pppl princeton plasma physics … rev.3 page 2 of 12 table 1 lists air permits in effect at the...

PPPL PRINCETON PLASMA PHYSICS LABORATORY

PROCEDURE EWM-007 Rev. 3 of 12

Subject: Environmental Air Permitting and

Monitoring Requirements

Effective Date:

2/9/18

Initiated by:

Head, ES&H Supersedes:

Rev. 2 6/20/14

Approved:

Director PPPL

Management System (Primary): 09.00 ES&H and Integrated Safety Management Management System Owner: Head, Environment, Health, & Safety Management Process: 09.10 Environmental Management and Compliance Process Owner: Head, Environment, Health, & Safety Subject Matter Expert (SME): Head, Environmental Services Division; and

Environmental Compliance Manager, Environmental Services Division

Applicability

This procedure applies to PPPL on-site activities with the potential to discharge air pollutants (non-radioactive releases and regulated equipment/activities), which are regulated under New Jersey statutes. The Ozone-Depleting Substances and non-exempt refrigerants as regulated by Federal statutes and regulations will be covered in a separate PPPL procedure.

Introduction

This procedure provides the PPPL requirements for obtaining and complying with air environmental permits. For success in planning and coordinating permit approvals with project implementation schedules, it is critical that permit requirements are recognized and identified early in the project design. This allows PPPL Environmental Services Division (ESD) to obtain pertinent information for regulatory requirements, begin discussions with regulatory contacts (where needed), prepare the appropriate applications, and obtain the final permit in a timely manner. The Cognizant Individual or Group (i.e., Department Head or Principle Investigator responsible for the equipment) operates and maintains the equipment in accordance with the permit conditions and manufacturer’s specifications and provides records to ESD. ESD monitors these permits, correspondence, and the requirements/records.

This procedure is arranged in the following sections: A. Initiating, Renewing and Revising Air Environmental PermitsB. Permits and Responsibilities for Permit Compliance

1. Boilers2. Dust Collectors3. AC Power - Emergency Generators (Stand-by generators)4. Fluorescent Bulb Crusher

C. TrainingD. RecordsE. Definitions - “Glossary”

Printed copies of this document are considered UNCONTROLLED/Information only copies. The official document can be found at http://bp.pppl_docs.html

The Planning Office maintains the signed originals.

PPPL PRINCETON PLASMA PHYSICS LABORATORY PROCEDURE EWM-007 Rev.3

of 12 Table 1 lists air permits in effect at the issue time of this procedure – ESD maintains the current list of air permits.

Table 1. PPPL Air Permits

Permit Type PPPL Designation Permit No. Responsible Organization

Boilers Units 2,3,4, and 5 PCP110001 Facilities and Site Services Dust Collectors MG Annex Shop

FED

GEN110001 GP-003

PCP960009

Fabrication- Group Facilities and Site Services

Emergency Generators (Standby)

D-site C-site

PCP960002 GEN100001

GP-005A

Power Systems Group Power Systems Group

Fluorescent bulb crusher Hazmat PCP060001 Environmental Services Reference Documents

New Jersey Administrative Code (NJAC) Title 7:27 – Air Pollution Control. A. Initiating, Renewing and Revising Air Environmental Permits Responsibility Action Initiator 1. Describes the activities on NEPA Planning Forms and sends

completed and signed forms to NEPA Manager. Provides additional information, if needed.

NEPA Manager 2. Reviews the NEPA Planning Form.

3. Notifies Environmental Services Division (ESD)

Environmental Compliance Manager of the possibility of a need of an air permit and provides information for the application through joint review of the NEPA Planning Form.

(ESD) Environmental Compliance Manager

4. Reviews project description and NEPA Planning Form or other information such as the Work Planning form or e-mail memo. Through a review of the applicable air regulations, determines the need and type of application for an air permit.

5. Obtains additional information, if needed and sends draft

application to the initiator for review and changes.

6. Transmits the air permit application, fees, and other documents to DOE-PSO for submittal to the appropriate regulatory agency.




of 12 7. Informs the Cognizant Individual or Group when the permit

is approved and provides a copy of the permit with the permit conditions or requirements, such as recordkeeping and/or monitoring emissions.

8. Updates permits list on a quarterly frequency and distributes

list to the Cognizant Individual or Group.

9. Submits permit renewal applications on an as need-basis.

10. Monitors compliance of permit requirements via an annual review of applicable records during a briefing and update meeting (as needed).

11. Provides assistance to responsible parties, suggestions for

process improvements. The above process is the same for a new permit or a revision(s) to an existing permit. B. Permits and Responsibilities for Permit Compliance 1. Boilers – Facilities and Site Services Department

Under NJAC 7:27-8.2(c) 1, Applicability: “commercial fuel burning equipment that has a maximum rated heat input of 1,000,000 BTU per hour or greater to the burning chamber;” is subject to the air control regulations. PPPL has four boilers that meet these criteria. Located in the boiler room of the Facilities and Site Services building, these boilers are operated by the Boiler Operators in the Facilities and Site Services Division. Boilers provide heat for PPPL’s buildings and steam for air-reheat in the summer. Each boiler has a stack located on the roof of the boiler room at a height of 30 feet.

Table 2. Boiler Information

Boiler # ID # Max. input Million British Thermal Units (MMBTU) per Hour

2 CB 621-250 10.5 3 CB 655-400 16.737 4 CB 600-350 14.645 5 CB 600-350 14.645




of 12 Responsibility Action Facilities and Site Services: Boiler Operators

1. Logs the hours of boiler operation (run-time logs) and fuel consumption, No. 2 or 4 in gallons and Natural gas in standard hundreds of cubic feet (sccf) on a daily basis. Provides monthly fuel consumption logs (excel spreadsheet file) to ESD for 12-month rolling calendar fuel total calculations.

2. Maintains and operates the boilers. 3. Observes stack for visual emissions (no visible emission,

exclusive of water vapor except for a period of no longer than 3 minutes in any consecutive 30-minute period) – visual determination each week when burning No. 2 fuel oil only and maintains records in log book. If smoke is visible, evaluate cause of smoke and notify ESD and PPPL Facility Manager, who contacts DOE-PSO.

4. Manually logs sulfur content of each fuel delivery.

Maintains fuel certification receipts. 5. Annually during the same quarter each year, performs stack

emission tests as described in the air permit compliance plan. 6. Submits stack emission tests to ESD for reporting to NJDEP 7. Burn only No. 2 Fuel oil during curtailment. If No.2 FO is

burned at other times, the Energy Assessment is required to comply with 40 CFR 63, Subpart JJJJJJ.

NOTE: ESD uses EM-OP-45 for reporting compliance.

2. Dust Collectors Under NJAC 7:27-8.8(c)2,General Permits, “one or more pieces of woodworking equipment, located at the same facility, where air contaminant emissions from the equipment are captured and vented to a particulate control apparatus with a minimum removal efficiency of 99 percent”. Each Dust Collector in the C-site MG annex and FED buildings captures the dust from several pieces of wood working or metal working equipment; these dust collectors provide a cleaner work environment.




of 12 Responsibility Action Facilities and Site Services

1. Operates and maintains the dust collector in the Facilities Building Carpenter’s Shop.

Fabrication Group RE NOTE: ESD

2. Operates and maintains the dust collectors in the C-site MG annex building.

3. Contact ESD if hours of operation exceed two continuous hours

for additional recordkeeping requirements. A visual check will need to be completed and documented.

4. If any air contamination should occur, contact ESD

immediately. 5. Upon notification of air contamination, immediately notify

NJDEP Environmental Action Hotline, Site Protection Communication Center, and PPPL Facility Manager/DOE-PSO.

3. Emergency Generators (Stand-by generators) – Power Systems Group PPPL operates three stand-by diesel generators for emergency power. The C-site diesel generators are permitted under the New Jersey Department of Environmental Protection General Permit (GP-005A) program for emergency generators. The D-site is permitted through the Pre-construction Permit (PCP) process.

Table 3. Diesel Generator Information

Diesel Generator

Model #

Electrical Output kW

Max. Input MM BTU

Permit Limit Annual

Stack Height ft

D-Site ALCO 251-G16

2600 9.36 200 hours 19

C-Site PPPLC

3508 Caterpillar Detroit Diesel 60 12.7L

900

300

3.068

1.03

100 hours

100 hours

Responsibility Action Power Systems 1. Enter start-up and shut-down times of day and total hours of

operation into log books. Maintain a record of reason(s) for operating emergency diesel generators.

2. Using the Ringlmann scale, make visual emissions (no

visible emission exclusive of water vapor) when operating. Record observation in log book.




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3. Prior to maintenance and testing of any emergency generator,NJDEP Air Quality website (http://www.njaqinow.net/)MUST be checked. IF any location in NJ is rated unacceptable, maintenance testing is not allowed.

NOTE: General Permit does not allow for the use of an emergency Generator other than for an emergency, for voltage reduction by PJM or for testing and maintenance.

4. Fluorescent Bulb Crusher – Environmental Services

PPPL ESD operates a fluorescent bulb crusher in the Hazardous Waste Storage Facility. ESD receives unbroken bulbs from Facilities personnel for disposal.

Responsibility Action

ESD Technicians 1. Maintains recordkeeping by manual logging for replacingbag filter and secondary HEPA filters per manufacturer’sspecification.

2. Maintains recordkeeping by manual logging of carbonabsorption unit at breakthrough.

3. Maintains recordkeeping by manual logging of opacity – novisible emissions

4. Maintains recordkeeping by manual logging of number ofbulbs crushed not to exceed 7,000 units per year.

C. TrainingEnvironmentalCompliance Manager

1. Specifies the appropriate training methods and means (below) andobtains concurrence of the Management System Owner and theManagement Process Owner.

Target Audience: Cognizant Individuals or GroupsInstructor: Environmental Compliance Manager or designee

Training Method:X Read only X Acknowledgment required – Formal (signature on file in Training Office)

Frequency: Annual Biannual Once only

X Other: Once every 3 years or a major procedure revision occurs




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Management System Owner or Designee

Human Resources

2. Notifies the Human Resources Training Office of the training so thatthey will be aware of the training requirements and be able to provideassistance and guidance in the course development, implementation,tracking, and maintenance.

3. Maintains training records for each employee who is certified to performmaintenance, service, repair, or disposal of refrigerants and equipmentcontaining refrigerants.

D. Records Management

Records Documents Records Custodian Where Records Kept Record Duration Boiler Chief Boiler Operator Facilities, ESD Min. 5 years Generators Head, Power Systems With Generators Min. 5 years Fluorescent bulb Crusher

Head, Waste Manager Environmental Services Min. 5 years

E. Glossary (Partial list from NJAC 7:27-8.1 Definitions for complete list go toReference Documents 3.2 or 3.4 )

“Actual emissions” means the rate at which an air contaminant is actually emitted, either directly or indirectly, to the outdoor atmosphere, in units of mass per calendar year, seasonal period, or other time period specified by the Department.

“Air contaminant” means any substance, other than water or distillates of air, present in the atmosphere as solid particles, liquid particles, vapors or gases

"AP-42" means the January 1995, 5th edition version of the manual entitled "Compilation of Air Pollutant Emission Factors," which is published by the EPA, and including supplements A, B, C, D, E, F and G and any subsequent revisions. This document may be obtained from the National Technical Information Service (NTIS), 5285 Port Royal Road, Springfield, Virginia 22161, (703) 487-4650; or from the Superintendent of Documents, Government Printing Office, Washington, DC 20402, (202) 783-3228. In addition, this document can be accessed electronically through the EPA technology transfer network chief site on the worldwide web at: http://www.epa.gov/ttn/chief/ap42.html

“Application form” means the form the Department requires an applicant to submit to apply for a preconstruction permit and operating certificate, a preconstruction permit and operating certificate for an environmental improvement pilot test, a preconstruction permit and operating certificate revision, or a compliance plan change. Also, a renewal application stub is an application form

"Certificate" means either an operating certificate or a temporary operating certificate, which is legally valid.




of 12 "Clean Air Act" or "CAA" means the Federal Clean Air Act, 42 U.S.C. §§7401 et seq.; and any subsequent amendments or supplements to that act. "Commercial fuel" means solid, liquid, or gaseous fuel normally produced or manufactured, and sold for the purpose of creating useful heat. "Compliance inspection" means the on-site examination by representatives of the Department of equipment or control apparatus to determine if the requirements of this subchapter and other applicable laws have been and are being complied with. "Compliance plan change" means a change made to a permit and certificate under N.J.A.C. 7:27-8.19, Compliance plan changes. "Construct" or "construction" means to fabricate or erect equipment or control apparatus at a facility where it is intended to be used, but shall not include the dismantling of existing equipment or control apparatus, site preparation, or the ordering, receiving, temporary storage, or installation of equipment or control apparatus. Unless otherwise prohibited by Federal law, this term shall also not include the pouring of footings or placement of a foundation where equipment or control apparatus is intended to be used. "Control apparatus" means any device which prevents or controls the emission of any air contaminant directly or indirectly into the outdoor atmosphere. "Distillates of air" means helium (He), nitrogen (N2 ), oxygen (O2 ), neon (Ne), argon (Ar), krypton (Kr), and xenon (Xe). “Emergency” means any situation that arises from sudden and reasonably unforeseeable events beyond the control of an owner or operator of a facility, such as an unforeseen system capacity shortage caused by an act of God, that requires immediate corrective action to prevent system collapse or to restore normal operations at the facility. "Emissions" means any air contaminant or category of air contaminants discharged directly or indirectly into the outdoor atmosphere. "Emit" means to cause or release emissions. "Emissions unit" means any part of activity of a stationary source that emits or has the potential to emit any regulated air pollutant or any pollutant listed under 42 U.S.C. §7412(b). "Federally enforceable" means any limitation or condition on operation, production, or emissions which can be enforced by the EPA. These limitations and conditions that can be enforced by EPA include, but are not limited to, those established pursuant to:

1. Any standard of performance for new stationary sources (NSPS) promulgated at 40 CFR Part 60 or promulgated under 42 U.S.C. §7411;




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2. Any national emission standard for hazardous air pollutants (NESHAP) promulgated at 40 CFR Part 61, 40 CFR Part 63, or promulgated under 42 U.S.C. §7412;

3. Any standard or other requirement provided for in a SIP that has been approved by EPA, or promulgated through rulemaking by EPA; or

4. Any permit or order issued pursuant to requirements established at 40 CFR 51, Subpart I (including any preconstruction permit and certificate issued pursuant to N.J.A.C. 7:27-8 or any operating permit issued pursuant to N.J.A.C. 7:27-22); 40 CFR 52.21; 40 CFR Part 70; 40 CFR Part 71; or 40 CFR Part 72.

"General permit" means a type of standardized permit and certificate, issued by the Department under N.J.A.C. 7:27-8.8. "Greenhouse gas" or "GHG" means any of the following gases: carbon dioxide (CO2); methane (CH4); nitrous oxide (N2O); certain hydrofluorocarbons (HFC-23, HFC-125, HFC-134a, HFC-143a, HFC-152a, HFC-227ea, HFC-236fa, HFC-4310mee); certain perfluorocarbons (CF4, C2F6, C4F10, C6F14); and sulphur hexafluoride (SF6). “Hazardous air pollutant” or “HAP” means an air contaminant listed in or pursuant to 42 U.S.C. § 7412(b). "Indirect emissions" means a discharge of any air contaminant into the outdoor atmosphere through any opening that is not a stack or chimney directly connected to the equipment. "Insignificant source" means, for the purposes of this subchapter, any equipment or source operation that does not need a permit and certificate under N.J.A.C. 7:27-8.2. "Install" or "Installation" means to carry out final setup activities necessary to provide equipment or control apparatus with the capacity for use or service. This term includes, but is not limited to, connection of equipment or control apparatus, associated utilities, piping, ductwork or conveyor systems. This term does not include construction, as defined above, nor the reconfiguration of equipment or control apparatus to an alternate configuration specified in a permit application and approved by the Department. This term includes relocation of existing equipment or control apparatus. "National ambient air quality standard" or "NAAQS" means an ambient air quality standard promulgated at 40 CFR 50. “NEPA” means National Environmental Policy Act, whose requirements are implemented at PPPL under procedure ESH-014, NEPA Review System. "NESHAP" means a National Emission Standard for a Hazardous Air Pollutant as promulgated under 40 CFR Part 61 or 40 CFR Part 63.




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"New Jersey ambient air quality standard" or "NJAAQS" means an ambient air quality standard promulgated at N.J.A.C. 7:27-13.

"NOx" means all oxides of nitrogen including, but not limited to, nitric oxide and nitrogen dioxide, except nitrous oxide.

"NSPS" means Standards of Performance for New Stationary Sources as promulgated under 40 CFR 60, commonly referred to as New Source Performance Standards.

"Operating certificate" or "certificate" means a "Certificate to Operate Control Apparatus or Equipment" issued by the Department pursuant to N.J.S.A. 26:2C-1 et seq., and in particular N.J.S.A. 26:2C-9.2, and this subchapter.

“Particles” means any material, except uncombined water, which exists as liquid particles or solid particles at standard conditions.

“Performance test” means a series of test runs used for the purpose of determining emissions of air contaminants to the outdoor atmosphere.

“Periodic compliance inspection” means any compliance inspection carried out in accordance with a schedule included in the conditions of approval of a permit or certificate. This term does not include a compliance inspection which the Department may carry out as part of its consideration as to whether to approve or renew an operating certificate.

“Permit” means a preconstruction permit as defined in this section.

“Permit revision” means a change made to a permit and certificate under N.J.A.C. 7:27-8.18, Permit revisions.

“Permittee” means, for the purpose of this subchapter, any person to whom the Department has issued a permit or certificate pursuant to this subchapter.

“Potential to emit” means the same as that term is defined by the EPA at 40 CFR 70.2 or any subsequent amendments thereto. In general, the potential to emit is the maximum aggregate capacity of a source operation or of a facility to emit an air contaminant under its physical and operational design. Any physical or operational limitation on the capacity of a source operation or a facility to emit an air contaminant, including any limitation on fugitive emissions as a result of any applicable requirement, control apparatus, and restrictions on hours of operation or on the type or amount of material combusted, stored or processed, shall be treated as part of its design, if the limitation is Federally enforceable. Unless otherwise indicated, source-related fugitive emissions shall be included in the determination of potential to emit. However, the determination shall not include the holding by the owner or operator of emission reductions that are banked pursuant to N.J.A.C. 7:27-18.8.




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Preconstruction permit" or "permit" means a "Permit to Construct, Install, or Alter Control Apparatus or Equipment" issued by the Department pursuant to N.J.S.A. 26:2C-1 et seq., in particular N.J.S.A. 26:2C-9.2, and this subchapter.

"Raw material" means any input to equipment, control apparatus, or a process, including fuels, but excluding heat and other forms of energy. Such inputs may include mixtures, composites, compounds and elemental substances.

"Reconfiguration" means a change in the setup of equipment or control apparatus, or both, to an alternate configuration. This term also includes reorientation or reconnection into an alternate pattern of equipment or control apparatus, or both. This term does not include a change in the location of equipment or control apparatus from that specified in the preconstruction permit.

"Reconstruct" or "reconstruction" means the replacement of part(s) of equipment included in a process unit, or the replacement of part(s) of control apparatus, if the fixed capital cost of replacing the part(s) exceeds both of the following amounts:

1. Fifty percent of the fixed capital cost that would be required to construct acomparable new process unit; or, if it is part(s) of control apparatus that is beingreplaced, 50 percent of the fixed capital cost that would be required to constructcomparable new control apparatus; and

2. $80,000, in 1995 dollars, adjusted by the Consumer Price Index (CPI).

"Repair or maintenance" means upkeep of existing equipment or control apparatus, including the replacement of parts, but does not include the reconstruction of equipment or control apparatus.

"Seven-day-notice change" means a change made to a permit and certificate under N.J.A.C. 7:27-8.20, Seven-day-notice changes.

"Significant net emission increase" means an emission increase of any air contaminant determined pursuant to the procedures set forth in N.J.A.C. 7:27-18.7 to be a significant net emission increase. Significant source operation" or "significant source" means a source that is classified as a significant source pursuant to N.J.A.C. 7:27-8.2(c) and that is not exempted from being a significant source pursuant to N.J.A.C. 7:27-8.2(d) or (e).

"Source emission testing" means the testing of a discharge of any air contaminant from equipment, control apparatus or source operation through any stack or chimney.

"Source operation" or "source" means any process, or any identifiable part thereof, that emits or can reasonably be anticipated to emit any air contaminant either directly or indirectly into the outdoor atmosphere. A source operation may include one or more pieces of equipment or control apparatus.




of 12 "Stack or chimney" means a flue, conduit or opening designed, constructed, or utilized for the purpose of emitting any air contaminant into the outdoor atmosphere. "Standard conditions" means 70 degrees Fahrenheit (21.1 degrees centigrade) and one atmosphere pressure (14.7 pounds per square inch absolute or 760.0 millimeters of mercury). "Storage tank" means any tank, reservoir, or vessel which is a container for liquids or gases, wherein:

1. No manufacturing process, or part thereof, other than filling or emptying takes place; and

2. The only treatment carried out is that necessary to prevent change from occurring in the physical condition or the chemical properties of the liquids or gases deposited into the container. Such treatment may include re-circulating, agitating, maintaining the temperature of the stored liquids or gases, or replacing air in the vapor space above the stored liquids or gases with an inert gas in order to inhibit the occurrence of chemical reaction.

"Stratospheric ozone depleting substance" means any Class I substance or any Class II substance. "Surface cleaner" means a device to remove unwanted foreign matter from the surfaces of materials by using VOC or HAP solvents in liquid or vapor state. “Volatile organic compound” or “VOC” means a volatile organic compound as that term is defined by the EPA at 40 CFR 51.100(s), as supplemented or amended, which is incorporated by reference herein. Attachments: A – Responsibilities Matrix – Air - Boilers 2-5

B – Facilities and Site Services Department Responsibilities and Actions Summary

C – Fabrication Group Responsibilities and Actions Summary D –Power Systems Group Responsibilities and Action Summary E – Environmental Services Responsibilities and Action Summary



PPPL PRINCETON PLASMA PHYSICS LABORATORY PROCEDURE EWM-007 Rev. 3

Attachments A

Attachment A. Responsibility Matrix Air – Boilers 2 - 5

Air – Emergency Generator (C and D-site)

Cognizant Individual or Group Regulatory Requirement Frequency Recordkeeping Facilities and Site Services – Boiler Operators

1. Fuel consumption – Natural gas, No. 2 & 4 oil Monthly Total by boiler and fuel type in Excel files

2. Visual observations of boiler stacks when operating Weekly Record in boiler logbook 3. Sulfur in fuel oil -. after June 30. 2016,No. 2, ≤0.0015 % by wt., 15 ppmw.

Per delivery Record of sulfur content on Bill of Lading or record of laboratory analysis

4. Performance adjustment -each boiler & fuel type Annually Adjustment report to NJDEP w/in 45 days Environmental Services Division

5. Fuel consumption 12-month rolling calendarcalculations for NG & fuel oil & check totals

Monthly Total of 12 months based on Step 1 files. Excel files and hard copies kept

6. Boiler Air Emissions – Total suspended particulates(TSP), Volatile organic compounds (VOCs), Sulfur dioxide(SO2), Nitrogen oxides (NOx), Carbon monoxide (CO)

Annually Excel files – calculates emissions based on AP-42 formulas and hours of operations by fuel type and by boiler.

Cognizant Individual or Group Regulatory Requirements Frequency Recordkeeping Power systems Group 1. Hours of operation – totalizing meter, date and

time of start-up and shut-downPer operation Record in generator logbook

2. Opacity when operating Per operation Record in generator logbook 3. Sulfur in fuel - Diesel 15 ppmw (0.0015%)maximum sulfur content

Per delivery Record of sulfur content on Bill of Lading or record of laboratory analysis for 5 years

Environmental Services Division 5. Check total operation hours Annually Check compliance with hour limits




Attachments B

Attachment B. Facilities and Site Services Responsibilities & Actions

Summary Air Permits

1. Maintain records as required in the Boiler permit conditions. 2. Notify ESD when proposing changes in equipment and/or operations. 3. Provide information regarding new operations or equipment that may require a

permit application.

Boiler Operation Actions

1. Log the run-time hours of boiler operation and fuel consumption on a daily basis. Provide monthly fuel consumption logs to ESD.

2. Maintain and operate the boilers. 3. Visual emissions check (no visible emission, exclusive of water vapor except for

a period of no longer than 3 minutes in any consecutive 30-minute period) – visual determination weekly when burning No.2 fuel oil during operation and maintains records.

4. Conduct Annual Performance check following N.J.A.C. 7:27-19.16, “Adjusting Combustion Processes.” Reporting annually (same quarter each year) within 45-days of adjustment of the combustion process is completed.

5. Conduct Biennial Tune-up for 40 CFR Part 63 Subpart JJJJJJ in even years, e.g. 2018, 2020, etc.

6. If No. 2 Fuel oil burned NOT during curtailment, then the Energy Assessment to comply with 40 CFR Part 63 Subpart JJJJJJ is required.

7. Maintain records for No. 2 fuel oil (<15ppm/0.0015% sulfur) ultra-low sulfur content – Bill of Lading (Purchasing) and/or laboratory sulfur analysis.

Dust Collector Actions

1. Operate and maintain the dust collector in the Facilities Building Carpenter’s Shop where all air contaminant emissions from the equipment are captured and vented to a particulate control apparatus with a minimum removal efficiency of 99%.

2. Contact ESD if hours of operation exceed two consecutive hours for additional recordkeeping requirements.




Attachments C & D

Attachment C. Fabrication Group Responsibilities & Actions Summary

Dust Collector Actions

Under NJAC 7:27-8.8(c)2, General Permits, “one or more pieces of woodworking equipment, located at the same facility, where all air contaminant emissions from the equipment are captured and vented to a particulate control apparatus with a minimum removal efficiency of 99 percent”.

Dust Collector in the C-site MG annex building captures the dust from several pieces of wood working or metal working equipment; these dust collectors provide a cleaner work environment.

1. Operate and maintain the dust collectors in the C-site MG annex Building inaccordance with the NJAC General Permit conditions, as cited above.

2. Contact ESD if hours of operation exceed two consecutive hours for additionalrecordkeeping requirements.

Attachment D. Power Systems Group Responsibilities & Actions Summary

Stand-by Emergency Generators 1. Record start-up and shut-down time, date, and total hours of operations and fuel

use (gallons) in log books.2. Maintain a record of reasons for operating diesel generators. Records are

maintained in each stationary generator’s logbook.3. Observe visual emissions (no visible emission, exclusive of water vapor) – visual

determination using the Ringlmann scale – when operating and maintain record inlogbook.

4. For each diesel fuel delivery, review each bill of lading to verify that sulfurcontent of fuel meets the sulfur-by-weight requirement of 0.0015% or 15 ppm ofultra-low sulfur fuel. Analysis by a subcontract independent analytical laboratorymay also be conducted.

5. Maintain records for a minimum of 5 years.6. Maintain and operate the generators.




Attachment E

Attachment E. ESD Responsibilities & Actions Summary

Air Permits and Update Briefing 1. Maintain permit list with expiration dates and fees.2. Prepare an update briefing for all responsible individuals/groups as changes occur.3. Provide guidance as needed arises.

Boilers 1. Calculate and update monthly the 12-month rolling calendar of total fuel

consumption for Fuel oil No. 2 and natural gas.2. Check totals do not exceed annual regulatory limits for natural gas (in hundreds of

cubic feet (ccfs)) and for No.2 fuel oil (in gallons) for each boiler.3. Prepare annual emissions totals using AP-42 (in tons per year) for nitrogen

oxides (NOx), carbon dioxide (CO2), carbon monoxide (CO), particulates (TSP),volatile organic compounds (VOCs) and sulfur dioxide (SO2).

4. Maintain records and file hard copies in permit file and on p drive..5. Submit to NJDEP On-line web portal - NOx RACT Annual Adjustment for each

boiler with each fuel type.6. Submit Notification of Compliance Status to DOE to comply with 40 CFR §63

Subpart JJJJJJ requirements.7. For each diesel fuel delivery, review each bill of lading to verify that sulfur

content of fuel meets the sulfur-by-weight requirement of 0.0015% or 15 ppm ofultra-low sulfur fuel.

(Stand-by) Emergency Generators 1. Compare hours of operations to permit limits.2. Check logbooks for record of reasons for operating diesel generators.3. Check for visual emission and record (no visible emission, except water vapor).4. For each diesel fuel delivery, review each bill of lading to verify that sulfur

content of fuel meets the sulfur-by-weight requirement of 0.0015% or 15 ppm ofultra-low sulfur fuel.

Greenhouse Gases (GHG) 1. Annually, calculate total carbon dioxide (CO2) emissions from boiler and emergency

generator operations in tons per year (TPY) and metric tons per year (MTPY).2. Annually, calculate sulfur hexafluoride (SF6) emissions from Neutral Beams (TPY

and MTPY).

