIG welder, identified as W01, constructed in 2011, with a maximum capacity of 10.40 pounds per year.

(2) Building 630 MIG welder, identified as W02, constructed in 2008, with a maximum

capacity of 20.80 pounds per year.


(3) Building 630 MIG welder, identified as W03, constructed in 2004, with a maximum capacity of 2.10 pounds per year.

(4) Building 630 plasma cutter, identified as PC01, constructed in 2003, with a maximum

capacity of 0.20 foot per minute. (5) Building 630 oxyacetylene torch, identified as TOR01, constructed after 1997, with a

maximum capacity of 1.0 foot per minute.

(e) Building 630, two (2) woodworking operations, identified as WW1 and WW2, with a maximum capacity of ten (10) 8x4 ft pieces of plywood per hour, using dust collectors (DC-1200 and DC-1900), respectively for particulate control, exhausting inside the building, including the following units: (1) One (1) band saw, with a 93.5 in. blade, constructed in 1987,

(2) One (1) chop saw (De Walt 718) with a 12 in. blade, constructed in 1987.

(f) Natural gas-fired combustion sources with heat input equal to or less than ten (10) MMBtu/hr

including but not limited to the following: Building 627:

(1) One (1) natural gas heater, identified as H1, with a nominal capacity of 0.09 MMBtu/hr; (2) One (1) natural gas heater, identified as H2, with a nominal capacity of 0.13 MMBtu/hr; (3) One (1) natural gas heater, identified as H3, with a nominal capacity of 0.02 MMBtu/hr; (4) One (1) natural gas heater, identified as H4, with a nominal capacity of 0.12 MMBtu/hr; (5) Two (2) natural gas heaters, identified as H5 and H6, each with a nominal capacity of

0.15 MMBtu/hr; (6) Three (3) natural gas heaters, identified as H7, H8 and H9, each with a nominal capacity

of 0.03 MMBtu/hr; (7) One(1) natural gas heater, identified as H10, with a nominal capacity of 0.30 MMBtu/hr; Building 630: (8) Two (2) natural gas heaters, identified as H11 and H12, each with a nominal capacity of

0.13 MMBtu/hr; (9) One (1) natural gas heater, identified as H13, with a nominal capacity of 0.13 MMBtu/hr; (10) One (1) natural gas heater, identified as H14, with a nominal capacity of 0.13 MMBtu/hr; (11) One (1) natural gas heater, identified as H15, with a nominal capacity of 0.08 MMBtu/hr; (12) Two (2) natural gas heaters, identified as H16 and H17, each with a nominal capacity of

0.024 MMBtu/hr; (13) Two (2) natural gas heaters, identified as H18 and H19, each with a nominal capacity of

0.06 MMBtu/hr;


(14) Two (2) natural gas heaters, identified as H20 and H21, each with a nominal capacity of 0.04 MMBtu/hr;

(15) Four (4) natural gas heaters, identified as H22, H23, H24 and H25, each with a nominal

capacity of 0.06 MMBtu/hr; (16) Two (2) natural gas heaters, identified as H26 and H27, each with a nominal capacity of

0.25 MMBtu/hr; (17) One (1) natural gas heater, identified as H28, with a nominal capacity of 0.25 MMBtu/hr; (18) One (1) natural gas heater, identified as H29, with a nominal capacity of 0.55 MMBtu/hr; (19) Four (4) natural gas heaters, identified as H30, H31, H32 and H33, each with a nominal

capacity of 0.40 MMBtu/hr;

The following is a list of the new emission units and pollution control devices:

(a) Natural gas-fired combustion sources with heat input equal to or less than ten (10) MMBtu/hr including but not limited to the following:

Building 633:

(1) One (1) natural gas-fired furnace, identified as H34, with a nominal capacity of 0.20

MMBtu/hr. (2) One (1) natural gas-fired water heater, identified as H35, with a nominal capacity of 0.18

MMBtu/hr. (3) Four (4) natural gas-fired heaters, identified as H36, H37, H38, and H39, each with a

nominal capacity of 0.12 MMBtu/hr. Building 709: (4) One (1) natural gas-fired furnace, identified as H40, with a nominal capacity of 0.20

MMBtu/hr. Building 631: (5) One (1) natural gas-fired furnace, identified as H41, with a nominal capacity of 0.10

MMBtu/hr. Building 710: (6) Eight (8) natural gas-fired heaters, identified as H42, H43, H44, H45, H46, H47, H48, and

H49, each with a nominal capacity of 0.12 MMBtu/hr. (7) Two (2) natural gas-fired heaters, identified as H50 and H51, each with a nominal

capacity of 0.12 MMBtu/hr. (8) One (1) natural gas-fired heater, identified as H52, with a nominal capacity of 0.12

MMBtu/hr.


“Integral Part of the Process” Determination

In October 1993 a Final Order Granting Summary Judgment was signed by Administrative Law Judge (“ALJ”) Garrettson resolving an appeal filed by Kimball Hospitality Furniture Inc. (Cause Nos. 92-A-J-730 and 92-A-J-833) related to the method by which IDEM calculated potential emissions from woodworking operations. In his findings, the ALJ determined that particulate controls are necessary for the facility to produce its normal product and are integral to the normal operation of the facility, and therefore, potential emissions should be calculated after controls. Based on this ruling, potential emissions from WW1 and WW2 for particulate matter were calculated after consideration of the controls.

Enforcement Issues

There are no pending enforcement actions related to this source.

Emission Calculations See Appendix A of this TSD for detailed emission calculations.

Permit Level Determination – Exemption The following table reflects the unlimited potential to emit (PTE) of the entire source before controls. Control equipment is not considered federally enforceable until it has been required in a federally enforceable permit.

Process/ Emission Unit

Potential To Emit of the Entire Source (tons/year)

PM PM10* PM2.5* SO2 NOx VOC CO Total HAPs Worst Single HAP

Abrasive Blasting Gloveboxes

negl. negl. negl. - - - - - -

Degreasing Operations - - - - - 0.49 - negl. negl.

Surface Coating 0.30 0.30 0.30 0.0 0.0 0.20 0.0 negl. negl.

Welding and Thermal Cutting

0.19 0.19 0.19 0.0 0.0 0.00 0.0 negl. negl.

Woodworking 1.16 1.16 1.16 0.0 0.0 0.0 0.0 0.0 -

Natural Gas-fired Heaters 0.06 0.24 0.24 0.02 3.16 0.17 2.65 0.06 0.06

Hexane

Paved Roads 0.21 0.04 0.01 0.0 0.0 0.0 0.0 0.0 -

Unpaved Roads 0.14 0.04 negl. 0.0 0.0 0.0 0.0 0.0 -

Total PTE of Entire Source 2.08 1.98 1.91 0.02 3.16 0.86 2.65 0.06 0.06 Hexane

Exemptions Levels** < 5 < 5 < 5 < 10 < 10 < 10 < 25 < 25 < 10

negl. = negligible *Under the Part 70 Permit program (40 CFR 70), PM10 and PM2.5, not particulate matter (PM), are each considered as a regulated air pollutant".

Indiana Army National Guard Combined Support Maintenance Shop #2 Page 7 of 13 Edinburgh, Indiana TSD for Exemption No. E081-37069-00074 Brooke Haldeman (a) The potential to emit (PTE) (as defined in 326 IAC 2-1.1-1) of all regulated criteria pollutants are

less than the levels listed in 326 IAC 2-1.1-3(e)(1). Therefore, the source is subject to the provisions of 326 IAC 2-1.1-3 (Exemptions).

(b) The potential to emit (PTE) (as defined in 326 IAC 2-1.1-1) of any single HAP is less than ten (10)

tons per year and the PTE of a combination of HAPs is less than twenty-five (25) tons per year. Therefore, this source is an area source under Section 112 of the Clean Air Act (CAA) and not subject to the provisions of 326 IAC 2-7.

Federal Rule Applicability Determination

New Source Performance Standards (NSPS) (a) The requirements of the New Source Performance Standards for Small Industrial-Commercial-

Institutional Steam Generating Units, 40 CFR 60, Subpart Dc, which is incorporated by reference as 326 IAC 12, do not apply to the natural gas heaters (H1-H33, H42-H52) and the gas-fired furnaces (H34 and H36-H41) since these units are not considered steam generating units as defined by 40 CFR 60.41c and each unit has a heat input capacity of less than ten (10) MMBtu/hr.

(b) The requirements of the New Source Performance Standards for Small Industrial-Commercial-

Institutional Steam Generating Units, 40 CFR 60, Subpart Dc, which is incorporated by reference as 326 IAC 12, are not included in the exemption for the natural gas-fired water heater (H35). The natural gas-fired water heater (H35) is a steam generating unit as defined by 40 CFR 60.41c but has a heat input capacity of less than ten (10) MMBtu/hr.

(c) The requirements of the New Source Performance Standard for Automobile and Light Duty Truck

Surface Coating Operations, 40 CFR 60, Subpart MM, which is incorporated by reference as 326 IAC 12, are not included in the exemption, since this source is not an automobile or light-duty truck assembly plant.

(d) There are no New Source Performance Standards (NSPS) (326 IAC 12 and 40 CFR Part 60)

included in the exemption. National Emission Standards for Hazardous Air Pollutants (NESHAP) (a) The requirements of the National Emission Standards for Halogenated Solvent Cleaning, 40

CFR 63, Subpart T, which is incorporated by reference as 326 IAC 20, are not included in the exemption for the degreasing activity because this unit uses solvents that do not contain specified halogenated HAPs equal to or greater than five percent (5%) by weight.

(b) The requirements of the National Emission Standards for Hazardous Air Pollutants: Surface

Coating of Automobiles and Light-Duty Trucks, 40 CFR 63, Subpart IIII, which is incorporated by reference as 326 IAC 20, are not included in this exemption, since the source does not apply topcoat to new automobile or new light-duty truck bodies or body parts for new automobiles or new light-duty trucks and is not a major source, or is not part of a major source of emissions of HAPs.

(c) The requirements of the National Emission Standards for Hazardous Air Pollutants for Surface

Coating of Miscellaneous Metal Parts and Products, 40 CFR 63, Subpart MMMM, which is incorporated by reference as 326 IAC 20, are not included in the exemption, since this source is not located in or part of a major source of HAPs.

(d) The requirements of the National Emission Standards for Hazardous Air Pollutants for Surface

Coating of Plastic Parts and Products, 40 CFR 63 Subpart PPPP, which is incorporated by


reference as 326 IAC 20-81, are not included in the exemption, since the source is not located at a major source of HAPs.

(e) The requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAPs)

for Industrial, Commercial, and Institutional Boilers and Process Heaters, 40 CFR 63, Subpart DDDDD, which is incorporated by reference as 326 IAC 20, are not included in the exemption, since the space heaters are not considered process heaters as defined in 40 CFR 63.7575 and since the source is not a major source of HAPs as defined in 40 CFR 63.2.

(f) The requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAPs)

for Paint Stripping and Miscellaneous Surface Coating Operations, 40 CFR 63, Subpart HHHHHH, which is incorporated by reference as 326 IAC 20, are not included in the exemption, since this source does not perform paint stripping using chemical strippers that contain methylene chloride in the removal of dried paint, does not perform spray application of coatings to motor vehicles or mobile equipment as defined in 40 CFR 63.11180, and does not perform spray application of coating that contains chromium, lead, manganese, nickel, or cadmium to a plastic and/or metal substrates. The source performs manual and spray painting touch-up of motor vehicle and mobile equipment parts only. The source also meets the criteria for exemption under 40 CFR63.11169(d)(1) because the requirements of this subpart do not apply to surface coating or paint stripping performed on site at installations owned or operated by the Armed Forces of the United States (including the Coast Guard and the National Guard of any such State), the National Aeronautics and Space Administration, or the National Nuclear Security Administration. This source is a National Guard facility.

(g) The requirements of the National Emission Standard for Hazardous Air Pollutants for Industrial,

Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ) are not included in this exemption for the natural gas-fired water heater (H35). Pursuant to 40 CFR 63.11195(f), hot water heaters are not subject to the requirements of this Subpart.

(h) There are no National Emission Standards for Hazardous Air Pollutants (NESHAPs) (326 IAC 14,

326 IAC 20 and 40 CFR Part 63) included in the exemption. Compliance Assurance Monitoring (CAM) (a) Pursuant to 40 CFR 64.2, Compliance Assurance Monitoring (CAM) is not included in the

exemption, because the unlimited potential to emit of the source is less than the Title V major source thresholds and the source is not required to obtain a Part 70 or Part 71 permit.

State Rule Applicability Determination - Source

The following state rules are applicable to the source: (a) 326 IAC 2-1.1-3 (Exemptions)

Exemption applicability is discussed under the Permit Level Determination - Exemption section above.

(b) 326 IAC 2-4.1 (Major Sources of Hazardous Air Pollutants (HAP)) The source is not subject to 326 IAC 2-4.1 because the source potential to emit of any single HAP is less than ten (10) tons per year and the potential to emit of a combination of HAPs is less than twenty-five (25) tons per year. Therefore, this source is an area source under Section 112 of the Clean Air Act (CAA) and not subject to the provisions of 326 IAC 2-4.1

(c) 326 IAC 2-6-1 (Emission Reporting) Pursuant to 326 IAC 2-6-1, this source is not subject to this rule, because it is not required to have an operating permit under 326 IAC 2-7 (Part 70), it is not located in Lake, Porter, or LaPorte


County, and it does not emit lead into the ambient air at levels equal to or greater than 5 tons per year. Therefore, 326 IAC 2-6 does not apply.

(d) 326 IAC 5-1 (Opacity Limitations) Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3 (Temporary Alternative Opacity Limitations), opacity shall meet the following, unless otherwise stated in this exemption: (1) Opacity shall not exceed an average of forty percent (40%) in any one (1) six (6) minute

averaging period as determined in 326 IAC 5-1-4. (2) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen

(15) minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix A, Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a continuous opacity monitor) in a six (6) hour period.

(e) 326 IAC 6-4 (Fugitive Dust Emissions Limitations)

Pursuant to 326 IAC 6-4 (Fugitive Dust Emissions Limitations), the source shall not allow fugitive dust to escape beyond the property line or boundaries of the property, right-of-way, or easement on which the source is located, in a manner that would violate 326 IAC 6-4.

(f) 326 IAC 6-5 (Fugitive Particulate Matter Emission Limitations)

The source is not subject to the requirements of 326 IAC 6-5, because the source does not have potential fugitive particulate emissions greater than 25 tons per year. Therefore, 326 IAC 6-5 does not apply.

(h) 326 IAC 8-1-6 (VOC Rules: General Reduction Requirements for New Facilities)

Each of the emission units at this source is not subject to the requirements of 326 IAC 8-1-6, since the unlimited VOC potential emissions from each emission unit is less than twenty-five (25) tons per year.

(i) 326 IAC 12 (New Source Performance Standards)

See Federal Rule Applicability Section of this TSD. (j) 326 IAC 20 (Hazardous Air Pollutants)

See Federal Rule Applicability Section of this TSD.

State Rule Applicability Determination - Individual Facilities Abrasive Blasting Gloveboxes (a) 326 IAC 6-3 (Particulate Emission Limitations for Manufacturing Processes) Pursuant to 326 IAC 6-3-1(b)(14), each of the two (2) abrasive gloveboxes, is exempt from the

requirements of 326 IAC 6-3, since each has particulate emissions less than five hundred fifty-one thousandths (0.551) pounds per hour.

Degreasing Operation Pursuant to 326 IAC 8-3-2 (Cold Cleaner Degreaser Control and Equipment Operating Requirements), each of the degreasers at this source is subject to the requirements of 326 IAC 8-3-2(a) and (b). The requirements of 326 IAC 8-3-2(a) are applicable to this source since this source operates a cold cleaning degreaser that uses a solvent containing VOC and did not exist on or before January 1, 1980. Additionally, the requirements in 326 IAC 8-3-2(b) are applicable to each of the cold cleaner degreasers at this source, since each was constructed after July 1, 1990 and operates without a remote solvent reservoir.

Indiana Army National Guard Combined Support Maintenance Shop #2 Page 10 of 13 Edinburgh, Indiana TSD for Exemption No. E081-37069-00074 Brooke Haldeman (a) In order to comply with the requirements of 326 IAC 8-3-2(a), the Permittee of a cold cleaner

degreaser shall ensure the following control equipment and operating requirements are met: (1) Equip the degreaser with a cover. (2) Equip the degreaser with a device for draining cleaned parts. (3) Close the degreaser cover whenever parts are not being handled in the degreaser. (4) Drain cleaned parts for at least fifteen (15) seconds or until dripping ceases. (5) Provide a permanent, conspicuous label that lists the operating requirements in

subdivisions (3), (4), (6), and (7). (6) Store waste solvent only in closed containers. (7) Prohibit the disposal or transfer of waste solvent in such a manner that could allow

greater than twenty percent (20%) of the waste solvent (by weight) to evaporate into the atmosphere.

(b) In order to comply with the requirements of 326 IAC 8-3-2(b), the owner or operator of a cold cleaner degreaser subject to this subsection shall ensure the following additional control equipment and operating requirements are met: (1) Equip the degreaser with one (1) of the following control devices if the solvent is heated

to a temperature of greater than forty-eight and nine-tenths (48.9) degrees Celsius (one hundred twenty (120) degrees Fahrenheit):

(A) A freeboard that attains a freeboard ratio of seventy-five hundredths (0.75) or

greater.

(B) A water cover when solvent used is insoluble in, and heavier than, water. (C) A refrigerated chiller. (D) Carbon adsorption. (E) An alternative system of demonstrated equivalent or better control as those

outlined in clauses (A) through (D) that is approved by the department. An alternative system shall be submitted to the U.S. EPA as a SIP revision.

(2) Ensure the degreaser cover is designed so that it can be easily operated with one (1) hand if the solvent is agitated or heated.

(3) If used solvent spray:

(A) Must be a solid, fluid stream; and (B) Shall be applied at a pressure that does not cause excessive splashing.

(c) 326 IAC 8-3-8 (Material Requirements for Cold Cleaner Degreasers) Pursuant to 326 IAC 8-3-8, (Material Requirements for Cold Cleaner Degreasers), the source shall comply with the following for DG01 and GD02:

(1) No person shall operate a cold cleaner degreaser with a solvent that has a VOC

composite partial vapor pressure that exceeds one (1) millimeter of mercury (nineteen-


thousandths (0.019) pound per square inch) measured at twenty (20) degrees Celsius (sixty-eight (68) degrees Fahrenheit).

(2) All persons subject to the requirements of subsection (b)(2) shall maintain each of the

following records for each purchase: (A) The name and address of the solvent supplier. (B) The date of purchase (or invoice/bill date of contract servicer indicating service

date).

(C) The type of solvent purchased. (D) The total volume of the solvent purchased. (E) The true vapor pressure of the solvent measured in millimeters of mercury at

twenty (20) degrees Celsius (sixty-eight (68) degrees Fahrenheit).

(3) All required records shall be: (A) Retained on-site or accessible electronically from the site for the most recent

three (3) year period; and (B) Reasonably accessible for an additional two (2) year period

Surface Coating Operation (a) 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes)

Pursuant to 326 IAC 6-3-1(b)(15), the one (1) spray booth, identified as SPB01, is exempt from the requirements of 326 IAC 6-3, since it uses less than five (5) gallons of coating per day.

(b) 326 IAC 8 (Volatile Organic Compound Rules)

Pursuant to 326 IAC 8-1-1(b), the one (1) spray booth, identified as SPB01, is not subject to the requirements of 326 IAC 8, since it has VOC emissions less than 15 pounds per day.

Welding and Torch Cutting Operations (a) 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes)

(1) Pursuant to 326 IAC 6-3-1(b)(9), each of the units compromising the welding operation is not subject to the requirements of 362 IAC 6-3-2 because each uses less than 625 pounds of weld wire or rod per day.

(2) Pursuant to 326 IAC 6-3-1(b)(10), each of the units compromising the torch cutting

operation are not subject to the requirements of 326 IAC 6-3-2 because each consumes less than 3,400 inches per hour of stock 1-inch thickness or less

Woodworking (a) 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes)

Pursuant to 326 IAC 6-3-1(b)(14), each if the units compromising the wood working operations is not subject to the requirements of 326 IAC 6-3-2 because each has particulate emissions less than five hundred fifty-one thousandths (0.551) pounds per hour after consideration of integral controls.

Indiana Army National Guard Combined Support Maintenance Shop #2 Page 12 of 13 Edinburgh, Indiana TSD for Exemption No. E081-37069-00074 Brooke Haldeman Natural Gas-Fired Emission Units (a) 326 IAC 6-2 (Particulate Emission Limitations for Sources of Indirect Heating)

(1) Pursuant to 326 IAC 6-2-1(d), indirect heating facilities which received permit to construct after September 21, 1983 are subject to the requirements of 326 IAC 6-2-4.

The particulate matter emissions (Pt) shall be limited by the following equation:

𝑃𝑃𝑃𝑃 = 1.09𝑄𝑄0.26

Where:

Pt = Pounds of particulate matter emitted per million British thermal units (lb/MMBtu). Q = Total source maximum operating capacity rating in MMBtu/hr heat input. The

maximum operating capacity rating is defined as the maximum capacity at which the facility is operated or the nameplate capacity, whichever is specified in the facility’s permit application, except when some lower capacity is contained in the facility’s operation permit; in which case, the capacity specified in the operation.

Pursuant to 326 IAC 6-2-4(a), for Q less than 10 MMBtu/hr, Pt shall not exceed 0.6 lb/MMBtu. Since the combined Q value for all sources of indirect heating at this source is less than 10 MMBtu/hr, the particulate emissions from H-35 shall not exceed 0.6 lb/MMBtu heat input.

(2) The natural gas heaters (H1-H33, H42-H52) and the gas-fired furnaces (H34 and H36-

H41) are not subject to the requirements of 326 IAC 6-2, since each the units are not a source of indirect heating.

(b) 326 IAC 6-3 (Particulate Emission Limitations for Manufacturing Processes)

Each of the gas-fired emission units is exempt from the requirements of 326 IAC 6-3, since, pursuant to 326 IAC 1-2-59, liquid and gaseous fuels and combustion air are not considered as part of the process weight. In addition pursuant to 326 IAC 6-3-1(b)(14), the natural gas-fired emission units are not subject to the requirements of 326 IAC 6-3, because the potential emissions from each of these units are less than five hundred fifty-one thousandths (0.551) pound per hour.

(c) 326 IAC 7-1.1 (Sulfur Dioxide Emission Limitations)

Pursuant to 326 IAC 7-1.1-1, each of the natural gas-fired emission units is not subject to the requirements of 326 IAC 7-1, since each has unlimited sulfur dioxide (SO2) emissions less than twenty-five (25) tons per year and ten (10) pounds per hour respectively.

Conclusion and Recommendation

Unless otherwise stated, information used in this review was derived from the application and additional information submitted by the applicant. An application for the purposes of this review was received on April 13, 2016. The operation of this source shall be subject to the conditions of the attached proposed Exemption No.: E081-37069-00074. The staff recommends to the Commissioner that this Exemption be approved.


IDEM Contact (a) Questions regarding this proposed exemption can be directed to Brooke Haldeman at the Indiana

Department Environmental Management, Office of Air Quality, Permits Branch, 100 North Senate Avenue, MC 61-53 IGCN 1003, Indianapolis, Indiana 46204-2251 or by telephone at (317) 234-5176 or toll free at 1-800-451-6027extension 4-5176.

(b) A copy of the findings is available on the Internet at: http://www.in.gov/ai/appfiles/idem-caats/ (c) For additional information about air permits and how the public and interested parties can

participate, refer to the IDEM Permit Guide on the Internet at: http://www.in.gov/idem/5881.htm; and the Citizens' Guide to IDEM on the Internet at: http://www.in.gov/idem/6900.htm.

http://www.in.gov/ai/appfiles/idem-caats/

http://www.in.gov/idem/5881.htm

http://www.in.gov/idem/6900.htm

App. A to TSD Page 1 of 9

Appendix A: Emission CalculationsEmissions Summary

Company Name: Indiana Army National Guard Combined Support Maintenance Shop #2Source Address: Building 630 Camp Atterbury, Edinburgh, IN 46124

Permit Number: E081-37069-00074Reviewer: Brooke Haldeman

Emission Unit PM PM10 PM2.5 SO2 NOx VOC CO Total HAPs

Abrasive Blasting Gloveboxes 2.5E-04 2.5E-04 2.5E-04 0.0 0.0 0.0 0.0 0.0 0.0 n/a

Degreasing Operations 0.0 0.0 0.0 0.0 0.0 0.49 0.0 negl. negl. n/aSurface Coating 0.30 0.30 0.30 0.0 0.0 0.20 0.0 negl. negl. n/a

Welding and Thermal Cutting 0.19 0.19 0.19 0.0 0.0 0.00 0.0 1.07E-03 negl. n/a

Woodworking 1.16 1.16 1.16 0.0 0.0 0.0 0.0 0.0 0.0 n/aNatural Gas-fired Heaters 0.06 0.24 0.24 0.02 3.22 0.18 2.70 0.06 0.06 HexanePaved Roads 0.21 0.04 0.01 0.0 0.0 0.0 0.0 0.0 0.0 n/aUnpaved Roads 0.14 0.04 3.65E-03 0.0 0.0 0.0 0.0 0.0 0.0 n/a

Total 2.08 1.98 1.92 0.02 3.22 0.87 2.70 0.06 0.06 Hexane

Emission Unit PM PM10 PM2.5 SO2 NOx VOC CO Total HAPs

Abrasive Blasting Gloveboxes 1.3E-05 1.3E-05 1.3E-05 0.0 0.0 0.0 0.0 0.0 0.0 n/a

Degreasing Operations 0.0 0.0 0.0 0.0 0.0 0.49 0.0 negl. negl. n/aSurface Coating 0.08 0.08 0.08 0.0 0.0 0.20 0.0 negl. negl. n/a

Welding and Thermal Cutting 0.19 0.19 0.19 0.0 0.0 0.00 0.0 1.07E-03 negl. n/a

Woodworking 1.16 1.16 1.16 0.00 0.00 0.00 0.00 0.00 0.00 n/aNatural Gas-fired Heaters 0.06 0.24 0.24 0.02 3.22 0.18 2.70 0.06 0.06 HexanePaved Roads 0.21 0.04 0.01 0.00 0.00 0.00 0.00 0.00 0.00 n/aUnpaved Roads 0.14 0.04 3.65E-03 0.00 0.00 0.00 0.00 0.00 0.00 n/a

Total 1.85 1.76 1.69 0.02 3.22 0.87 2.70 0.06 0.06 Hexane

*The Highest Single HAP for the entire source is hexane. Therefore, if an emission unit emits hexane, it is listed in the table.

Highest Single HAP (hexane)*

Highest Single HAP (hexane)*

Unlimited/Uncontrolled Potential to Emit (tons/yr)

Controlled Potential to Emit (tons/yr)


Appendix A: Emission CalculationsAbrasive Blasting Glove Boxes

Company Name: Indiana Army National Guard Combined Support Maintenance Shop #2Source Address: Building 630 Camp Atterbury, Edinburgh, IN 46124Permit Number: E081-37069-00074

Reviewer: Brooke Haldeman

Table 1 - Emission Factors for AbrasivesEmission Factor (EF)

Abrasive lb PM / lb abrasiveOther (Glass Bead, Boiler Slag) 0.01

Maximum Hourly Particulate Matter (PM) Emissions (lbs/hour)

Emission Unit Abrasive Materal Used

Maximum Hourly Usage Rate

(lbs abrasive/hr)*

Uncontrolled PTE of PM

(lbs/hr)

Control Efficiency %

Controlled PTE of PM

(lbs/hr)Abrasive blasting glovebox AB01 Boiler Slag 1.92 0.02 95% 9.62E-04

Abrasive blasting glovebox AB02 Boiler Slag 1.92 0.02 95% 9.62E-04

0.04 1.92E-03

Maximum Annual Emissions (tons/year)

Emission Unit Abrasive Materal Used

Annual Usage Rate

(lbs abrasive/year)

Uncontrolled PTE of

PM/PM10/PM2.5 (tons/yr)

Control Efficiency %

Controlled PTE of

PM/PM10/PM2.5 (tons/yr)

Abrasive blasting glovebox AB01 Boiler Slag 25 1.3E-04 95% 6.3E-06

Abrasive blasting glovebox AB02 Boiler Slag 25 1.3E-04 95% 6.3E-06

2.50E-04 1.25E-05Note:Abrasive blasting gloveboxes are located in vehicle repair areas and are used for vehicle repair, paint removal, or preparing equipment for spot welding.

METHODOLOGY*Source states that these units are not used very often at most they are used 15 to 30 minutes per week and that one of the units has only be used once in the past 3 years.Maximum Hourly Usage Rate (lbs abrasive/hr) = Annual Usage Rate (lbs abrasive/year) * (year/52 weeks) / [(Hours Operated of 15 minutes/week) * (hour/60 minutes)]Emission Factors from STAPPA/ALAPCO "Air Quality Permits", Vol. I, Section 3 "Abrasive Blasting" (1991 edition)Potential to Emit (lbs/hour) = [Sand Usage Rate (lbs abrasive/hr)] x [Emission Factor (lb/lb abrasive)]Potential to Emit (tons/year) = [Potential to Emit (lbs/hour)] x [8760 hours/year] x [ton/2000 lbs]*PM2.5 emissions assumed equal to PM10.


Appendix A: Emissions Calculations VOC Emissions

From Degreasing Operations

Company Name: Indiana Army National Guard Combined Support Maintenance Shop #2Address City IN Zip: Building 630 Camp Atterbury, Edinburgh, IN 46124

Permit No.: E081-37069-00074Reviewer: Brooke Haldeman

Degreasing Operations - Highest VOC Degreaser

Emission Unit *Usage (gal/year)

Solvent Density (lb/gal)

Percentage VOC

Potential VOC Emissions (lb/year)

Potential VOC Emissions (tons/year)

Building 630 System One parts washer DG01Building 630 Recycle-Kleen parts washer DG02NotesThe solvent used is a CITGO's Mineral Spirits.

MethodologyPotential VOC Emissions (lb/year) = Usage (gal/year) * Solvent Density (lb/gal)Potential VOC Emissions (tons/year) = Potential VOC Emissions (lb/year) * 1 ton/2000 lbs

145.00 6.7 100.00% 971.5 0.49

*All cleaners and solvents combined, do not exceed one hundred forty-five (145) gallons per twelve (12) months. A combined usage rate of 145 gallons/yr is the highest allowable for units to be insignficant.


Appendix A: Emission CalculationsSurface Coating Booths PSB01 and PH01

VOC and Particulate



Emission Unit Material Density (lb/gal)

Weight % Volatile (H20 &

Organics)

Weight % Water +

Non-VOCWeight % VOC Volume % Water +

Non-VOCVolume %

Solids

Maximum Throughput (gal/week)

Maximum Throughput

(gal/hr)

Pounds VOC per gallon of

coating less water

Transfer Efficiency

Particulate Control

Efficiency

Brown 383 10.25 14.00% 49.0% 14.0% 53.9% 33.30% 1.0 5.95E-03 3.11 60% 75%Green 383 12.41 8.46% 36.5% 8.5% 54.4% 37.14% 1.0 5.95E-03 2.31 60% 75%

37030 Black 10.54 10.43% 47.0% 10.4% 59.5% 29.03% 1.0 5.95E-03 2.71 60% 75%Catalyst 8.91 24.00% 0.0% 24.0% 0.0% 0.0% 3.0 1.79E-02 2.14 60% 75%

PTE of PM/PM10/PM2.5 and VOC Uncontrolled Controlled

Material VOC Content (lbs/gal)

lb VOC/gal solids

PTE of VOC

(lbs/hour)

PTE of VOC (lbs/day)

PTE of VOC (tons/yr)

PTE of PM/PM10/PM2.5 Before Control

(tons/yr)

PTE of PM/PM10/PM2

.5 After Control (tons/yr)

Brown 383 1.43 4.31 0.01 0.20 0.04 0.092 0.023Green 383 1.05 2.83 0.01 0.15 0.03 0.118 0.030

37030 Black 1.10 3.79 0.01 0.16 0.03 0.098 0.025Catalyst 2.14 0.00 0.04 0.92 0.17 0.212 0.053

Totals 0.05 1.12 0.20 0.30 0.08

MethodologyPounds of VOC per Gallon Coating less Water = [Density (lb/gal)] * [Weight % VOC] / [1 - Volume % water]VOC Content (lbs/gal) = [Density (lb/gal)] * [Weight % VOC]PTE of VOC (lbs/hour) = VOC Content (lbs/gal) * Maximum Throughput (gal/week)*1 week/168 hoursPTE of VOC (lbs/day)= PTE of VOC (lbs/hour) * 24 hours/1 dayPTE of VOC (tons/year) = [PTE of VOC (lbs/day)] * [365 days/yr] * [ton/2000 lbs]Particulate Potential Tons per Year = (lbs/hour) * (lbs/gal) * (1- Weight % Volatiles) * (1-Transfer efficiency) *(8760 hrs/yr) *(1 ton/2000 lbs)

SPB01


Appendix A: Emissions CalculationsWelding and Thermal Cutting

Company Name: Indiana Army National Guard Combined Support Maintenance Shop #2Address City IN Zip: Building 630 Camp Atterbury, Edinburgh, IN 46124

Permit Number: E081-37069-00074Reviewer: Brooke Haldeman

PROCESS Number of Max. electrode Max. electrode Max. electrode HAPSStations consumption per consumption per consumption per (lbs/hr)

WELDING station (lbs/hr) station (lbs/day) station (lbs/year) PM = PM10 Mn Ni Cr PM = PM10 Mn Ni Cr

Metal Inert Gas (MIG)(carbon steel)(WE01) 1 0.00119 0.0285 10.4 0.0055 0.0005 6.5E-06 5.9E-07 0 0 5.94E-07Metal Inert Gas (MIG)(carbon steel)(WE02) 1 0.00237 0.0569 20.8 0.0055 0.0005 1.3E-05 1.2E-06 0 0 1.19E-06Metal Inert Gas (MIG)(carbon steel)(WE03) 1 0.00024 0.0058 2.1 0.0055 0.0005 1.3E-06 1.2E-07 0 0 1.20E-07

Number of Max. Metal Max. Metal Max. Metal HAPSStations Thickness Cutting Rate Cutting Rate (lbs/hr)

FLAME CUTTING Cut (in.) (in./minute) (in./hour) PM = PM10 Mn Ni Cr PM = PM10 Mn Ni Cr

Oxyacetylene(TOR01) 1 0.375 12 720 0.1622 0.0005 0.0001 0.0003 0.044 0.000 0.000 0.000 2.43E-04Plasma**(PC01) 1 0.5 2.4 144 0.0039 0.000 0.000 0.000 0.000 0.00E+00

EMISSION TOTALS

Potential Emissions lbs/hr 0.04 1.37E-04 0.00 0.00 2.45E-04

Potential Emissions lbs/day 1.06 3.29E-03 0.00 0.00 0.01

Potential Emissions tons/year 0.19 6.00E-04 0.00 0.00 1.07E-03

Methodology:

EMISSION FACTORS* EMISSIONS

(lb pollutant/1,000 inches cut, 1" thick)** (lbs/hr)

*Emission Factors are default values for carbon steel unless a specific electrode type is noted in the Process column.

(lb pollutant/lb electrode) (lbs/hr)

EMISSION FACTORS EMISSIONS

**Emission Factor for plasma cutting from American Welding Society (AWS). Trials reported for wet cutting of 8 mm thick mild steel with 3.5 m/min cutting speed (at 0.2 g/min emitted). Therefore, the emission factor for plasma cutting is for 8 mm thick rather than 1 inch, and the maximum metal thickness is not used in calculting the emissions. Using AWS average values: (0.25 g/min)/(3.6 m/min) x (0.0022 lb/g)/(39.37 in./m) x (1,000 in.) = 0.0039 lb/1,000 in. cut, 8 mm thick

Emissions, lbs/day = emissions, lbs/hr x 24 hrs/dayEmissions, tons/yr = emissions, lb/hr x 8,760 hrs/year x 1 ton/2,000 lbs.

Plasma cutting emissions, lb/hr: (# of stations)(max. cutting rate, in./min.)(60 min./hr.)(emission factor, lb. pollutant/1,000 in. cut, 8 mm thick)Cutting emissions, lb/hr: (# of stations)(max. metal thickness, in.)(max. cutting rate, in./min.)(60 min./hr.)(emission factor, lb. pollutant/1,000 in. cut, 1" thick)Welding emissions, lb/hr: (# of stations)(max. lbs of electrode used/hr/station)(emission factor, lb. pollutant/lb. of electrode used)


Appendix A: Emission CalculationsNatural Gas Combustion Only

MM BTU/HR <100Natural Gas-Fired Heaters



UnitMaximum Heat Input Capacity

(MMBtu/hr)

High Heat Value (MMBtu/MMscf)

Potential Throughput

(MMcf/yr)

H1 0.09 1020 0.77H2 0.13 1020 1.12H3 0.02 1020 0.17H4 0.12 1020 1.03H5 0.12 1020 1.03H6 0.15 1020 1.29H7 0.03 1020 0.26H8 0.03 1020 0.26H9 0.03 1020 0.26

H10 0.3 1020 2.58H11 0.13 1020 1.12H12 0.13 1020 1.12H13 0.13 1020 1.12H14 0.13 1020 1.12H15 0.08 1020 0.69H16 0.024 1020 0.21H17 0.024 1020 0.21H18 0.06 1020 0.52H19 0.06 1020 0.52H20 0.04 1020 0.34H21 0.04 1020 0.34H22 0.06 1020 0.52H23 0.06 1020 0.52H24 0.06 1020 0.52H25 0.06 1020 0.52H26 0.25 1020 2.15H27 0.25 1020 2.15H28 0.25 1020 2.15H29 0.55 1020 4.72H30 0.4 1020 3.44H31 0.4 1020 3.44H32 0.4 1020 3.44H33 0.4 1020 3.44H34 0.20 1020 1.72H35 0.18 1020 1.55H36 0.12 1020 1.03H37 0.12 1020 1.03H38 0.12 1020 1.03H39 0.12 1020 1.03H40 0.20 1020 1.72H41 0.10 1020 0.86H42 0.12 1020 1.03H43 0.12 1020 1.03H44 0.12 1020 1.03H45 0.12 1020 1.03H46 0.12 1020 1.03H47 0.12 1020 1.03H48 0.12 1020 1.03H49 0.12 1020 1.03H50 0.12 1020 1.03H51 0.12 1020 1.03H52 0.12 1020 1.03

Total: 7.49 64.31

Criteria Pollutants PM* PM10* PM2.5* SO2 NOx VOC COEmission Factor in lb/MMcf 1.9 7.6 7.6 0.6 100 5.5 84

**see below

Potential Emission in tons/yr 0.06 0.24 0.24 0.019 3.22 0.18 2.70

*PM emission factor is filterable PM only. PM10 emission factor is filterable and condensable PM10 combined. PM2.5 assumed equal to PM10**Emission Factors for NOx: Uncontrolled = 100, Low NOx Burner = 50, Low NOx Burners/Flue gas recirculation = 32

Hazardous Air Pollutants Benzene DCB Formaldehyde Hexane TolueneEmission Factor in lb/MMcf 2.1E-03 1.2E-03 7.5E-02 1.8E+00 3.4E-03Potential Emission in tons/yr 6.752E-05 3.859E-05 2.412E-03 5.788E-02 1.093E-04*The five highest organic and metal HAPs emission factors are provided above. Additional HAPs emission factors are available in AP-42, Chapter 1.4.

Pb Cd Cr Mn Ni5.0E-04 1.1E-03 1.4E-03 3.8E-04 2.1E-03

1.608E-05 3.537E-05 4.502E-05 1.222E-05 6.752E-05Potential to Emit Total HAPs (tons/year) = 0.06

MethodologyAll emission factors are based on normal firing.MMBtu = 1,000,000 BtuMMCF = 1,000,000 Cubic Feet of GasEmission Factors are from AP 42, Chapter 1.4, Tables 1.4-1, 1.4-2, 1.4-3, SCC #1-02-006-02, 1-01-006-02, 1-03-006-02, and 1-03-006-03Potential Throughput (MMCF) = Heat Input Capacity (MMBtu/hr) x 8,760 hrs/yr x 1 MMCF/1,020 MMBtuEmission (tons/yr) = Throughput (MMCF/yr) x Emission Factor (lb/MMCF)/2,000 lb/ton

Pollutant

HAPs - Organics*

HAPs - Metals*


Appendix A: Emission CalculationsWoodworking Operation

PM/PM10/PM2.5 Emissions - Integrally Controlled



Wood Working Operation - Control

Devices

Grain loading grain/ft3

Air Flow (ACFM)

PM/PM10/PM2.5 before control

(lbs/hr)

PM/PM10/PM2.5 before control

(tons/yr)

PM/PM10/PM2.5 after control

(lbs/hr)

PM/PM10/PM2.5 after control

(tons/yr)DC-1200 0.01 1200 2.06 9.01 0.10 0.45DC-1900 0.01 1900 3.26 14.27 0.16 0.71

Total 5.31 23.28 0.27 1.16

Methodology:Emission Rate in lbs/hr (after controls) = (grains/cub. ft.)* (cub. ft./min.)* (60 min/hr)* (lb/7000 grains)Emission Rate in tons/yr = (lbs/hr)* (8760 hr/yr)* (ton/2000 lb)Emission Rate in lbs/hr (before controls) = Emission Rate (after controls): (lbs/hr)/(1-control efficiency)Emission Rate in tons/yr (before controls) = (lbs/hr) (8760 hr/yr) (ton/2000 lb)

NotesControl Efficiency = 95%In October of 1993 a Final Order Granting Summary Judgment was signed by an Administrative Law Judge("ALJ") resolving an appeal of an IDEM permit related to the method by which IDEM calculated potentialemissions from woodworking operations. In his findings, the ALJ determined that particulate controls werenecessary for the facility, and therefore, potential emissions were to be calculated after controls. Based onthis ruling, potential emissions for particulate matter were calculated after consideration of the controls.

Uncontrolled Emission Controlled Emissions

Appendix A: Emission Calculations App. A to TSD Page 8 of 9Fugitive Dust Emissions - Paved Roads



Paved Roads at Industrial SiteThe following calculations determine the amount of emissions created by paved roads, based on 8,760 hours of use and AP-42, Ch 13.2.1 (1/2011).

Vehicle Informtation (provided by source)

Type

Maximum number of

vehicles per day

Number of one-way trips per day per

vehicle

Maximum trips per day

(trip/day)

Maximum Weight Loaded

(tons/trip)

Total Weight driven per day

(ton/day)

Maximum one-way distance (feet/trip)

Maximum one-way distance

(mi/trip)

Maximum one-way miles (miles/day)

Maximum one-way miles (miles/yr)

POV (entering plant) (one-way trip) 40.0 1.0 40.0 2.5 100.0 150 0.028 1.1 414.8Heavy Weight Military Vehicle (entering) 4.0 1.0 4.0 20.0 80.0 150 0.028 0.1 41.5Medium Weight Military Vehicle (entering) 6.0 1.0 6.0 10.0 60.0 150 0.028 0.2 62.2Light Weight Military Vehicle (entering) 10.0 1.0 10.0 1.0 10.0 150 0.028 0.3 103.7POV (leaving plant) (one-way trip) 40.0 1.0 40.0 2.5 100.0 150 0.028 1.1 414.8Heavy Weight Military Vehicle (leaving) 4.0 1.0 4.0 20.0 80.0 150 0.028 0.1 41.5Medium Weight Military Vehicle (leaving) 6.0 1.0 6.0 10.0 60.0 150 0.028 0.2 62.2Light Weight Military Vehicle (leaving) 10.0 1.0 10.0 1.0 10.0 150 0.028 0.3 103.7

Totals 120.0 500.0 3.4 1244.3

Average Vehicle Weight Per Trip = 4.2 tons/tripAverage Miles Per Trip = 0.03 miles/trip

Unmitigated Emission Factor, Ef = [k * (sL)^0.91 * (W)^1.02] (Equation 1 from AP-42 13.2.1)

PM PM10 PM2.5where k = 0.011 0.0022 0.00054 lb/VMT = particle size multiplier (AP-42 Table 13.2.1-1)

W = 4.2 4.2 4.2 tons = average vehicle weight (provided by source)sL = 9.7 9.7 9.7 g/m^2 = silt loading value for paved roads at iron and steel production facilities - Table 13.2.1-3)

Taking natural mitigation due to precipitation into consideration, Mitigated Emission Factor, Eext = E * [1 - (p/4N)] (Equation 2 from AP-42 13.2.1) Mitigated Emission Factor, Eext = Ef * [1 - (p/4N)]

where p = 125 days of rain greater than or equal to 0.01 inches (see Fig. 13.2.1-2)N = 365 days per year

PM PM10 PM2.5Unmitigated Emission Factor, Ef = 0.373 0.075 0.0183 lb/mileMitigated Emission Factor, Eext = 0.341 0.068 0.0167 lb/mile

Dust Control Efficiency = 0% 0% 0%

ProcessUnmitigated PTE of PM (tons/yr)

Unmitigated PTE of PM10

(tons/yr)

Unmitigated PTE of PM2.5

(tons/yr)

Mitigated PTE of PM (tons/yr)

Mitigated PTE of PM10 (tons/yr)

Mitigated PTE of PM2.5

(tons/yr)

Controlled PTE of PM (tons/yr)

Controlled PTE of PM10 (tons/yr)

Controlled PTE of PM2.5 (tons/yr)

POV (entering plant) (one-way trip) 0.08 0.02 3.80E-03 0.07 0.01 3.47E-03 0.07 0.01 3.47E-03Heavy Weight Military Vehicle (entering) 0.01 1.55E-03 3.80E-04 0.01 1.41E-03 3.47E-04 0.01 1.41E-03 3.47E-04Medium Weight Military Vehicle (entering) 0.01 2.32E-03 5.69E-04 0.01 2.12E-03 5.21E-04 0.01 2.12E-03 5.21E-04Light Weight Military Vehicle (entering) 0.02 3.87E-03 9.49E-04 0.02 3.54E-03 8.68E-04 0.02 3.54E-03 8.68E-04POV (leaving plant) (one-way trip) 0.08 0.02 3.80E-03 0.07 0.01 3.47E-03 0.07 0.01 3.47E-03Heavy Weight Military Vehicle (leaving) 0.01 1.55E-03 3.80E-04 0.01 1.41E-03 3.47E-04 0.01 1.41E-03 3.47E-04Medium Weight Military Vehicle (leaving) 0.01 2.32E-03 5.69E-04 0.01 2.12E-03 5.21E-04 0.01 2.12E-03 5.21E-04Light Weight Military Vehicle (leaving) 0.02 3.87E-03 9.49E-04 0.02 3.54E-03 8.68E-04 0.02 3.54E-03 8.68E-04

Totals 0.23 0.05 0.01 0.21 0.04 0.01 0.21 0.04 0.01

Methodology AbbreviationsTotal Weight driven per day (ton/day) = [Maximum Weight Loaded (tons/trip)] * [Maximum trips per day (trip/day)] PM = Particulate MatterMaximum one-way distance (mi/trip) = [Maximum one-way distance (feet/trip) / [5280 ft/mile] PM10 = Particulate Matter (<10 um)Maximum one-way miles (miles/day) = [Maximum trips per year (trip/day)] * [Maximum one-way distance (mi/trip)] PM2.5 = Particle Matter (<2.5 um)Average Vehicle Weight Per Trip (ton/trip) = SUM[Total Weight driven per day (ton/day)] / SUM[Maximum trips per day (trip/day)] PTE = Potential to EmitAverage Miles Per Trip (miles/trip) = SUM[Maximum one-way miles (miles/day)] / SUM[Maximum trips per year (trip/day)]Unmitigated PTE (tons/yr) = [Maximum one-way miles (miles/yr)] * [Unmitigated Emission Factor (lb/mile)] * (ton/2000 lbs)Mitigated PTE (tons/yr) = [Maximum one-way miles (miles/yr)] * [Mitigated Emission Factor (lb/mile)] * (ton/2000 lbs)Controlled PTE (tons/yr) = [Mitigated PTE (tons/yr)] * [1 - Dust Control Efficiency]

Appendix A: Emission Calculations App A. to TSD Page 9 of 9Fugitive Dust Emissions - Unpaved Roads



Unpaved Roads at Industrial SiteThe following calculations determine the amount of emissions created by unpaved roads, based on 8,760 hours of use and AP-42, Ch 13.2.2 (11/2006).

Vehicle Information (provided by source)

TypeMaximum number of vehicles

Number of one-way trips per day per

vehicle

Maximum trips per day

(trip/day)

Maximum Weight Loaded

(tons/trip)

Total Weight driven per day

(ton/day)


(feet/trip)


(mi/trip)

Maximum one-way

miles (miles/day)

Maximum one-way

miles (miles/yr)

Heavy Weight Military Vehicle (entering) 4.0 1.0 4.0 20.0 80.0 100 0.019 0.1 27.7Medium Weight Military Vehicle (entering) 6.0 1.0 6.0 10.0 60.0 100 0.019 0.1 41.5Light Weight Military Vehicle (entering) 10.0 1.0 10.0 1.0 10.0 100 0.019 0.2 69.1Heavy Weight Military Vehicle (leaving) 4.0 1.0 4.0 20.0 80.0 100 0.019 0.1 27.7Medium Weight Military Vehicle (leaving) 6.0 1.0 6.0 10.0 60.0 100 0.019 0.1 41.5Light Weight Military Vehicle (leaving) 10.0 1.0 10.0 1.0 10.0 100 0.019 0.2 69.1

Totals 10.0 10.0 0.2 69.1

Average Vehicle Weight Per Trip = 1.0 tons/tripAverage Miles Per Trip = 0.02 miles/trip

Unmitigated Emission Factor, Ef = k*[(s/12)^a]*[(W/3)^b] (Equation 1a from AP-42 13.2.2)

PM PM10 PM2.5where k = 4.9 1.5 0.15 lb/mi = particle size multiplier (AP-42 Table 13.2.2-2 for Industrial Roads)

s = 4.8 4.8 4.8 % = mean % silt content of unpaved roads (AP-42 Table 13.2.2-1 Sand/Gravel Processing Plant)a = 0.7 0.9 0.9 = constant (AP-42 Table 13.2.2-2 for Industrial Roads)

W = 1.0 1.0 1.0 tons = average vehicle weight (provided by source)b = 0.45 0.45 0.45 = constant (AP-42 Table 13.2.2-2 for Industrial Roads)

Taking natural mitigation due to precipitation into consideration, Mitigated Emission Factor, Eext = E * [(365 - P)/365] (Equation 2 from AP-42 13.2.2)Mitigated Emission Factor, Eext = E * [(365 - P)/365]

where P = 125 days of rain greater than or equal to 0.01 inches (see Fig. 13.2.2-1)

PM PM10 PM2.5Unmitigated Emission Factor, Ef = 1.57 0.40 0.04 lb/mileMitigated Emission Factor, Eext = 1.03 0.26 0.03 lb/mile

Dust Control Efficiency = 0% 0% 0%

ProcessUnmitigated PTE of PM (tons/yr)

Unmitigated PTE of PM10

(tons/yr)

Unmitigated PTE of PM2.5

(tons/yr)

Mitigated PTE of PM (tons/yr)

Mitigated PTE of PM10

(tons/yr)

Mitigated PTE of PM2.5

(tons/yr)

Controlled PTE of PM (tons/yr)

Controlled PTE of PM10

(tons/yr)

Controlled PTE of PM2.5

(tons/yr)

Heavy Weight Military Vehicle (entering) 0.02 0.01 5.55E-04 0.01 3.65E-03 3.65E-04 0.01 3.65E-03 3.65E-04Medium Weight Military Vehicle (entering) 0.03 0.01 8.32E-04 0.02 0.01 5.47E-04 0.02 0.01 5.47E-04Light Weight Military Vehicle (entering) 0.05 0.01 1.39E-03 0.04 0.01 9.12E-04 0.04 0.01 9.12E-04Heavy Weight Military Vehicle (leaving) 0.02 0.01 5.55E-04 0.01 3.65E-03 3.65E-04 0.01 3.65E-03 3.65E-04Medium Weight Military Vehicle (leaving) 0.03 0.01 8.32E-04 0.02 0.01 5.47E-04 0.02 0.01 5.47E-04Light Weight Military Vehicle (leaving) 0.05 0.01 1.39E-03 0.04 0.01 9.12E-04 0.04 0.01 9.12E-04

Totals 0.22 0.06 0.01 0.14 0.04 3.65E-03 0.14 0.04 3.65E-03

Methodology AbbreviationsTotal Weight driven per day (ton/day) = [Maximum Weight Loaded (tons/trip)] * [Maximum trips per day (trip/day)] PM = Particulate MatterMaximum one-way distance (mi/trip) = [Maximum one-way distance (feet/trip) / [5280 ft/mile] PM10 = Particulate Matter (<10 um)Maximum one-way miles (miles/day) = [Maximum trips per year (trip/day)] * [Maximum one-way distance (mi/trip)] PM2.5 = Particulate Matter (<2.5 um)Average Vehicle Weight Per Trip (ton/trip) = SUM[Total Weight driven per day (ton/day)] / SUM[Maximum trips per day (trip/day)] PTE = Potential to EmitAverage Miles Per Trip (miles/trip) = SUM[Maximum one-way miles (miles/day)] / SUM[Maximum trips per year (trip/day)]

Unmitigated PTE (tons/yr) = (Maximum one-way miles (miles/yr)) * (Unmitigated Emission Factor (lb/mile)) * (ton/2000 lbs)

Mitigated PTE (tons/yr) = (Maximum one-way miles (miles/yr)) * (Mitigated Emission Factor (lb/mile)) * (ton/2000 lbs)

Controlled PTE (tons/yr) = (Mitigated PTE (tons/yr)) * (1 - Dust Control Efficiency)

Indiana Department of Environmental Management We Protect Hoosiers and Our Environment.

100 N. Senate Avenue • Indianapolis, IN 46204

(800) 451-6027 • (317) 232-8603 • www.idem.IN.gov

Michael R. Pence Carol S. Comer Governor Commissioner

An Equal Opportunity Employer

Recycled Paper

SENT VIA U.S. MAIL: CONFIRMED DELIVERY AND SIGNATURE REQUESTED TO: Chief Warrant Officer James Simmons

Indiana Army National Guard Combined Support Maintenance Shop #2 Building 630, Camp Atterbury

Edinburg, IN 46124 DATE: May 26, 2016 FROM: Matt Stuckey, Branch Chief Permits Branch Office of Air Quality SUBJECT: Final Decision Exemption 081-37069-00074 Enclosed is the final decision and supporting materials for the air permit application referenced above. Please note that this packet contains the original, signed, permit documents. The final decision is being sent to you because our records indicate that you are the contact person for this application. However, if you are not the appropriate person within your company to receive this document, please forward it to the correct person. A copy of the final decision and supporting materials has also been sent via standard mail to: Maj Richard Kerr, Shop Supervisor OAQ Permits Branch Interested Parties List If you have technical questions regarding the enclosed documents, please contact the Office of Air Quality, Permits Branch at (317) 233-0178, or toll-free at 1-800-451-6027 (ext. 3-0178), and ask to speak to the permit reviewer who prepared the permit. If you think you have received this document in error, please contact Joanne Smiddie-Brush of my staff at 1-800-451-6027 (ext 3-0185), or via e-mail at [email protected].

Final Applicant Cover letter.dot 2/17/2016

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indiana department of environmental managementpermits.air.idem.in.gov/37069f.pdf · 08/04/2014 ·...

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