PART 70 OPERATING PERMIT FACT SHEET

PART 70 OPERATING PERMIT FACT SHEET U.S. ARMY GARRISON AT FORT DETRICK

201 BEASLEY DRIVE, FREDERICK, MD 21702-5000 PART 70 PERMIT NO. 24-021-00131

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BACKGROUND Fort Detrick is a Federal military installation located within the city limits of Frederick, Maryland in Frederick County. The military installation is comprised of the following four noncontiguous parcels: Main Post (728 acres); Area B, including the FLAIR Armory (399 acres); Water Treatment Plant (7 acres); and Sewage Treatment Plant (9 acres). Frederick County is located in emission control Area II (in fact Area II is comprised only of Frederick County). Only the Main Post is subject to Part 70 permitting. Fort Detrick houses several medical research laboratories and a worldwide communications area and satellite dishes for satellite tracking. Consequently, the facility’s equipment list includes steam generating boilers, space heating boilers, several incinerators, and emergency generators. The SIC code for the facility is 9711. The following table summarizes the actual emissions from Fort Detrick based on its Annual Emission Certification Reports: Table 1: Actual Emissions

Calendar Year

NOx (TPY)

SOx (TPY)

PM10 (TPY)

CO (TPY)

VOC (TPY)

Total HAP (TPY)

2013 20.7 3.13 3.68 5.16 1.78 < 1 2012 42.6 6.8 3.68 22.9 4.23 1.2 2011 29.1 5.1 6.37 20.8 4.04 < 2 2010 30.2 11.9 2.19 18.5 3.61 < 2 2009 39.1 44.9 4.91 15.9 3.49 < 2

The major source threshold for triggering Title V permitting requirements in Frederick County is 25 tons per year for VOCs or NOx, 100 tons per year for any other criteria pollutant, 10 tons per year of any single hazardous air pollutant (HAP) or 25 tons per year of any combination of HAPs. Since actual emissions of NOx is greater than the major source thresholds of 25 tons per year, Fort Detrick is required to obtain a Title V Part 70 Operating Permit. The initial Part 70 permit was issued on April 1, 2004. A subsequent renewal Part 70 permit was issued on November 1, 2009 covering the period from April 1, 2009 through March 31, 2014. The Part 70 permit renewal application for Fort Detrick was received by the Department on June 6, 2013. An administrative completeness review was conducted and the application was deemed to be timely and administratively complete. The facility is operating under an application shield. New Construction Since the prior Part 70 permit was issued, Fort Detrick has added one small (1.4 million Btu/hr) gas-fired boiler and four emergency diesel generators. A Permit to Construct was issued on August 12, 2014 to replace two 3.35 million Btu/hr No 2 oil fired boilers with two 3.35 million Btu/hr dual-fired natural gas/No.2 oil fired boilers. A Permit to Construct for the additional control equipment required to bring the two hospital-medical-infectious waste incinerators



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(HMIWI) into compliance with the October 6, 2009 Federal emission standards was issued on May 1, 2014. The construction was required to be completed and be operational no later than October 6, 2014. Two small natural gas fired boilers, A10 and A13, rated at 1.5 and 2.5 million Btu/hr were removed from service during the term of the previous permit. Two small No.2 oil-fired boilers, A6 and A7, rated at 3.35 million Btu/hr were removed in September 2013 and replaced with two boilers also rated 3.35 million Btu/hr but firing both natural gas and No. 2 oil. As of March 31, 2015 two large boilers, A4 and A5 which are rated at 98 million Btu/hr were permanently shut down. Applicable NSPS and MACTs Several of the boilers are subject to Federal New Source Performance Standards (NSPS) under 40 CFR part 60, subpart Dc and the Area Source NESHAP for Industrial, Commercial, and Institutional Boilers 40 CFR part 63, subpart JJJJJJ. There are two ‘large’ hospital-medical-infectious waste incinerators (HMIWI) and two ‘small’ municipal waste combustors at the facility, which were constructed prior to the effective date for the NSPS 40 CFR part 60 subpart Ec and 40 CFR part 60 subpart AAAA. However, the installations are subject to Federal Emission Guidelines (EG) 40 CFR part 60 subpart Ce and the Federal Implementation Plans 40 CFR part 62 subpart HHH for HMIWI and 40 CFR part 62 subpart JJJ for small Municipal Waste Combustion units. The requirements of subpart JJJ have been incorporated into Maryland’s Air Quality regulations. Additionally, there are 16 emergency diesel generators subject to either the NSPS 40 CFR part 60 subpart IIII or the NESHAP 40 CFR part 63 subpart ZZZZ. There is a gasoline dispensing facility with two 12,000 gallon underground storage tanks subject to the NESHAP 40 CFR part 63 subpart CCCCCC. Compliance Assurance Monitoring (40 CFR Part 64) The U.S. Army Garrison at Fort Detrick is exempt from CAM plan requirements since no individual installation with an add-on control device is a major source of any regulated pollutant before control. GREENHOUSE GAS (GHG) EMISSIONS Fort Detrick emits the following greenhouse gases (GHGs) related to Clean Air Act requirements: carbon dioxide, methane, and nitrous oxide. These GHGs originate from various processes, i.e., steam heating plants, incinerators, and internal combustion engines contained within the facility premises applicable to Fort Detrick. The facility has not triggered Prevention of Significant Deterioration (PSD) requirements for GHG emissions; therefore, there are no applicable GHG Clean Air Act requirements. While there may be no applicable requirements as a result of PSD, Fort Detrick is a potential major source of GHG emissions (threshold: 100,000 tpy CO2e) for GHGs. The Permittee must quantify facility-wide GHG emissions and report them in accordance with Section 3 of the Part 70 permit.



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The following table summarizes the actual emissions from Fort Detrick based on its Annual Emission Certification Reports: Table 2: Greenhouse Gases Emissions Summary

GHG Conversion factor

2008 tpy CO2e

2009 tpy CO2e

2010 tpy CO2e

2011 tpy CO2e

2012 tpy CO2e

Carbon dioxide CO2 1 44,400 33,400 25,800 28,113 26,900 Methane CH4 21 21 12.1 9.3 9.1 2.5 Nitrous Oxide N2O 310 253.9 184.8 142.6 154.4 144.2 Total GHG CO2eq 44,666 33,594 25,952 28,270 27,054

EMISSION UNIT IDENTIFICATION Fort Detrick has identified the following emission units as being subject to Title V permitting requirements and having applicable requirements: Table 3: Emission Unit Identification

MDE Registration

Number

Emissions Unit

Number

Emissions Unit Name

Emission Unit Description Date of Installation

021-131-5-0116 and 5-0117

A1 and A2 Boiler Two (2) Cleaver Brooks Model DL76E natural gas-fired boilers, each rated at 77 MMBtu/hr, located in Bldg. 190.

06/13/90

021-131-5-0267 and 5-0268

A1-1 and A2-1

Boiler Two (2) Cleaver Brooks Model DL766 natural gas-fired boilers, each rated at 77 MMBtu/hr, located in Bldg. 190.

11/2003

021-131-4-0187 and -4-0225 A8 and A9 Boiler

Two (2) Burnham Model 4F-450 No.2 fuel oil-fired boilers, each rated at 3.35 MMBtu/hr, located in Bldg. 1673

01/88 and 12/92

021-131-4-0278 and -4-0279

A8-1 and A9-1

Boiler Two (2) Burnham dual natural gas/No.2 fuel oil-fired boilers, each rated at 3.35 MMBtu/hr, located in Bldg. 1673

09/2013

021-0131-5-0223

A11

Boiler

One (1) H.B. Smith Co. Inc. Model 28A-6 natural gas-fired boiler, rated at 1.827 MMBtu/hr, located in Bldg. 1686.

08/79

021-0131-5-0213

A12 Boiler One (1) Reznor RDF3-280 natural gas-fired boiler, rated at 1.75 MMBtu/hr, located in Bldg. 832.

12/10/96

021-0131-5-0229 and 5-0230

A14 and A17

Boilers Two (2) H.B. Smith Co. Inc. Model 28A-9 natural gas-fired boilers, rated at 2.836 MMBtu/hr, located in Bldg. 1532.

6/30/98



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MDE Registration

Number

Emissions Unit

Number

Emissions Unit Name


021-0131-5-0231

A15 Boiler One (1) Peerless Model #G-LC-09-WUP natural gas-fired boiler, rated at 1.664 MMBtu/hr, located in Bldg. 1435.

6/29/98

021-0131-5-0239

A16 Boiler One (1) H.B. Smith Co. Inc. Model 28A-7 natural gas-fired boiler, rated at 2.163 MMBtu/hr, located at Bldg. 1507.

1/19/2000

021-0131-5-0346

A20-1 Boiler One (1) PVI Industries Model 3000P natural gas fired boiler, rated at 2.4 MMBtu/hr located at Bldg. 1507.

06/05/2000

021-0131-5-0292

A21 Boiler One (1) Weil-McLain Model 1088 natural gas-fired boiler, rated at 2.887 MMBtu/hr Bldg. 1529.

01/2006

021-0131-5-0323

A23 Boiler One (1) Raypak Model # P-1223 natural gas fired boiler rated at 1.223 million Btu/hr, located at Bldg. 1507.

09/2004

021-0131-5-0377 and -0378

A24 and A25

Boiler Two (2) Bryan Model CLN-270-W natural gas fired boilers rated at 2.7 million Btu/hr, located at Bldg. 693

07/2008

021-0131-5-0381 and -0382

A26 and A27

Boiler Two (2) Weil-McLain Mdl 980 natural gas fired boilers rated at 1.23 million Btu/hr, located at Bldgs. 1545 and 1546

02/2007

021-0131-5-0457

A28 Boiler One (1) Fulton Model PHW-1400 natural gas-fired boiler rated at 1.4 million Btu/hr, located in Bldg. 1419

12/3/2012

021-0131-2-0066 and 2-0067

B5 and B6 Incinerator

Two (2) hospital, medical, and infectious waste incinerators (HMIWI) each rated at 1,000 lbs/hr and each equipped with an emissions control system and a waste heat recovery boiler, located in Bldg. 393.

06/6/95

021-0131-2-0049 and 2-0050

B1 and B4

Incinerator

Two (2) small municipal waste combustion units, ECP Model 2500T, each rated at 39 ton/day and each equipped with an emissions control system and a waste heat recovery boiler, located in Bldg. 393.

1975

021-0131-9-0101 and 9-0102

C1 and C2

Emergency Diesel Generators

Two (2) 993 kW No.2 oil -fired generators, Alban and Caterpillar, located in Bldg. 1425. 01/1985

021-0131-9-0148 (registered as a group, 4 each)

C3 thru C6


Four (4) 2,000 kW No. 2 oil –fired generators, Williams and Lane, located in Bldg. 1673. 04/1985 to

09/1987



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MDE Registration

Number

Emissions Unit

Number

Emissions Unit Name


021-0131-9-0153

C7 Emergency Diesel Generator

One (1) 900 kW No. 2 oil-fired generator, Caterpillar, located in Bldg. 1420

05/1996

021-0131-9-0155


One (1) 880 kW No. 2 oil-fired generator, Caterpillar Model 3508, located in Bldg. 1414.

12/2001

021-0131-9-0202


One 1,502 BHP (1000 kW) No. 2 oil-fired Caterpillar Model 3508 generator located in Bldg. 1414.

09/2004

021-0131-9-0205


One 2,876 BHP (2000 kW) No. 2 oil -fired generator, Caterpillar Model 3516/SR4B generator located in Bldg. 1425.

09/2004

021-0131-9-0312


One 600 kW Kohler Model 600REOZv located in Bldg 693 05/2011

021-0131-9-0236


One 764 BHP (570 kW) No.2 oil-fired generator, Caterpillar Model 3456 located at Bldg. 190 (boiler plant)

06/2006

021-0131-9-0209


One 685 BHP (511 kW) No. 2 oil-fired Perkins Model CV12TA-RG3 located at Bldg. 810. 09/1988

021-0131-9-0317


One 1000 kW Kohler Model 1000REOZMB located in Bldg 568 09/2011

021-0131-9-0353


One 2000 kW Caterpillar Model SR45/3516C located in Bldg 8100 12/2012

021-0131-9-0354


One 500 kW Kohler Model 500REOZJ located in Bldg 1419 12/2012

021-0131-9-0146 F1

Gasoline Storage tanks

Two (2) 12,000 gallon underground storage tanks, using Stage I vapor recovery systems, fuel feed to 6 dispensers which use Stage II vapor recovery systems.

06/2004



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AN OVERVIEW OF THE PART 70 PERMIT The Fact Sheet is an informational document. If there are any discrepancies between the Fact Sheet and the Part 70 permit, the Part 70 permit is the enforceable document. Section I of the Part 70 Permit contains a brief description of the facility and an inventory list of the emissions units for which applicable requirements are identified in Section IV of the permit. Section II of the Part 70 Permit contains the general requirements that relate to administrative permit actions. This section includes the procedures for renewing, amending, reopening, and transferring permits, the relationship to permits to construct and approvals, and the general duty to provide information and to comply with all applicable requirements. Section III of the Part 70 Permit contains the general requirements for testing, record keeping and reporting; and requirements that affect the facility as a whole, such as open burning, air pollution episodes, particulate matter from construction and demolition activities, asbestos provisions, ozone depleting substance provisions, general conformity, and acid rain permit. This section includes the requirement to report excess emissions and deviations, to submit an annual emissions certification report and an annual compliance certification report, and results of sampling and testing. Section IV of the Part 70 Permit identifies the emissions standards, emissions limitations, operational limitations, and work practices applicable to each emissions unit located at the facility. For each standard, limitation, and work practice, the permit identifies the basis upon which the Permittee will demonstrate compliance. The basis will include testing, monitoring, record keeping, and reporting requirements. The demonstration may include one or more of these methods. Section V of the Part 70 Permit contains a list of insignificant activities. These activities emit very small quantities of regulated air pollutants and do not require a permit to construct or registration with the Department. For insignificant activities that are subject to a requirement under the Clean Air Act, the requirement is listed under the activity. Section VI of the Part 70 Permit contains State-only enforceable requirements. Section VI identifies requirements that are not based on the Clean Air Act, but solely on Maryland air pollution regulations. These requirements generally relate to the prevention of nuisances and implementation of Maryland's Air Toxics Program.



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REGULATORY REVIEW/TECHNICAL REVIEW/COMPLIANCE METHO DOLOGY 1. EMISSION UNITS A1 and A2: Two (2) Cleaver Brooks Model DL76E natural gas-

fired boilers, each rated at 77 MMBtu/hr. These steam boilers are located in Building 190 and provide space heating, hot water, and process steam for most of the buildings at Fort Detrick. These boilers replaced existing boilers. No control equipment is currently used on these units. The Permittee was issued a minor new source review construction permit in June 1990. Therefore, 40 CFR Part 60 Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, is applicable to these boilers. APPLICABLE STANDARDS and LIMITATIONS Visible Emissions Limitations

♦ COMAR 26.11.09.05A(1), which prohibits the discharge of emissions from any fuel-burning

equipment in Area II, other than water in uncombined form, greater than 20 percent opacity except as allowed under COMAR 26.11.09.05A(3), and

♦ 40 CFR §60.43c(d) which limits visible emissions to 20 percent opacity (6-minute average),

except for one 6-minute period per hour of not more than 27 percent opacity. Compliance Demonstration - When the facility combusted No. 6 fuel oil it was subject to an opacity CEMS requirement under the NSPS 40 CFR part 60 subpart Dc, §60.47c(a). Since the planned operation with residual oil was limited, the EPA approved an alternative monitoring approach for these boilers in accordance with 40 CFR §60.8(b)(3)1 However, as of March 31, 2015, these boilers no longer combust any fuel oil and continuous opacity monitoring or the EPA alternative monitoring to be conducted while combusting No. 6 fuel oil is no longer required. These boilers now have an uninterruptible supply of natural gas and combust natural gas exclusively. The Permittee must operate and maintain the boiler in a manner to prevent the visible emissions by maintaining an Operations Manual and Preventive Maintenance Plan and monitoring in accordance with the Operations Manual and Preventative Maintenance Plan. The Permittee must maintain a log of all maintenance performed that relates to combustion performance. The Permittee must keep records of the date and time of visible emissions observations, along with the results of each observation and. must report incidents of visible emissions in accordance with permit condition 4 of Section III, Plant Wide Conditions, "Report of Excess Emissions and Deviations." The basis for these monitoring, record keeping, and 1letter dated 25 May 2004, from Judith M. Katz, Director, Air Protection Division, USEPA to Robert P. Craig, Chief, Environmental Management Office, U.S. Army Garrison at Fort Detrick.



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reporting requirements is the Department's authority to create periodic monitoring requirements, COMAR 26.11.03.06C(3). Control of Particulate Matter ♦ COMAR 26.11.09.06A(2), which states that “a person may not cause or permit particulate

matter caused by the combustion of solid fuel or residual oil in any fuel burning equipment erected on or after January 17, 1972 to be discharged into the atmosphere in excess of the amounts in Figure 2.”

This regulation no longer applies since the boilers ceased burning any fuel oil after March 31, 2015 and are now limited to combusting natural gas exclusively. There are no particulate matter emission limitations on boilers combusting only natural gas. Control of Sulfur Oxides ♦ COMAR 26.11.09.07A(1)(b) Control of Sulfur Oxides from fuel burning equipment. “A

person may not burn, sell, or make available for sale any fuel with a sulfur content by weight in excess of or which otherwise exceeds the following limitations: in Areas I, II, V, and VI, for residual fuel oils, 2 percent.

♦ 40 CFR 60.42c(d) which limits the discharge of sulfur dioxide from the combustion of fuel

oil to not more than 0.50 lb/million Btu or 0.5 percent by weight. These boilers ceased combusting fuel oil after March 31, 2016 and are now limited to combusting natural gas exclusively. There are no sulfur oxides emission limitations on boilers combusting only natural gas. Control of Nitrogen Oxides Emissions Permit condition 4.1a.2 D provides that the Permittee must comply with one of the following NOx RACT: ♦ COMAR 26.11.09.08F(1) states that a person who owns or operates a space heater as

defined in Regulation .01B of this chapter shall do the following: (a) Submit to the Department a list of each affected installation on the premises and the types of fuel used in each installation; (b) Develop an operating and maintenance plan to minimize NOx emissions based on the recommendations of equipment vendors and other information including the source’s operating and maintenance experience; (c) Implement the operating and maintenance plan and maintain the plan at the premises for review upon request by the Department;



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(d) Require installation operators to attend in-State operator training programs once every 3 years on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and (e) Prepare and maintain a record of training program attendance for each operator at the site, and make these records available to the Department upon request. COMAR 26.11.09.08F(2) requires that a person who owns or operates an installation that no longer qualifies as a space heater shall inform the Department no later than 60 days after the date when the fuel burning equipment did not qualify, and shall meet the applicable fuel-burning equipment RACT requirement in this regulation.

♦ COMAR 26.11.09.08E which states that for fuel-burning equipment with a rated heat input

capacity of 100 MMBtu per hour or less, the Permittee shall do the following:

(1) Submit to the Department an identification of each affected installation, the rated heat input capacity of each installation, and the type of fuel burned in each; (2) Perform a combustion analysis for each installation at least once each calendar quarter and optimize combustion based on the analysis; (3) Maintain the results of the combustion analysis and stack tests at the site for at least 2 years and make this data available to the Department and EPA upon request; (4) Once every three years, require each operator of the installation to attend operator training programs on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and (5) Prepare and maintain a record of training program attendance for each operator at the site, and make these records available to the Department upon request.

Compliance Demonstration with COMAR 26.11.09.08F.

The Permittee must develop and implement the operating and maintenance plan and maintain the plan at the premises for review upon request by the Department. The Permittee must maintain: (a) The operating and maintenance plan at the premises for review by the Department upon request. (b) Records of the quantity of fuel burned each month and calculation of heat input in a manner that the Permittee can determine whether the boiler no longer qualifies as a “Space Heater.” (c) Records of the training program attendance for each operator at the site. [Authority: COMAR 26.11.09.8F(1)]. The Permittee must inform the Department no later than 60 days after the date when the boilers no longer qualify as a space heater, and must meet the requirements under COMAR 26.11.09.08E or identify an alternative NOx RACT requirement under COMAR 26.11.09.08 with which the source will comply. The Permittee shall submit a list of trained operators and training attendance records to the Department upon request. [Authority: COMAR 26.11.09.08F(2)].



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Rationale The boilers typically operate in manner that meets the definition for a space heater. COMAR 26.11.09.01B(7) defines "Space heater" as fuel-burning equipment that consumes more than 60 percent of its annual fuel during the period from October 31 of one year through March 31 of the following year. For the purpose of this regulation, annual fuel use is the total fuel consumed during the period October 1 of one year to September 30 of the following year, beginning October 1, 1989. When operating as a “Space Heater”, the Permittee must comply with the NOx RACT requirements of COMAR 26.11.09.08F. If the operations change so that the boilers do not quality as a “Space Heater”, the Permittee must comply with the NOx RACT requirements of COMAR 26.11.09.08E, “Requirements for Fuel-burning Equipment with a Rated Heat Input of 100 MMBtu per Hour or Less” at the time a boiler no longer operates as a “Space Heater”. The Permittee shall continue to comply with the NOx RACT for Fuel-burning equipment with a rated heat input of 100 MMBtu per hour or less until the boiler operates for one heating season as a “Space Heater”. After successfully operating as a space heater for a heating season (Oct 1 to Sept 30), the Permittee may return to complying with the requirements for a “Space Heater”.

Compliance Demonstration with COMAR 26.11.09.08E . The Permittee must perform a combustion analysis for each installation not qualifying as a space heater at least once each year and optimize combustion based on the analysis. The Permittee must maintain the results of the annual combustion analysis and stack tests at the site and maintain a record of training program attendance for each operator. The Permittee must make the results of the combustion analyses and stack tests available to the Department and EPA upon request. The Permittee must submit a list of trained operators and training attendance records to the Department upon request [Authority: COMAR 26.11.09.08E]. Operational Limitations Permit Condition 4.1.2 C after March 31, 2015, requires the Permittee to combust only natural gas unless the Permittee receives a permit or approval from the Department [Authority: COMAR 26.11.02.09A]. Note: Previous permit condition 4.1.2 E, which limited the annual capacity factor for Number 6 fuel oil of no more than 10 percent in any calendar year [Ref: Letter dated 25 May 2004, from Judith M. Katz, Director, Air Protection Division, USEPA; to Robert P. Craig, Chief, Environmental Management Office, U.S. Army Garrison at Fort Detrick], is now considered obsolete and was not included in the current permit. Exemption from Boiler NESHAP requirements: Since the boilers, as of March 31, 2015 no longer combust any fuel oil and combust only natural gas, the boilers are exempt from the NESHAP requirements in accordance with §63.11195(e).



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Compliance Demonstration

Permit condition 4.1.5 C requires the Permittee to retain monthly fuel records of each boiler [Authority: COMAR 26.11.03.06C(3)]. Permit condition 4.1.6 C requires the Permittee to submit an annual emissions certification report (permit condition 8 of Section III, Plant Wide Conditions "Emissions Certification Report). The annual certification report must contain the type, quantities, and analyses of all fuels burned. No additional requirements are needed to show compliance with this operational limitation [Authority: 26.11.02.19C(2)]. 2. EMISSION UNIT A1-1 and A2-1: Two (2) Cleaver Brooks (Model DL766) natural gas-

fired boilers, each rated at 77 MMBtu/hr. located in Bldg. 190. These steam boilers provide space heating, hot water, and process steam for most of the buildings at Fort Detrick. The boilers replaced an existing 165 MMBtu/hr boiler. No add-on control equipment was used on these units. The Permittee was issued a minor new source review construction permit on May 20, 2003, Permit to Construct 021-5-0267 & -0268N. Therefore, 40 CFR Part 60 Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, is applicable to these boilers. Permit to Construct 021-5-0267 & -0268N required the Permittee to remove or render inoperative the existing Erie City Iron Works 165 MM/Btu per hour boiler within 180 days of the initial operation of these two Cleaver Brooks boilers in order to avoid New Source Review requirements for NOx. This requirement was satisfied. APPLICABLE STANDARDS and LIMITATIONS Visible Emissions Limitations ♦ COMAR 26.11.09.05A(1), which prohibits the discharge of emissions from any fuel-burning

equipment in Area II, other than water in uncombined form, greater than 20 percent opacity except as allowed under COMAR 26.11.09.05A(3), and

♦ 40 CFR §60.43c(d) which limits visible emissions to 20 percent opacity (6-minute average),

except for one 6-minute period per hour of not more than 27 percent opacity.



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Compliance Demonstration The Permittee must to demonstrate compliance with the opacity standard when the boilers are burning natural gas by maintaining an Operations Manual and Preventive Maintenance Plan. The Permittee must maintain a log of maintenance performed that relates to combustion performance. The Permittee shall report incidents of visible emissions in accordance with permit condition 4 of Section III, Plant Wide Conditions, "Report of Excess Emissions and Deviations." The basis for these monitoring, record keeping, and reporting requirements is the Department's authority to create periodic monitoring requirements, COMAR 26.11.03.06C. Rationale for Periodic Monitoring.

Boilers that burn natural gas rarely have visible emissions if properly operated and maintained. The Permittee is required to maintain on site an operations manual, a preventative maintenance plan, and records of maintenance performed that relate to combustion performance.

Control of Particulate Matter ♦ COMAR 26.11.09.06A(2), which states that “a person may not cause or permit particulate

matter caused by the combustion of fuel in any fuel burning equipment created on or after January 17, 1972 to be discharged into the atmosphere in excess of the amounts in Figure 2.”

This regulation no longer applies since the boilers ceased burning any fuel oil after March 31, 2015. There are no particulate matter emission limitations on boilers combusting only natural gas. Control of Sulfur Oxides ♦ COMAR 26.11.09.07A(1)(b) Control of Sulfur Oxides from fuel burning equipment. “A

person may not burn, sell, or make available for sale any fuel with a sulfur content by weight in excess of or which otherwise exceeds the following limitations: in Areas I, II, V, and VI, for residual fuel oils, 2 percent.

♦ 40 CFR §60.42c(d) which limits the discharge of sulfur dioxide from the combustion of fuel

oil to not more than 0.50 lb/million Btu or 0.5 percent by weight. These regulations no longer apply since the boilers ceased burning any fuel oil after March 31, 2015. There are no sulfur oxides emission limitations on boilers combusting only natural gas. Control of Nitrogen Oxides Emissions

In order to avoid major new source review, the Permittee netted out emissions of NOx by agreeing to shut down an existing boiler and accepting a NOx emissions rate limitation of 0.095



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pounds per MMBtu while burning natural gas and an annual limit of 80.4 tons of NOx from these two boilers.

♦ Permit to Construct Number 021-5-0267& -0268 N issued May 20, 2003 - The boilers shall

be equipped with low NOx burners and flue gas recirculation equipment as necessary to discharge not more than 0.095 lb/million Btu while firing natural gas.

♦ Permit to Construct Number 021-5-0267& -0268 N issued May 20, 2003 - The total NOx

emissions from the two boilers shall not exceed 80.4 tons in any consecutive 12-month period.

NOx RACT Requirements ♦ COMAR 26.11.09.08F which states that a person who owns or operates a space heater as

defined in Regulation .01B of this chapter shall do the following: (a) Submit to the Department a list of each affected installation on the premises and the types of fuel used in each installation; (b) Develop an operating and maintenance plan to minimize NOx emissions based on the recommendations of equipment vendors and other information including the source’s operating and maintenance experience; (c) Implement the operating and maintenance plan and maintain the plan at the premises for review upon request by the Department; (d) Require installation operators to attend in-State operator training programs once every 3 years on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and (e) Prepare and maintain a record of training program attendance for each operator at the site, and make these records available to the Department upon request.”

COMAR 26.11.09.08F also requires that a person who owns or operates an installation that no longer qualifies as a space heater shall inform the Department no later than 60 days after the date when the fuel burning equipment did not qualify, and shall meet the applicable fuel-burning equipment RACT requirement in this regulation.

♦ COMAR 26.11.09.08E which states that for fuel-burning equipment with a rated heat input

capacity of 100 MMBtu per hour or less, the Permittee shall do the following:

(a) Submit to the Department an identification of each affected installation, the rated heat input capacity of each installation, and the type of fuel burned in each; (b) Perform a combustion analysis for each installation at least once each calendar quarter and optimize combustion based on the analysis; (c) Maintain the results of the combustion analysis and stack tests at the site for at least 2 years and make this data available to the Department and EPA upon request;



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(d) Once every three years, require each operator of the installation to attend operator training programs on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and (e) Prepare and maintain a record of training program attendance for each operator at the site, and make these records available to the Department upon request.

Compliance demonstration. The boilers will typically operate in manner that meets the definition for a space heater. COMAR 26.11.09.01B(7) defines "Space heater" as fuel-burning equipment that consumes more than 60 percent of its annual fuel during the period from October 31 of one year through March 31 of the following year. For the purpose of this regulation, annual fuel use is the total fuel consumed during the period October 1 of one year to September 30 of the following year, beginning October 1, 1989.

When operating as a “Space Heater”, the Permittee must comply with the NOx RACT requirements of COMAR 26.11.09.08F. If the operations change so that the boilers do not quality as a “Space Heater”, the Permittee must comply with the NOx RACT requirements of COMAR 26.11.09.08E, “Requirements for Fuel-burning Equipment with a Rated Heat Input of 100 MMBtu per Hour or Less” at the time a boiler no longer operates as a “Space Heater”. The Permittee must continue to comply with the NOx RACT for Fuel-burning equipment with a rated heat input of 100 MMBtu per hour or less until the boiler operates for one heating season as a “Space Heater”. After successfully operating as a space heater for a heating season (Oct 1 to Sept 30), the Permittee may return to complying with the requirements for a “Space Heater”. Previous permit condition 4.2.4 D(1) requiring the Permittee to measure the NOx content of the flue gases from each boiler for a 5-minute period once a month using a portable gas analyzer was deemed no longer necessary and deleted. Additionally, previous permit condition 4.2.4 D(2) requiring the Permittee to calculate monthly the quantity of NOx emissions emitted during a calendar month and for the previous consecutive 12 month period from the two boilers was also considered unnecessary since, even operating continuously (8,760 hour/year) at maximum load, the NOx emissions from both boilers would be less than 80.4 tons per year, keeping in mind that the boilers typically operate as space heaters. Operational Limitations Permit condition 4.2.2 C, requires that, after March 31, 2015, the Permittee must combust only natural gas unless the Permittee receives a permit or approval from the Department [Authority: COMAR 26.11.02.09A].

Exemption from Boiler NESHAP requirements: Since the boilers, as of March 31, 2015, will no longer combust any fuel oil and combust only natural gas are exempt from NESHAP requirements.



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Compliance Demonstration Permit condition 4.2.5 C requires the Permittee to retain monthly fuel usage records for each boiler [Authority: COMAR 26.11.03.06C(3)].: Additionally, the Permittee is required to submit an annual emissions certification report (permit condition 8 of Section III, Plant Wide Conditions "Emissions Certification Report). Permit Condition 4.2.6 E requires that the annual certification report must contain the type, quantities, and analyses of all fuels burned. 4. EMISSION UNITS A8, A9: Two (2) No.2 fuel oil-fired boilers, each rated at 3.35

MMBtu/hr, located in Bldg 1673.

EMISSION UNITS A8-1 and A9-1: Two (2) dual natural gas/No.2 fuel oil-fired boilers, each rated at 3.35 MMBtu/hr, located in Bldg 1673.

These boilers provide space heating and hot water for residential buildings at Fort Detrick. No control equipment is currently used on these units. Emission Units A8 and A9 were registered with the Department in 1988 and 1992. No reconstruction or modification has occurred on these boilers since then. However, an after-the-fact Permit to Construct was issued by the Department on July 16, 2014 for the boilers designated as A8-1 and A9-1 above, which replaced boilers A6 and A7 in September 2013. The NSPS, 40 CFR part 60 subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, is not applicable since the individual heat input capacity is less than 10 million Btu/hr. However, the boilers are subject to certain work practice requirements under the area source NESHAP, 40 CFR part 63, subpart JJJJJJ. APPLICABLE STANDARDS and LIMITATIONS Visible Emissions Limitations ♦ COMAR 26.11.09.05A(1), which prohibits the discharge of emissions from any fuel-burning

equipment in Area II, other than water in uncombined form, greater than 20 percent opacity except as allowed under COMAR 26.11.09.05A(3).

COMAR 26.11.09.05A(3) provides that Section A(1) and (2) of this regulation do not apply to emissions during load changing, soot blowing, startup, or adjustments or occasional cleaning of control equipment if: (a) The visible emissions are not greater than 40 percent opacity; and (b) The visible emissions do not occur for more than 6 consecutive minutes in any sixty minute period.



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Compliance Demonstration The Permittee shall properly operate and maintain the boilers in a manner to prevent visible emissions. The Permittee shall maintain an operations manual and preventive maintenance plan, and a log of maintenance performed that relates to combustion performance. The Permittee shall report incidents of visible emissions in accordance with permit condition 4 of Section III, Plant Wide Conditions, "Report of Excess Emissions and Deviations." The basis for these monitoring, record keeping, and reporting requirements is the Department's authority to create periodic monitoring requirements, COMAR 26.11.03.06C. Rationale for Periodic Monitoring Boilers that burn No.2 fuel oil with a rated heat input capacity of less than 10 MM Btu/hr typically never have visible emissions if properly operated and maintained. Boilers in this size range are set up to operate in an automatic mode without oversight of an operator. The completion of annual preventative maintenance as recommended by the boiler manufacturer, focusing on combustion performance, is sufficient to maintain compliance with the no visible emissions requirement. Even though there is not a specific schedule to perform observations of the stack emissions, the Permittee is required under the general reporting requirement for excess emissions and deviations to report incidents when visible emissions exceed 20 percent opacity. Control of Particulate Matter

♦ COMAR 26.11.09.06A(3)(c), exempts natural gas and distillate fuel oil from a numerical

particulate matter standard. Control of Sulfur Oxides ♦ COMAR 26.11.09.07A , Control of Sulfur Oxides from Fuel Burning Equipment, “A

person may not burn, sell, or make available for sale any fuel with a sulfur content by weight in excess of or which otherwise exceed the following limitations: (1) In Areas I, II, V, and VI: Distillate fuel oils , 0.3 percent.”

Compliance Demonstration The Permittee must obtain a certification from the fuel supplier indicating that the oil complies with the limitation on the sulfur content of fuel oil. The Permittee shall retain fuel supplier certifications of sulfur content in fuel. The Permittee shall report fuel supplier certifications of sulfur content in fuel to the Department upon request. The basis for these monitoring, record keeping, and reporting requirements is the Department's authority to create periodic monitoring requirements, COMAR 26.11.03.06C.



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Control of Nitrogen Oxides Emissions

♦ COMAR 26.11.09.08F(1) A person who owns or operates a space heater as defined in Regulation .01B of this chapter shall: (a) Submit to the Department a list of each affected installation on the premises and the

types of fuel used in each installation; (b) Develop an operating and maintenance plan to minimize NOx emissions based on the

recommendations of equipment vendors and other information including the source’s operating and maintenance experience;

(c) Implement the operating and maintenance plan and maintain the plan at the premises

for review upon request by the Department; (d) Require installation operators to attend in-State operator training programs once

every 3 years on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and

(e) Prepare and maintain a record of training program attendance for each operator at the

site, and make these records available to the Department upon request.”

♦ COMAR 26.11.09.08F(2) A person who owns or operates an installation that no longer qualifies as a space heater shall inform the Department no later than 60 days after the date when the fuel burning equipment did not qualify, and shall meet the applicable fuel-burning equipment RACT requirement in this regulation. COMAR 26.11.09.08B(5) – Operator Training:

(a) For the purpose of this regulation, the equipment operator to be trained may be the

person who maintains the equipment and makes the necessary adjustments for efficient operation.

(b) The operator training course sponsored by the Department shall include an in-house

training course that is approved by the Department. [Authority: COMAR 26.11.09.08E(3)]

Compliance Demonstration The Permittee must develop an operating and maintenance plan to minimize NOx emissions based on the recommendations of equipment vendors and other information including the source’s operating and maintenance experience. The Permittee must keep a copy of the operation and maintenance plan on-site and records of fuel use which demonstrate that the boiler



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meets the definition of a space heater [Authority COMAR 26.11.09.08K(3) and COMAR 26.11.03.06C] Operational Limitations. Permit condition 4.3.2 D(1) requires the Permittee to burn only No. 2 fuel oil in units A8 and A9 and only No. 2 fuel oil or natural gas in units A8-1 and A9-1 unless the Permittee applies for and receives an approval or permit from the Department to burn an alternative fuel. [Authority: COMAR 26.11.02.09A] Permit condition 4.3.2 D(2) requires the Permittee to conduct initial and subsequent boiler tune-ups in accordance with the procedures specified in §63.11223(b) [Authority: 40 CFR part 63, subpart JJJJJJ, §63.11201(b), §63.11214(b), §63.11223, and, Table 2, item 12]:

(a) Prior to the issuance of this Part 70 Permit, the Permittee must complete an initial tune-up

of the boilers A8, A9, A8-1, and A9-1 and submit the required Notifications of Compliance Status to the EPA. Note: Ms. Rhonda B. Wolf, Air Program Manager/Environmental Engineer, USAG Fort Detrick, in an email dated March 18, 2015 informed MDE-ARMA that the required tune-ups for these boilers were conducted over the period from 12/16 – 12/19/2014 and the Notification of Compliance Status was submitted electronically to EPA’s Compliance and Emissions Data Reporting Interface (CEDRA) on March 18, 2015.

(b) The Permittee must conduct subsequent tune-ups of each boiler every 5 years. Each 5-year

tune-up must be conducted no more than 61 months after the previous tune-up. Compliance Demonstration. Permit condition 4.3.5 D(1) requires the Permittee to maintain a record of the quantity of each type fuel burned [Authority: COMAR 26.11.02.19C(1)(c)] Permit condition 4.3.6 D(1) requires the Permittee to submit an annual emissions certification report (permit condition 8 of Section III, Plant Wide Conditions "Emissions Certification Report). The annual certification report must contain the type, quantities, and analyses of all fuels burned.

Permit condition 4.3.5 D(2) requires the Permittee to maintain the records and copies of all notifications and reports required by 40 CFR §63.11225(c) and (d) make them available to the Department and EPA upon request. The following paragraphs apply [Authority: §63.11225]:

§63.11225(c) (1) requires the Permittee to keep a copy of each notification and report submitted to comply with this subpart and all documentation supporting any Initial Notification or Notification of Compliance Status submitted.



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§63.11225(c)(2) requires the Permittee to keep records to document conformance with the work practices, emission reduction measures, and management practices required by §63.11223. §63.11225(c)(2)(i) require that records must identify each boiler, the date of tune-up, the procedures followed for tune-up, and the manufacturer's specifications to which the boiler was tuned. With regard to the tune-up every 5 years, the Permittee must maintain the following information [Authority: condition E(1), Permits to Construct 021-0132-4-0278 and -4-279 issued on July 16, 2014; 40 CFR §63.11223(b)(6)]:

(a) The concentration of CO in the effluent stream in parts per million, by volume, and oxygen in volume percent, measured at high fire or typical operating load , before and after the tune-up of the boiler; (b) A description of any corrective actions taken as part of the tune-up of the boiler. (c)The type and amount of fuel used over the 12 months prior to the tune-up of the boiler, but only if was physically and legally capable of using more than one type of fuel during that period. Units using a shared fuel meter may estimate the fuel use by each unit.

§63.11225(c)(4) requires the Permittee to keep records of the occurrence and duration of each malfunction of the boiler or of the associated pollution control equipment affecting compliance with a Subpart JJJJJJ requirement (e.g., oxygen trim system). §63.11225(c)(5) requires the Permittee to keep records of actions taken during periods of malfunction to minimize emissions in accordance with general duty to minimize emissions in §63,11205(a), including corrective actions to restore the malfunctioning boiler, air pollution or monitoring equipment to its normal or usual manner §63.11225(d) The records must be in a form suitable and readily available for expeditious review. You must keep each record for 5 years following the date of each recorded action. You must keep each record on-site or be accessible from a central location by computer or by other means that instantly provide access at the site for at least 2 years after the date of each recorded action. You may keep the records off site for the remaining 3 years. Permit condition 4.3.6 D(2)(a) requires the Permittee to submit an initial notification to the EPA Administrator or delegated authority by no later than January 20, 2014 or within 120 days of startup of boilers [Authority: 40 CFR §63.11225(a)(2] . Note: The initial notification for boilers A6 through A9 was submitted on September 13, 2011. The initial notification for boilers A8-1 and A9-1 was submitted late on March 10, 2014, with an after-the-fact permit application . Boilers A8-1 and A9-1 were installed in September 2013 , replacing boilers A8 and A9,



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Permit condition 4.3.6 D(2)(b) requires the Permittee to complete an initial tune-up of the boilers A8, A9, A8-1, and A9-1 and to submit the required Notifications of Compliance Status to electronically to EPA.

Permit condition 4.3.6 D(2)(c) requires that the Notification of Compliance Status must include the information and certification(s) of compliance in paragraphs §63.11225(a)(4))(i) through (v), as applicable, and signed by a responsible official [Ref: §63.11225(a)(4)].

(i) Submit the information required in §63.9h(2), except the information listed in

§63.9h(2)(i)(B), (D), (E), and (F). If the Permittee conducts any opacity or visible emission observations, or other monitoring procedures or methods, the Permittee must submit that data to the Administrator at the appropriate address listed in §63.13. Note: Since the Permittee is not required to conduct performance tests or use CMS and is not subject to any emission limits under 40 CFR part 63, subpart JJJJJJ, Table 1, The requirement to submit this data to the EPA Administrator under paragraph §63.11225(a)(4)(i) does not apply to these emission units.

(ii) Certify that, “This facility complies with the requirements in §63.11214 to conduct an initial

tune-up of the boiler.”

(iii) – (v) not applicable.

(vi) The notification must be submitted electronically using the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, the written Notification of Compliance Status must be submitted to the Administrator at the appropriate address listed in §63.13.

Note: The required tune-ups were conducted between 12/16 -12/19/2014 and the Notification of Compliance Status was submitted electronically to EPA’s Compliance and Emissions Data Reporting Interface (CEDRA) on March 18, 2015. Permit condition 4.3.6 D(2)(d) requires that, every five (5) years, by March 1 after the tune-ups are conducted, the Permittee must prepare and submit to the delegated authority, upon request, a compliance certification report that contains the following information [Authority: condition E(2), Permits to Construct 021-0132-4-0278 and -4-279 issued on July 16, 2014 and 40 CFR §63.11225(b)]: (i) Company name and address.

(ii) Statement by a responsible official, with the official’s name, title, phone number, e-mail address, and signature, certifying the truth, accuracy and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of this subpart. Your notification must include the following certification(s) of compliance, as applicable, and signed a responsible official:



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a. “This facility complies with the requirements in §63.11223 to conduct a biennial or 5-

year tune-up, as applicable, of each boiler.” [Ref: §63.11225(b)(2)(i)] b. If the source experiences any deviations from the applicable requirements during the

reporting period, include a description of deviations, the time periods during which the deviations occurred, and the corrective action taken” [Ref: §63.11225(b)(3)]

The following certification requirements under paragraph §63.11225(b) are not applicable to these boilers for the reasons indicated below and were omitted from the Title V permit: §63.11225(b)(2(ii): For units that do not qualify for a statutory exemption as provided in section 129(g) of the Clean Air Act : “No secondary materials that are solid waste were combusted in any affected unit.” The boilers are not permitted, nor are they capable of, combusting solid fuels, or fuels that qualify as solid waste. §63.11225(b)(2)(iii): “This facility complies with the requirement in §§63.11214(d) and 63.11223(g) to minimize the boiler's time spent during startup and shutdown and to conduct startups and shutdowns according to the manufacturer's recommended procedures or procedures specified for a boiler of similar design if manufacturer's recommended procedures are not available.” This requirement only applies to boilers subject to an emission limit under 40 CFR part 63, subpart JJJJJJ, Table 1. §63.11225(b)(4): The total fuel use by each affected boiler subject to an emission limit, for each calendar month within the reporting period, including, but not limited to, a description of the fuel, whether the fuel has received a non-waste determination by you or EPA through a petition process to be a non-waste under §241.3(c), whether the fuel(s) were processed from discarded non-hazardous secondary materials within the meaning of §241.3, and the total fuel usage amount with units of measure. This requirement only applies to boilers subject to an emission limit under 40 CFR part 63, subpart JJJJJJ, Table 1.

5. EMISSION UNITS A11, A12, A14 through A17, A20-1, A21, and A23 through A28: 14 natural gas-fired boilers, ranging in size from 1.2 to 2.9 MMBtu/hr. These boilers are located in various buildings throughout the installation, providing space heating and hot water. No control equipment is currently used on these units. Emission Units A11 was registered in 05/1998. The Permittee was issued minor new source review construction permits and/or General Permits for Small Fuel Burning Equipment for Emission Units A12, A14 and A17, A15, A16, A20-1, A21, A23, A24 and A25, A26 and A27, and A28, which were installed on or about 12/10/96, 06/30/98, 06/29/98, 01/19/2000, 06/05/2000, 01/2006, 09/2004, 07/2008, 02/2007, and 12/2012 respectively. NSPS, 40 CFR Part 60 Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, is not applicable since the individual heat input capacity is less than 10



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million Btu/hr. These boilers are exempt from the area source NESHAP, 40 CFR part 63, subpart JJJJJJ since they combust only natural gas. APPLICABLE STANDARDS AND LIMITATIONS Visible Emissions Limitations ♦ COMAR 26.11.09.05A(1), which prohibits the discharge of emissions from any fuel-burning

equipment in Area II, other than water in uncombined form, greater than 20 percent opacity except as allowed under COMAR 26.11.09.05A(3).

Compliance Demonstration. The Permittee is required to report incidents of visible emissions in accordance with permit condition 4 of Section III, Plant Wide Conditions, “Report of Excess Emissions and Deviations.” Rationale for Periodic Monitoring. Boilers that burn natural gas fuel with a rated heat input capacity of less than 10 MM Btu/hr will not have visible emissions. Boilers in this size range are set up to operate in an automatic mode without oversight of an operator and require minimal preventative maintenance to maintain a level of combustion performance that does not cause visible emissions. Even though there is not a specific schedule to perform observations of the stack emissions, the Permittee is required under the general reporting requirement for excess emissions and deviations to report incidents when visible emissions are observed. Control of Nitrogen Oxides Emissions

♦ COMAR 26.11.09.08F(1) A person who owns or operates a space heater as defined in

Regulation .01B of this chapter shall: (a) Submit to the Department a list of each affected installation on the premises and the

types of fuel used in each installation; (b) Develop an operating and maintenance plan to minimize NOx emissions based on the

recommendations of equipment vendors and other information including the source’s operating and maintenance experience;

(c) Implement the operating and maintenance plan and maintain the plan at the premises

for review upon request by the Department;



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(d) Require installation operators to attend in-State operator training programs once every 3 years on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and

(e) Prepare and maintain a record of training program attendance for each operator at the

site, and make these records available to the Department upon request.”

♦ COMAR 26.11.09.08F(2) A person who owns or operates an installation that no longer qualifies as a space heater shall inform the Department no later than 60 days after the date when the fuel burning equipment did not qualify, and shall meet the applicable fuel-burning equipment RACT requirement in this regulation.

COMAR 26.11.09.08B(5) – Operator Training:

(a) For the purpose of this regulation, the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation.

(b) The operator training course sponsored by the Department shall include an in-house

training course that is approved by the Department.[Authority: COMAR 26.11.09.08E(3)]

Compliance Demonstration The Permittee must keep a copy of the operation and maintenance plan on-site and must keep records of fuel use which demonstrate that the boiler meets the definition of a space heater [Authority COMAR 26.11.09.08K(3) and COMAR 26.11.03.06C] Operational Limitation The Permittee shall burn only natural gas unless the Permittee applies for and receives an approval or permit from the Department to burn an alternative fuel. [Authority: COMAR 26.11.02.09A] Compliance Demonstration The Permittee is required to submit an annual emissions certification report (permit condition 8 of Section III, Plant Wide Conditions “Emissions Certification Report”). The annual certification report must contain the type, quantities, and analyses of all fuels burned. No additional requirements are needed to show compliance with this operational limitation.



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6. EMISSION UNITS B5 and B6: Two (2) hospital, medical, and infectious waste

incinerators (HMIWI), each rated at 1,000 lbs/hr. and each equipped with a rotary atomizing scrubber, a pre-particulate filter, an activated carbon adsorption module, and a post-particulate filter, for PM, metals, dioxins/furans, and acid gas emissions control, and a waste heat recovery boiler.

The two HMIWI are dual-burn incinerators with a primary and secondary chamber. These incinerators use as auxiliary fuel natural gas, with No. 2 fuel oil for backup, and are equipped with rotary atomizing (wet) scrubbers and cyclonic separators for air pollution control. Each incinerator has a primary stack and they both share a dump stack which will be used when the primary stacks are not operational or in the case of an emergency situation. The rotary atomizing scrubber, manufactured by Emcotek, Inc., is an emission control device that uses a water spray from a high velocity rotor (rotating at several hundred feet per second) to effect particulate and acid gas emissions control. The current drawn by the rotor motor is continuously monitored and is regarded as an operating parameter equivalent to pressure drop across a venturi scrubber. The Permittee was issued a minor new source review construction permit on June 6, 1995 for the incinerators and the facility commenced construction prior to June 20, 1996, the effective date of the New Source Performance Standard (NSPS) 40 CFR part 60, subpart Ec,. The units are however subject to the Emission Guidelines (EG) 40 CFR part 60, subpart Ce. The Emission Guidelines formed the basis of State regulation COMAR 26.11.08.08-1 and the 111(d)/129 plan for existing HMIWIs for which construction was commenced on or before June 20, 1996. The standards became final on September 15, 1997. Maryland’s 111(d)/129 plan revision was submitted for approval to EPA on April 14, 2000. Maryland Regulation COMAR 26.11.08.08-1 became federally enforceable on October 20, 2000, the effective date of the 111(d)/129 plan approval by EPA. The Emission Guidelines were revised on October 6, 2009 to include significantly more stringent standards. The Department incorporated these standards in a revised COMAR 26.11.08.08-1 and adopted new COMAR 26.11.08.08-2, but these revisions have not as yet been approved by EPA for incorporation into the 111(d)/129 plan. On May 13 2013 and on September 6, 2013, the EPA amended the Federal Plan 40 CFR part 62, subpart HHH for HMIWI to include the new standards and monitoring requirements. Consequently, the standards are currently federally enforceable. The final compliance date for these emission standards was October 6, 2014. Results of Initial Compliance Testing and Required Subsequent Testing for the September 15, 1997 Standards. In keeping with the initial testing requirements described under COMAR 26.11.08.08-1A(4), Fort Detrick conducted stack testing on August 12-25, 2000, March 12-20, 2001, August 20-22, 2001, and August 12-16, 2002 to determine compliance with the medical waste regulations.



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During the stack tests conducted in August 2003, the feed rate, pH, flue gas exit temperature, pressure drop across the wet scrubber, flow rate through the scrubber and secondary chamber temperature were continuously monitored and recorded to establish the parametric minimums and maximums. The parametric limits, based on the stack testing, were determined to be as follows: Incinerator B5

(a) charge rate- 1000 lbs per hour (maximum); (b) exit flue gas temperature- 105° F (maximum); (c) secondary chamber temperature- 1708° F (minimum); (d) scrubber amps- 53.9 (minimum) (e) flow rate through the scrubber- 19.4 gpm (minimum); and (f) pH- 6.6 (minimum).

Incinerator B6

(a) charge rate- 1000 lbs per hour (maximum); (b) exit flue gas temperature- 100° F (maximum); (c) secondary chamber temperature- 1677° F (minimum); (d) scrubber amps- 53.7(minimum); (e) flow rate through the scrubber- 19.4 gpm (minimum); and (f) pH- 6.6 (minimum).

All parametric limits were determined based on the minimum or maximum three-hour rolling averages documented during the performance (stack) tests. These parametric limits can be revised as a result of subsequent performance testing required to be conducted during the term of the Part 70 permit. In keeping with the annual testing requirements, the Permittee has demonstrated annual compliance with opacity limits, has demonstrated annual compliance with PM. CO and HCl limits in August 2001, 2002, 2003, and, as required by 40 CFR part 60 subpart Ce, demonstrated once every 3 years thereafter, in 2006, 2009, and 2012. Additionally, in August 2006, the Permittee repeated the initial emissions stack test at the request of the Department. The testing verified compliance for the following limits: PM, opacity, CO, dioxins/furans, HCl, Pb, Cd, and Hg. The Permittee has established and is currently maintaining compliance with required operating parameter limits and all operating parameters. Additionally, to comply with State-only enforceable Air Toxics regulations, the Permittee has installed, calibrates, maintains, and operates a CEMS that monitors CO and O2.



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Results of Testing - Comparison with the October 6, 2009 Standards. Fort Detrick’s test results, with dioxins/furans corrected as reported by the Corp of Engineers’ memo dated November 14, 2013, are: Pollutant Units 09/15

/1997 Standard

10/06 /2009 Standard

Incinerator B5 Incinerator B6

Stack test year = 2012 2009 or 2006

2012 2009 or 2006

PM mg/dscm 34 25 27.5 25.1 26.9 24.0 CO ppm(v) 40 11 < 1 0 < 1 0 Dioxins/furans (total)

ng/dscm 125 9.3 30.0 44.1 45.6 29.8

Dioxins/furans (TEQ)

ng/dscm 2.3 0.054 0.368 0.518 0.550 0.856

HCl ppm(v) 100 6.6 0.733 0.6 1.2 0.4 SO2 ppm(v) 55 9.0 < 1 1.0 < 1 0.7 NOx ppm(v) 250 140 61 136 76.3 85 Lead (Pb) mg/dscm 1.2 0.036 0.12 0.080 0.17 0.047 Cadmium (Cd) mg/dscm 0.16 0.0092 0.022 0.003 0.024 0.004 Mercury (Hg) mg/dscm 0.55 0.018 0.00133 0.001 0.0037 0.001

The Permittee’s testing determined that additional control equipment was needed to achieve compliance with the October 6, 2009 standards for PM, dioxin/furans, lead (Pb), and cadmium (Cd). The facility was required to submit a Plan for Compliance with the standards to the Department and the EPA. The Permittee submitted an initial Plan for Compliance in December 2012. Previously, the only add-on control device used to control these pollutants was the rotary atomizing scrubber described above. Fort Detrick submitted a Permit to Construct application, initially on October 23, 2013 (revised on March 18, 2014) for additional add-on control devices to upgrade the HMIWIs in order to achieve compliance with the revised standards. Permit to Construct 021-0131-2-0066 and -0067 M was issued by the Department on May 1, 2014. The additional control devices to be used consist of a pre-particulate filter, an activated carbon adsorption system and a post-particulate filter as described below. The final compliance date was October 6, 2014, by which all equipment was required to be in place and operational. The installation of this equipment was virtually complete by July 19, 2014. The deadline for completing the initial performance tests is April 4, 2015. The initial report of the performance test results demonstrating final compliance must be submitted to the Department no later than May 19, 2015. Pre-filter - A filter utilizing fiber particulate filters similar in design and function to a HVAC grade filter, is located before the activated carbon adsorption system and consists up to two (2) sections of 2” thick MERV-8 pleated filters or better, or tested filters used during the most recent performance tests for PM, dioxins/furans , BP, Cd, or Hg.



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Carbon adsorption system - The Permittee is required to maintain a fixed bed activated carbon adsorption system totaling at least 3,800 pounds of activated carbon in each unit, and replace the entire amount of carbon with fresh carbon at intervals not to exceed 13 months, unless the Permittee can demonstrate to the satisfaction of the Department that a lesser replacement rate or a lesser amount of activated carbon will not lead to a violation of the emission standard for either dioxins/furans or mercury [Ref: condition D(5), Permit to Construct 021-0131-2-0066 and -0067 M was issued by the Department on May 1, 2014] Post-filter - a filter utilizing fiber particulate filters similar in design and function to a HVAC grade filter located after the activated carbon adsorption system and consists of two sections. The first section is a MERV-8 filter or better, or tested filters used during the most recent performance tests for PM, dioxins/furans, Pb, Cd, or Hg, for intercepting large diameter particles followed by a filter of MERV-12, or equivalent or better as determined during the most recent performance tests for PM, dioxins/furans, Pb, Cd, or Hg, for intercepting small diameter particles down to 1.0 micron in size or smaller. §62.14453(b)(2) of subpart HHH and §60.56c(j) and §60.57c(d) of subpart Ec require that

“ If you are using an air pollution control device other than a dry scrubber followed by an FF, a wet scrubber, a dry scrubber followed by an FF and a wet scrubber, or a SNCR system to comply with the emissions limits under §62.14411, you must petition the EPA Administrator for site-specific operating parameters to be established during the initial performance test and you must continuously monitor those parameters thereafter. You may not conduct the initial performance test until the EPA Administrator has approved the petition.” 40 CFR §60.57c(d) provides that, “The owner or operator of an affected facility using an air pollution control device other than a dry scrubber followed by a fabric filter, a wet scrubber, a dry scrubber followed by a fabric filter and a wet scrubber, or selective non-catalytic reduction technology to comply with the emissions limits under §60.52c shall install, calibrate (to manufacturers' specifications), maintain, and operate the equipment necessary to monitor the site-specific operating parameters developed pursuant to §60.56c(j).”

The use of the alternative control technology and alternative site-specific operating parameters was approved via letter from Ms. Diana Esher, Director, Air Protection Division, USEPA Region III, dated April 22, 2014. APPLICABLE STANDARDS and LIMITATIONS

A. Emission Standards for Large HMIWI Constructed before June 20, 1996. The following State of Maryland regulations apply. COMAR 26.11.08.08-1A(2) The source is subject to the following emission standards for large HMIWI as promulgated in the Federal Register on September 15, 1997 and remain applicable



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until the source comes into full and final compliance in accordance with regulation COMAR 26.11.08.08-2 and its related 111(d)/129 plan revision.

COMAR 26.11.08.08-2A Notwithstanding the requirements of regulation COMAR 26.11.08.08-1, the emission standards of §B(1) – (7) of regulation COMAR 26.11.08.08-2 apply to a person who owns and operates an HMIWI subject to 40 CFR part 60, subpart Ce as revised on October 6, 2009. COMAR 26.11.08.08-2B(1) The source is subject to the following emission standards for large HMIWI as promulgated on October 6, 2009 [Authority: 40 CFR part 62, subpart HHH, §62.14411-12(a)]. Regulations COMAR 26.11.08.08-2A-E are currently State-only enforceable pending approval by EPA of the 111(d)/129 plan revision. However the October 6, 2009 emission standards are currently Federally enforceable through the Federal Plan 40 CFR part 62, subpart HHH. Note that the 10 percent opacity standard cited by COMAR 26.11.08.08-2B is greater than the 6 percent opacity cited by either the Emission Guidelines 40 CFR part 60, subpart Ce or the Federal Plan, 40 CFR part 60, subpart HHH. The emission limits, stack opacity, and visible emissions apply at all times. Previously periods of startup, shutdown, or malfunction were excluded [Authority: 40 CFR part 60 subpart Ec, §60.56c(a) and 40 CFR part 62, subpart HHH, §62.14413].

Pollutants

Units (7 percent oxygen,

dry basis)

09/15/1997 Emission Limits for Large HMIWI

10/06/2009 Emission Limits For Large HMIWI

PM milligrams per dry standard cubic meter (gr per dry standard gr/dscf)

34 (0.015) 25 (0.011)

Opacity 6 minute block average percent 10 6

CO ppm by volume 40 11

Dioxins/furans nanograms per dry standard cubic meter total dioxins/furans (gr per billion dscf) or nanograms per dry standard cubic meter TEQ (gr per billion dscm)

125 (55) or 2.3 (1.0)

9.3 (4.1) or 0.054 (0.024)

Hydrogen Chloride (HCl)

ppm by volume or percent reduction

100 or 93%

6.6 n/a

SO2 ppm by volume 55 9.0

NOx ppm by volume 250 140

Lead milligrams per dry standard cubic meter (gr per thousand dscf) or percent

1.2 (0.52) or

0.036 (0.016)



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Pollutants

Units (7 percent oxygen,

dry basis)


10/06/2009 Emission Limits For Large HMIWI

reduction 70% n/a

Cadmium milligrams per dry standard cubic meter (gr per thousand dscf) or percent reduction

0.16 (0.07) or 65%

0.0092 (0.0040) n/a

Mercury milligrams per dry standard cubic meter (gr per thousand dscf) or percent reduction

0.55 (0.24) or 85%

0.018 (0.0079) n/a

Compliance Demonstration Permit condition 4.5.3 A(1) requires the Permittee to demonstrate initial compliance with the October 6, 2009 emission limits for each of the pollutants referenced above. The Permittee must conduct initial performance (stack) tests on each incinerator train using the applicable test methods and procedures specified in paragraphs §60.56c(b)(1) through (14) of subpart Ec. The initial performance tests must be conducted no later than 180 days after the final compliance date, October 6, 2014 [Authority: 40 CFR part 62 subpart HHH, §62.14451(a) and §62.14452(r); COMAR 26.11.08.08-2B(4), which references §60.56c; §60.56c(b) and (c)]. Permit condition 4.5.3 A(2) allows the Permittee to use the results of previous emissions tests to demonstrate initial compliance with the emission limits for those pollutants for which compliance the October 6, 2009 emission limits has already been demonstrated, i.e., opacity, CO, SO2,and NOx. [Authority: 40 CFR part 62, subpart HHH, §62.14451(a) and (e)] . Permit condition 4.5.3 A(3)(a) requires the Permittee to submit a test protocol to the Department for approval at least 30 days prior to conducting any compliance stack test and to submit a copy of the results of compliance stack tests to the Department within 45 days after the date the test is completed [Authority: condition E(4), Permit to Construct 021-0131-2-0066 & 0067 M issued on May 1, 2014]. Permit conditions 4.5.3 A(3)(b) through (f) address performance test conduct and data reduction requirements of the Federal rules §60.56c(b) of subpart Ec and §62.14452 of subpart HHH. Permit condition 4.5.3 A(4), in keeping with §60.56c(c)(2) and §62.14451(b), requires the Permittee to determine compliance with the emission limits for PM, CO, and HCl by conducting an annual performance test (no more than 12 months following the previous performance test) using the applicable procedures and test methods listed in §60.56c(b)(1) –(14). Exceptions are allowed if CEMS are used to determine compliance and if three successive annual tests for a pollutant indicate compliance. However, at a minimum the Permittee must conduct a performance test for PM, CO, and HCl every third year [Authority: 40 CFR part 62, subpart



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HHH, §62.14451(a), (b), and §62.14452; COMAR 26.11.08.08-2B(4), which references 40 CFR §60.56c; §60.56c(c)(2)]. Permit condition 4.5.3 A(5) requires the Permittee to perform annual performance stack tests for dioxins/furans and mercury in accordance with the following timing requirements [Authority: Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014]: (a) The annual performance test must be performed no later than 12 months after the

previous stack test, (b) The annual performance test shall be performed prior to the replacement of the

activated carbon in the adsorption system. (c) Condition 4.5.3 A(5)(a) may be waived by the Department if the replacement of

activated carbon is deferred beyond the 13 month period in accordance with condition D(5), Permit to Construct 021-0131-2-0066 and -0067 issued on May 1, 2014.

(d) Within 48 hours before each dioxins/furans and mercury performance test, verify

the amount [volume or weight (cubic feet, pounds)] of activated carbon During all performance tests to determine compliance with the emission limits, the Federal rules require the Permittee to establish surrogate parameter limits appropriate to each pollutant and emission limit depending on the types of control devices used. These parameters must be monitored during routine operation to assure that they do not exceed the parameter limits established during the most recent performance test conducted by the facility for that emission unit. Permit condition 4.5.3 A(6) requires the Permittee to establish during the initial and any subsequent performance tests the following set of alternative site-specific operating parameters approved by the Department and EPA in accordance with 40 CFR §60.56c(j) of Subpart Ec or §62.14453(b) of Subpart HHH. (a) Maximum charge rate (b) Minimum secondary chamber temperature (c) Minimum rotary atomizing scrubber amperage (d) Minimum rotary atomizing scrubber pH (e) Maximum rotary atomizing scrubber temperature (f) Maximum carbon adsorption system inlet temperature (g) Maximum post-filter differential pressure The parameters 4.5.3 A(6)(a) through (d) are from §60.56c(f) of Subpart Ec and are retained with additional parameters (e) – (g) added addressing the additional control devices, i.e., the three fiber particulate filters and the carbon adsorption unit. Prior to the modifications necessary



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to comply with the October 6, 2009 standards, the parametric monitoring criteria cited by §60.56c(f) for a wet scrubber only was applicable. The definitions for the parameters (a) – (d) above are virtually the same as that found in §60.51c of subpart Ec and are the same as those used in the Title V permit issued in 2009. The definitions for the additional parameters (e) – (g) are from the Permit to Construct issued May 1, 2014 and were approved by EPA. (e) Maximum rotary atomizing scrubber temperature – for the purposes of this permit, means

17 ºC (30.6 ºF) more than the lowest 3-hour average flue gas temperature at the outlet from the rotary atomizing scrubber prior to entering the steam coil re-heating unit (T1) (taken, at a minimum, once every minute) measured during the most recent performance tests demonstrating compliance with the dioxin/furans (D/F) and mercury (Hg) emission limits.

(f) Maximum carbon adsorption system inlet temperature - means 17 ºC (30.6 ºF) more than

the lowest 3-hour average flue gas temperature (taken, at a minimum, once every minute), at the inlet to the carbon adsorption system at a position after the steam coil re-heating unit but before the particulate pre-filter (T2), measured during the most recent performance test demonstrating compliance with the dioxin/furan (D/F) and mercury (Hg) emissions limit., whichever is lower.

(g) Maximum post-filter differential pressure - The greater differential pressure across the

MERV-12 or better second section of the post-filter determined during the most recent performance tests demonstrating compliance with the emission limitations for dioxins/furans, particulate matter, lead, cadmium, and mercury as determined by consideration of the following: (a) 0.5 inch of water column (WC) more than the highest 3-hour average differential pressure (inches WC) measured during the performance tests or (b) 110 percent of the highest 3-hour average differential pressure (inches WC) determined during the performance tests.

Post-filter means - a filter utilizing fiber particulate filters similar in design and function to a HVAC grade filter located after the activated carbon adsorption system and consists of two sections. The first section is a MERV-8 filter or better, or tested filters used during the most recent performance tests for PM, dioxins/furans, Pb, Cd, or Hg, for intercepting large diameter particles followed by a filter of MERV-12, or equivalent or better as determined during the most recent performance tests for PM, dioxins/furans, Pb, Cd, or Hg, for intercepting small diameter particles down to 1.0 micron in size or smaller.

Definitions (e) and (f) serve the same function and closely follow the definitions from §60.51c of Subpart Ec for Maximum fabric filter inlet temperature and Maximum flue gas temperature:

Maximum flue gas temperature means 110 percent of the lowest 3-hour average temperature at the outlet from the wet scrubber (taken, at a minimum, once every minute)



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measured during the most recent performance test demonstrating compliance with the mercury (Hg) emission limit. Maximum fabric filter inlet temperature means 110 percent of the lowest 3-hour average temperature at the inlet to the fabric filter (taken, at a minimum, once every minute) measured during the most recent performance test demonstrating compliance with the dioxin/furan emission limit.

Permit condition 4.5.4 A requires that the Permittee comply with the monitoring requirements under 40 CFR §60.57c, subpart Ec, subject to 4.5.4 A(1) and 4.5.4 A(2) [Authority: §62.14453 and §62.14454 of subpart HHH; COMAR 26.11.08.08-2B(5)]:

Permit condition 4.5.4 A(1) Exemptions. A person may elect to use the exemptions listed under 40 CFR §§ 60.56c(c)5)(ii) through (v), (c)(6), (c)(7), (e)(6) through (10), (f)(7) through (10), (g)(6) through (10) and (h) for HMIWI units subject to .08-2B(1) [Authority: COMAR 26.11.08.08-2B(5(a)].

Permit condition 4.5.4 A(2) allows a CO CEMS as alternative compliance option. COMAR 26.11.08.08-2B(5(b) provides that, “… A person may elect to use CO CEMS as specified under 40 CFR §60.56c(c)(4) …” §62.14452(o) of Subpart HHH also provides that, if the Permittee is using a CEMS to demonstrate compliance with any of the emissions limits under §§62.14411 or 62.14412, the Permittee:

(a) Must determine compliance with the appropriate emissions limit(s) using a 12-hour rolling

average, calculated as specified in section 12.4.1 of EPA Reference Method 19 of 40 CFR part 60, appendix A-7. Performance tests using EPA Reference Methods are not required for pollutants monitored with CEMS [Ref: §62.14452(o)(1)].2

2Note that the two Federal rules are currently in conflict with respect to CEM averaging time. The Federal Plan, 40 CFR part 62, subpart HHH, specifies a 12-hour rolling average, while the Emission Guidelines specifies 40 CFR part 60, subpart Ce specifies a 24-hour block average. Regulation COMAR 26.11.08.08-2B(5)(b) is in agreement the Emission Guideline requirements 40 CFR part 60, subpart Ce, both of which cite §60.56c(c)(4):

§60.37e(a)(2) of Subpart Ce: “… . Source subject to the emission limits 60.33e(a) and (a)(3) may, however, elect to use CO CEMS as specified under §60.56c(c)(4)…”

and §60.56c(c)(4) specifies a 24-hour block average. In the case of CO, for example, the same standard, 11 ppmv adjusted to 7% O2, applies to both new large HMIMI and those constructed prior to June 20, 1996. But the Federal Plan requires compliance with a 12-hour rolling average, while the New Source Performance Standard allows a 24-hour block average. Consequently, existing HMIWI, e.g., constructed prior to 1996 are subject to a more stringent standard than new HMIWI. This is certainly inconsistent and should be corrected one way or the other.



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(b) Must operate a CEMS to measure oxygen concentration, adjusting pollutant concentrations to 7 percent oxygen as specified in §60.56c(b)(5) or §62.14452(e) [Ref: §62.14452(o)(2)].

(c) Must operate all CEMS in accordance with the applicable procedures under appendices B

and F of 40 CFR part 60 [Ref: §62.14452(o)(3)].

(d) May substitute use of a CO CEMS for the CO annual performance test and minimum secondary chamber temperature to demonstrate compliance with the CO emissions limit.[Ref: §62.14452(o)(4)]

Although CO and O2 CEMS are installed, they are not currently required for compliance with the Federally enforceable emission limit for CO. The CO CEMS was originally a Permit to Construct requirement to determine compliance with a State-only enforceable emission limit of 100 ppmv arising out of State Air Toxics regulation COMAR 26.11.15.05. For Fort Detrick’s HMIWI, use of a CEMS for CO compliance with the Federal rule (in lieu of the required annual CO stack test) is optional if the CEMS are able to meet appendices B and F requirements for the October 6, 2009 CO standard. Permit condition 4.5.4 A(4) requires the Permittee obtain monitoring data at all times during HMIWI operation except during periods of monitoring equipment malfunction, calibration, or repair. At a minimum, valid monitoring data must be obtained for 75 percent of the operating hours per day and for 90 percent of the operating days per calendar quarter that the affected facility is combusting hospital waste and/or medical/infectious waste. [Authority: 40 CFR §62.14454(d) and 40 CFR §60.57c(e)] Permit condition 4.5.4 A(5) requires the Permittee to comply with the requirement to monitor the bypass stack by using the following alternative methodology, which the Department deems as an acceptable alternative to continuously recording the status of the bypass stack [Authority: 40 CFR §62.14454(b) and §60.57c(c)]: (a) The bypass stack must be equipped with guillotine dampers to prevent exhaust gases from

leaking out through the bypass stack. [Authority: conditions C(6), Permits to Construct 10-2-0066 & 0067 N issued on June 6, 1995].

(b) The incinerator is equipped with an interlock to the waste feed system to prevent the

loading of additional waste to the incinerator whenever the flue gases are diverted to the bypass stack. The bypass stack guillotine dampers are required to be equipped with limit switches to detect when the dampers are open. The incinerator is required to be equipped with an interlock device that will halt the ram feeders if the dampers are open. ” [Authority: C(7), Permits to Construct 10-2-0066 & 0067 N issued on June 6, 1995].

(c) The incinerator is equipped with an audible alarm that sounds and a control panel indicator

that displays a notification to the operator whenever the bypass stack is in use.



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(d) The operator is required to record in the daily operator log any use of the bypass stack

including date, time, and duration. Permit condition 4.5.4 A(6) requires the Permittee to continuously monitor and maintain the specified averages for the following operating parameters, 1-hour average and a 3-hour moving average, computed once each hour. The limits apply at all times except as noted in condition 4.5.4 A(7) below [Authority: condition E(6), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].

(a) Limit the 3-hour average HMIWI unit charge rate to no more than the maximum charge

rate (110 percent of the lowest 3-hour average charge rate measured during the most recent performance tests demonstrating compliance with all applicable emission limits).

(b) Maintain the 3-hour average rotary atomizing (collision) scrubber flow rate (GPM) and

amperage at least at 90 percent of the highest level established during the most recent performance tests for all applicable emission limits.

(c) Maintain the 3-hour average rotary atomizing scrubber pH at least at 90 percent of the

highest level established during the most recent performance test demonstrating compliance with the HCl emission limit.

(d) Maintain the 3-hour average secondary chamber temperature at least at 90 percent of

highest secondary chamber temperature established during the most recent performance test demonstrating compliance with the PM, CO, dioxin/furan, and NOx emissions limits [Ref: 40 CFR §60.51c]

(e) Continuously limit the carbon filter outlet temperature (T3) at least 15 ºF or more than the

rotary atomizing scrubber outlet temperature (T1) to prevent condensation.

(f) The carbon filter outlet temperature (T3) shall not exceed 80 ºC.3 (g) Limit the 3-hour average activated carbon adsorption system inlet temperature (T2), to no

more than 17 ºC (30.6 ºF) more than the lowest 3-hour average flue gas temperature (taken, at a minimum, once every minute), at the inlet to the carbon adsorption system at a position after the steam coil re-heating unit but before the particulate pre-filter , measured during the most recent performance test demonstrating compliance with the dioxin/furan (D/F) and mercury (Hg) emissions limit.

(h) Limit the 3-hour average differential pressure across the post-filter second section, rated at

MERV 12, or equivalent or better, as determined during the performance tests, to no more

3 Page3, letter from Robert P. Craig, Chief, Environmental Management Office, U.S. Army Garrison at Fort Detrick, MD to Ms. Diana Esher, Director, Air Protection Division, U.S. EPA Region III, dated March 24, 2014, “Petition for Site-Specific Operating Parameters for Hospital/Medical/Infectious Waste Incinerators.”



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than 0.5 inch WC greater than the highest level established during the most recent performance tests for dioxins/furans, PM, lead, cadmium, and mercury, or if this quantity is larger, 110 percent of the highest level established during the most recent performance tests for dioxins/furans, PM, lead, cadmium, and mercury.

(i) Record the pre-filter and post-filter specifications (Make, Model No., and MERV rating), at

every replacement period to demonstrate the operational use of replacement filters consistent with, or better than, those filters used during the most recent performance tests for PM, Pb, D/F Hg, and Cd.

(j) Limit the 3-hour average differential pressure drop across the activated carbon adsorption

unit to less than 7.2 inches WC. Permit condition 4.5.4 A(7) provides that the operating parameter limits stated in paragraphs 4.5.4 A(6)(a) through (d), (f), and (g) above do not apply during performance tests conducted to reestablish the operating parameter limits [Ref: 40 CFR §60.56c(d)(2)]. The operating parameter limits stated in paragraphs 4.5.4 A(6)(d) and (e) do not apply during startup, prior to the loading of the first charge to the HMIWI unit [Authority: condition E(7), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].

Permit condition 4.5.4 A(8) requires the Permittee to maintain a fixed bed activated carbon adsorption system totaling at least 3,800 pounds of activated carbon in each unit, and replace the entire amount of carbon with fresh carbon at intervals not to exceed 13 months, unless the Permittee can demonstrate to the satisfaction of the Department that a lesser replacement rate or a lesser amount of activated carbon will not lead to a violation of the emission standard for either dioxins/furans or mercury [Authority: condition D(5), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].

Permit condition 4.5.4 A(9) requires the Permittee to change the particulate pre-filter sections to the carbon adsorption unit each operating day, unless the pressure drop across the pre-filter section is less than 1.0 inch WC at the end of the operating day [Authority: condition D(6), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].

Permit condition 4.5.4 A(10) requires the Permittee to change the, MERV-8, or equivalent or better, first section to the post-filter each operating day, unless the pressure drop across that section is less than 1.0 inch WC at the end of the operating day [Authority: condition D(7), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].

Permit condition 4.5.4 A(11) requires the Permittee to change the MERV-12, or equivalent or better, second section of the post-filter when the pressure drop across that section cannot be maintained less than the following: (a) 0.5 inch WC more than the highest 3-hour average pressure differential established during the applicable performance tests, or if this quantity is larger, 110 percent of the highest 3-hour average pressure differential established during the applicable performance tests [Authority: condition D(8). Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].



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Rationale: permit conditions 4.5.4 A(9) – (11) assure that pressure drop will not become excessive due to particulate loading and lead to breaching of the particulate filter(s).

Permit condition 4.5.4 A(12) specifies the following surrogate indicators of compliance with emission limits for the HMIWI units [Authority: 40 CFR §60.56c(j); letter from Diana Esher, Director, Air Protection Division, USEPA Region III, dated April 22, 2014; page 17, Permit to Construct 021-0131-2-0066 and -2-0067 M issued on May 1, 2014]:

3Note: Permit to Construct erroneously specified “rotary atomizing scrubber amperage” rather than “rotary atomizing scrubber liquor flow rate,” which was specified by the previous Title V permit as well as §60.56c(f)(3)

Operating Parameter Violation(s) on 3-hour rolling averaged values

Related Pollutant Emission Violation(s)

1. Operation above the maximum charge rate and simultaneously below the minimum rotary atomizing scrubber amperage [Ref: §60.56c(f)(1)]

PM emission limit.

2. Operation above the maximum charge rate and simultaneously below the minimum secondary chamber temperature [Ref: §60.56c(f)(2)].

CO emission limit.

3. Operation above the maximum charge rate, below the minimum secondary chamber temperature, and below the minimum rotary atomizing scrubber liquor flow rate4 simultaneously [Ref: §60.56c(f)(3)]

Dioxin/furan emission limit.

4. Operation above the maximum charge rate, and below the minimum rotary atomizing scrubber liquor pH simultaneously [Ref: §60.56c(f)(4)].

HCl emission limit

5 . Operation above the maximum charge rate, the maximum rotary atomizing scrubber outlet temperature, and above the maximum activated carbon adsorption system inlet temperature simultaneously [Ref: §60.56c(e)(2) and §60.56c(f)(5)]

Dioxins/furans and mercury emission limits

6. Use of the bypass stack [Ref: §60.56c(f)(6)] . PM, dioxin/furan, HCl, Pb, Cd, and Hg emission limits

7. Minimum 30 ºF flue gas temperature rise across the steam reheat coil based on a 3-hour average of inlet versus outlet temperatures [i.e., T2 – T1 ≥ 30 ºF]

Dioxins/furans and mercury emission limits.

8. Operation above the maximum post-filter differential pressure (DP-4) [Ref: §60.56c(j)].

PM, dioxin/furan, Pb, and Cd, emission limits



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Note: Operational parameter requirements No. 1 through No. 4 and No 6. are from the existing Federal rule. Operational parameter requirements No. 5, No. 7, and No. 8 are new additions . The applicable State regulations addressing reporting and recordkeeping requirements are:

COMAR 26.11.08.08-1A(7): Reporting and Recordkeeping Requirements. A person who owns and operates an HMIWI subject this regulation shall report and maintain records in accordance with the requirements listed in 40 CFR §60.58c(b), (c), (d), (e), and (f) of subpart Ec, excluding 40 CFR §60.58c(b)(2)(ii) (fugitive emissions) and 40 CFR §60.58c(b)(7) (siting). COMAR 26.11.08.08-2B(6): Reporting and Recordkeeping Requirements. A person who owns and operates an HMIWI subject to §B of this regulation shall report and maintain records in accordance with the requirements listed in 40 CFR §60.58c(b) through (g) of subpart Ec, excluding 40 CFR §§60.58c(b)(2)(viii) and 40 CFR §60.58c(b)(2) (xvii), (b)(2)(xviii), and (b)(2)(xix).

Permit condition 4.5.5 A requires the Permittee to maintain for at least five (5) years and to make them available to the Department upon request, records of the following information, as applicable. [Authority: COMAR 26.11.08.08-2B(6), 40 CFR part 60, subpart Ec, §60.58c; and 40 CFR part 62, subpart HHH, §62.14460-62 condition F(1), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].

§60.58c(b)(1) Calendar date of each record;

§60.58c(b) (2) Records of the following data:

(i) Concentrations of any pollutant listed in § 60.52c or measurements of opacity as determined by the continuous emission monitoring system (if applicable);

(iii) HMIWI charge dates, times, and weights and hourly charge rates;

Note: §60.58c(b)(2)(ii), (iv) – (viii), (x), (xii ), (xviii) and (xix) and §60.58c(b)(7) do not apply to this facility.

(ix) Secondary chamber temperatures recorded during each minute of operation;

(xi) Horsepower or amperage and recirculated flow rate (GPM) to the rotary atomizing (wet) scrubber during each minute of operation, as applicable;

(xiii) Temperature at the outlet from the rotary atomizing (wet) scrubber during each minute of operation



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(xiv) pH at the inlet to the rotary atomizing (wet) scrubber during each minute of operation. (xv) Records indicating use of the bypass stack, including dates, times, and durations, and

(xvi) For affected facilities complying with §60.56c(j) and §60.57c(d), the owner or operator shall maintain all operating parameter data collected. The following applies:

(xvi)-1 Temperature of the flue gas leaving the wet scrubber at a point prior to the inlet of the steam reheat coil (T1), recorded once each minute.

(xvi)-2 Temperature of the flue gas at a point leaving the steam re-heat coil and entering the activated carbon adsorption system (T2), recorded once each minute

(xvi)-3 Temperature of the flue gas leaving the activated carbon adsorption system at a point located after the particulate matter post-filter (T3), recorded once each minute.

(xvi)-4 Temperature rise across the reheat coil (T2 – T1), recorded once each minute. (xvi)-5 Temperature rise across the add-on control system (T3 –T1), recorded once each minute. (xvi)-6 Pressure drop across the activated carbon adsorption unit, in inches WC (DP-2), recorded at least at 5 minute intervals. (xvi)-7 Pressure drop across each pre-filter section in inches WC (DP-1A and DP-1B), (if more than one section is installed) recorded at least at 5 minute intervals. (xvi)-8 Pressure drop across the post-filter first section in inches WC, (DP-3) recorded at least at 5 minute intervals. (xvi)-9 Pressure drop across the post-filter second section in inches WC, (DP-4) recorded at least at 5 minute intervals. (xvi)-10 The pre-filter and post-filter specifications (Make, Model No., and MERV rating), shall be recorded at every replacement period to demonstrate the operational use of replacement filters consistent with, or better than, those filters used during the most recent performance tests for PM, Pb, D/F Hg, and Cd. (xvi)-11 The activated carbon performance specifications (density, particle size, specific surface area (cm2/g ) from each activated carbon vendor. (xvi)-12 The amounts of activated carbon replaced, including the date and the hours of operation of the HMIWI unit since the previous replacement of carbon, including the vendor’s performance specifications.



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§60.58c(b)(3): Identification of calendar days for which data on emission rates or operating parameters specified under paragraph (b)(2) of §60.58c, have not been obtained, with an identification of the emission rates or operating parameters not measured, reasons for not obtaining the data, and a description of corrective actions taken. §60.58c(b)(4): Identification of calendar days, times and duration of malfunctions, a description of the malfunction and the corrective action taken. §60.58c(b)(5): Identification of calendar days for which data on emission rates or operating parameters specified under paragraph (b)(2) of §60.58c exceeded the applicable limits, with a description of the exceedances, reasons for such exceedances, and a description of corrective actions taken. §60.58c(b)(6): The results of the initial, annual, and any subsequent performance tests conducted to determine compliance with the emission limits and/or to establish operating parameters, as applicable, and a description, including sample calculations, of how the operating parameters were established or re-established, if applicable. §60.58c(b)(7) siting requirements documentation not required §60.58c(b)(11): Records of calibration of any monitoring devices as required under §60.57c (a), (b), and (c), Permit condition 4.5.6 A requires the Permittee to report to the Department and the EPA in accordance with the requirements listed in 40 CFR §60.58c(b) through (g), excluding 40 CFR §60.58c(b)(2)(viii) and 60.58c(b)(2)(xvii) and (b)(2)(xix) [Authority: COMAR 26.11.08.08-2B(6); 40 CFR part 62, subpart HHH, §62.14463-65].

Permit condition 4.5.6 A(1), in accordance with §60.58c(c), requires the Permittee to submit the information specified below no later than 60 days following the initial performance test. All reports must be signed by the facilities manager:5

(a) The initial performance test data as recorded under § 60.56c(b)(1) through (14), as applicable;

(b) The values of the site specific operating parameters established pursuant to

§60.56c(d), (h) or (j) as applicable.

5 40 CFR §60.58c(c) [§62.14463(a) and §62.14464(a)] The owner or operator of an affected facility shall submit the information specified in paragraphs (c)(1) through (c)(4) of this section no later than 60 days following the initial performance test. All reports shall be signed by the facilities manager.



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Note: For the September 15, 1997 standards §60.56c(d) is the applicable paragraph. For the October 6, 2009 standards, §60.56c(j) is the applicable paragraph. The Permittee complied with the initial testing reporting requirements for the September 15, 1997 standards. Permit condition 4.5.6 A(2), in accordance with §60.58c(d) – (e), requires the Permittee to submit semiannual reports no later than 60 days following the reporting period. The first semiannual reporting period ends 6 months following the submission of information in paragraph (c) of 40 CFR 60.58c. The semiannual report must include the information specified in paragraphs (d)(1) through (d)(9) and (d)(11) of 40 CFR 60.58c. Subsequent reports must be submitted no later than 6 calendar months following the previous report. All reports must be signed by the facilities manager. Note: The Permittee is subject to permitting requirements under Title V and must submit the reports required by 40 CFR §60.58c(d) [or §62.14464(b)] semiannually.6 (a) The values for the site-specific operating parameters established pursuant to

§60.56c(d), (h), or (j), as applicable [Ref: §60.58c(d)(1)]. (b) The highest maximum operating parameter and the lowest minimum operating

parameter, as applicable, for each operating parameter recorded for the calendar year being reported, pursuant to § 60.56c(d), (h), or (j), as applicable. [Ref: §60.58c(d)(2)]

(c) The highest maximum operating parameter and the lowest minimum operating

parameter, as applicable, for each operating parameter recorded pursuant to § 60.56c(d), (h), or (j) for the calendar year preceding the year being reported, in order to provide the Administrator with a summary of the performance of the affected facility over a 2-year period. [Ref: §60.58c(d)(3)]

(d) Any information recorded under paragraphs (b)(3) through (b)(5) of 40 CFR

60.58c, for the calendar year being reported. [Ref: §60.58c(d)(4)]

6 40 CFR §60.58c(d) [§62.14464(b)] An annual report shall be submitted 1 year following the submissions of the information in paragraph (c) of this section and subsequent reports shall be submitted no more than 12 months following the previous report (once the unit is subject to permitting requirements under title V of the Clean Air Act, the owner or operator of an affected facility must submit these reports semiannually). The annual report shall include the information specified in paragraphs (d)(1) through (11) of this section. All reports shall be signed by the facilities manager. 40 CFR §60.58c(e) [§62.14464(c)] The owner or operator of an affected facility shall submit semiannual reports containing any information recorded under paragraphs (b)(3) through (b)(5) of this section no later than 60 days following the reporting period. The first semiannual reporting period ends 6 months following the submission of information in paragraph (c) of this section. Subsequent reports shall be submitted no later than 6 calendar months following the previous report. All reports shall be signed by the facilities manager.



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(e) Any information recorded under paragraphs (b)(3) through (b)(5) of 40 CFR 60.58c, for the calendar year preceding the year being reported, in order to provide the Administrator with a summary of the performance of the affected facility over a 2-year period. [Ref: §60.58c(d)(5)]

(f) If a performance test was conducted during the reporting period, the results of that

test. [Ref: §60.58c(d)(6)] (g) If no exceedances or malfunctions were reported under paragraphs (b)(3) through

(b)(5) of 40 CFR §60.58c, for the calendar year being reported, a statement that no exceedances occurred during the reporting period. [Ref: §60.58c(d)(7)].

(h) Any use of the bypass stack, the duration, reason for malfunction, and corrective

action taken. [Ref: §60.58c(d)(8)]. (i) Concentrations of CO determined by a CO CEMS, if the Permittee elects to

determine compliance with the CO emission limit using a CEMS [Ref: §60.58c(d)(11)] .

B. Waste Management Plan. COMAR 26.11.08.08-1A(3) requires preparation of a Waste Management Plan that meets the requirements of 40 CFR §60.55c, subpart Ec.

40 CFR §60.55c The waste management plan shall identify both the feasibility and the approach to separate certain components of solid waste from the health care waste stream in order to reduce the amount of toxic emissions from incinerated waste. A waste management plan may include, but is not limited to, elements such as paper, cardboard, plastics, glass, battery, or metal recycling; or purchasing recycled or recyclable products. A waste management plan may include different goals or approaches for different areas or departments of the facility and need not include new waste management goals for every waste stream. It should identify, where possible, reasonably available additional waste management measures, taking into account the effectiveness of waste management measures already in place, the costs of additional measures, the emission reductions expected to be achieved, and any other environmental or energy impacts they might have. The American Hospital Association publication entitled ``An Ounce of Prevention: Waste Reduction Strategies for Health Care Facilities'' (incorporated by reference, see §60.17) shall be considered in the development of the waste management plan.

COMAR 26.11.08.08-2B(3) requires preparation of a Waste Management Plan that meets the requirements of 40 CFR §60.55c, subpart Ec (as amended October 6, 2009) and requires that a revised waste management plan be submitted within 60 days of completion of the initial compliance tests required under regulation COMAR 26.11.08.08-2.



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Compliance Demonstration Permit condition 4.6.6 B requires the Permittee to submit a revised waste management plan as specified in §60.55c, signed by the facilities manager, no later than 60 days following the initial performance tests required under regulation COMAR 26.11.08.08-2 [Authority: COMAR 26.11.08.08-2B(3) and 40 CFR §60.58c(c)(3)]. The Permittee has submitted a Waste Management Plan required by COMAR 26.11.08.08-1A(4) and the Waste Management Plan is kept in the Department’s files. In accordance with COMAR 26.11.08.08-2B(3)(c), a revised Waste Management Plan must be submitted within 60 days after completion of the required initial compliance tests under regulation COMAR 26.11.08.08-2. C. Equipment and Control Device Inspection Requirements. COMAR 26.11.08.08-2D [ §§62.14440 – 62.14443] Initial and Annual Equipment and Control Device Inspections (1) COMAR 26.11.08.08-2D(1)-(3) specifies the initial and subsequent annual inspection

requirements that each HMIWI undergo beginning June 15, 2012 and that all necessary repairs be completed within 10 operating days unless otherwise approved by the Department. The inspections shall include as a minimum the following [Ref: §62.14442(a)]:

(a) Inspect all burners, pilot assemblies, and pilot sensing devices for proper operation and

clean pilot flame sensor, as necessary; (b) Ensure proper adjustment of primary and secondary chamber combustion air, and

adjust as necessary; (c) Inspect hinges and door latches, and lubricate as necessary; (d) Inspect dampers, fans, and blowers for proper operation; (e) Inspect HMIWI door and door gaskets for proper sealing; (f) Inspect motors for proper operation; (g) Inspect primary chamber refractory lining; clean and repair or replace lining as

necessary; (h) Inspect incinerator shell for corrosion or hot spots, or both; (i) Inspect secondary/tertiary chamber and stack and clean as necessary;



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(j) Inspect mechanical loader, including limit switches, for proper operation, if applicable; (k) Visually inspect waste bed (grates), and repair or seal, as appropriate; (l) For the burn cycle that follows the inspection, document that the incinerator is

operating properly and make any necessary adjustments; (m) Inspect air pollution control device or devices for proper operation, if applicable; (n) Inspect waste heat boiler systems to ensure proper operation, if applicable; (o) Inspect bypass stack components; (p) Ensure proper calibration of thermocouples, sorbent feed systems and any other

monitoring equipment; (q) Include inspection elements according to manufacturer’s recommendations [Ref:

§62.14442(a)(17)]; and (r) Generally observe that the equipment is maintained in good operating condition.

(2) COMAR 26.11.08.08-2D(4)-(5) specifies that beginning June 15, 2012, the control devices

of an HMIWI shall undergo an initial and subsequent annual inspections that include the following [Ref: §62.14442(b)]:

(a) Inspect air pollution control device(s) for proper operation; (b) Ensure proper calibration of thermocouples, sorbent feed systems, and any other

monitoring equipment; (c) Include inspection elements according to manufacturer’s recommendations [Ref:

§62.14442(b)(3)]; (d) Generally observe that the equipment is maintained in good operating condition;

and (e) Within 10 operating days following an air pollution control device inspection, all

necessary repairs shall be completed unless the owner or operator obtains written approval from the Department establishing a date whereby all necessary repairs of the designated facility shall be completed.




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Permit condition 4.5.5C requires the Permittee to maintain equipment inspection records for at least five (5) years and to make available to the Department upon request, records of the following information [Authority: COMAR 26.11.08.08-2B(6); 40 CFR part 62, subpart HHH, §62.14460-62; and condition F(1), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].


§60.58c(b(2)(xvii) Records of the annual air pollution control device inspections, any required maintenance and any repairs not completed within 10 days or the timeframe established by the EPA Administrator or the Department upon delegation of authority.

§62.14460(14) Records of the annual equipment inspections, any required maintenance and any repairs not completed within 10 days or the timeframe established by the EPA Administrator or the Department upon delegation of authority. Permit condition 4.5.6 C requires the Permittee to include in the semiannual reports referenced in 4.5.6 A(2) records of the annual equipment and air pollution control device inspection, any required maintenance, and any repairs not completed within 10 days of an inspection or the timeframe established by the EPA Administrator or the Department [Authority: §60.58c(d)(9) and §62.14463(12) –(13)]. D. Operator Training Requirements. 40 CFR §62.14420: “You must have a fully trained and qualified operator, either at your facility or able to be at your facility within 1 hour. The trained and qualified HMIWI operator may operate the HMIWI directly or be the direct supervisor of one or more HMIWI operators.”

40 CFR §62.14421(a): “ The HMIWI operator can obtain training and qualification through a State-approved program or as provided in paragraph (b) of this section” COMAR 26.11.08.09B and C requires that the owner certify to the Department that the incinerator operator has completed the proper training and review courses and is present at all times whenever the incinerator is in operation, and also specifies the specific training course and course requirements for the incinerator operator. Compliance Demonstration Permit condition 4.5.5 D(1) requires the Permittee keep the following records on site for at least 5 years: §60.58c(b)(1) Calendar date of each record;



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§60.58c(b)(8) Records showing the names of HMIWI operators who have completed review of the information in §60.53c(h) as required by §60.53c(i), including the date of the initial review and all subsequent annual reviews.

§60.58c(b)(9) Records showing the names of the HMIWI operators who have completed the operator training requirements, including documentation of training and the dates of training;

§60.58c(b)(10) Records showing the names of the HMIWI operators who have met the criteria under §60.53c and the dates of their qualification; and Permit condition 4.5.5 D(2) requires the Permittee to maintain documentation of training (operator training manual) on site and update the documentation annually at the time of the annual review course. The documentation must be as specified in 40 CFR §60.53c(h). [Ref: COMAR 26.11.08.09C(5)] E. Plan for Compliance with the October 6, 2009 HMIWI Emission Standards The Permittee shall comply with the following milestones based on the Plan for Compliance submitted by the Permittee and as subsequently amended and specifying a final compliance date of October 6, 2014 in accordance with 40 CFR part 60, subpart Ce, §60.39e and COMAR 26.11.08.08-2E(2); 40 CFR part 62, subpart HHH, §62.14470(b), [Authority: COMAR 26.11.08.08-2E(2) and COMAR 26.11.03.06C]:

Award contracts for control systems or process modifications or orders for purchase of components and; submit a signed copy of the contract(s) to the Department; Initiate on-site construction or installation of the air pollution control devices; Complete on-site construction or installation of control equipment or process changes; By October 6, 2014, achieve final compliance. This includes incorporating all process changes and/or completing all retrofit construction as described in the final control plan, connecting the air pollution control equipment or process changes such that the HMIWI is brought on line, and ensuring that all necessary process changes and air pollution control equipment are operating properly;

By 180 days after October 6, 2014, demonstrate final compliance with the October 6, 2009 emission limits by conducting an initial performance test meeting 40 CFR §60.58c(b) requirements demonstrating final compliance with the October 6, 2009 limit; and By 45 days after completing an initial performance test , submit an initial report including the results of the performance tests. Compliance Demonstration



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Permit condition 4.5.6 E requires the Permittee to provide monthly progress reports to the Department, due within 10 business days after the end of the calendar month, on the control implementation as stated in the Plan for Compliance. The reports shall include dates and projected dates for interim activities, such as ordering control devices, site preparation, initial startup, and initial compliance tests [Authority: condition E(1), Permit to Construct 021-0131-2-0066 and -0067 M, issued on May 1, 2014]. The deadline for completing the initial performance tests is April 4, 2015. The initial report of the performance test results demonstrating final compliance must be submitted to the Department no later than May 19, 2015. F. Inapplicable Requirements under 40 CFR part 60 subpart Ec or 40 CFR part 62 subpart

HHH. The following requirements under 40 CFR §60.56c -§60.58c do not apply to the HMIWI emission units for the reasons indicated: 40 CFR §60.56c(b)(12) …determine compliance with the fugitive ash emission limit - Not applicable to existing sources falling under 40 CFR 60.32e(a).

40 CFR §60.56c(c)(3) For large HMIWI determine compliance with the visible emissions limits for fugitive emissions - Not applicable to existing sources falling under 40 CFR 60.32e(a)]

40 CFR §60.56c(e) Except as provided in paragraph (i) of this section, for affected facilities equipped with a dry scrubber followed by a fabric filter … - Not applicable since the facility does not continuously inject dry sorbent to achieve compliance with the dioxins/furans, HCl, or Hg emission limits. 40 CFR §60.56c(f) Except as provided in paragraph (i) of this section, for affected facilities equipped with a wet scrubber: … This paragraph is no longer applicable because the facility employs additional add-on control devices. 40 CFR §60.56c(g) Except as provided in paragraph (i) of this section, for affected facilities equipped with a dry scrubber followed by a fabric filter and a wet scrubber… . Not applicable since the facility does not continuously inject dry sorbent to achieve compliance with the dioxins/furans, HCl, or Hg emission limits The following monitoring requirements under 40 CFR §60.57c do not apply to these HMIWI installation for the reasons indicated: 40 CFR §60.57c(a) “Except as provided in §60.56c(c)(4) through (c)(7), the owner or operator of an affected facility shall install, calibrate (to manufacturers' specifications), maintain, and operate devices (or establish methods) for monitoring the applicable maximum and minimum operating parameters listed in Table 3 to this subpart (unless CEMS are used as a substitute for certain parameters as specified) such that these devices (or methods) measure and record values for these operating parameters at the frequencies indicated in Table 3 of this subpart at all times.” The HMIWI units no longer fit any of the control



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device categories specified in Table 3 and do not fall under any of the exceptions provided in §60.56c(c)(4) through (c)(7). , 40 CFR §60.57c(b) “ The owner or operator of an affected facility … that uses selective noncatalytic reduction technology shall install, calibrate (to manufacturers' specifications),… Not applicable. The HMIWI units do not use selective reduction control technology to control NOx emissions 40 CFR §60.57c(h) For affected facilities … that … determine compliance with the PM emissions limit using a bag leak detection system …. Not applicable since the HMIWI units do not employ a bag leak detection system. The following recordkeeping requirements under 40 CFR §60.58c do not apply to these HMIWI units for the reasons indicated: 40 CFR §60.58c(a) is not applicable to existing sources falling under 40 CFR 60.32e(a). 40 CFR §60.58c(b)(2)(ii), (v)-(vii), and (xii) are not applicable for the reasons indicated below:

(ii) Results of fugitive emissions (by EPA Reference Method 22) - Not applicable, since fugitive emissions observations are not required of installations qualifying as an existing source under 40 CFR 60.32e(a). (v) Amount and type of dioxin/furan sorbent used during each hour of operation, as applicable - Although the Permittee does employ dry dioxin/furan sorbent (activated carbon) the sorbent is not continuously injected but consists of an activated carbon bed, which must be periodically replaced based on performance testing approved by the Department. (vi) Amount and type of Hg sorbent used during each hour of operation, as applicable - Although the Permittee does employ dry Hg sorbent (activated carbon) the sorbent is not continuously injected but consists of an activated carbon bed, which must be periodically replaced based on performance testing approved by the Department. (vii) Amount and type of HCl sorbent used during each hour of operation, as applicable - Not applicable since the Permittee does not employ a dry HCl sorbent. (xii) Pressure drop across the wet scrubber system during each minute of operation, as applicable - Not applicable, since the Permittee records the wet scrubber horsepower or amperage and the pressure drop is not an appropriate parameter for this type of wet scrubber

40 CFR §60.58c(b)(7) All documentation produced as a result of the siting requirements of §60.54c - Not applicable, since the Permittee is not subject to the siting requirements.

40 CFR §60.58c(d) (10) For affected facilities as defined in §60.50c(a)(3) and (4), records of each bag leak detection system alarm, the time of the alarm, the time corrective action was initiated and completed, and a brief description of the cause of the alarm and the corrective action taken, as applicable. …. Not applicable since the HMIWI units do not employ a bag leak detection system.



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7. EMISSION UNITS B1 and B4: Two (2) small municipal waste combustion units, ECP Model 2500T, each rated at 39 ton/day and each equipped with an emissions control system and heat recovery boiler, located in Bldg. 393.

Emission Units B1 and B4 were first registered with the Department in 1975. The incinerators use natural gas as auxiliary fuel, with No. 2 fuel oil for backup. The units were originally designated as general refuse waste incinerators and nominally rated at 2,000 pounds per hour. Each incinerator is equipped with two primary chamber burners and one secondary chamber burner with venturi scrubbers and cyclonic separators for air pollution control, and operate as starved-air units. Each incinerator is equipped with two waste heat recovery boilers. The emissions control system for these incinerators is being extensively redesigned in order to achieve compliance with the Federal Plan for Small Municipal Waste Combustion Units Constructed on or Before August 30, 1999, 40 CFR 62 Subpart JJJ. The control system on each incinerator will include a quench tower, a rotary atomizing (wet) scrubber, a demister, a fixed bed carbon adsorption system (chiefly for mercury and dioxins/furans emissions control) , and two final stages of HVAC-type fiber filters for control of particulates. Because of the very stringent control requirements being proposed by EPA at the time on municipal waste combustion units with capacities less than 35 tons per day, Fort Detrick contracted with MACTEC to reexamine the issue of the throughput capacity size and appropriate size category of the incinerators. Owing to the age of the incinerators and the fact that that manufacturer was no longer in business the rated capacity was not precisely known. On the basis of physical dimensions of the primary and secondary chambers, burner sizes, blower capacity, etc. MACTEC determined the actual capacity for MSW to be at least 39 tons per day (for 5,000 Btu/lb waste), bringing them into the Small Municipal Waste Combustion Unit category (i.e., 35 tons per day or larger, but less than 250 tons per day). The incinerators qualify as ‘Class II’ incinerators since the facility-wide total capacity for MSW is less than 250 tons per day. EPA concurred with the Fort Detrick’s determination that these incinerators are subject to the provisions of Subpart JJJ Federal Plan. However, the final compliance date for the Federal plan, May 5, 2005, had already passed. Stack testing done during January - February 2006 showed that the units were out of compliance with the Subpart JJJ by a factor 2 for dioxins/furans and lead and a factor of 3 for cadmium and particulate matter. More effective emission controls were clearly required. With respect to compliance with Subpart JJJ operating requirements, a problem arises because the incinerators will use a rotary atomizing (wet) scrubber and fixed-bed activated carbon system to control dioxins/furans and mercury emissions, rather than a baghouse and continuous injection of activated carbon powder. The Department was required to obtain EPA approval of variances from Subpart JJJ requirements relating to the use of activated carbon to control dioxins/furans and mercury emissions. ARMA submitted the request on March 11, 2008 to EPA Region III. EPA’s approach was to write alternative Subpart JJJ provisions applicable exclusively to Fort Detrick. EPA’s approval to alternative Subpart JJJ requirements was given, subject to the



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condition that the provisions be incorporated into the Title V permit (letter from Judith M. Katz, Director, Air Protection Division, EPA Region III to MDE, dated January 14, 2009). The EPA approval included alternative Subpart JJJ requirements for monitoring and limiting the liquor pH of the acid gas scrubbing system, the pressure drops across the carbon adsorption system, and the HVAC-type filter system, the flue gas temperature exiting carbon adsorption system, and electric current (amperes) to the rotary atomizing scrubber, a surrogate for the scrubber liquor flow rate and pressure drop across a venturi scrubber. A Consent Order agreement was completed between the U.S. Army Garrison at Fort Detrick and the Maryland Department of the Environment signed by Fort Detrick on October 12, 2007 and the Department on October 22, 2007. The Consent Order provided milestone dates for coming into compliance with all requirements by no later than December 31, 2010. In August 2012, stack testing was conducted on the B1 and B4 Municipal Waste Combustion (MWC) Units. The Department reviewed the stack test report and found Fort Detrick to be in compliance with the limits for the tested pollutants. In addition, Fort Detrick correctly established surrogate indicators of compliance using the methodology described in the Part 70 Permit. APPLICABLE STANDARDS and LIMITATIONS

COMAR 26.11.08.04A(1) The Permittee may not cause or permit the discharge of emissions from any incinerator or hazardous waste incinerator, other than water in an uncombined form, which is greater than 20 percent opacity. COMAR 26.11.08.04C allows the following exceptions. COMAR 26.11.08.04A does not apply to emissions during start-up, or adjustments or occasional cleaning of control equipment: (1) the visible emissions are not greater than 40 percent opacity; and (2) the visible emissions do not occur for more than 6 consecutive minutes in any 60 minute period. COMAR 26.11.08.07 A person may not operate a municipal waste combustor that has a burning capacity of 35 tons or more per day and less than or equal to 250 tons per day that was constructed on or before August 30, 1999 which results in violation of the provisions of 40 CFR 62 Subpart JJJ. §62.15165 What happens to the emission limits during periods of startup, shutdown, and malfunction? §62.15165 provides that the emission limits from 40 CFR 62 Subpart JJJ apply at all times except during periods of municipal waste combustion unit startup, shutdown, or malfunction. Each startup, shutdown, or malfunction must not last for longer than 3 hours. A maximum of 3 hours of test data can be dismissed from compliance calculations during periods of startup, shutdown, or malfunction. During startup, shutdown, or malfunction periods longer than 3 hours, emissions data cannot be discarded from compliance calculations and all provisions under § 60.11(d) of subpart A of 40 CFR part 60 apply. All concentrations are adjusted to 7 percent oxygen, dry basis.



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Pollutant

Standard


A1.

Opacity

10 percent

Thirty 6-minute averages (annual test) EPA Method 9. Ref: Table 4

A2.

Fugitive ash

Visible emissions for no more than 5 percent of hourly observation period.

Three 1-hour observation periods (annual test) EPA Method 22. Ref: Table 4

B.

Particulate Matter

70 milligrams per dry standard cubic meter

Stack test, 3-run average (run duration specified in test method) Ref: Table 4

C.

Carbon Monoxide

50 parts per million by dry volume

4-hour block average, arithmetic mean determined by CEM. Ref: Table 5

D.

Nitrogen Oxides

500 parts per million by dry volume

24-hour daily block arithmetic average (no monitoring required) Ref: Table 4

E.

Sulfur Dioxide

77 parts per million by dry volume or 75 percent reduction of potential sulfur dioxide emissions

24-hour daily block geometric average concentration determined by CEM. Ref: Table 4.

F.

Lead

1.6 milligrams per dry standard cubic meter

Stack test, 3-run average (run duration specified in test method)

Compliance Demonstration with Visible Emissions/Opacity Emission Limits Permit condition 4.6.3 A(1) requires the Permittee to conduct initial and annual Method 9 observations for opacity of stack emissions at intervals less than 13 months. The Permittee must use a 3-hour observation period (thirty 6-minute averages). The results of the observations of opacity must be used to demonstrate compliance with the applicable emission limits in Table 4, 40 CFR Part 62, Subpart JJJ. (cf. Table 8, 40 CFR Part 62, Subpart JJJ). Permit condition 4.6.3 A(2) requires the Permittee to conduct initial and annual Method 22 observations for fugitive ash at intervals less than 13 months. The Permittee shall make the three 1-hour observation periods for fugitive ash. The observations must include periods when the facility transfers fugitive ash from the municipal waste combustion unit to the area where the fugitive ash is stored or loaded into containers or trucks. The Permittee must use results of the



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observations of fugitive ash to demonstrate compliance with the applicable emission limits in Table 4, 40 CFR Part 62, Subpart JJJ. [Authority: §§62.15230 through §62.15255, 40 CFR Part 62, Subpart JJJ]. The ARMA Compliance Program reports that the Permittee has made the required annual Method 9 and Method 22 visible emissions observations on each MWC. The required annual performance tests were conducted during the period 08/13-08/23 /2012 and 09/16-09/25/2013 The MWC’s were found to be in compliance with the allowable emission limits. Permit condition 4.6.4 A(1)(a) requires the Permittee, no later than December 31, 2009, to install and commence continuous operation of each continuous opacity monitoring system (COMS) according to of 40 CFR part 60, subpart A §60.13 [Authority: Permit to Construct 021-0131-2-0049 & -0050 issued on January 30, 2009]. Permit condition 4.6.4 A(1)(b) requires the Permittee, no later than December 31, 2015, to complete an initial evaluation of the COMS according to Performance Specification 1 in Appendix B of 40 CFR Part 60 [Authority: § 62.15170(d) and §62.15215, 40 CFR Part 62, Subpart JJJ, and Permit to Construct 021-0131-2-0049 & -0050 issued on January 30, 2009]. Permit condition 4.6.4 A(1)(c) requires the Permittee to use the required span values and applicable performance specifications in Table 7 of Subpart JJJ. Note: Table 7 specifies a span value of 100 percent opacity and Performance Specification 1, Appendix B, 40 CFR Part 60. Table 7 also specifies alternate methods for collecting data when these systems malfunction or when repairs, calibration checks, or zero and span checks keep you from collecting the minimum amount of data [Authority: § 62.15220 and § 62.15225, 40 CFR Part 62, Subpart JJJ]. Compliance Demonstration with Carbon Monoxide (CO) and Sulfur Dioxide (SO2) Emission Limits.

Permit conditions 4.6.3 C and E require the Permittee to perform initial, daily, quarterly and annual evaluations of the Continuous Emissions Monitoring Systems (CEMS) for CO and SO2 Permit condition 4.6.4 C-E(1) requires the Permittee to use any of the quality assurance procedures specified in Appendix F to test the CEMs once each calendar quarter. The Permittee shall have a Relative Accuracy Test Audit (RATA), in accordance with Appendix F of 40 CFR Part 60 performed on each CEM at least once per calendar year [Authority: §60.13 of Subpart A of 40 CFR Part 60]. Permit condition 4.6.4 C-E(2) requires the Permittee, by December 31, 2009, the Permittee to install and commence continuous operation CEMS for carbon monoxide, sulfur dioxide, and oxygen meeting 40 CFR Part 62, Subpart JJJ requirements stated in §§62.15170 through 62.15225 [Authority: Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009]



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Permit condition 4.6.4 C-E(3) requires the Permittee, by June 30, 2010, to complete an initial evaluation of each CEM meeting the requirements of §62.15175(b), §§62.15185 through 62.15200 [Authority: §62.15170 - 62.15225, 40 CFR Part 62, Subpart JJJ and Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009]. USAG Fort Detrick conducted an initial evaluation of the CO and SO2 CEMS during April 6-12 2010. A relative accuracy test audit (RATA) was conducted for CO and SO2 during March 18 -21, 2011. The RATA results were reviewed by the ARMA Compliance Program and were found to be acceptable.

Compliance Demonstration with Nitrogen Oxides (NOx) Emission Limits. Permit conditions 4.6.3 D requires the Permittee, by December 31, 2016 , to conduct a stack test to determine compliance with the NOx emission limit on at least one emission unit using the appropriate Appendix A methods or other procedures approved in writing by the Department. Unless otherwise approved by the Department, the stack test must consist of three runs of at least one hour duration. A stack test protocol must be submitted to the Department at least 30 days prior to the anticipated date of the stack test and the stack test results must be submitted to the Department within 60 days of completion of the stack test [Authority: COMAR 26.11.03.06C(3)]. Note that 40 CFR part 62, subpart JJJ does not require any periodic monitoring or testing for the NOx standard for Class II units. G. Control of Non-Criteria Pollutant Emissions Limits

All concentrations adjusted to 7 percent oxygen, dry basis Pollutant Standard Compliance Demonstration G1.

Dioxins/furans (total mass basis)

125 nanograms per dry standard cubic meter.

Stack test. 3- run average, (minimum run duration is 4 hours)

G2.

Cadmium

0.10 milligrams per dry standard cubic meter.


G3.

Mercury

0.080 milligrams per dry standard cubic meter. or 85 percent reduction of potential mercury emissions




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Pollutant Standard Compliance Demonstration G4.

Hydrogen Chloride

250 parts per million by dry volume or 50 percent reduction of potential hydrogen chloride emissions

Stack test, 3-run average (minimum run duration is 1 hour)

Compliance Demonstration with Particulate Matter, Lead, and Non-Criteria Pollutant Emission Limits. Permit condition 4.6.3 B requires the Permittee to conduct an initial stack test for particulate matter and subsequent annual stack tests, meeting the requirements of §§62.15230 through 62.15255, 40 CFR Part 62, Subpart JJJ. See discussion below [Authority: §§62.15230 through 62.15255, 40 CFR Part 62, Subpart JJJ]. Permit condition 4.6.3 G(1) (from the Permit to Construct) requires the Permittee to conduct initial stack tests on both MWC units to establish compliance with all emission limitations in 40 CFR Part 62, Subpart JJJ no later than December 31, 2010. Each stack test must be performed in accordance with the requirements of 40 CFR §§62.15230, 62.15235, 62.15240(b), 62.15245, and alternative requirements 62.15240(a) and (c) approved by EPA [Authority: condition E(4), Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009]. Permit condition 4.6.3 G(2) requires the Permittee to conduct initial and annual (at intervals less than 13 months) stack tests for dioxins/furans (total mass), cadmium, lead, mercury, and hydrogen chloride. The test shall be completed in accordance with §§62.15230 through 62.15255. [Authority: 40 CFR Part §§ 62.15230 through 62.15255]. Permit condition 4.6.3 G(3) specifies the following EPA approved Federal Plan 40 CFR 62 Subpart JJJ Rule Provision Alternatives for §62.15240(a) and (c) for the U.S. Army (Owner/Operator) Fort Detrick Facility. Additionally, condition E(5), Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009, requires the Permittee to perform the annual stack test for dioxins/furans and mercury in accordance with the following timing requirements:

(a) No later than 13 months after the previous stack test, in accordance with §62.15240(b);

(b) Within the period 60 days prior to the replacement of the activated carbon in the

adsorption system in accordance with alternative requirement §62.15240(c); and (c) Condition (b) above may be waived by the Department if the replacement of

activated carbon is deferred beyond the 13 month period in accordance with §62.15145(d).



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[Italics = 40 CFR part 62 subpart JJJ text amended by EPA for USAG Fort Detrick]

§62.15145 What are the operating practice requirements for my municipal waste combustion unit? … (d) [Revised] Maintain a fixed bed activated carbon adsorption system, consisting of two beds, totaling at least 2,800 pounds of activated carbon. Replace the entire amount of carbon with fresh activated carbon at intervals not to exceed 13 months unless the owner/operator can demonstrate to the satisfaction of the Maryland Department of the Environment and EPA Administrator that a lesser replacement rate will not lead to a violation of the emissions standard for either dioxins/furans or mercury

§62.15240 What schedule must I follow for the stack testing? (a) Conduct initial stack tests for the pollutants listed in §62.15230 by 180 days after your final compliance date. [Added.] Also, conduct an initial stack test after installation of the rotary atomizer wet scrubber and fix bed carbon filtration system in order to demonstrate compliance with all emission limitations under part 62, subparts JJJ and V. The test shall be completed within 180 days after completion of control equipment installation or by December 31, 2010, whichever date is earlier. (b) Conduct annual stack tests for these pollutants after the initial stack test. Conduct each annual stack test no later than 13 months after the previous stack test. (c) [Added.] Except for the initial performance test with the rotary atomizer wet scrubber and fixed bed carbon adsorption system under paragraph (a), perform the annual stack tests for dioxins/furans and mercury within the period 60 days prior to replacement of the activated carbon in the adsorption system, as required in §62.15145 (d).

See Part 70 Permit, 4.6.3 G(3) for complete text of §§62.15245 – 62.15255, which are unchanged from the original rule and address the following:

§62.15245 What test methods must I use to stack test? §62.15250 May I conduct stack testing less often? §62.15255 May I deviate from the 13-month testing schedule if unforeseen circumstances arise?

Permit condition 4.6.3 H requires the Permittee to determine the maximum or maximum value as appropriate of each parameter limit identified § 62.15145(a)-(c) as revised for the Fort Detrick facility and as defined in § 62.15410 as revised for the Fort Detrick facility during the appropriate initial or annual compliance stack tests required 4.6.3 G. The continuous parameter monitoring requirements for particulate matter, lead, and non-criteria pollutants are covered by permit conditions 4.6.4 H(1)-H(4) which are discussed in the next section.



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The required annual performance tests were conducted during the periods 08/13-8/23/2012 and 09/16 - 9/25/2013 The MWC’s were found to be in compliance with the allowable emission limits. In addition, USAG Fort Detrick correctly established surrogate indicators of compliance using the methodology described in their Part 70 permit. Results from the stack test reports received by MDE on 02/26/2013 and 01/13/2014 concerning stack testing conducted during the periods from 08/13 – 08/23/2012 and 09/16 – 09/25/2013 are given below:

Pollutant Units Standard* Incinerator B1 Incinerator B4

Test dates (mo/yr) 08/2012 09/2013 08/2012 09/2013

Opacity % 10% 0% <10% 0% <10%

Fugitive ash % 5% 0% <5% 0% <5%

PM mg/dscm 70 6.3 14.1 8.5 19.2

Lead (Pb) mg/dscm 1.6 0.04 0.15 0.11 0.25 Dioxins/furans (total mass) **

ng/dscm 125 0.48 0.95 0.51 …

Cadmium (Cd) mg/dscm 0.10 0.01 0.02 0.01 0.02

Mercury (Hg) mg/dscm 0.080 0.00017 0.00005 0.00024 0.00022

HCl ppm(v) 250 0.2 0.48 0.1 0.40 *Adjusted to 7 percent O2 dry gas. ** D/F was performed only on B1 in 2013. USAG Fort Detrick emission rate is well below the 30 ng/dscm specified by §62.15250(b). H. Operational Limitations from 40 CFR Part 62 Subpart JJJ Permit Condition 4.6.2 H(1) requires the Permittee, by no later than December 31, 2009, to install and commence continuous operation of the quenching and acid gas absorption towers, rotary atomizing scrubbers, the carbon adsorption systems, and continuous emission monitoring systems (CEMS) to monitor opacity, sulfur dioxide, carbon monoxide and oxygen, and other such modifications and control technology as is necessary to achieve compliance with the emission standards of 40 CFR 62, Subpart JJJ. The CEMS must be installed in accordance with 40 CFR 62, Subpart JJJ [Authority: conditions C(2) and D(2), Permit to Construct 021-0131-2-0049 & - 0050, issued on January 30, 2009].

Permit Condition 4.6.2 H(2) requires the Permittee, by no later than December 31, 2010, to be in compliance with all applicable operating requirements of 40 CFR Part 62, Subpart JJJ, including the alternative requirements approved by the EPA Administrator in accordance with §62.15405 [Authority: letter from Judith M. Katz, Director, Air Protection Division, U.S. EPA Region III and attached Federal Plan Subpart JJJ Rule Provision Alternatives for the U.S. Army (Owner/Operator) Ft. Detrick Facility, dated January 14, 2009; condition D(3), Permit to Construct 021-0131-2-0049 & - 0050, issued on January 30, 2009].



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Permit Condition 4.6.2 H(3) requires the Permittee to maintain the specified block averages for the following operating parameters [Authority: condition D(5), Permit to Construct 021-0131-2-0049 & -0050 issued on January 30, 2009]. (1) Maintain the 4-hour block average rotary atomizing scrubber amperage at least at 90

percent of the highest level established during the most recent performance tests for all §129 pollutants [Ref: Alternative requirement §62.15145(c)(2) and §62.15410].

(2) Maintain the 4-hour block average rotary atomizing scrubber pH at least at 90 percent of

the highest level established during the most recent performance test demonstrating compliance with the HCl emission limit [Ref: Alternative requirement §62.15145(c)(1) and §62.15410].

(3) Limit the 4-hour block averages of the rotary atomizing scrubber inlet temperature and

activated carbon adsorption system inlet temperature to no more than 17ºC (30.6ºF) above the highest level established during the most recent performance test demonstrating compliance with either the dioxins/furans or mercury emission limits, whichever is lower [Ref: Alternative requirements §62.15145(b) and §62.15145(c)(3)-(4) and the corresponding §62.15410 definitions].

(4) Limit the 4-hour block average activated carbon adsorption system outlet temperature to no

more than 110 percent of the highest level established during the most recent performance test demonstrating compliance with either the dioxins/furans or mercury emission limits, whichever is lower. However, in no case shall the 4-hour block average activated carbon adsorption system outlet temperature exceed 155 ºF or 68 ºC [Ref: Alternative requirements §62.15145(b) and §62.15145(c)(5) and the corresponding §62.15410 definitions].

(5) Limit the 4-hour block average differential pressure across the carbon adsorption system to

no more than 0.5 inches or water column greater than the highest level established during the most recent performance tests for dioxins/furans and mercury, or if this quantity is larger, 110 percent of the highest level established during the most recent performance tests for dioxins/furans and mercury [Ref: Alternative requirement §62.15145(c)(6) and the corresponding §62.15410 definition].

(6) Limit the 4-hour block average differential pressure across the HVAC grade pre-filter and

HVAC grade post-filter each to no more than 0.5 inches of water column greater than the highest level established during the most recent performance tests for dioxins/furans, PM, lead, cadmium, and mercury, or if this quantity is larger, 110 percent of the highest level established during the most recent performance tests for dioxins/furans, PM, lead, cadmium, and mercury [Ref: Alternative requirement §62.15145(c)(7)-(8) and the corresponding §62.15410 definition].



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(7) Comply with §62.15145(a) by not operating the municipal waste combustion unit at loads greater than 110 percent of the maximum demonstrated load of the municipal waste combustion unit as defined in §62.15410.

(8) In keeping with alternative condition §62.15145(e) approved by EPA, parts (a)-(g) above do not apply during the stack tests for particulate matter, dioxins/furans, or mercury emissions.

Permit Condition 4.6.2 H(4), in keeping with alternative requirement §62.15145(d) approved by EPA, requires the Permittee to maintain a fixed bed activated carbon adsorption system, consisting of two beds, totaling at least 2800 pounds of carbon and replace the entire amount of carbon with fresh carbon at intervals not to exceed 13 months, unless the Permittee can demonstrate to the satisfaction of the Department and the EPA Administrator that a lesser replacement rate will not lead to a violation of the emission standard for either dioxins/furans or mercury [Authority: condition D(6), Permit to Construct 021-0131-2-0049 & -0050 issued on January 30, 2009]. Permit Condition 4.6.2 H(5) states approved Federal Plan Subpart JJJ Rule Provision Alternatives for the U.S. Army (Owner/Operator) Ft. Detrick Facility, dated January 6, 2009. Letter from Judith M. Katz, Director, Air Protection Division, U.S. EPA Region III, dated January 14, 2009.

[Added.] Indicates a new or additional requirement has been added to the original subpart JJJ requirement

[Revised.] Indicates the original subpart JJJ requirement has been revised or amended. Amended §62.15410 Alternative Definitions were provided by EPA for these emission units.

§62.15410 Definitions [Added.] Maximum demonstrated load of a municipal waste combustion unit means the highest 4-hour block arithmetic average municipal waste combustion unit load achieved during 4 consecutive hours in the course of the most recent dioxins/furans stack test that demonstrates compliance with the applicable emission limit for dioxins/furans specified in [Subpart JJJ]. Maximum demonstrated temperature of the particulate matter control device means the highest 4-hour block arithmetic average flue gas temperature measured at the inlet of the particulate matter control device during 4 consecutive hours in the course of the most recent stack test for dioxins/furans emissions that demonstrates compliance with the limits specified in [Subpart JJJ].

The terms Maximum demonstrated load and Maximum demonstrated temperature of the particulate matter control device are unchanged from 40 CFR part 62, subpart JJJ, §62.15410.



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[Added.] Minimum rotary atomizing scrubber liquor pH means: 90 percent of the highest 4-hour average liquor pH at the inlet to the scrubber (taken, at a minimum, once every minute) measured during the most recent performance test demonstrating compliance with the HCl emission limit. [Added.] Minimum rotary atomizing scrubber pump flow rate (or rotary atomizing scrubber amperage) means: 90 percent the highest 4-hour average rotary atomizing scrubber liquor flow rate at the outlet of the pump (or rotary atomizing scrubber amperage) taken, at a minimum, once every minute, measured during the most recent performance test demonstrating compliance with all 129 pollutant emission limits. [Added.] Maximum activated carbon adsorption system exhaust temperature means: 110 percent of the highest 4-hour average system outlet temperature (Fahrenheit) measured during the most recent performance test demonstrating compliance with either the dioxins/furans limit or mercury emission limits, whichever is lower. In no case shall the exhaust temperature exceed 155 degrees Fahrenheit or 68 º Centigrade (4-hour average). [Added.] Maximum activated carbon adsorption system differential pressure means: The greater differential pressure determined during the most recent performance test demonstrating compliance with either the emission limitation for dioxins/furans, or mercury as determined by a consideration of the following: (a) 0.5 inch of water column (WC) more than the highest 4-hour average system differential pressure (inches WC) measured during the performance tests, or (b) 110 percent of the highest 4-hour average differential pressure (inches WC) determined during the performance tests. In no case shall the differential pressure exceed 7.2 inch WC . [Added.] Industrial Heating, Ventilating and Air Conditioning (HVAC) grade filter system means: A filter system utilizing fiber particulate filters similar in design and function to a HVAC grade filter that is located after the activated carbon adsorption system and consists of two stages, a pre-filter for intercepting large diameter particles followed by a post-filter for intercepting small diameter particles down to 1.0 micron in size. [Added.] Maximum pre-filter differential pressure means: The greater differential pressure determined during the most recent performance test demonstrating compliance with the emission limitations for dioxins/furans, particulate matter, lead, cadmium, and mercury, as determined by consideration of the following: (a) 0.5 inch of water column (WC) more than the highest 4-hour average pre-filter differential pressure (inches WC) measured during the performance tests, or (b) 110 percent of the highest 4-hour average differential pressure (inches WC) determined during the performance tests. [Added.] Maximum post-filter differential pressure means: The greater differential pressure determined during the most recent performance test demonstrating compliance with the emission limitations for dioxins/furans, particulate matter, lead, cadmium, and mercury as determined by consideration of the following: (a) 0.5 inch of water column (WC) more than the highest 4-hour average post-filter differential pressure (inches WC) measured during the performance tests or (b) 110 percent of the highest 4-hour average differential pressure (inches WC) determined during the performance tests. [Added.] Bypass stack means: A device used for discharging combustion gases to avoid severe damage to the air pollution control device or other equipment.



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§62.15145 What are the operating practice requirements for my municipal waste combustion unit? (a) You must not operate your municipal waste combustion unit at loads greater than 110 percent of the maximum demonstrated load of the municipal waste combustion unit (4-hour block average), as specified under ``Definitions'' (§62.15410). (b) [Revised.] You must not operate your MWC unit so that the temperature at the inlet of the particulate control device, except for the Industrial Heating, Ventilating and Air Conditioning (HVAC) filter system described in §62.15145(f), exceeds 17 0 C (Centigrade) above the maximum demonstrated temperature of the particulate matter control device (4-hour block average), as specified under “Definitions”, §62.15410. (c) [Added.] For a MWC unit that uses a quench tower, rotary atomizing scrubber, and fixed activated carbon bed, and a HVAC grade filter system to control acid gases, heavy metals, and dioxins/furans, you must maintain a 4-hour block average for the following nine operating parameter levels, as defined in §62.15410, as amended below:

(1) Minimum rotary atomizing scrubber liquor pH; (2) Minimum rotary atomizing scrubber pump flow rate or minimum rotary atomizing scrubber amperage (The owner/operator must identify either flow rate or amperage as the operating parameter with submittal of the initial compliance test report.); (3) Maximum rotary atomizing scrubber inlet temperature; (4) Maximum activated carbon adsorption system inlet temperature; (5) Maximum activated carbon adsorption system exhaust temperature (6) Maximum activated carbon adsorption system differential pressure; (7) Maximum differential pressure across the pre-filter; (8) Maximum differential pressure across the post-filter; and (9) Maximum demonstrated load of the MWC unit.

The following surrogate indicators of compliance with emission limitations were specified in the alternative monitoring approval by EPA: Operating Parameter Violation(s) Related Pollutant Emission Violation(s)

1. Minimum rotary atomizing scrubber liquor pH

HCl

2. Minimum rotary atomizing scrubber pump flow rate or rotary atomizing scrubber amperage

All 129 pollutants, except CO, NOx, and SO2

3. Maximum rotary atomizing scrubber inlet temperature plus 17 ºC *

Dioxins/furans and mercury

4. Maximum activated carbon adsorption system inlet temperature plus 17 ºC *


5. Maximum activated carbon adsorption system exhaust temperature**




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Operating Parameter Violation(s) Related Pollutant Emission Violation(s)

6. Maximum activated carbon adsorption system differential pressure


7. Maximum pre-filter differential pressure. Dioxins/furans, PM, lead, cadmium, and mercury

8. Maximum post-filter differential pressure. Dioxins/furans, PM, lead, cadmium, and mercury

9. Maximum demonstrated load of the MWC unit times 1.1

All 129 pollutants

(d) [Revised] Maintain a fixed bed activated carbon adsorption system, consisting of two beds, totaling at least 2,800 pounds of activated carbon. Replace the entire amount of carbon with fresh activated carbon at intervals not to exceed 13 months unless the owner/operator can demonstrate to the satisfaction of the Maryland Department of the Environment and EPA Administrator that a lesser replacement rate will not lead to a violation of the emissions standard for either dioxins/furans or mercury (e) [Revised] Your municipal waste combustion unit is exempt from limits on load level, temperature at the inlet of the particulate matter control device (.e., the rotary atomizing scrubber) , during any of five situations:

(1) During your annual tests for dioxins/furans. (2) [not applicable.] (3) During the 2 weeks preceding your annual tests for dioxins/furans. (4) [not applicable.] (5) Whenever the Administrator permits you to do any of five activities:

(i) Evaluate system performance. (ii) Test new technology or control technologies. (iii) Perform diagnostic testing. (iv) Perform other activities to improve the performance of your municipal waste combustion unit. (v) Perform other activities to advance the state of the art for emission controls for your municipal waste combustion unit.

(f) [Added.] The §62.15145(c) pre and post filter differential pressure operational requirements, parameters 7 and 8, will not be considered an indicator of SMWC unit compliance for a listed pollutant, except for particulate matter, providing the owner/operator demonstrates through three consecutive annual performance tests, as required under §62.15240, that each SMWC unit, when operating without the use of the HVAC grade pre-filter and post filter system, can achieve compliance with the emission standard for either dioxins/furans, lead, cadmium, or mercury. This provision is applicable only to the SMWC unit and pollutant for which compliance has been demonstrated for three consecutive annual performance tests.

§62.15150 What happens to the operating requirements during periods of startup, shutdown, and malfunction? (a) The operating requirements of [Subpart JJJ] apply at all times except during periods of municipal waste combustion unit startup, shutdown, or malfunction.



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(b) Each startup, shutdown, or malfunction must not last for longer than 3 hours.

Compliance Demonstration with 40 CFR Part 62 Subpart JJJ Operational Limits. Permit condition 4.6.3 H. requires the Permittee to determine the maximum or maximum value as appropriate of each parameter limit identified § 62.15145(a)-(c) as revised for the Fort Detrick facility and as defined in § 62.15410 as revised for the Fort Detrick facility during the appropriate initial or annual compliance stack tests required by permit conditions 4.7.3 G(1) – (2). Permit condition 4.6.4 H(1) specifies the following EPA approved Federal Plan Subpart JJJ Rule Provision Alternatives for §62.15260(b) and (c) for the U.S. Army (Owner/Operator) Fort Detrick Facility. Note that amended rules §62.15275 and §62.15280 cited in permit conditions 4.6.4 H(4) and 4.6.4 H(5) require 4-hour block averages as well as 1-hour averages.

§62.15260 What other requirements must I meet for continuous monitoring ? The owner/operator shall obtain 1-hour arithmetic averages for the following parameters:

(a) Load level of each municipal waste combustion unit. (b) [Revised.] The temperature of the flue gases at the inlets of the following particulate matter control devices:

(1) The rotary atomizing scrubber; and (2) The activated carbon adsorption system.

(c) [Revised] Record the dates and amounts of activated carbon replaced and the hours of operation of the MWC unit since the previous replacement of carbon (d) [Added.] The rotary atomizing scrubber pump flow rate or rotary atomizing scrubber amperage. (e) [Added.] The rotary atomizing scrubber inlet temperature; (f) [Added.] The pH of the recirculation rotary atomizing scrubber solution; and (g) [Added.] The activated carbon adsorption system exhausts temperature, and system differential pressure. (h) [Added.] The HVAC grade pre-filter differential pressure (inch water column); and (i) [Added.] The HVAC grade post-filter differential pressure (inch water column).



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Permit condition 4.6.4 H(2) provides that the Permittee must install, calibrate, maintain, and operate a steam flowmeter meeting the requirements of §62.15265(a). In the event of failure of the steam monitoring system, or if steam production is discontinued, the Permittee may, on approval by the Department, continuously monitor the feed rate of municipal solid waste (MWS) in accordance with §62.15265(b) by:

(a) Weighing on a calibrated scale each increment of MWS and recording in an automatic

data processing system the weight of MSW increment measured adjusting for the tare weight of the container;

(b) Recording the time into the automatic data processing system that the MSW increment

is loaded into the incinerator; (c) Employing an automatic data processing system that, from the data entered, calculates

and records 1–hour block and 4-hour block averages of the weight of MSW loaded; and

(d) Calibrating the equipment according to the manufacturer instructions before each

dioxins/furans stack test, or at least once a year.

(e) Have determined the maximum demonstrated load as defined in §62.15410 in terms of the mass rate of MSW combustion during the most recent dioxins/furans stack test.

§62.15265 How do I monitor the load of my municipal waste combustion unit? (a) If your municipal waste combustion unit generates steam, you must install, calibrate, maintain, and operate a steam flowmeter or a feed water flowmeter and meet five requirements: (1) Continuously measure and record the measurements of steam (or feed water) in kilograms per hour (or pounds per hour). (2) Calculate your steam (or feed water) flow in 4-hour block averages. (3) Calculate the steam (or feed water) flow rate using the method in “American Society of Mechanical Engineers (ASME PTC 4.1—1964): Test Code for Steam Generating Units, Power Test Code 4.1-1964 (Reaffirmed 1991),” section 4. The Director of the Federal Register approves this incorporation by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. You may obtain a copy from the American Society of Mechanical Engineers, Service Center, 22 Law Drive, Post Office Box 2900, Fairfield, NJ 07007. You may inspect a copy at the Office of Air Quality Planning and Standards Air Docket, EPA, 109 T.W. Alexander Drive, Room C521C, RTP, NC 27709 or at the National Archives and Records Administration (NARA). For information on the availability of this material at NARA, call 202-741-6030, or go to: http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html.



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(4) Design, construct, install, calibrate, and use nozzles or orifices for flow rate measurements, using the recommendations in “American Society of Mechanical Engineers Interim Supplement 19.5 on Instruments and Apparatus: Application, Part II of Fluid Meters”, 6th Edition (1971), chapter 4. The Director of the Federal Register approves this incorporation by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. You may obtain a copy from the American Society of Mechanical Engineers, Service Center, 22 Law Drive, Post Office Box 2900, Fairfield, NJ 07007. You may inspect a copy at the Office of Air Quality Planning and Standards Air Docket, EPA, 109 T.W. Alexander Drive, Room C521C, RTP, NC 27709 or at the National Archives and Records Administration (NARA). For information on the availability of this material at NARA, call 202-741-6030, or go to: http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html. (5) Before each dioxins/furans stack test, or at least once a year, calibrate all signal conversion elements associated with steam (or feed water) flow measurements according to the manufacturer instructions. (b) If your municipal waste combustion unit does not generate steam, or, if your municipal waste combustion units have shared steam systems and steam load cannot be estimated per unit, you must determine, to the satisfaction of the Administrator, one or more operating parameters that can be used to continuously estimate load level (for example, the feed rate of municipal solid waste or refuse-derived fuel). You must continuously monitor the selected parameters.

Permit condition 4.6.4 H(3) requires the Permittee, in accordance with §62.15270, for each incinerator to continuously monitor the flue gas temperature at the inlet of each particulate matter control device:

§62.15270 How do I monitor the temperature of flue gases at the inlet of my particulate matter control device? You must install, calibrate, maintain, and operate a device to continuously measure the temperature of the flue gas stream at the inlet of each particulate matter control device.

Permit condition 4.6.4 H(4) specifies the following EPA approved Federal Plan Subpart JJJ Rule Provision Alternatives for §62.15275 (a), (b), and (c) for the U.S. Army (Owner/Operator) Fort Detrick Facility.

§62.15275 [Revised.] How do I monitor operations of the rotary atomizer wet scrubber and fixed bed carbon filtration system? The owner/operator shall: (a) [Revised.] Select, during the initial or annual compliance test, a rotary atomizer operating parameter, either rotary atomizing scrubber pump flow rate or rotary atomizing scrubber amperage, as an indicator of compliance; (b) [Revised.] Within 48 hours before each dioxins/furans and mercury stack test, verify the amount [volume or weight (cubic feet, pounds)] of activated carbon in each fixed bed; and



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(c) [Revised.] Continuously monitor the §62.15145(c) operating parameters during all periods when the municipal waste combustion unit is operating and combusting waste and calculate the 1-hour and 4-hour arithmetic block averages, excluding hours when the unit is in a shutdown, startup, or malfunction mode of operation.

Permit condition 4.6.4 H(5) specifies the following EPA approved Federal Plan Subpart JJJ Rule Provision Alternatives for §62.15280(a) for the U.S. Army (Owner/Operator) Fort Detrick Facility:

§62.15280 What minimum amount of monitoring data must I collect with my continuous parameter monitoring systems and is this requirement enforceable?

The owner/operator shall:

(a) Where continuous parameter monitoring systems are used, obtain 1-hour and 4-hour block arithmetic averages for the following parameters:

(1) Load level of the municipal waste combustion unit. (2) [Revised.] Temperature of the flue gases at the inlet of each of the particulate control devices – rotary atomizer and activated carbon adsorption system. (3) [Revised.]

(i) The pH of the rotary atomizing scrubber solution; (ii) The rotary atomizing scrubber pump flow rate (or rotary atomizing scrubber amperage); (iii) The rotary atomizer scrubber inlet temperature; (iv) The carbon adsorption system exhaust temperature; and (v) The carbon adsorption system differential pressure (i.e., inches water column). (vi) The pre-filter differential pressure (inch water column); and (vii) The post-filter differential pressure (inch water column).

(b) Obtain at least two data points per hour in order to calculate a valid 1-hour arithmetic average. (c) Obtain valid 1-hour averages for at least 75 percent of the operating hours per day for 90 percent of the operating days per calendar quarter. An operating day is any day the unit combusts any municipal solid waste or refuse-derived fuel. (d) If you do not obtain the minimum data required in paragraphs (a) through (c) of this section, you are in violation of this data collection requirement and you must notify the Administrator according to §62.15340(e).

Permit condition 4.6.3 A-H(1) requires the Permittee to conduct all testing at a reasonable time and with at least seven (7) days in notice in advance for each stack test and keep the Department informed of any circumstances that may lead to a change in the test date [Authority: COMAR 26.11.03.06C and condition E(6)(b) , Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009].



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Permit condition 4.6.3 A-H(2) requires the Permittee to submit a stack test protocol to the Department at least 30 days prior to the anticipated date of any emissions stack test to determine compliance with this permit [Authority: COMAR 26.11.03.06C and condition E(6)(a), Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009] Permit condition 4.6.3 A-H(3) requires the Permittee to submit a report detailing the stack test results, all pertinent operating data, and all other information required by 40 CFR §60.8 and §62.15245 within 60 days after the stack testing is complete [Authority: condition E(7), Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009]. Permit conditions 4.6.5 A-H(1) – (5) require the Permittee to maintain on site for at least five (5) years, and must make available to the Department upon request, all records of the information required by 40 CFR Part 62, Subpart JJJ as modified by EPA for the Fort Detrick facility. EPA has approved alternative requirements for the following paragraphs [Authority: 40 CFR part 62, subpart JJJ; condition F(1), Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009]:

§62.15285(d) activated carbon specifications and usage data §62.15300(c) monitored pollutants and parameters §62.15310(a)(1)-(3) carbon feed rate. §62.15310(a)(4) quarterly carbon purchase records §62.15310(a)(5) required quarterly usage of carbon §62.15310(b) records of low carbon feed rates §62.15310(c) missing carbon feed rate data

Permit conditions under 4.6.6 A-H(1) – (5) require the Permittee to submit all initial, semiannual, and annual reports required by, and in accordance with 40 CFR Part 62, Subpart JJJ as modified by the EPA for the Fort Detrick facility. EPA has approved alternative requirements for the following paragraphs [Authority: condition G(1), Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009] :

§62.15325 Initial report, due date for §62.15330(a) (revised) §62.15330(f) Initial report – carbon feed rates during initial stack test. §62.15340(d) (revised) §62.15355(c) Semiannual out-of-compliance reports – carbon.

The initial report required by §62.15325(a) was required to be submitted no later than March 2, 2011. In accordance with §62.15325(b), the initial compliance stack test report required after installation of the rotary atomizing scrubber and fixed bed carbon adsorption system was required to be submitted within 60 days after completion of the test required under §62.15240(a) [Authority: condition G(2), Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009] .



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Currently, USAG Fort Detrick has successfully completed three consecutive comprehensive annual stack tests on units B1 and B4. USAG Fort Detrick’s first stack tests with the carbon beds fully operational and which demonstrated compliance were conducted during the period 13-23 August 2012. Subsequent stack tests for all the required pollutants were conducted during the periods 16-25 September 2013 and 8-16 September 2014. The Department reviewed the stack test reports and found USAG Fort Detrick to be in compliance with all the emission limits. Additionally, USAG Fort Detrick correctly established surrogate indicators of compliance using the methodology described in their Part 70 permit. Compliance with permit condition 4.6.4 A(1), which requires an initial evaluation of the COMS, is still pending. See remarks under Compliance Schedule section. I. Operator Training Requirements - 40 CFR §62.15100 – 140 and COMAR 26.11.08.09A,

and COMAR 26.11.09.08J(2), (3), and (5)

COMAR 26.11.08.09B Certification and Operation. A person may not operate or allow an incinerator to be operated unless the owner certifies to the Department on a form approved by the Department that the incinerator operator: (1) has completed an initial training course approved by the Department which meets the requirements of COMAR 26.11.08.09D; (2) annually, after initial certification, completes a review course approved by the Department; (3) is present at all times whenever the incinerator is in operation

COMAR 26.11.08.09D Training Course Requirements:

(1) For any incinerator operator who operates a municipal waste combustor (MWC), the training course shall address the following subjects in detail [Authority: COMAR 26.11.08.09D(1)]: (a) Overall operation, maintenance, and performance of the facility; (b) Start-up and shut-down of the facility; (c) Applicable federal, State, and local environmental regulations, and sanctions for

violations; (d) Policies and procedures for proper and safe plant operation; (e) Maintaining records of facility operations; (f) Actions to correct upsets or emergencies; (g) Control room operations; (h) Ash handling and disposal; (i) Combustion theory; (j) Air pollution control technology; and (k) Continuous emission monitors and their calibration, and quality assurance

requirements.

(2) For the operator of any municipal waste combustor (MWC) completing a training course means: (a) completing an initial training course approved by the Department of at least 5



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days (40 hours) duration; (b) passing a written test approved by the Department [Authority: COMAR 26.11.08.09D(2)].

(3) (not applicable) (4) The certified operator shall, after initial training, complete and pass an annual review course

approved by the Department of at least 1 day (8 hours) duration [Authority: COMAR 26.11.08.09D(4)].

COMAR 26.11.09.08J(2), (3) and (5) – NOx RACT Training Requirements.

(1) Prepare and implement a written in-house training program for all operators that includes instruction on good operating and maintenance practices;

(2) Maintain and make available to the Department upon request the written in-

house training program; (3) Maintain operator training records at the site for at least 2 years and make

these records available to the Department. 40 CFR part 62, subpart JJJ, §62.15100 through §62.15140.

The Permittee is subject to the operator training and certification requirements stated in 40 CFR Part 62, Subpart JJJ, which include paragraphs 40 CFR Part 62, Subpart JJJ requirements §62.15100 through §62.15140. 40 CFR part 62, subpart JJJ addresses the following operator training requirements: §62.15100 What types of training must I do? There are two types of required training: §62.15105 Who must complete the operator training course? By when? §62.15110 Who must complete the plant-specific training course? §62.15115 What plant-specific training must I provide §62.15120 What information must I include in the plant-specific operating manual? §62.15125 Where must I keep the operating manual? §62.15130 What types of operator certification must the chief facility operator and shift supervisor obtain and by when must they obtain it? §62.15135 After the required date for operator certification, who may operate the municipal waste combustion unit? §62.15140 What if all the certified operators must be temporarily offsite? Compliance Demonstration with Operator Training Requirements



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The Permittee must comply with all applicable operator training requirements of COMAR 26.11.08.09D as well as those stated in 40 CFR §62.15100 through §62.15140. With regard to the plant-specific operator training and the plant specific operating manual required by §62.15110 - §62.15125, the Department recognizes that the site-specific training given of each type employee may be limited to training appropriate to the employee’s respective areas of responsibility which affect the operation of the municipal waste combustion unit. For example, the training given ash handlers, or load handlers would not include the same topics as maintenance personnel, shift supervisors, or the chief facility operator. The deadlines stated in §62.15105(b), §62.15115, §62.15130(b) and (d) had already passed at the time of installation of the control equipment. In accordance with the Consent Order and the Permit to Construct issued for the control equipment, the Permittee was required to comply with these deadlines no later than December 31, 2010 [Authority: condition C(3), Permit to Construct No. 021-2-0049 and -0050, issued on January 30, 2009]. 40 CFR 62 Subpart JJJ, §62.15130 addresses certification requirements for chief facility operators and shift supervisors. Each chief facility operator and shift supervisor must obtain and maintain a current provisional operator certification from either the American Society of Mechanical Engineers QRO-1-1994 or a State certification program in Connecticut and Maryland. If ASME certification is chosen, the Permittee must proceed in accordance with ASME QRO-1-1994 Standard for the Qualification and Certification of Resource Recovery Facility Operators. Additionally, each chief facility operator and shift supervisor must either obtain full certification or schedule a full certification exam with the American Society of Mechanical Engineers (QRO-1-1994). In the case of full certification, §62.15130(c) omits the reference to the State certification program although the reference to a State certification program was included under the recordkeeping provisions §62.15295(b). Additionally, the New Source Performance Standard for small MWC, 40 CFR Part 60, Subpart AAAA, §60.1185 provides for full certification by a State program of chief facility operators and shift supervisors. Maryland does have a State certification program and there does not appear to be a good reason for this omission. For this reason additional language to the Part 70 permit was added to allow for State full certification as well as provisional certification. In the Annual Compliance Certification Report dated April 16, 2013 regarding conditions 4.6.1a, 4.6.2a meet operator certification and training requirements (identified as being in intermittent compliance) USAG Fort Detrick stated: “Operators are present at all times when the MWC is in operation. Records of training certificates are maintained for 5 years and provided to MDE. MDE determined in 2011 that Fort Detrick’s training did not meet all requirements of COMAR 26.11.08.09D for approved training courses. Owner developed an in-house training program, which was approved by MDE in September 2012. The approved training was implemented in October 2012.”.



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J. Limit on the Combustion of Hospital, Medical and Infectious Waste (HMIW) The Permittee shall limit the combustion of hospital waste and/or medical /infectious waste with municipal solid waste to 10 percent or less of the weight of which is comprised, in aggregate, of hospital waste and medical/infectious waste as measured on a calendar quarter basis [Authority: 40 CFR 60 Subpart Ec, §60.50c(c)] Compliance Demonstration Prior to combusting any amount of HMIW in the MWC units, the Permittee is required to notify the EPA Administrator of an exemption claim and provide an estimate of the relative amounts of hospital waste, medical/infectious waste, and other fuels and wastes to be combusted. The Permittee is required to maintain records on a calendar quarter basis of the weight of hospital waste and medical/infectious waste (HMIW) combusted, and the weight of all other fuels and wastes combusted at the co-fired combustor necessary to demonstrate compliance with the 10 percent HMIW limit [Authority: 40 CFR 60 Subpart Ec, §60.50c(c)]. The Permittee has not combusted any amount of HMIW in these emission units. COMAR 26.11.09.08J - Requirements for Industrial Furnaces and Other Miscellaneous Installations that Cause Emissions of NOx. A person who owns or operates any installation other than fuel-burning equipment that causes NOx emissions shall:

(1) Maintain good operating practices as recommended by the equipment vendor to

minimize NOx emissions;


(3) Maintain and make available to the Department upon request the written in-house

training program;

(4) Burn natural gas, where natural gas is available, during the period May 1 through September 30 of each year; and

(5) Maintain operator training records at the site for at least 2 years and make these records available to the Department.

Compliance Demonstration. The Permittee maintains a copy of the good operating practices, a copy of the in-house training program, a record of the type of fuel burned in the summer months, operator training attendance records for each operator on site. The Permittee must submit for review the in-house training program for NOx and the records of operator training attendance to the Department upon request.



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8. EMISSION UNITS C1 and C2: Two (2) 993 kW diesel fuel oil-fired generators,

Alban and Caterpillar, located in Bldg. 1425.

C3 thru C6: Four (4) 2,000 kW diesel fuel oil-fired generators, Williams and Lane, located in Bldg. 1673.

C7: 900 kW emergency diesel generator, located in Bldg 1420

C8: 880 kW emergency diesel generator, located in Bldg 1414

C9: 1000 kW emergency diesel generator, located in Bldg. 1414.

C10: 2000 kW emergency diesel generator, located in Bldg. 1425.

C13: 511 kW emergency diesel generator, located at Bldg. 810.

There are 11 diesel-fired emergency diesel generators, rated from 511 – 2,000 kW . These emergency generators provide backup power to key facilities and operations at Fort Detrick in the event of a power outage. No control equipment is currently used on these units. Emission units C1 and C2 were installed in January 1985 (after-the-fact registration applications were submitted in August 1997). Emission units C3 through C6 were registered after-the-fact in October 1991 and installed during the period April 1985 to September 1987. Emission unit C7 was installed in May 1996 (an after-the-fact Permit to Construct was issued on September 1, 2000). Emission unit C8 was installed in December 2001 (a permit to construct 10-9-0155 N was issued in February 2001). Permits to Construct 021-9-0202 N and 021-9-0205 N were issued for C9 and C10 in 2004. Emission unit C13 was installed in September 1988 and brought into the registration system with the change in regulation COMAR 26.11.02.10E adopted November 24, 2003 that lowered the registration threshold from 1000 to 500 brake horsepower. APPLICABLE STANDARDS and LIMITATIONS Visible Emissions Limitations COMAR 26.11.09.05E(2), which prohibits the discharge of emissions from any engine, operating at idle, greater than 10 percent opacity, except as allowed under COMAR 26.11.09.05E(4). COMAR 26.11.09.05E(3), which prohibits the discharge of emissions from any engine, operating at other than idle conditions, greater than 40 percent opacity, except as allowed under COMAR 26.11.09.05E(4). COMAR 26.11.09.05E(4) provides that COMAR 26.11.09.05E(2) does not apply for a period of 2 consecutive minutes after a period of idling of 15 minutes for the purpose of clearing the



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exhaust system. COMAR 26.11.09.05E(2) does not apply to emissions resulting directly from cold engine start-up and warm-up for the following maximum periods: (a) engines that are idled continuously when not in service: 30 minutes; (b) all other engines: 15 minutes. COMAR 26.11.09.05E(2) and E(3) do not apply while maintenance, repair, or testing is being performed by qualified mechanics. Compliance Demonstration These units are emergency generators that operate a few hours each year. No periodic monitoring will be required. However, the Permittee is required to report incidents of visible emissions in accordance with the requirements of Permit Condition 4, Section III of the permit, “Report of Excess Emissions and Deviations.”

Control of Sulfur Oxides COMAR 26.11.09.07A(1)(c), which prohibits the burning of any distillate fuel with a sulfur content by weight in excess of 0.3 percent.

40 CFR part 63, subpart ZZZZ, §63.6604(b), beginning January 1, 2015, limits the diesel fuel sulfur content to 15 ppm maximum if an engine operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in §63.6640(f)(2)(ii) and (iii)

§63.6640(f)(2)(ii): Operation for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see §63.14), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3. §63.6640(f)(2)(iii): Operation for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency.

Compliance Demonstration The Permittee must obtain a certification from the fuel supplier indicating that the oil complies with the limitation on the sulfur content of fuel oil. The Permittee shall retain fuel supplier certifications of sulfur content in fuel. The Permittee shall report fuel supplier certifications of sulfur content in fuel to the Department upon request. The basis for these monitoring, record keeping, and reporting requirements is the Department's authority to create periodic monitoring requirements, COMAR 26.11.03.06C. Control of Nitrogen Oxides Emissions



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COMAR 26.11.09.08G(1) -Requirements for Fuel-Burning Equipment with a Capacity Factor of 15 Percent or Less - a person who owns or operates fuel-burning equipment with a capacity factor (as defined in 40 CFR Part 72.2) of 15 percent or less shall:

(a) Provide certification of the capacity factor of the equipment to the Department in writing;

(b) For fuel-burning equipment that operates more than 500 hours during a calendar year, perform a combustion analysis and optimize combustion at least once annually;

(c) Maintain the results of the combustion analysis at the site for at least 2 years and make these results available to the Department and the EPA upon request;

(d) Require each operator of an installation, except combustion turbines, to attend operator training programs at least once every 3 years, on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and

(e) Maintain a record of training program attendance for each operator at the site and make these records available to the Department upon request.

COMAR 26.11.09.08B(5) states that; (a) for the purpose of COMAR 26.11.09.08, the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation; and (b) that the operator training course sponsored by the Department shall include an in-house training course that is approved by the Department.

Compliance Demonstration The Permittee monitors and retains records of the hours of operation of each installation on a monthly basis and calculate the capacity factor of the installation at the end of each month and determine whether an installation’s operations exceeded the 15 percent capacity factor on a rolling 12 month basis. The capacity factor typically does not exceed 2 percent and the hours of operation of any individual installation have been well under 500 hours per year. The Permittee must submit a certification of the annual capacity factor for each engine with the annual emissions certification report. The Permittee must retain records of training program attendance for each operator at the site and must submit a list of operator training upon request [Authority: COMAR 26.11.09.08G(1) and COMAR 26.11.03.06C]. Operational Standards.



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(1) The Permittee shall combust only No. 2 diesel fuel oil unless the Permittee applies for and receives an approval or permit from the Department to burn alternative fuels [Authority: COMAR 26.11.02.09A].

(2) The Permittee shall comply with the applicable requirements of 40 CFR part 63, subpart ZZZZ, §63.6603, Table 2d; §63.6604(b); §63.6605; §63.6625(e), (f), and (h); and §63.6640(f) :

§ 63.6603 What emission limitations, operating limitations, and other requirements must I meet if I own or operate an existing stationary RICE located at an area source of HAP emissions? §63.6603(a). If you own or operate an existing stationary RICE located at an area source of HAP emissions, you must comply with the requirements in Table 2d to this subpart and the operating limitations in Table 2b to this subpart that apply to you. §63.6603(b) through (f) - apply only to non-emergency engines.

TABLE 2b TO SUBPART ZZZZ OF PART 63—OPERATING LIMITATIONS FOR … EXISTING CI STATIONARY RICE >500 HP

Table 2b requirements: (No applicable Table 2b requirements for existing CI emergency engines at area sources).

TABLE 2d TO SUBPART ZZZZ OF PART 63—REQUIREMENTS FOR EXISTING STATIONARY

RICE LOCATED AT AREA SOURCES OF HAP EMISSIONS

As stated in §§63.6603 and 63.6640, you must comply with the following requirements for existing stationary RICE located at area sources of HAP emissions:

Table 2d requirements, item 4 - Emergency stationary CI RICE and black start stationary CI RICE.:

(a) Change oil and filter every 500 hours of operation or annually whichever comes first

(b) Inspect air cleaner every 1,000 hours operation or annually, whichever comes first, and replace as necessary;

(c) Inspect all hoses and belts every 500 hours of operation or annually, and replace as necessary.

§63.6625(i) provides the Permittee with the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Table 2d. However the oil analysis must be performed at the same frequency specified for changing the oil in Table 2d. See permit condition 4.7.2 D(2) for complete text.

§63.6604 What fuel requirements must I meet if I own or operate a stationary CI RICE?



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§63.6604(b) Beginning January 1, 2015, if you own or operate an existing emergency CI stationary RICE with a site rating of more than 100 brake HP and a displacement of less than 30 liters per cylinder that uses diesel fuel and operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in §63.6640(f)(2)(ii) and (iii) or that operates for the purpose specified in §63.6640(f)(4)(ii), you must use diesel fuel that meets the requirements in 40 CFR 80.510(b) for nonroad diesel fuel, except that any existing diesel fuel purchased (or otherwise obtained) prior to January 1, 2015, may be used until depleted.

§80.510(b) …. Except as otherwise specifically provided in this subpart, all NR [non-road] …diesel fuel is subject to the following per-gallon standards:

(1) Sulfur content.

(i) 15 ppm maximum for NR diesel fuel. (ii) (omitted) .

(2) Cetane index or aromatic content, as follows:

(i) A minimum cetane index of 40; or (ii) A maximum aromatic content of 35 volume percent.

§63.6605 What are my general requirements for complying with this subpart?

§63.6605(a) You must be in compliance with the emission limitations, operating limitations, and other requirements in this subpart that apply to you at all times. §63.6605(b) At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source.

§63.6625 What are my monitoring, installation, collection, operation, and maintenance requirements?



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§63.6625(e)(3) If you own or operate [an existing emergency … stationary RICE located at an area source of HAP emissions], you must operate and maintain the stationary RICE and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions: §63.6625(f) If you own or operate … an existing emergency stationary RICE located at an area source of HAP emissions, you must install a non-resettable hour meter if one is not already installed.

§63.6640 How do I demonstrate continuous compliance with the … operating limitations, and other requirements?

§63.6640(f) If you own or operate an emergency stationary RICE, you must operate the emergency stationary RICE according to the requirements in paragraphs (f)(1) through (4) of this section. In order for the engine to be considered an emergency stationary RICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in paragraphs (f)(1) through (4) of this section, is prohibited. If you do not operate the engine according to the requirements in paragraphs (f)(1) through (4) of this section, the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines. §63.6640(f)(1) There is no time limit on the use of emergency stationary RICE in emergency situations. §63.6640(f)(2) You may operate your emergency stationary RICE for any combination of the purposes specified in paragraphs (f)(2)(i) through (iii) of this section for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by paragraphs (f)(3) and (4) of this section counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2).

(i) Emergency stationary RICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency RICE beyond 100 hours per calendar year.

(ii) Emergency stationary RICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see §63.14), or other authorized entity as determined by the



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Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3.

(iii) Emergency stationary RICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. Note: The Permittee currently does not have a permit from the Department to operate the emergency diesel generators in the non-emergency situations described in paragraphs §63.6640(f)(3) and (f)(4), which are subject to emission limitations under regulation COMAR 26.11.36.

Compliance Demonstration Permit condition 4.7.4 D(2) requires the Permittee to comply with the applicable monitoring requirements of 40 CFR part 63, subpart ZZZZ: § 63.6640 How do I demonstrate continuous compliance with the … operating limitations, and other requirements? §63.6640(a) You must demonstrate continuous compliance with each … operating limitation, and other requirements in … Table 2d to this subpart that apply to you according to methods specified in Table 6 to this subpart.

Item 9 of Table 6 requires existing emergency stationary RICE located at an area source of HAP, to demonstrate continuous compliance by either: (1) operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions; or (2) developing and following the Permittee’s own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. Permit condition 4.7.5 D(1) require the Permittee to maintain records of the type and quantity of fuel burned in each engine. Permit condition 4.7.5 D(2) requires the Permittee to comply with the applicable recordkeeping requirements of 40 CFR part 63, subpart ZZZZ: §63.6625(i) requires the Permittee to keep records of the parameters that are analyzed as part of the oil analysis program, the results of the analysis, and the oil changes for the engine §63.6655(a) If you must comply with the … operating limitations, you must keep the records described in paragraphs (a)(1) through (a)(5), (b)(1) through (b)(3) and (c) of this section §63.6655(a)(1) A copy of each notification and report that you submitted to comply with this subpart, including all documentation supporting any Initial Notification or Notification of Compliance Status that you submitted, according to the requirement in §63.10(b)(2)(xiv).



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§63.6655(a)(2) – (5) Not applicable – no air pollution control or air pollution monitoring equipment required under 40 CFR part 63, subpart ZZZZ. §63.6655(b) Not applicable – no CEMS or CPMS required under 40 CFR part 63, subpart ZZZZ. §63.6655(c) Not applicable – does not fire landfill or digester gas. §63.6655(d) You must keep the records required in Table 6 to this subpart to show continuous compliance with each … operating limitation that applies to you.. Item 9 of Table 6 applies to “ … existing emergency and black start stationary RICE located at an area source of HAP…” Accordingly, the Permittee must keep the records necessary to demonstrate that the Permittee is operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions; or the Permittee has developed and is following their own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions.

§63.6655(e)(2) You must keep records of the maintenance conducted on the stationary RICE in order to demonstrate that you operated and maintained the stationary RICE and after-treatment control device (if any) according to your own maintenance plan if you own or operate … (2) An existing stationary emergency RICE.

§63.6655(f)(2) If you own or operate …[an existing emergency stationary RICE located at an area source of HAP emissions that does not meet the standards applicable to non-emergency engines ], you must keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The owner or operator must document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. If the engine is used for the purposes specified in §63.6640(f)(2)(ii) or (iii) …, the owner or operator must keep records of the notification of the emergency situation, and the date, start time, and end time of engine operation for these purposes. ….

Permit condition 4.7.6 D(2) requires the Permittee to comply with the applicable reporting requirements of 40 CFR part 63, subpart ZZZZ:

§63.6640(a) referencing Table 2d, the following reporting requirement in footnote 2 to Table 2d: If an emergency engine is operating during an emergency and it is not possible to shut down the engine in order to perform the management practice requirements on the schedule required in Table 2d of this subpart, or if performing the management practice on the required schedule would otherwise pose an unacceptable risk under federal, state, or local law, the management practice can be delayed until the emergency is over or the unacceptable risk under federal, state,



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or local law has abated. The management practice should be performed as soon as practicable after the emergency has ended or the unacceptable risk under federal, state, or local law has abated. Sources must report any failure to perform the management practice on the schedule required and the federal, state or local law under which the risk was deemed unacceptable. §63.6640(e) You must report each instance in which you did not meet the requirements in Table 8 to this subpart that apply to you, with the exception of the following items: §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) [Ref: §63.6645(a)(5)] §63.6645(a) not applicable to an existing stationary emergency RICE. [Ref: §63.6645(a)(5)] §63.6650(a) You must submit each report in Table 7 of this subpart that applies to you.

TABLE 7 TO SUBPART ZZZZ OF PART 63—REQUIREMENTS FOR REPORTS As stated in §63.6650, you must comply with the following requirements for reports: Table 7, Item 4 requirements. For each emergency stationary RICE that operate or are contractually obligated to be available for more than 15 hours per year for the purposes specified in §63.6640(f)(2)(ii) and (iii) …. You must submit a report, which must contain the information in 63.6650(h)(1). The report must be submitted annually according to the requirements in 63.6650(h)(2) – (3). §63.6650(b) Unless the Administrator has approved a different schedule for submission of reports under §63.10(a), you must submit each report by the date in Table 7 of this subpart and according to the requirements in paragraphs (b)(1) through (b)(9) of this section.

§63.6650(b)(1) For semiannual Compliance reports, the first Compliance report must cover the period beginning on the compliance date that is specified for your affected source in §63.6595 and ending on June 30 or December 31, whichever date is the first date following the end of the first calendar half after the compliance date that is specified for your source in §63.6595.

§63.6650(b)(2) For semiannual Compliance reports, the first Compliance report must be postmarked or delivered no later than July 31 or January 31, whichever date follows the end of the first calendar half after the compliance date that is specified for your affected source in §63.6595. §63.6650(b)(3) For semiannual Compliance reports, each subsequent Compliance report must cover the semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. §63.6650(b)(4) For semiannual Compliance reports, each subsequent Compliance report must be postmarked or delivered no later than July 31 or January 31, whichever date is the first date following the end of the semiannual reporting period.



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§63.6650(b)(5) For each stationary RICE that is subject to permitting regulations pursuant to 40 CFR part 70 …, and if the permitting authority has established dates for submitting semiannual reports pursuant to 40 CFR 70.6(a)(3)(iii)(A) [State Title V program]… you may submit the first and subsequent Compliance reports according to the dates the permitting authority has established instead of according to the dates in paragraphs (b)(1) through (b)(4) of this section. Note: Section III, part 4d. of this permit requires that semiannual monitoring reports be submitted within 30 days of the end of the reporting period specified in §63.6650(b)(1)and (b)(3) above. §63.6650(b)(6) For annual Compliance reports, the first Compliance report must cover the period beginning on the compliance date that is specified for your affected source in §63.6595 and ending on December 31. §63.6650(b)(7) and (b)(9): The reporting dates specified in paragraphs (b)(7) and (b)(9) are not applicable to facilities with a Title V permit. Section III, part 9. of this permit requires that annual Compliance Certification reports covering the previous calendar year be submitted by April 1 of each year. See §63.6650(f) below. §63.6650(b)(8) For annual Compliance reports, each subsequent Compliance report must cover the annual reporting period from January 1 through December 31. §63.6650(c) The Compliance report must contain the information in paragraphs (c)(1) through (6) of this section.

§63.6650(c)(1) Company name and address.

§63.6650(c)(2) Statement by a responsible official, with that official's name, title, and signature, certifying the accuracy of the content of the report.

§63.6650(c)(3) Date of report and beginning and ending dates of the reporting period.

§63.6650(c)(4) If you had a malfunction during the reporting period, the compliance report must include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report must also include a description of actions taken by an owner or operator during a malfunction of an affected source to minimize emissions in accordance with §63.6605(b), including actions taken to correct a malfunction.

§63.6650(c) (5) If there are no deviations from … operating limitations that apply to you, a statement that there were no deviations from the … operating limitations during the reporting period.

§63.6650(c) (6) not applicable. CEMS or CPMS not required.



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§63.6650(d) For each deviation from an… operating limitation that occurs for a stationary RICE …. , the Compliance report must contain the information in paragraphs (c)(1) through (4) of this section and the information in paragraphs (d)(1) and (2) of this section.

§63.6650(d)(1) The total operating time of the stationary RICE at which the deviation occurred during the reporting period.

§63.6650(d)(2) Information on the number, duration, and cause of deviations (including unknown cause, if applicable), as applicable, and the corrective action taken. §63.6650(e) – not applicable. Not required to have a CMS.

§63.6650(f) Each affected source that has obtained a title V operating permit pursuant to 40 CFR part 70 … must report all deviations as defined in this subpart in the semiannual monitoring report required by 40 CFR 70.6 (a)(3)(iii)(A) …. If an affected source submits a Compliance report pursuant to Table 7 of this subpart along with, or as part of, the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A) … , and the Compliance report includes all required information concerning deviations from any emission or operating limitation in this subpart, submission of the Compliance report shall be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring report. However, submission of a Compliance report shall not otherwise affect any obligation the affected source may have to report deviations from permit requirements to the permit authority.

§63.6650(g) - not applicable. Not new or reconstructed RICE. §63.6650(h) If you own or operate an emergency stationary RICE with a site rating of more than 100 brake HP that operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in §63.6640(f)(2)(ii) and (iii) or that operates for the purpose specified in §63.6640(f)(4)(ii), you must submit an annual report according to the requirements in paragraphs (h)(1) through (3) of this section.

§63.6650(h)(1) The report must contain the following information:

(i) Company name and address where the engine is located.

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

(iii) Engine site rating and model year.

(iv) Latitude and longitude of the engine in decimal degrees reported to the fifth decimal place.



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(v) Hours operated for the purposes specified in §63.6640(f)(2)(ii) and (iii), including the date, start time, and end time for engine operation for the purposes specified in §63.6640(f)(2)(ii) and (iii).

(vi) Number of hours the engine is contractually obligated to be available for the purposes specified in §63.6640(f)(2)(ii) and (iii).

(vii) Hours spent for operation for the purpose specified in §63.6640(f)(4)(ii), including the date, start time, and end time for engine operation for the purposes specified in §63.6640(f)(4)(ii). The report must also identify the entity that dispatched the engine and the situation that necessitated the dispatch of the engine.

(viii) If there were no deviations from the fuel requirements in §63.6604 that apply to the engine (if any), a statement that there were no deviations from the fuel requirements during the reporting period.

(ix) If there were deviations from the fuel requirements in §63.6604 that apply to the engine (if any), information on the number, duration, and cause of deviations, and the corrective action taken.

§63.6650(h)(2) The first annual report must cover the calendar year 2015 and must be submitted no later than March 31, 2016. Subsequent annual reports for each calendar year must be submitted no later than March 31 of the following calendar year.

§63.6650(h)(3) The annual report must be submitted electronically using the subpart specific reporting form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, the written report must be submitted to the Administrator at the appropriate address listed in §63.13.



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9. EMISSION UNITS C12: One(1) emergency diesel generator, 764 BHP (570 kW) No.2 oil-fired generator, Caterpillar Model 3456 located at Bldg. 190 (boiler plant)

C11: One(1) emergency diesel generator, 600 kW Kohler Model 600REOZv located in Bldg 693

C14: One(1) emergency diesel generator, 1000 kW Kohler Model 1000REOZMB located in Bldg 568

C15: One(1) emergency diesel generator, 2000 kW Caterpillar Model SR45/3516C located in Bldg 8100

C16: One(1) emergency diesel generator, 500 kW Kohler Model 500REOZJ located in Bldg 1419

Emission unit C12 is now a 570 kW Caterpillar Model 3456 generator (permit to construct 021-9-0236 N issued on June 1, 2006) which replaced a 671 kW Cummins generator previously designated as emission unit C12. APPLICABLE STANDARDS and LIMITATIONS Visible Emissions Limitations COMAR 26.11.09.05E(2), which prohibits the discharge of emissions from any engine, operating at idle, greater than 10 percent opacity, except as allowed under COMAR 26.11.09.05E(4). COMAR 26.11.09.05E(3), which prohibits the discharge of emissions from any engine, operating at other than idle conditions, greater than 40 percent opacity, except as allowed under COMAR 26.11.09.05E(4).

COMAR 26.11.09.05E(4) provides that COMAR 26.11.09.05E(2) does not apply for a period of 2 consecutive minutes after a period of idling of 15 minutes for the purpose of clearing the exhaust system. COMAR 26.11.09.05E(2) does not apply to emissions resulting directly from cold engine start-up and warm-up for the following maximum periods: (a) engines that are idled continuously when not in service: 30 minutes; (b) all other engines: 15 minutes. COMAR 26.11.09.05E(2) and E(3) do not apply while maintenance, repair, or testing is being performed by qualified mechanics.

Compliance Demonstration These units are emergency generators that operate a few hours each year. No periodic monitoring will be required. However, the Permittee is required to report incidents of visible emissions in accordance with the requirements of Permit Condition 4, Section III of the permit, “Report of Excess Emissions and Deviations.”



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Control of Sulfur Oxides 40 CFR part 60, subpart IIII, §60.4207, which cites §80.510(b) limiting the sulfur content of non-road diesel fuel to 15 ppm or less. Compliance Demonstration The Permittee must obtain a certification from the fuel supplier indicating that the oil complies with the limitation on the sulfur content of fuel oil. The Permittee must retain fuel supplier certifications of sulfur content in fuel. The Permittee must report fuel supplier certifications of sulfur content in fuel to the Department upon request. The basis for these monitoring, record keeping, and reporting requirements is the Department's authority to create periodic monitoring requirements, COMAR 26.11.03.06C. Control of Nitrogen Oxides Emissions COMAR 26.11.09.08G(1) -Requirements for Fuel-Burning Equipment with a Capacity Factor of 15 Percent or Less - a person who owns or operates fuel-burning equipment with a capacity factor (as defined in 40 CFR Part 72.2) of 15 percent or less shall:

(a) Provide certification of the capacity factor of the equipment to the Department in writing;

(b) For fuel-burning equipment that operates more than 500 hours during a calendar year, perform a combustion analysis and optimize combustion at least once annually;

(c) Maintain the results of the combustion analysis at the site for at least 2 years and make these results available to the Department and the EPA upon request;

(d) Require each operator of an installation, except combustion turbines, to attend operator training programs at least once every 3 years, on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and

(e) Maintain a record of training program attendance for each operator at the site and make these records available to the Department upon request.

COMAR 26.11.09.08B(5) states that; (a) for the purpose of COMAR 26.11.09.08, the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation; and (b) that the operator training course sponsored by the Department shall include an in-house training course that is approved by the Department.



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Compliance Demonstration The Permittee monitors and retains records of the hours of operation of each installation on a monthly basis and calculate the capacity factor of the installation at the end of each month and determine whether an installation’s operations exceeded the 15 percent capacity factor on a rolling 12 month basis. The capacity factor typically does not exceed 2 percent and the hours of operation of any individual installation have been well under 500 hours per year. The Permittee must submit a certification of the annual capacity factor for each engine with the annual emissions certification report. The Permittee must retain records of training program attendance for each operator at the site and must submit a list of operator training upon request [Authority: COMAR 26.11.09.08G(1) and COMAR 26.11.03.06C]. Operational Standards. Permit condition 4.8.2 D(1) requires the Permittee to combust only No. 2 diesel fuel oil unless the Permittee applies for and receives an approval or permit from the Department to burn alternative fuels [Authority: COMAR 26.11.02.09A].

Permit condition 4.8.2 D(2) requires the following, that for any diesel generator whose engine was manufactured after April 1, 2006 and was ordered by the Permittee on or after July 11, 2005, and therefore subject to 40 CFR 60 Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines: (a) Pre-2007 model year emergency stationary CI ICE with a displacement of less than 10

liters per cylinder must comply with the emission standards in Table 1 to Subpart IIII of Part 60 [Authority: §60.4205(a), 40 CFR part 60, subpart IIII].

(b) 2007 model year and later emergency stationary CI ICE with a displacement of less than 30 liters per cylinder must comply with the emission standards for new nonroad CI engines in §60.4202, for all pollutants, for the same model year and maximum engine power for their 2007 model year and later emergency stationary CI ICE. [Authority: §60.4205(b), 40 CFR part 60, subpart IIII].

§60.4202(a) Stationary CI internal combustion engine manufacturers must certify their 2007 model year and later emergency stationary CI ICE with a maximum engine power less than or equal to 2,237 KW (3,000 HP) and a displacement of less than 10 liters per cylinder to the emission standards specified in §60.4202(a)(2). §60.4202(a)(2) For engines with a maximum engine power greater than or equal to 37 KW (50 HP), the certification emission standards for new nonroad CI engines for the same model year and maximum engine power in 40 CFR 89.112 and 40 CFR 89.113 for all pollutants beginning in model year 2007.



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(c) The Permittee shall combust only diesel fuel meeting the requirements of 40 CFR §80.510(b) [Authority: §60.4207, 40 CFR part 60, subpart IIII]:

(i) The maximum sulfur content shall not exceed 15 ppm by weight;

(ii) Either the minimum cetane index shall be at least 40 or the maximum aromatic content shall not exceed 40 percent by volume.

(d) In keeping with §60.4211(f)(2) through (f)(2)(iii), the Permittee must limit the hours of

operation for nonemergency use to 100 hours per year or less unless prior approval is obtained from the Department [Authority: §60.4211(f), 40 CFR part 60, subpart IIII].

§60.4211(f) If you own or operate an emergency stationary ICE, you must operate the emergency stationary ICE according to the requirements in paragraphs (f)(1) through (3) of this section. In order for the engine to be considered an emergency stationary ICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in paragraphs (f)(1) through (3) of this section, is prohibited. If you do not operate the engine according to the requirements in paragraphs (f)(1) through (3) of this section, the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines.

§60.4211(f)(1) There is no time limit on the use of emergency stationary ICE in emergency situations.

§60.4211(f)(2) You may operate your emergency stationary ICE for any combination of the purposes specified in paragraphs (f)(2)(i) through (iii) of this section for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by paragraph (f)(3) of this section counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2).

§60.4211(f)(2)(i) Emergency stationary ICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar year.

§60.4211(f)(2)(ii) Emergency stationary ICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see §60.17), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3.



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§60.4211(f)(2)(iii) Emergency stationary ICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency.

Compliance Demonstration Permit condition 4.8.4 D(1) requires the Permittee to operate and maintain, over the entire life of the source, each emergency diesel generator and control devices according to the manufacturer’s written instructions or according to procedures developed by the Permittee that are approved by the manufacturer. Additionally, the Permittee may change only those settings that are permitted by the manufacturer. The Permittee must also meet the requirements of 40 CFR parts 89, 94 and/or 1068 as they may apply to an owner or operator [Authority: 40 CFR part 60, subpart IIII, §60.4211(a)]. Permit condition 4.8.4 D(2) requires the Permittee to install a non-resettable hour meter on each engine prior to the startup of engine [Authority: 40 CFR part 60, subpart IIII, §60.4209(a)]. Permit condition 4.8.4 D(3) requires the Permittee to keep records of the operation of each emergency diesel generator in emergency and non-emergency service that are recorded through the non-resettable hour meter. The Permittee must record the time of operation of each emergency diesel generator and the reason the emergency diesel generator was in operation during that time [Authority: 40 CFR part 60, subpart IIII, §60.4214(b)]. Permit conditions 4.8.5 D(1) requires the Permittee to maintain on site for the life of the source the following records for the emergency diesel generators [Authority: condition E(2), Permit to Construct 021-0131-9-0353 issued by the Department on November 13, 2012, and COMAR 26.11.03.06C(3)]:

(a) The installation date of each emergency generator; and (b) The certifications of compliance or manufacturer engine test data required by 40 CFR

§60.4211 and §60.4214(b). Permit condition 4.8.5 D(2) requires the Permittee to keep records of the operation of each emergency diesel generator in emergency and non-emergency service that are recorded through the non-resettable hour meter. The Permittee must record the time of operation of each emergency diesel generator and the reason the emergency diesel generator was in operation during that time [Authority: 40 CFR part 60, subpart IIII, §60.4214(b)]. Permit condition 4.8.5 D(3) requires the Permittee, for each delivery of fuel to be used in the emergency diesel generators, to obtain from the fuel supplier a fuel supplier certification consisting of the name of the oil supplier, the date of delivery, the amount of fuel delivered, and a statement from the fuel supplier that the diesel fuel oil complies with the specifications of 40 CFR §80.510(b) [Authority: condition E(3), Permit to Construct 021-0131-9-0353 issued by the Department on November 13, 2012, COMAR 26.11.03.06C(3)].



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Permit condition 4.8.6 D(1) requires the Permittee to submit a record of the quantity of each type of fuel burned with the annual emissions certification report that is due April 1 of each year [Authority: COMAR 26.11.02.19C(2)]. Permit condition 4.8.6 D(2) requires the Permittee to comply with the following reporting requirements of 40 CFR part 60, subpart IIII:

§60.4214(d) If you own or operate an emergency stationary CI ICE with a maximum engine power more than 100 HP that operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in §60.4211(f)(2)(ii) and (iii) or that operates for the purposes specified in §60.4211(f)(3)(i), you must submit an annual report according to the requirements in paragraphs (d)(1) through (3) of this section.

§60.4214(d) (1) The report must contain the following information:







(vii) Hours spent for operation for the purposes specified in §60.4211(f)(3)(i), including the date, start time, and end time for engine operation for the purposes specified in §60.4211(f)(3)(i). The report must also identify the entity that dispatched the engine and the situation that necessitated the dispatch of the engine.

§60.4214(d)(2) The first annual report must cover the calendar year 2015 and must be submitted no later than March 31, 2016. Subsequent annual reports for each calendar year must be submitted no later than March 31 of the following calendar year.

§60.4214(d)(3) The annual report must be submitted electronically using the subpart specific reporting form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, the written report must be submitted to the Administrator at the appropriate address listed in §60.4.



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10. EMISSION UNIT F1: Two (2) 12,000-gallon underground gasoline storage tanks, using Stage I vapor recovery systems, fuel feed to 6 dispensers which use Stage II vapor recovery systems. An air quality Permit to Construct to install two (2) 12,000 gallon gasoline underground storage tanks for this facility was issued on March 10, 2003. The tanks were installed in June 2004. The tanks service an Army/Air Force Exchange Service (AAFES) gasoline dispensing facility for motor vehicles. Control equipment consists of Stage I and II vapor recovery systems. The NSPS, 40 CFR Part 60 Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels (including petroleum liquid storage vessels) for which Construction, Reconstruction, or Modification commenced after July 23, 1984, is not applicable because the size of the tanks is below the applicable size threshold for gasoline storage tanks. The facility is nominally subject to National Emission Standards for Hazardous Air Pollutants area source standard for Gasoline Dispensing Facilities (GDF).40 CFR 63 Subpart CCCCCC. The source qualifies as an existing affected source since it commenced construction prior to November 9, 2006 and for this reason would not required to comply with the standard until January 10, 2011 or 3 years after becoming subject to additional control requirements owing to an increase in the average monthly throughput. Nominally, Fort Detrick gasoline dispensing facility must comply with §§63.11116(a) and 63.11117(b) requirements. §63.11116(a) requires that facility to use several common good operating practices and §63.11117(b) specifies submerged filling requirements for the gasoline storage tanks. The facility is already in compliance with the submerged filling requirements, which are covered under the requirements for an “approved system” under regulation COMAR 26.11.24.03A and therefore the source is not subject to Initial notification and Notification of Compliance Status under 63.11124(a). The Fort Detrick gasoline dispensing facility surpassed the 100,000 gallon/month in 2009, which nominally brought in §63.11118(b) Stage I control requirements. However, §63.11118(b)(2) provides that the facility will be deemed in compliance with §63.11118(b), if prior to January 10, 2008, the gasoline dispensing facility is covered by an enforceable State rule or permit that requires a vapor balance system that either (1) achieves an emissions reduction of at least 90 percent; or (2) requires operation using management practices at least as stringent as those specified in Table 1 to Subpart CCCCCC. Accordingly, in keeping with §63.11118(b)(2)(ii), the Department deems the gasoline storage tanks operating in compliance with §63.11118(b). Additionally, the tanks are not subject to the requirement to perform the periodic testing (once every 3 years) under §63.11120 because the vapor balance system is not “a vapor balance system required under §63.11118(b)(1)” but falls under §63.11118(b)(2) for existing systems subject to an enforceable State rule or permit prior to January 10, 2008. In summary, virtually all requirements coincide with equivalent State requirements.



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APPLICABLE STANDARDS and LIMITATIONS Stage I Requirements – Gasoline Dispensing Facilities ♦ COMAR 26.11.13.04C(1) &(2) , which applies to a person who owns or operates a gasoline

storage tank that has a tank capacity greater than 2,000 gallons but less than 40,000 gallons. The Permittee may not cause or permit gasoline to be loaded into a stationary tank unless the loading system is equipped with a vapor balance line that is properly installed, maintained and used (Stage I Vapor Recovery).

♦ COMAR 26.11.13.04D General Standards. A person may not cause or permit gasoline or

VOC having a TVP of 1.5 psia (10.3 kilonewtons/square meter) or greater to be loaded into any tank truck, railroad tank car, or other contrivance unless the:

(1) Loading connections on the vapor lines are equipped with fittings that have no leaks and that automatically and immediately close upon disconnection to prevent release of gasoline or VOC from these fittings; and

(2) Equipment is maintained and operated in a manner to prevent avoidable liquid leaks during loading or unloading operations.

♦ 40 CFR 63 Subpart CCCCCC - National Emission Standards for Hazardous Air Pollutants -

Gasoline Dispensing Facilities (GDF). As an existing affected source that commenced construction prior to November 9, 2006, the Permittee must comply with the requirements of 40 CFR §63.11116 through §63.11118 as applicable [Authority: 40 CFR §63.11111 and §63.11113(b)-(c)]. §63.11113 When do I have to comply with this subpart? §63.11113 (b) If you have an existing affected source, you must comply with the standards in this subpart no later than January 10, 2011. §63.11118 Requirements for facilities with monthly throughput of 100,000 gallons of gasoline or more. §63.11118 (a) You must comply with the requirements in §§63.11116(a) and 63.11117(b):. §63.11116 Requirements for facilities with monthly throughput of less than 10,000 gallons of gasoline.

§63.11116 (a) You must not allow gasoline to be handled in a manner that would result in vapor releases to the atmosphere for extended periods of time. Measures to be taken include, but are not limited to, the following:

(1) Minimize gasoline spills;



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(2) Clean up spills as expeditiously as practicable; (3) Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when not in use; (4) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to reclamation and recycling devices, such as oil/water separators.

§63.11117 Requirements for facilities with monthly throughput of 10,000 gallons of gasoline or more.

§63.11117 (b) Except as specified in paragraph (c), you must only load gasoline into storage tanks at your facility by utilizing submerged filling, as defined in §63.11132, and as specified in paragraph (b)(1) or paragraph (b)(2) of this section.

(1) Submerged fill pipes installed on or before November 9, 2006, must be no more than 12 inches from the bottom of the storage tank. (2) Submerged fill pipes installed after November 9, 2006, must be no more than 6 inches from the bottom of the storage tank.

§63.11118 (b) Except as provided in paragraph (c) of this section, you must meet the requirements of either paragraph (b)(1) or paragraph (b)(2) of this section. (1) Each management practice in Table 1 to this subpart that applies to your gasoline dispensing facility (GDF). (2) If prior to January 10, 2008, you satisfy the requirements in both paragraphs (b)(2)(i) and (ii) of this section, you will be deemed in compliance with this subsection [i.e., §63.11118(b)].

(i) You operate a vapor balance system at your GDF that meets the requirements of either paragraph (b)(2)(i)(A) or paragraph (b)(2)(i)(B) of this section

(A) Achieves emissions reduction of at least 90 percent. (B) Operates using management practices at least as stringent as those in Table 1 to this subpart.

(ii) Your gasoline dispensing facility is in compliance with an enforceable State, local, or tribal rule or permit that contains requirements of either paragraph (b)(2)(i)(A) or paragraph (b)(2)(i)(B) of this section.

Note: In keeping with §63.11118(b)(2)(ii), the Department deems gasoline storage tanks operating in compliance with a permit that was issued by the Department before January 10, 2008 to be in compliance with §63.11118(b).

§63.11118 (c) (not applicable)



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§63.11118 (d) Cargo tanks unloading at GDF must comply with the management practices in Table 2 to Subpart CCCCCC of Part 63 – Applicability Criteria and Management Practices for Gasoline Cargo Tanks Unloading at Gasoline Dispensing Facilities With Monthly Throughput of 100,000 Gallons of Gasoline or More. Table 2 specifies the following requirements:

(i) All hoses in the vapor balance system are properly connected, (ii) The adapters or couplers that attach to the vapor balance line on the storage tank have closures that seal upon disconnect, (iii) All vapor return hoses, couplers, and adapters used in the gasoline delivery are vapor-tight, (iv) All tank truck vapor return equipment is compatible in size and forms a vapor-tight connection, and (v) All hatches on the tank truck are closed and securely fastened. (vi) The filling of storage tanks at GDF shall be limited to unloading by vapor-tight gasoline cargo tanks. Documentation that the cargo tank has met the specifications of EPA Method 27 shall be carried on the cargo tank.

§63.11118 (e) – (h) (omitted)

Compliance Demonstration (Stage I Requirements). At least once a month, the Permittee is required to monitor a fuel drop to verify that the Stage 1 vapor balance system is used, and at least once a month during a delivery, monitor the fuel drop for liquid spills, and check the hose fittings and connections for leaks and proper operation. Permittee must maintain a record of the results of the monthly observations for use of the Stage I vapor balance system, and the results of the monthly observations for leaks and spills [Authority: COMAR 26.11.03.06C(3)]

§63.11120 What testing and monitoring requirements must I meet? §63.11120 (a) Each owner or operator, at the time of installation of a vapor balance system required under §63.11118(b)(1), and every 3 years thereafter, must comply with the requirements in paragraphs (a)(1) and (2) of this section. Not applicable - as an existing source issued a permit by the Department prior to January 10, 2008, the installations are exempt from testing under this paragraph.

§63.11124 What notifications must I submit and when?



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§63.11124 (a) Each owner or operator subject to the control requirements in §63.11117 must comply with paragraphs (a)(1) through (3) of this section. … §63.11124 (b) Each owner or operator subject to the control requirements in §63.11118 must comply with paragraphs (b)(1) through (5) of this section.

Note: In keeping with §§63.11124(a)(3) and 63.11124 (b)(3), owners or operators of gasoline storage tanks operating in compliance with a permit that was issued by the Department before January 10, 2008 are not required to submit an Initial Notification or a Notification of Compliance Status under §63.11124.

§63.11125 What are my recordkeeping requirements? §63.11125 (a) Each owner or operator subject to the management practices in §63.11118 must keep records of all tests performed under §§63.11120(a) and (b). §63.11125 (b) Records required under paragraph (a) of this section shall be kept for a period of 5 years and shall be made available for inspection by the Administrator's delegated representatives during the course of a site visit. §63.11126 What are my reporting requirements? Each owner or operator subject to the management practices in §63.11118 shall report to the Administrator the results of all volumetric efficiency tests required under §63.11120(b). Reports submitted under this paragraph must be submitted within 180 days of the completion of the performance testing.

For owners or operators of gasoline storage tanks operating in compliance with a permit that was issued by the Department before January 10, 2008, there are no recordkeeping requirements under §63.11125 or reporting requirements under §63.11126. Stage II Requirements – Gasoline Dispensing Facilities. . ♦ COMAR 26.11.24.03 General Requirements (Only §§ A, E, F, H and I are applicable)

(A) New Gasoline Dispensing Facilities. After May 15, 1993, an owner or operator of a new gasoline dispensing facility may not operate the gasoline dispensing facility unless it is equipped and operated with an approved system. An approved system is a properly installed Stage II vapor recovery system for which the California Air Resources Board (CARB) issued an Executive Order certifying the system using procedures in effect in California before April 1, 2001; or a system approved by the Department that involves certification procedures comparable to or similar to the certification procedures used by CARB and in effect in California before April 1, 2001.



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(E) After the applicable dates established in §§A - C of this regulation, an operator may not use or allow the use of defective equipment associated with the transfer of gasoline from a stationary gasoline storage tank to motor vehicle fuel tanks. (F) The operator may not install or use a replacement part in an approved system unless that part has been certified by the CARB or approved by the Department for the approved system. (H) Gasoline storage tanks serving a gasoline dispensing facility that is subject to this chapter shall be equipped with a properly designed and installed pressure and vacuum valve with minimum pressure and vacuum settings as specified in the CARB Executive Order for that system. (I) If an approved system is certified under more than one Executive Order, the most recent Executive Order shall apply.

♦ COMAR 26.11.24.06 Training Requirements for Operation and Maintenance of Approved Systems. (A) General. An operator shall ensure that:

(1) At least one employee at each facility subject to this regulation is trained in accordance with the requirements of paragraph (B) below.

(2) The trained employee assists in the training of each of the other employees at that

facility who are involved in the operation or maintenance of the approved system. (B) Approved Training Course Contents and Duration.

(1) An approved training course shall contain, at a minimum, a discussion of the following:

(a) Purposes and effects of Stage II vapor recovery; (b) Stage II vapor recovery equipment design, function, operation and

maintenance; (c) Daily inspection requirements and development and maintenance of records

and files; and (d) Equipment warranties and spare parts.

(2) The approved training course shall be of a duration sufficient to properly train

persons in the requirements of this chapter.



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♦ COMAR 26.11.24.08 Instructional Signs. The Permittee shall place instructional signs in conspicuous locations at each gasoline dispenser. The instructional signs shall include:

(1) Instructions, with illustrations, on how to insert the nozzle, dispensing gasoline, and how to remove the nozzle;

(2) A warning against attempts to continue refueling after automatic shutoff of the

gasoline (that is, topping off); and (3) The Department’s toll-free telephone number which may be used for complaints or

comments concerning the use of the Stage II vapor recovery systems. Compliance Demonstration (Stage II requirements) The following regulations and requirements address compliance with the applicable standards/limits under COMAR 26.11.24.03, COMAR 26.11.24.06, COMAR 26.11.24.08 identified above . (Testing Requirements)

COMAR 26.11.24.04A Except as provided in §§E and F of this regulation, an owner subject to this chapter shall perform the following CARB-approved tests:

(1) A leak test in accordance with the Vapor Recovery Test Procedure TP-201.3 referenced in

regulation COMAR 26.11.24.01-1B(1), “Vapor Recovery Test Procedure TP-201.3 Determination of 2 Inch WC Static Pressure Performance of Vapor Recovery Systems of Dispensing Facilities, amended March 17, 1999.”

(2) An air to liquid volume ratio test in accordance with the Vapor Recovery Test Procedure

TP-201.5 referenced in regulation COMAR 26.11.24.01-1B(2), “Vapor Recovery Test Procedure TP-201.5 Determination (By Volume Meter) of Air to Liquid Volume Ratio of Vapor Recovery Systems of Dispensing Facilities, adopted April 12, 1996.”

(3) A dynamic pressure performance test in accordance with the Vapor Recovery Test

Procedure TP-201.4 referenced in regulation COMAR 26.11.24.01-1B(3), “Vapor Recovery Test Procedures TP-201.4 Determination of Dynamic Pressure Performance of Vapor Recovery Systems of Dispensing Facilities, amended April 28, 2000.”

(4) A vapor return line vacuum integrity test for the Healy Model 400 ORVR System in

accordance with Executive Order G-70-186, Exhibit 4 referenced in regulation COMAR 26.11.24.01-1B(4),

(5) A vapor return line vacuum integrity test for the Healy Model 600 System in accordance

with Executive Order G-70-165 Exhibit 4 referenced in regulation COMAR 26.11.24.01-1B(5),



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COMAR 26.11.24.04B requires that the leak and liquid blockage tests required in §A of regulation COMAR 26.11.24.04 be performed on each approved system before the gasoline dispensing facility is initially used to refuel motor vehicles. COMAR 26.11.24.04C(1) requires an owner of a Stage II vapor recovery system subject to Chapter 24 must repeat the required tests in accordance with the test schedule in regulation COMAR 26.11.24.04C(2) and upon replacement of 75 percent or more of an approved system.

COMAR 26.11.24.04C(2) Test Schedule provided is : Type of Stage II Vapor Recovery System Initial Test Frequency of

Retest (a) Vapor Balance System

Dynamic Back Pressure 12 months Leak Test 12 months Liquid Blockage Test 5 years

(b) Vapor Assist System – Type 1

Air to Liquid Ratio Test 12 months Leak Test 12 months Nozzle Regulation Test 5 years

(c) Vapor Assist System - Type 2 Model 400

Nozzle Regulation Test 12 months Air to Liquid Ratio Test 12 months

(d) Vapor Assist System -Type 2 Model 600

Air to Liquid Ratio Test 12 months Vapor Return Line Integrity Test

12 months

COMAR 26.11.24.04D - If a gasoline dispensing facility fails any test required by Chapter 24, the owner notify the Department of the failure in writing within 5 working days after the test and before retesting. COMAR 26.11.24.04E - Alternative test methods approved by CARB may be used in place of the test methods specified in §A of this regulation, if the alternative test methods are approved by the U.S. EPA as a revision to the SIP, which is Maryland’s plan for meeting National Ambient Air Quality Standards. COMAR 26.11.24.04F - Allows the test methods and the frequency of testing required by regulation to be modified for vapor assist systems, if the test methods and testing frequency are approved by the Department and the EPA (Monitoring Requirements) The owner must test the automatic shutoff and flow prohibiting mechanisms upon installation and at least monthly after to ensure that they operate properly [Authority: COMAR 26.11.03.06C].



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COMAR 26.11.24.05 requires the Permittee to perform the following inspections:

COMAR 26.11.24.05A - An operator subject to this chapter shall ensure that each approved system is inspected at least once each day of operation to verify that it is working properly.

COMAR 26.11.24.05B - Except as provided in §C of this regulation, the Department shall consider an operator of a gasoline dispensing facility to be in violation of §E of regulation COMAR 26.11.24.03 during periods of time when defective equipment at the facility is placed in operation.

COMAR 26.11.24.05C - provides that the operator is not in violation of §E of regulation COMAR 26.11.24.03 during any period of time that the operator establishes, to the satisfaction of the Department, that nozzles associated with defective equipment were tagged out of service and that no nozzle associated with the defective equipment was actually used. COMAR 26.11.24.05D - requires that, for any defective equipment identified by the Department, the operator shall effect necessary repairs before placing the equipment in service, and shall inform the Department by telephone within 72 hours after the repair or replacement of the defective equipment has been affected. COMAR 26.11.24.05-1 - Inspection Requirements by a Certified Inspector.

COMAR 26.11.24.05-1A(1) Operator Requirements-1. A person that operates a gasoline dispensing facility or a gasoline storage tank with a vapor recovery system shall ensure that a certified inspector performs an inspection of each vapor recovery system

COMAR 26.11.24.05-1A(2) also specifies operator requirements. . Each vapor recovery system must be inspected by a certified inspector in accordance with the schedules set forth in COMAR 26.10.03.10.

COMAR 26.11.24.05-1B(1) requires that the certified inspector must inspect each vapor recovery system to confirm that all the necessary equipment has been installed, the equipment is functioning properly; and that there is no defective equipment in use. COMAR 26.11.24.05-1B(2) require that the certified inspector review the facility files to confirm that all testing required by COMAR 26.11.24 has been completed, that the operator has performed daily inspections of the Stage II equipment, that the records required by COMAR 26.11.24 are complete and maintained onsite; and that all other requirements of COMAR 26.11.24 are being met.

COMAR 26.11.24.05-1B(3) requires that the certified inspector complete an inspection form provided by the Department and submit the completed form to the Department within 30 days after completing the inspection .



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(Recordkeeping Requirements) COMAR 26.11.24.07A-B requires that the Permittee must create and maintain a record file at the facility or at an alternative site approved by the Department. The record file must contain copies of all test reports, permits, violation notices, correspondence with the Department, equipment maintenance records, training records, and other information pertinent to the requirements of this chapter. Verification of training must be maintained in the facility file. Equipment maintenance records must be maintained for at least 2 years. Test records must be maintained for at least 5 years. COMAR 26.11.24.07C requires that the equipment maintenance records must include: (1) The date on which defective equipment was found, a description of each defect, a

description of the corrective action and the date on which the defect was corrected, and the probable cause of the defect;

(2) If parts are replaced, the location within the approved system of the part, the part number,

and assurance that the replacement part does not degrade the efficiency of the system; and (3) Inspection reports and any other information relating to maintenance or care of the system. (Notification and Reporting Requirements) COMAR 26.11.24.07E the following reporting requirements apply to a test under Chapter 24. (1) The Department shall be notified 21 days before a test is to be conducted [Authority:

COMAR 26.11.03.06C]; (2) Copies of results shall be forwarded to the Department; and (3) Test failures shall be reported to the Department in writing within 5 days following the date

of the failure. COMPLIANCE SCHEDULE Emission Units B1 and B4: the Permittee identified the following requirement being violated in Section 7 of the Part 70 Permit Application: Applicable Federally Enforceable Requirement being Violated: 40 CFR part 62, subpart JJJ requires an initial evaluation of the continuous opacity monitoring system and annual evaluations. USAG Fort Detrick stated the following in Section 7 of the Part 70 Permit Application that was submitted on June 6, 2013:



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“Fort Detrick failed to perform the initial and first annual evaluation of the COMS upon installation. The initial evaluation was performed in September 2012 and the first annual evaluation was planned in September 2013. Because of a part failure after the initial evaluation was initiated, and then a lack of funded caused by budget sequestration, Fort Detrick has been unable to gather the required 7 days of data to complete the initial evaluation. Fort Detrick anticipates the part will be installed and the data will be gathered in June 2013 to finish the initial evaluation. The first annual evaluation will be conducted by the end of October 2013 unless otherwise directed by MDE.”

Fort Detrick has been unable to meet the schedule stated in the Title V application owing to a series of continuing problems. In the letter to the Department dated December 10, 2014, Mr. Laurin E. Potter, Jr., Director, Public Works, USAG Fort Detrick wrote:

“… regarding the certification of the continuous opacity monitoring systems (COMS) for the two municipal waste combustors (MWCs), I regret to advise you that this issue has not been resolved. Ms. Wolf and Mr. Mark Dressler, our incinerator Plant Supervisor, have talked to the contractor who is currently performing the maintenance on the COMS. The contractor has agreed to have the smoke eyes in the COMS removed in sequence (using one pre-purchased smoke eye while maintaining operations) and send to the manufacturing site in Australia for recalibration and certification, and then returned and reinstalled. The entire process, to obtain initial certification from both the manufacturer and then the installer for each unit will take approximately four months …. ”

USAG Fort Detrick is submitting a revised Plan for Compliance for the COMS. Permit conditions 4.6.4 A(1)(b) requires that a satisfactory initial evaluation of the COMS be completed no later than December 31, 2015. TITLE IV - ACID RAIN The Acid Rain Program does not apply to Fort Detrick. TITLE VI - OZONE DEPLETING SUBSTANCES There are ozone depleting substances released to the atmosphere at this location. Fort Detrick is currently complying with the applicable federal requirements in 40 CFR 82. SECTION 112 (r) - ACCIDENTAL RELEASE Fort Detrick is subject to the requirements of Section 112 (r) of the Clean Air Act. Their risk management plan (RMP) was received by EPA on June 21, 1999. The plan is required to address the potential for accidental releases of chlorine, which is routinely stored at the facility in quantities exceeding the threshold quantity of 2500 lbs. PERMIT SHIELD



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Fort Detrick did not request a permit shield. INSIGNIFICANT ACTIVITIES This section contains a list of the insignificant emissions units that were reported in the Title V permit application. The applicable Clean Air Act requirements, if any, are listed below the insignificant activity. (1) No. 172 Fuel burning equipment using gaseous fuels or no. 1 or no. 2 fuel oil, and

having a heat input less than 1,000,000 Btu (1.06 gigajoules) per hour; [For Areas I, II, V, and VI]

The boilers are subject to the following requirements:

(A) COMAR 26.11.09.05A(1), which establishes that the Permittee may not cause or permit the discharge of emissions from any fuel burning equipment, other than water in an uncombined form, which is greater than 20 percent opacity.

(B) Exceptions: COMAR 26.11.09.05A(2) does not apply to emissions

during load changing, soot blowing, start-up, or adjustments or occasional cleaning of control equipment if:

(i) The visible emissions are not greater than 40 percent

opacity; and

(ii) The visible emissions do not occur for more than 6 consecutive minutes in any sixty minute period.

[For Distillate Fuel Oil]

(C) COMAR 26.11.09.07A(1)(c), which establishes that the Permittee may

not burn, sell, or make available for sale any distillate fuel with a sulfur content by weight in excess of 0.3 percent.

(2) No. 0 Fuel-burning equipment using solid fuel and having a heat input of less than

350,000 Btu (0.37 gigajoule) per hour; (3) No. 18 Stationary internal combustion engines with an output less than 500 brake

horsepower (373 kilowatts) and which are not used to generate electricity for sale or for peak or load shaving;



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The emergency generators are subject to the following requirements:

(A) COMAR 26.11.09.05E(2), Emissions During Idle Mode: The Permittee

may not cause or permit the discharge of emissions from any engine, operating at idle, greater than 10 percent opacity.

(B) COMAR 26.11.09.05E(3), Emissions During Operating Mode: The

Permittee may not cause or permit the discharge of emissions from any engine, operating at other than idle conditions, greater than 40 percent opacity.

(C) Exceptions:

(i) COMAR 26.11.09.05E(2) does not apply for a period of 2

consecutive minutes after a period of idling of 15 consecutive minutes for the purpose of clearing the exhaust system.

(ii) COMAR 26.11.09.05E(2) does not apply to emissions resulting

directly from cold engine start-up and warm-up for the following maximum periods:

(a) Engines that are idled continuously when not in service: 30

minutes; (b) All other engines: 15 minutes.

(iii) COMAR 26.11.09.05E(2) & (3) do not apply while maintenance,

repair or testing is being performed by qualified mechanics.

(4) 0 Space heaters utilizing direct heat transfer and used solely for comfort heat; (5) 0 Water cooling towers and water cooling ponds unless used for evaporative

cooling of water from barometric jets or barometric condensers, or used in conjunction with an installation requiring a permit to operate;

(6) No. 18 Unheated VOC dispensing containers or unheated VOC rinsing containers of 60

gallons (227 liters) capacity or less;

The containers are subject to COMAR 26.11.19.09D, which requires that the Permittee control emissions of volatile organic compounds (VOC) from cold degreasing operations by meeting the following requirements:



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(a) COMAR 26.11.19.09D(2)(b), which establishes that the Permittee shall not use any VOC degreasing material that exceeds a vapor pressure of 1 mm Hg at 20 ° C;

(b) COMAR 26.11.19.09D(3)(a—d), which requires that the Permittee

implement good operating practices designed to minimize spills and evaporation of VOC degreasing material. These practices, which shall be established in writing and displayed such that they are clearly visible to operators, shall include covers (including water covers), lids, or other methods of minimizing evaporative losses, and reducing the time and frequency during which parts are cleaned;

(c) COMAR 26.11.19.09D(4), which prohibits the use of any halogenated

VOC for cold degreasing. The Permittee shall maintain on site for at least five (5) years, and shall make

available to the Department upon request, the following records of operating data:

(a) Monthly records of the total VOC degreasing materials used; and

(b) Written descriptions of good operating practices designed to minimize spills and evaporation of VOC degreasing materials.

(7) 0 Commercial bakery ovens with a rated heat input capacity of less than

2,000,000 Btu per hour; (8) 0 Kilns used for firing ceramic ware, heated exclusively by natural gas, liquefied

petroleum gas, electricity, or any combination of these; (9) 0 Confection cookers where the products are edible and intended for human

consumption; (10) 0 Die casting machines; (11) �� Photographic process equipment used to reproduce an image upon sensitized

material through the use of radiant energy; (12) �� Equipment for drilling, carving, cutting, routing, turning, sawing, planing, spindle

sanding, or disc sanding of wood or wood products; (13) �� Brazing, soldering, or welding equipment, and cutting torches related to

manufacturing and construction activities that emit HAP metals and not directly related to plant maintenance, upkeep and repair or maintenance shop activities;



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(14) 0 Equipment for washing or drying products fabricated from metal or glass, provided that no VOC is used in the process and that no oil or solid fuel is burned;

(15) 0 Containers, reservoirs, or tanks used exclusively for electrolytic plating work, or

electrolytic polishing, or electrolytic stripping of brass, bronze, cadmium, copper, iron, lead, nickel, tin, zinc, and precious metals;

(16) Containers, reservoirs, or tanks used exclusively for:

(a) 0 Dipping operations for applying coatings of natural or synthetic resins that contain no VOC;

(b) 0 Dipping operations for coating objects with oils, waxes, or greases, and

where no VOC is used;

(c) �� Storage of butane, propane, or liquefied petroleum, or natural gas;

(d) No. 75 Storage of lubricating oils;

(e) No. 0 Unheated storage of VOC with an initial boiling point of 300 °F (149 °C) or greater;

(f) No. 14 Storage of Numbers 1, 2, 4, 5, and 6 fuel oil and aviation jet engine fuel;

(g) No. 0 Storage of motor vehicle gasoline and having individual tank capacities

of 2,000 gallons (7.6 cubic meters) or less;

(h) No. 2500 The storage of VOC normally used as solvents, diluents, thinners, inks, colorants, paints, lacquers, enamels, varnishes, liquid resins, or other surface coatings and having individual capacities of 2,000 gallons (7.6 cubic meters) or less;

(17) 0 Gaseous fuel-fired or electrically heated furnaces for heat treating glass or metals,

the use of which does not involve molten materials; (18) Crucible furnaces, pot furnaces, or induction furnaces, with individual capacities of 1,000

pounds (454 kilograms) or less each, in which no sweating or distilling is conducted, or any fluxing is conducted using chloride, fluoride, or ammonium compounds, and from which only the following metals are poured or in which only the following metals are held in a molten state:

(a) 0 Aluminum or any alloy containing over 50 percent aluminum, if no

gaseous chloride compounds, chlorine, aluminum chloride, or aluminum fluoride is used;



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(b) 0 Magnesium or any alloy containing over 50 percent magnesium;

(c) 0 Lead or any alloy containing over 50 percent lead;

(d) 0 Tin or any alloy containing over 50 percent tin;

(e) 0 Zinc or any alloy containing over 50 percent zinc;

(f) 0 Copper;

(g) 0 Precious metals;

(19) �� Charbroilers and pit barbecues as defined in COMAR 26.11.18.01 with a total

cooking area of 5 square feet (0.46 square meter) or less; (20) �� First aid and emergency medical care provided at the facility, including related

activities such as sterilization and medicine preparation used in support of a manufacturing or production process;

(21) �� Certain recreational equipment and activities, such as fireplaces, barbecue pits and

cookers, fireworks displays, and kerosene fuel use; (22) �� Potable water treatment equipment, not including air stripping equipment; (23) 0 Firing and testing of military weapons and explosives; (24) 0 Emissions resulting from the use of explosives for blasting at quarrying

operations and from the required disposal of boxes used to ship the explosive; (25) �� Comfort air conditioning subject to requirements of Title VI of the Clean Air

Act; (26) 0 Grain, metal, or mineral extrusion presses; (27) 0 Breweries with an annual beer production less than 60,000 barrels; (28) 41 Natural draft hoods or natural draft ventilators that exhaust air pollutants into the

ambient air from manufacturing/industrial or commercial processes; (29) 263 Laboratory fume hoods and vents; (30) No. 0 Sheet-fed letter or lithographic printing press(es) with a cylinder width of less

than 18 inches;



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For the following, attach additional pages as necessary: (31) Any other emissions unit, not listed in this section, with a potential to emit less than the

“de minimis” levels listed in COMAR 26.11.02.10X (list and describe units): (no units identified) (32) Any other emissions unit at the facility which is not subject to an applicable requirement

of the Clean Air Act (list and describe): No. 2 Usage of paraformaldehyde to decontaminate biological research suites,

SSP, and equipment. No. 1 Usage of ethylene oxide to decontaminate all laboratory research equipment

and supplies.

(Note: This activity is exempt from the provisions of 40 CFR 63 subpart O, Ethylene Oxide Emissions Standards for Sterilization Facilities under §63.360(d), which exempts research laboratory facilities).



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STATE- ONLY ENFORCEABLE REQUIREMENTS This section of the permit contain state-only enforceable requirements. The requirements in this section will not be enforced by the U.S. Environmental Protection Agency. The requirements in this section are not subject to COMAR 26.11.03 10 - Public Petitions for Review to EPA Regarding Part 70 Permits. 1. FACILITY-WIDE

COMAR 26.11. 06.08 and .09 which generally prohibit the discharge of emissions beyond the property line in such a manner that a nuisance or air pollution is created. COMAR 26.11.15.05 which requires the installation and operation of T-BACT for new installations or sources discharging a toxic air pollutant to the atmosphere. COMAR 26.11.15.06 which prohibits the discharge of toxic air pollutants to the extent that the emissions will unreasonably endanger human health. The Permittee shall certify in writing to the Department the results of an air toxics analysis for the previous calendar year by April 1 of each year during the term of this permit. The air toxics analysis shall include either:

(a) a statement that the previously submitted toxics compliance demonstrations remain valid; or

(b) a new toxics compliance demonstration developed in accordance with the

requirements set forth under COMAR 26.11.15, if the Permittee has made changes to its operations that make the last submitted compliance demonstration invalid.

2. EMISSION UNITS B5 AND B6

Two (2) medical waste incinerators, each rated at 1,000 lbs/hr, located in Bldg. 393. 1. The incinerator may charge up to 400 pounds per charge of animal bedding materials.

Under this circumstance, the incinerator cannot be loaded within the next 24 minutes after such a charge.

2. Radioactive waste shall not be incinerated without having in current effect all required

permits from the Department. The following requirements are from Permit to Construct number 10-2-0066 & 0067 issued by the Department on June 6, 1995:

3. To meet the T-BACT requirement for HCl emissions, the incinerators shall be equipped wet



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collision caustic scrubbers, or equivalent. The scrubbers shall be designed to achieve a removal efficiency of at least 95 percent unless the HCl concentration does not exceed 50 parts per million (ppm) by volume in the dry scrubber exhaust gases corrected to 7 percent oxygen (O2).

4. To meet the T-BACT requirement for incomplete combustion products:

(a) The incinerators shall be equipped with secondary combustion chambers designed to meet a minimum retention time of 2 seconds at 1,800 deg F.

(b) The carbon monoxide (CO) concentration in the secondary combustion chamber

exhaust gas shall not exceed 100 ppm corrected to 7% O2. 5. The incinerators shall be constructed with the following design specifications:

(a) The primary combustion chamber shall have a minimum interior volume of 568 cubic feet;

(b) The secondary combustion chamber shall have a minimum interior volume of

604 cubic feet to meet the T-BACT requirement of a 2 second retention time at 1,800 deg. F.

(c) The incinerators shall be equipped with electronic devices to continuously

monitor and record the temperature of the flue gases exiting the primary and secondary combustion chamber

(d) Continuous emission monitors and recorders shall be installed to continuously

monitor and record the CO and O2. 6. Auxiliary burners shall be used to raise the temperature in the secondary combustion

chamber to greater than 1,700 deg. F prior to charging any special medical waste [T-BACT]. 7. The secondary combustion chambers shall be maintained at a temperature of not less than

1,700 deg. F while the incinerators are charging any special medical waste [T-BACT]. 8. The weight of each charge and the time it is fed into the primary combustion chamber shall

be recorded. 9. The weight of each charge may not exceed one-fifth of the rated hourly burn. The time

interval between two succeeding charges may not be less than the time (T) in minutes determined as follows: T = 60 * (charge/hourly burn rate)



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10. Each incinerator shall not burn more than 1,000 pounds per hour. 11. The scrubbing solution exiting the wet collision scrubber, or equivalent, shall be kept at a

pH of not less than 7.0 while the incinerator is in operation. 12. The temperature of the gas leaving the secondary combustion chamber shall be maintained

at least 1,500 deg. F for at least two hours when the temperature of the gas leaving the primary combustion chamber drops below 1, 400 deg. F.

13. The incinerators and the scrubbers shall be properly maintained and visually inspected daily

to ensure the integrity and good working conditions for each unit operation. Each inspection shall be recorded and maintained on-site.

14. The Permittee shall not use the incinerators to dispose of any waste generated off-site. The Permittee shall retain an outside contractor to haul its special medical waste away for a proper off-site disposal when its incineration system has been shut down for more than four (4) days.

15. Ash shall be visually inspected to assure the complete combustion of infectious waste.

3. EMISSION UNITS B1 AND B4 Two (2) Small Municipal Waste Combustion units, each rated at 39 ton/day, each equipped an emission control system, and heat recovery boilers. The following State-only terms of the Consent Order signed by Fort Detrick on October 12, 2007 and by the Department on October 22, 2007 remain in effect.

"4. Fort Detrick shall complete the Supplemental Environmental Project (SEP) described

below, which the parties agree is intended to secure significant environmental and public health benefits through the reduction of emissions of carbon monoxide, hydrocarbons, particulate, and air toxics. The SEP shall be completed as follows:

"(b) Subject to Subparagraph 4(c), commencing with the first full year following the date

upon which construction of the 20,000-gallon tank is completed pursuant to Paragraph 4(a) of this Consent Order, Fort Detrick shall utilize a minimum of 60,000 gallons of B-20 biodiesel in each calendar year.

"(c) Commencing with the calendar year beginning January 1, 2010, Fort Detrick shall

utilize a minimum of 100,000 gallons of B-20 biodiesel in that year and in each calendar year thereafter.



Page 108 of 108

4. EMISSION UNITS C1 THROUGH C16 16 Emergency diesel generators 500 kW – 2000 kW firing diesel fuel oil.

COMAR 26.11.36.03A(1). The owner or operator of an emergency generator may not operate the generator except for emergencies, testing, and maintenance purposes. COMAR 26.11.36.03A(5). The owner or operator of an emergency generator or load shaving unit may not operate the engine for testing and engine maintenance purposes between 12:01 a.m. and 2:00 p.m. on any day on which the Department forecasts that the air quality will be a code orange, code red, or code purple unless the engine fails a test and engine maintenance and a re-test are necessary.

U. S. ARMY GARRISON AT FORT DETRICK 201 BEASLEY DRIVE, FREDERICK, MD 21702-5000

PART 70 OPERATING PERMIT NO. 24-021-00131

Page 2 of 131

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

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

SECTION II GENERAL CONDITIONS ................................ ........................................ 7

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

SECTION III PLANT WIDE CONDITIONS ............................. ................................. 24

1. PARTICULATE MATTER FROM CONSTRUCTION AND DEMOLITION .......... 24 2. OPEN BURNING ............................................................................................... 24 3. AIR POLLUTION EPISODE ............................................................................... 24 4. REPORT OF EXCESS EMISSIONS AND DEVIATIONS ................................... 24 5. ACCIDENTAL RELEASE PROVISIONS ............................................................ 25 6. GENERAL TESTING REQUIREMENTS ............................................................ 25 7. EMISSIONS TEST METHODS .......................................................................... 26 8. EMISSIONS CERTIFICATION REPORT ........................................................... 26 9. COMPLIANCE CERTIFICATION REPORT ....................................................... 27 10. CERTIFICATION BY RESPONSIBLE OFFICIAL ........................................... 28 11. SAMPLING AND EMISSIONS TESTING RECORD KEEPING ...................... 28 12. GENERAL RECORDKEEPING...................................................................... 29 13. GENERAL CONFORMITY ............................................................................. 29



Page 3 of 131

14. ASBESTOS PROVISIONS ............................................................................ 29 15. OZONE DEPLETING REGULATIONS........................................................... 29 16. ACID RAIN PERMIT ...................................................................................... 30

SECTION IV PLANT SPECIFIC CONDITIONS ......................... .............................. 31

SECTION V INSIGNIFICANT ACTIVITIES .......................... .................................... 124

SECTION VI STATE-ONLY ENFORCEABLE CONDITIONS ................. .............. 128



Page 4 of 131

SECTION I SOURCE IDENTIFICATION 1. DESCRIPTION OF FACILITY Fort Detrick is a Federal military installation located within the city limits of Frederick, Maryland, comprised of the following four noncontiguous parcels: Main Post (728 acres); Area B, including the FLAIR Armory (399 acres); Water Treatment Plant (7 acres); and Sewage Treatment Plant (9 acres). Only the Main Post is subject to Part 70 permitting because its potential emissions are above major source threshold levels for all criteria pollutants, except lead.

Fort Detrick houses several medical research laboratories and a worldwide communications area providing a “hot line” to Moscow and satellite dishes for satellite tracking. Consequently, the facility’s equipment list includes steam generating boilers, space heating boilers, several incinerators, and emergency generators.

The SIC code for the facility is 9711. 2. FACILITY INVENTORY LIST

Emissions

Unit Number

MDE Registration Number(s)

Emissions Unit Name

Emissions Unit Description Date of Installation

A1 and A2 021-0131-5-0116 and 5-0117

Boiler Two (2) Cleaver Brooks Model DL76E natural gas-fired boilers, each rated at 77 MMBtu/hr, located in Bldg 190.

6/13/1990

A1-1 and A2-1

021-0131-5-0267 and 5-0268

Boiler Two (2) Cleaver Brooks Model DL766 natural gas-fired boilers, each rated at 77 MMBtu/hr, located in Bldg. 190.

12/2003

A8 and A9 021-0131-4-0187 and -4-0225

Boiler Two (2) Burnham Model 4F-450 No. 2 fuel oil-fired boilers, each rated at 3.35 MMBtu/hr, located in Bldg. 1673.

01/88 and 12/92

A8-1 and A9-1

021-0131-4-0278 and -4-0279

Boiler Two (2) Burnham natural gas and No. 2 fuel oil-fired boilers, each rated at 3.35 MMBtu/hr, located in Bldg. 1673.

09/2013

A11 021-0131-5-0223

Boiler One (1) H.B. Smith Co. Inc. Model 28A-6 natural gas-fired boiler, rated at 1.827 MMBtu/hr, located in Bldg. 1686.

08/79

A12 021-0131-5-0213

Boiler One (1) Reznor RDF3-280 natural gas-fired boiler, rated at 1.75 MMBtu/hr, located in Bldg. 832.

12/10/96

A14 and A17

021-0131-5-0229 and 5-0230

Boiler Two (2) H. B. Smith Co. Inc. Model 28A-9 natural gas-fired boilers, rated at 2.836 MMBtu/hr, located in Bldg. 1532.

6/30/98

A15 021-0131-5-0231

Boiler One (1) Peerless Model #G-LC-09-WUP natural gas-fired boiler, rated at 1.664 MMBtu/hr, located in Bldg. 1435.

6/29/98

A16 021-0131-5-0239

Boiler One (1) H.B. Smith Co. Inc. Model 28A-7 natural gas-fired boiler, rated at 2.163 MMBtu/hr, located at Bldg. 1507.

1/19/00



Page 5 of 131

Emissions Unit

Number


Emissions Unit Name


A20-1 021-0131-5-0346

Boiler One (1) PVI Industries Model 3000P natural gas fired boiler rated at 2.4 MMBtu/hr located in Bldg. 1507

06/2000

A21 021-0131-5-0292

Boiler One (1) Weil-McLain Model 1088 natural gas fired boiler rated at 2.887 MMBtu/hr, located in Bldg. 1529

01/2006

A23 021-0131-5-0323

Boiler One (1) Raypak Model # P-1223 natural gas fired boiler rated at 1.223 MMBtu/hr, located at Bldg 1507.

08/20/2004

A24 and A25

021-0131-5-0377 and -0378

Boiler Two (2) Bryan Model CLN-270-W natural gas fired boilers rated at 2.7 million Btu/hr, located at Bldg. 693

07/2008

A26 and A27

021-0131-5-0381 and -0382

Boiler Two (2) Weil-McLain Mdl 980 natural gas fired boilers rated at 1.23 million Btu/hr, located at Bldgs. 1545 and 1546

02/2007

A28 021-0131-5-0457

Boiler One (1) Fulton Model PHW-1400 natural gas-fired boiler rated at 1.4 million Btu/hr, located in Bldg. 1419

12/3/2012

B5 and B6 021-0131-2-0066 and 2-0067

Incinerator Two (2) hospital, medical, and infectious waste incinerators (HMIWI), each rated at 1,000 lb/hr and each equipped with an emissions control system and a waste heat recovery boiler, located in Bldg. 393.

06/1995

B1 and B4 021-0131-2-0049 and -0050

Incinerator Two (2) small municipal waste combustion units, ECP Model 2500T, each rated at 39 ton/day and each equipped with an emissions control system and a waste heat recovery boiler, located in Bldg. 393.

1975, modified 2009

C1 and C2 021-0131-9-0101 and 9-0102


Two (2) 993 kW diesel fuel-fired generators, Alban and Caterpillar, located in Bldg. 1425.

01/1985

C3 thru C6 021-0131-9-0148 (registered as a group)


Four (4) 2,000 kW diesel fuel-fired generators, Williams and Lane, located in Bldg. 1673.

1985

C7 021-0131-9-0153

Emergency Diesel Generator

One 900 kW diesel fuel-fired generator, Caterpillar, located in Bldg 1420.

05/1996

C8 021-0131-9-0155


One 880 kW diesel fuel-fired Caterpillar Model 3508 generator located in Bldg. 1414

09/2000

C9 021-0131-9-0202


One 1,502 BHP (1000 kW) diesel fuel-fired Caterpillar Model 3508 generator located in Bldg. 1414

09/2004

C10

021-0131-9-0205


One (1) 2,876 BHP (2000 kW) diesel fuel-fired Caterpillar Model 3516/SR4B generator located in Bldg. 1425

09/2004

C11 021-0131-9-0312


One (1) 600 kW Kohler Model 600REOZv located in Bldg 693

05/2011



Page 6 of 131

Emissions Unit

Number


Emissions Unit Name


C12 021-0131-9-0236


One (1) 764 BHP (570 kW) diesel fuel-fired generator, Caterpillar Model 3456 located at Bldg. 190 (boiler plant)

06/2006

C13 021-0131-9-0209


One (1) 685 BHP (511 kW) diesel fuel-fired generator, Perkins Model CV12TA-RG3 located at Bldg. 810

09/1988

C14 021-0131-9-0317


One (1) 1000 kW Kohler Model 1000REOZMB located in Bldg 568

09/2011

C15 021-0131-9-0353


One (1) 2000 kW Caterpillar Model SR45/3516C located in Bldg 8100

12/2012

C16 021-0131-9-0354


One (1) 500 kW Kohler Model 500REOZJ located in Bldg 1419

12/2012

F1 021-0131-9-0146

Gasoline Storage tanks

Two (2) 12,000-gallon underground gasoline storage tanks, using Stage I vapor recovery systems, fuel feed to 6 dispensers which use Stage II vapor recovery systems

06/2004



Page 7 of 131

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

under COMAR 26.11.01 and .02 unless otherwise stated in this permit. 2. ACRONYMS ARMA Air and Radiation Management Administration BACT Best Available Control Technology Btu British thermal unit CAA Clean Air Act CAM Compliance Assurance Monitoring CEM Continuous Emissions Monitor CFR Code of Federal Regulations CO Carbon Monoxide COMAR Code of Maryland Regulations EPA United States Environmental Protection Agency FR Federal Register gr grains HAP Hazardous Air Pollutant MACT Maximum Achievable Control Technology MDE Maryland Department of the Environment MVAC Motor Vehicle Air Conditioner NESHAPS National Emission Standards for Hazardous Air Pollutants NOx Nitrogen Oxides NSPS New Source Performance Standards NSR New Source Review OTR Ozone Transport Region PM Particulate Matter PM10 Particulate Matter with Nominal Aerodynamic Diameter of 10

micrometers or less ppm parts per million ppb parts per billion PSD Prevention of Significant Deterioration PTC Permit to construct PTO Permit to operate (State) SIC Standard Industrial Classification SO2 Sulfur Dioxide TAP Toxic Air Pollutant tpy tons per year VE Visible Emissions VOC Volatile Organic Compounds



Page 8 of 131

3. EFFECTIVE DATE The effective date of the conditions in this Part 70 permit is the date of permit

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

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

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

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

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

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

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

6. CONFIDENTIAL INFORMATION [COMAR 26.11.02.02G] In accordance with the provisions of the State Government Article, Sec. 10-611

et seq., Annotated Code of Maryland, all information submitted in an application shall be considered part of the public record and available for inspection and copying, unless the Permittee claims that the information is confidential when it is submitted to the Department. At the time of the request for inspection or copying, the Department will make a determination with regard to the confidentiality of the information. The Permittee, when requesting confidentiality,



Page 9 of 131

shall identify the information in a manner specified by the Department and, when requested by the Department, promptly provide specific reasons supporting the claim of confidentiality. Information submitted to the Department without a request that the information be deemed confidential may be made available to the public. Subject to approval of the Department, the Permittee may provide a summary of confidential information that is suitable for public review. The content of this Part 70 permit is not subject to confidential treatment.

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

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

The Department shall reopen and revise, or revoke the Permittee’s Part 70

permit under the following circumstances:

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

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

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

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

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

d. Additional requirements become applicable to an affected source under the

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

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



Page 10 of 131

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

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

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

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

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

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

c. The Permittee may not change any provision of a compliance plan or

schedule in a Part 70 permit as an administrative permit amendment or as a minor permit modification unless the change has been approved by the Department in writing.

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

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

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

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



Page 11 of 131

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

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

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

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

c. Significant permit modifications are subject to all requirements of COMAR

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

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

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

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

to only the application and those federally enforceable terms and conditions of the Part 70 permit that are affected by the significant permit modification.

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

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

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

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

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

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

g. The permit shield in COMAR 26.11.03.23 applies to a final significant permit modification that has been issued by the Department, to the extent applicable under COMAR 26.11.03.23.



Page 12 of 131

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

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

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

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

Clean Air Act;

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

(a) Adding new requirements,

(b) Eliminating the requirements if they are rendered meaningless

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

(c) Changing from one approved test method for a pollutant and

source category to another;

(3) Does not require or modify a:

(a) Case-by-case determination of a federally enforceable emissions standard,

(b) Source specific determination for temporary sources of ambient

impacts, or

(c) Visibility or increment analysis;

(4) Does not seek to establish or modify a federally enforceable permit term or condition for which there is no corresponding underlying applicable requirement of the Clean Air Act, but that the Permittee has assumed to avoid an applicable requirement to which the source would otherwise be subject, including:

(a) A federally enforceable emissions standard applied to the

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



Page 13 of 131

(b) An alternative emissions standard applied to an emissions unit pursuant to regulations promulgated under Section 112(i)(5) of the Clean Air Act

(5) Is not a Title I modification; and

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

significant modification to this Part 70 permit.

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

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

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

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

(2) The proposed minor permit modification;

(3) Certification by a responsible official, in accordance with COMAR

26.11.02.02F, that:

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

(b) The Permittee has obtained or applied for all required permits-

to-construct required by COMAR 26.11.03.16 with respect to the proposed change;

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

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

c. Permittee’s Ability to Make Change

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

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

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

(a) The Permittee shall comply with applicable requirements of the

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



Page 14 of 131

(b) The Permittee is not required to comply with the terms and conditions in the permit it seeks to modify. If the Permittee fails to comply with the terms and conditions in the application during this time, the terms and conditions of both this permit and the application for modification may be enforced against it.

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

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

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

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

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

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

a. An application for an administrative permit amendment shall:

(1) Be in writing;

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

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

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

amendment is requested, including the basis for the request.

b. An administrative permit amendment:

(1) Is a correction of a typographical error;

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

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



Page 15 of 131

(4) Allows for a change in ownership or operational control of a source for which the Department determines that no other revision to the permit is necessary and is documented as per COMAR 26.11.03.15B(4);

(5) Incorporates into this permit the requirements from preconstruction

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

(6) Incorporates any other type of change, as approved by the EPA,

which is similar to those in COMAR 26.11.03.15B(1)—(4);

(7) Notwithstanding COMAR 26.11.03.15B(1)—(6), all modifications to acid rain control provisions included in this Part 70 permit are governed by applicable requirements promulgated under Title IV of the Clean Air Act; or

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

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

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

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

d. The permit shield in COMAR 26.11.03.23 applies to administrative permit

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

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

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

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

COMAR 26.11.03.19 and in accordance with the following conditions:

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

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

COMAR 26.11.02 and .03;



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

Clean Air Act;

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

(4) The change does not violate an applicable requirement of the Clean Air Act or a federally enforceable term or condition of the permit.

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

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

c. Upon satisfying the requirements of COMAR 26.11.03.19, the Permittee

may make the proposed change.

d. The Permittee shall keep a record describing:

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

(2) The emissions resulting from those changes.

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

requirements for Part 70 revisions.

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

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

changes made under COMAR 26.11.03.19.

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



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

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

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

revision to this Part 70 permit if:

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

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

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

COMAR 26.11.02 and .03;

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

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

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

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

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

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

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

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

26.11.03.18.

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

(1) A description of the proposed change;



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

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

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

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

c. The responsible official of this facility shall certify in accordance with

COMAR 26.11.02.02F that the proposed change meets the criteria for the use of on-permit changes under COMAR 26.11.03.18.

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

above to this Part 70 permit.

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

f. Upon satisfying the requirements under COMAR 26.11.03.18, the Permittee

may make the proposed change.

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

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

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

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

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

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

anniversary date of the permit.

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



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

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

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

required, except for generating stations constructed by electric companies;

b. Prevention of Significant Deterioration source, as defined in COMAR 26.11.01.01, approval required, except for generating stations constructed by electric companies;

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

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

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

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

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

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

f. All stationary sources of air pollution, including installations and air pollution

control equipment, except as listed in COMAR 26.11.02.10, permit to construct required;

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

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

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

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

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

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



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

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

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

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

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

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

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

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

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

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

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

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

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



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

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

For information claimed by the Permittee to be confidential and therefore

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

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

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

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

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

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

a. Enforcement action,

b. Permit revocation or revision,

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

d. Any combination of these actions.

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

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

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



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

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

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

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

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

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

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

including the authority of EPA under that section;

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

c. The requirements of the Acid Rain Program, consistent with Section 408(a)

of the Clean Air Act;

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

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

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



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

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



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

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

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

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

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

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

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

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

a. Report any deviation from permit requirements that could endanger human

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

b. Promptly report all occurrences of excess emissions that are expected to

last for one hour or longer by orally notifying the Department of the onset and termination of the occurrence;

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

from permit conditions, including those attributed to malfunctions as defined



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

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

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

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

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

5. ACCIDENTAL RELEASE PROVISIONS [COMAR 26.11.03.03B(23)] and [40 CFR 68] The Permittee shall submit risk management plans by the date specified in 40

CFR 68.150. The Permittee shall certify compliance with the requirements of 40 CFR 68 as

part of the annual compliance certification as required by 40 CFR 70. 6. GENERAL TESTING REQUIREMENTS [COMAR 26.11.01.04] The Department may require the Permittee to conduct, or have conducted,

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



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

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

Reference documents of the test methods approved by the Department include

the following:

a. 40 CFR 60, appendix A

b. 40 CFR 51, appendix M

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

8. EMISSIONS CERTIFICATION REPORT

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

The Permittee shall certify actual annual emissions of regulated pollutants from

the facility on a calendar year basis.

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

b. The individual making the certification shall certify that the information is

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

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

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

c. The Permittee shall maintain records necessary to support the emissions

certification including the following information if applicable:

(1) The total amount of actual emissions of each regulated pollutant and the total of all regulated pollutants;

(2) An explanation of the methods used to quantify the emissions and the

operating schedules and production data that were used to determine emissions, including significant assumptions made;



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

(4) Emissions data from continuous emissions monitors that are required

by this permit, including monitor calibration and malfunction information;

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

equipment and compliance monitoring equipment including:

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

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

significantly affect emissions; and

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

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

a. The compliance certification shall include:

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

basis of the certification;

(2) The compliance status;

(3) Whether the compliance was continuous or intermittent;

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

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

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

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

Department and EPA simultaneously.



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

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

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

prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.”

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

and testing for compliance demonstrations:

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

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

measurements are taken;

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

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

analysis;

e. The analytical techniques and methods used; and

f. The results of each analysis.



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

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

These records and support information shall include:

a. All calibration and maintenance records;

b. All original data collected from continuous monitoring instrumentation;

c. Records which support the annual emissions certification; and

d. Copies of all reports required by this permit. 13. GENERAL CONFORMITY [COMAR 26.11.26.09] The Permittee shall comply with the general conformity requirements of 40 CFR

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

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

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

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

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



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b. Equipment used during the maintenance, service, repair or disposal of appliances shall comply with the standards for recycling and recovery equipment pursuant to 40 CFR 82.158.

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

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

d. Persons performing maintenance, service, repairs or disposal of appliances

shall certify with the Administrator pursuant to 40 CFR 82.162.

e. Persons disposing of small appliances, MVACS, and MVAC-like appliances as defined in 40 CFR 82.152, shall comply with record keeping requirements pursuant to 40 CFR 82.166.

f. Persons owning commercial or industrial process refrigeration equipment

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

g. Owners/operators of appliances normally containing 50 or more pounds of refrigerant shall keep records of refrigerant purchased and added to such appliances pursuant to 40 CFR 82.166.

16. ACID RAIN PERMIT Not applicable



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SECTION IV PLANT SPECIFIC CONDITIONS This section provides tables that include the emissions standards, emissions limitations, and work practices applicable to each emissions unit located at this facility. The Permittee shall comply with all applicable emissions standards, emissions limitations and work practices included herein. The tables also include testing, monitoring, record keeping and reporting requirements specific to each emissions unit. In addition to the requirements included here in Section IV , the Permittee is also subject to the general testing, monitoring, record keeping and reporting requirements included in Section III – Plant Wide Conditions of this permit. Unless otherwise provided in the specific requirements for an emissions unit, the Permittee shall maintain at the facility for at least five (5) years, and shall make available to the Department upon request, all records that the Permittee is required under this section to establish. [Authority: COMAR 26.11.03.06C(5)(g)] 4.1.1 Emissions Unit Number(s) A1 and A2:

• Two (2) Cleaver Brooks Model DL76E natural gas-fired boilers, each rated at 77 million Btu/hr.

4.1.2 Applicable Standards/Limits: A. Visible Emissions Limit:

(1) COMAR 26.11.09.05A(1) which states that, “...a person may not cause or permit the

discharge of emissions from any fuel burning equipment, other than water in an uncombined form, which is greater than 20 percent opacity.”

Exceptions. COMAR Section 26.11.09.05A(3) - “Section A(1) and (2) of this regulation do not apply to emissions during load changing, soot blowing, startup, or occasional cleaning of control equipment which do not exceed 40 percent opacity for a period or periods aggregating not more than 6 consecutive minutes in any 60 minutes.”

(2) 40 CFR 60.43c(d)1 which limits visible emissions to 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity.

B. Control of Nitrogen Oxides

The Permittee shall comply with one of the NOx RACT regulations in Table 4.1a.

Operational Limitations C. After March 31, 2015, the Permittee shall combust only natural gas unless the Permittee

receives a permit or approval from the Department [Authority: COMAR 26.11.02.09A] .

4.1.3

Testing Requirements: A..- C: See Monitoring Requirements.

1 Federal New Source Performance Standards (NSPS) for Small Industrial-commercial-institutional Steam Generating Units with a heat input capacity less than 100 million Btu/hour but greater than 10 million Btu/hour for which construction began after June 9, 1989, 40 CFR 60, Subpart Dc.



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4.1.4 Monitoring Requirements: A. The Permittee shall operate and maintain the boiler in a manner to prevent the visible

emissions by maintaining an Operations Manual and Preventive Maintenance Plan and monitoring in accordance with the Operations Manual and Preventative Maintenance Plan [Authority: COMAR 26.11.03.06C(3)].

B. See Section 4.1a.4 of Table 4.1a.

C. See 4.1.5 C. Record Keeping below

4.1.5 Record Keeping Requirements:

Note: All records shall be kept on site for at least 5 years and made available to the Department upon request [Authority: COMAR 26.11.03.06C(7)].

A. The following apply [Authority: COMAR 26.11.03.06C(3)] :

(1) The Permittee shall keep records of the date and time of visible emissions observations, along with the results of each observation.

(2) The Permittee shall maintain a log of all maintenance performed that relates to

combustion performance.


C. Permittee shall retain monthly fuel usage records for each boiler [Authority: COMAR 26.11.03.06C(3)]..

4.1.6

Reporting Requirements: A. The Permittee shall report incidents of visible emissions in accordance with permit

condition 4 of Section III, Plant Wide Conditions, "Report of Excess Emissions and Deviations."


C. Permittee shall submit records of fuel use as an attachment to the annual emissions certification [Authority: COMAR 26.11.02.19C(2)].



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4.1a.1 Emissions Unit and Number(s): • A1 and A2: Two natural gas-fired Cleaver Brooks boilers, each rated at 77 million Btu/hr,

. • A1-1 and A2-1: Two natural gas-fired Cleaver Brooks boilers, each rated at 77 million

Btu/hr [Permit to Construct 021-5-0267 & -0268 N issued on May 20, 2003]. .

4.1a.2 NOx RACT Applicable Standards/Limits :

B. The Permittee shall comply with one of the following NOx RACT:

(1) COMAR 26.11.09.08F(1) - NOx RACT Requirements for Space Heaters: A person who owns or operates a space heater2 as defined in Regulation .01B of this chapter shall:

(a) Submit to the Department a list of each affected installation on the premises

and the types of fuel used in each installation;

(b) Develop an operating and maintenance plan to minimize NOx emissions based on the recommendations of equipment vendors and other information including the source’s operating and maintenance experience;

(c) Implement the operating and maintenance plan and maintain the plan at the

premises for review upon request by the Department;


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

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

COMAR 26.11.09.08F(2) A person who owns or operates an installation that no longer qualifies as a space heater shall inform the Department no later than 60 days after the date when the fuel burning equipment did not qualify, and shall meet the applicable fuel-burning equipment RACT requirement in this regulation;

(2) COMAR 26.11.09.08E Requirements for Fuel-Burning Equipment with a Rated Heat

Input Capacity of 100 MMBtu/hr or Less; or COMAR 26.11.09.08G(1), Requirements for Fuel-Burning Equipment with a Capacity Factor of 15 Percent or Less. The Permittee shall: (a) Submit to the Department an identification of each affected installation, the rated

heat input capacity of each installation, and the type of fuel burned in each; (b) Perform a combustion analysis and optimize combustion based on the analysis

at least once annually (Note: if an installation operates less than 500 hours per year, COMAR 26.11.09.08G applies and an annual combustion analysis is not

2 COMAR 26.11.09.01B(7) states, "Space heater" means fuel-burning equipment that consumes more than 60 percent of its annual fuel during the period from October 31 of one year through March 31 of the following year. For the purpose of this regulation, annual fuel use is the total fuel consumed during the period October 1 of one year to September 30 of the following year, beginning October 1, 1989.



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required [Authority: COMAR 26.11.09.08E(2) and .08G(1)(b)]; (c) Maintain the results of the combustion analysis at the site for at least 2 years and

make these results available to the Department and the EPA upon request;

(d) Require each operator of an installation to attend operator training programs3 at least once every 3 years on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and

(e) Maintain a record of training program attendance for each operator at the site, and

make these records available to the Department upon request.

4.1a.3 Testing Requirements : B. See Monitoring Requirements.

4.1a.4 Monitoring R equirements: B. The Permittee shall comply with the monitoring requirements associated with the NOx

RACT regulation that applies to the boiler. A boiler that is complying as a “Space Heater” and its operation changes such that it no longer qualifies as a “Space Heater”, shall comply with the requirements of a boiler with a rated heat input of 100 MMBtu per hour or less until such time the boiler operates as a “Space Heater” for one heating season, October 1st till September 30th of the following year.

(1) The Permittee shall develop and implement the operating and maintenance plan and

maintain the plan at the premises for review upon request by the Department [Authority: COMAR 26.11.09.08F(1)(c)]; OR

(2) The Permittee shall perform a combustion analysis for each installation not qualifying

as a space heater, and operating more than 500 hours per year, at least once each year and optimize combustion based on the analysis [Authority: COMAR 26.11.09.08E(2) or .08G(1)(b)].

4.1a.5 Record Keeping Requirements :

B. The Permittee shall comply with the record keeping requirements associated with the NOx

RACT regulation that applies to the boiler. The Permittee shall maintain the following records:

(1) The operating and maintenance plan at the premises for review by the Department

upon request, for a boiler that is complying as a “Space Heater” [Authority: COMAR 26.11.09.08F(1)(c)].

(2) Records of the quantity of fuel burned each month and calculation of heat input in a

manner that the Permittee can determine whether the boiler no longer qualifies as a “Space Heater” [Authority: COMAR 26.11.03.06C(3)].

(3) Records of hours of operation [Authority: COMAR 26.11.02.19.C(1)(b)]

3 COMAR 26.11.09.08B(5)(a) states, “For the purpose of this regulation, the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation.” COMAR 26.11.09.08B(5)(b) states, “The operator training course sponsored by the Department shall include an in-house training course that is approved by the Department.”



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(4) For boiler that do not qualify as space heaters, records of the annual combustion analysis performed if the hours of operation exceed 500 hours per year [Authority: COMAR 26.11.09.08E and .08G(1)(c)].

(5) Records of the training program attendance for each operator at the site [Authority: COMAR 26.11.09.08F(1)(e) or .08E(5)].

4.1a.6 Reporting Requirements :

B. The Permittee shall comply with the following reporting requirements:

(1) For a boiler that is currently complying as a “Space Heater,” the Permittee shall inform the Department no later than 60 days after the date when the boilers no longer qualify as a space heater, and shall meet the requirements under COMAR 26.11.09.08E or identify an alternative NOx RACT requirement under COMAR 26.11.09.08 with which the source will comply [Authority: COMAR 26.11.09.08F(2)].

(2) The Permittee shall submit a list of trained operators and training attendance

records to the Department upon request [Authority: COMAR 26.11.09.08F(1)(e) or .08E(5)].

(3) Permittee shall make the results of the combustion analyses and stack tests

available to the Department and EPA upon request [Authority: COMAR 26.11.09.08E(3)] .

4.2.1 Emissions Unit Number(s)

• A1-1 and A2-1: Two (2) Cleaver Brooks Model DL766 natural gas-fired boilers, each rated

at 77 million Btu/hr [Permit to Construct 021-5-0267 & -0268 N issued on May 20, 2003].

4.2.2 Applicable Standards/Limits: A. Visible Emissions Limitation:

(1) COMAR 26.11.09.05A(1) which states that, “...a person may not cause or permit the discharge of emissions from any fuel burning equipment, other than water in an uncombined form, which is greater than 20 percent opacity.”

Exceptions. COMAR Section 26.11.09.05A(3) - “Section A(1) and (2) of this regulation do not apply to emissions during load changing, soot blowing, startup, or occasional cleaning of control equipment which do not exceed 40 percent opacity for a period or periods aggregating not more than 6 consecutive minutes in any 60 minutes.”

(2) 40 CFR Part 60, Subpart Dc, §60.43c(d) which limits visible emissions to 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity.

B. Control of Nitrogen Oxides.



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(1) The boilers shall be equipped with low NOx burners and flue gas recirculation equipment as necessary to discharge not more than 0.095 lb/million Btu while firing natural gas. [Authority: Permit to Construct Number 021-5-0267& -0268 N issued May 20, 2003]

(2) The total NOx emissions from the two boilers shall not exceed 80.4 tons in any

consecutive 12-month period. [Authority: Permit to Construct Number 021-5-0267 & -0268 N issued May 20, 2003]

(3) NOx RACT requirements - The Permittee shall comply with one of the NOx RACT

regulations in Table 4.1a.

C. Operational Limitations. After March 31, 2015, the Permittee shall combust only natural gas unless the Permittee receives a permit or approval from the Department [Authority: COMAR 26.11.02.09A].

4.2.3

Testing Requirements: A. – B. See Monitoring Requirements.

C. See Record Keeping and Reporting requirements

4.2.4 Monitoring Requirements: A. The Permittee shall operate and maintain the boiler in a manner to prevent the visible

emissions by maintaining an Operations Manual and Preventive Maintenance Plan and monitoring in accordance with the Operations Manual and Preventative Maintenance Plan. [Authority: COMAR 26.11.03.06C(3)].

B. See Table 4.1a for NOx RACT monitoring requirements. C. See Record Keeping and Reporting Requirements.

4.2.5 Record Keeping Requirements:

Note: All records shall be kept on site for at least 5 years and made available to the Department upon request [Authority: COMAR 26.11.03.06C(3) ]

A. The following apply [Authority: COMAR 26.11.03.06C(3)] : (1) The Permittee shall keep records of the date and time of visible emissions observations,

along with the results of each observation.

(2) The Permittee shall maintain a log of all maintenance performed that relates to combustion performance.

B. See record keeping requirements for NOx RACT in Table 4.1a.

C. The Permittee shall retain monthly fuel usage records for each boiler [Authority: COMAR 26.11.03.06C(3)].:



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4.2.6

Reporting Requirements: A. The Permittee shall report incidents of visible emissions in accordance with permit

condition 4 of Section III, Plant Wide Conditions, "Report of Excess Emissions and Deviations."

B. See the reporting requirements for NOx RACT in Table 4.1a

C. The Permittee shall submit records of fuel use as an attachment to the annual emissions certification [Authority: COMAR 26.11.02.19C(2)].


• A8 and A9: Two (2) No. 2 fuel oil-fired boilers, each rated at 3.35 MMBtu/hr.

• A8-1 and A9-1: Two (2) dual-fired boilers firing either natural gas or No. 2 oil, each rated

at 3.35 MMBtu/hr.

4.3.2 Applicable Standards/Limits: A. Visible Emissions Limitations

COMAR 26.11.09.05A(1), which states that “a person may not cause or permit the discharge of emissions from any fuel burning equipment, other than water in an uncombined form, which is greater than 20 percent.”

Exceptions. COMAR Section 26.11.09.05A(3)- “Section A(1) and (2) of this regulation do not apply to emissions during load changing, soot blowing, startup, or occasional cleaning of control equipment which do not exceed 40 percent opacity for a period or periods aggregating not more than 6 consecutive minutes in any 60 minutes.”

B. Control of Sulfur Oxides

COMAR 26.11.09.07A(1)(c), which states that “a person may not burn, sell, or make available for sale any distillate fuel with a sulfur content by weight in excess of 0.3 percent.”

C. Control of Nitrogen Oxides

(1) COMAR 26.11.09.08F(1) A person who owns or operates a space heater as defined in Regulation .01B of this chapter shall:

(a) Submit to the Department a list of each affected installation on the premises

and the types of fuel used in each installation; (b) Develop an operating and maintenance plan to minimize NOx emissions based

on the recommendations of equipment vendors and other information including the source’s operating and maintenance experience;



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(c) Implement the operating and maintenance plan and maintain the plan at the

premises for review upon request by the Department;


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

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

(2) COMAR 26.11.09.08F(2) A person who owns or operates an installation that no longer qualifies as a space heater shall inform the Department no later than 60 days after the date when the fuel burning equipment did not qualify, and shall meet the applicable fuel-burning equipment RACT requirement in this regulation.

(3) COMAR 26.11.09.08B(5) – Operator Training:

(a) For the purpose of this regulation, the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation.

(b) The operator training course sponsored by the Department shall include an in-house training course that is approved by the Department.

[Authority: COMAR 26.11.09.08E(3)] Operational Limitations D. The following requirements apply:

(1) The Permittee shall burn only No. 2 fuel oil in units A8 and A9 and only No. 2 fuel oil or natural gas in units A8-1 and A9-1 unless the Permittee applies for and receives an approval or permit from the Department to burn an alternative fuel [Authority: COMAR 26.11.02.09A].

(2) The Permittee shall conduct initial and subsequent boiler tune-ups in accordance with

the procedures specified in §63.11223(b) [Authority: 40 CFR part 63, subpart JJJJJJ, §63.11201(b), §63.11214(b), §63.11223, and, Table 2, item 12]: (a) Prior to the issuance of this Part 70 Permit, the Permittee shall complete an initial

tune-up of the boilers A8, A9, A8-1, and A9-1 and submit the required Notifications of Compliance Status to the EPA.

(b) The Permittee shall conduct subsequent tune-ups of each boiler every 5 years.

Each 5-year tune-up must be conducted no more than 61 months after the previous tune-up.

4.3.3 Testing Requirements: See Monitoring Requirements.

4.3.4 Monitoring Requirements: A. The Permittee shall properly operate and maintain the boilers in a manner to prevent visible

emissions [Authority: COMAR 26.11.03.06C(3) ].



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B. The Permittee shall obtain a certification from the fuel supplier indicating that the oil

complies with the limitation on the sulfur content of fuel oil [Authority: COMAR 26.11.03.06C(3) ].

C. The Permittee shall develop and implement an operations and maintenance plan [Authority:

COMAR 26.11.09.08F(1)] D. See Recordkeeping and Reporting Requirements.

4.3.5 Record Keeping Requirements : NOTE: All records must be maintained for a period of 5 years [Authority: COMAR 26.11.03.06C(5)(g)]. A. The Permittee shall maintain an operations manual and preventive maintenance plan. The

Permittee shall maintain a log of maintenance performed that relates to combustion performance [Authority: COMAR 26.11.03.06C(3) ]

B. The Permittee shall retain fuel supplier certifications stating that the fuel oil is in compliance

with this regulation [Authority: COMAR 26.11.09.07C]. C. The Permittee shall maintain

(1) The operating and maintenance plan at the premises [Authority: COMAR 26.11.09.08F(1)(c)]

(2) Records of training program attendance for each operator on site for at least 5 years.

[Authority: COMAR 2611.09.08F(1)(e)]

(3) Records of fuel use which demonstrate that the boiler meets the definition of a space heater.[Authority COMAR 26.11.09.08K(3) and COMAR 26.11.03.06C(3) ]

D. The following requirements apply:

(1) The Permittee shall maintain a record of the quantity each type of fuel burned.

[Authority: COMAR 26.11.02.19C(1)(c)]

(2) The Permittee shall maintain the records and copies of all notifications and reports required by 40 CFR §63.11225(c) and (d) make them available to the Department and EPA upon request. The following paragraphs apply [Authority: §63.11225]:

§63.11225(c)(1) requires the Permittee to keep a copy of each notification and report submitted to comply with this subpart and all documentation supporting any Initial Notification or Notification of Compliance Status submitted.

§63.11225(c)(2) requires the Permittee to keep records to document conformance with the work practices, emission reduction measures, and management practices required by §63.11223. §63.11225(c)(2)(i) requires that records must identify each boiler, the date of tune-up, the procedures followed for tune-up, and the manufacturer's specifications to which the boiler was tuned. With regard to the tune-up every 5 years, in accordance with §63.11223(b)(6), the Permittee must maintain the following information [Authority: condition E(1), Permits to Construct 021-0132-4-0278 and -4-279 issued on July 16, 2014, and 40 CFR §63.11223(b)(6)]:



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(a) The concentration of CO in the effluent stream in parts per million, by volume, and

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

(b) A description of any corrective actions taken as part of the tune-up of the boiler. (c) The type and amount of fuel used over the 12 months prior to the tune-up of the

boiler, but only if was physically and legally capable of using more than one type of fuel during that period. Units using a shared fuel meter may estimate the fuel use by each unit.

§63.11225(c)(4) Records of the occurrence and duration of each malfunction of the boiler or of the associated pollution control equipment affecting compliance with a Subpart JJJJJJ requirement §63.11225(c)(5) Records of actions taken during periods of malfunction to minimize emissions in accordance with general duty to minimize emissions in 63,11205(a), including corrective actions to restore the malfunctioning boiler, air pollution or monitoring equipment to its normal or usual manner

§63.11225(d) The records must be in a form suitable and readily available for expeditious review. You must keep each record for 5 years following the date of each recorded action. You must keep each record on-site or be accessible from a central location by computer or by other means that instantly provide access at the site for at least 2 years after the date of each recorded action. You may keep the records off site for the remaining 3 years.

4.3.6 Reporting Requirements:

A. The Permittee shall report incidents of visible emissions in accordance with permit

condition 4, Section III, Plant Wide Conditions, “Report of Excess Emissions and Deviations”

B. The Permittee shall report fuel supplier certifications to the Department upon request

[Authority: COMAR 26.11.09.07C].

C. The following requirements apply:

(1) The Permittee shall submit a list of trained operators and training program attendance to the Department upon request. [Authority: COMAR 26.11.09.08E(5)];

(2) The Permittee shall inform the Department no later than 60 days after the date when the

boilers no longer qualify as a space heater, and shall meet the requirements under COMAR 26.11.09.08E or identify an alternative NOx RACT requirement under COMAR 26.11.09.08 with which the source will comply [Authority: COMAR 26.11.09.08F(2)].

D. The following requirements apply:

(1) The Permittee shall submit a record of the quantity of each type of fuel burned with the annual emissions certification report that is due April 1 of each year. [Authority: COMAR 26.11.02.19C(2)]



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(2) The Permittee is required to submit the following notifications and reports to the Administrator [Authority: §63.11225]:

(a) An Initial Notification must be submitted no later than January 20, 2014 or within 120 days after the source becomes subject to Subpart JJJJJJ of Part 63. [Ref: §63.11225(a)(2)]. Note: For units A8 and A9, the required initial notification of applicability was submitted to EPA and MDE on September 13, 2011. For units A8-1 and A9-1, the initial notification was submitted late on March 10, 2014.

(b) The Permittee shall complete an initial tune-up of the boilers A8, A9, A8-1, and A9-1 and submit the required Notifications of Compliance Status to the EPA.

(c) The Notification of Compliance Status must include the information and

certification(s) of compliance in paragraphs §63.11225(a)(4))(i) through (v), as applicable, and signed by a responsible official [Ref: §63.11225(a)(4)]. (i) You must submit the information required in §63.9(h)(2), except the information

listed in §63.9(h)(2)(i)(B), (D), (E), and (F)…. [Ref: §63.11225(a)(4))(i)] Note: Since the Permittee is not required to conduct performance tests or use CMS and is not subject to any emission limits under 40 CFR part 63, subpart JJJJJJ, Table 1, the requirement to submit this data to the EPA Administrator under paragraph §63.11225(a)(4)(i) does not apply to these emission units.

(ii) Certify that, “This facility complies with the requirements in §63.11214 to conduct an initial tune-up of the boiler.”

(iii) – (v) not applicable.

(vi) The notification must be submitted electronically using the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, the written Notification of Compliance Status must be submitted to the Administrator at the appropriate address listed in §63.13.

(d) Every five (5) years, by March 1 after the tune-ups are conducted, the Permittee

must prepare and submit to the delegated authority, upon request, a compliance certification report that contains the following information [Authority: condition E(2), Permits to Construct 021-0132-4-0278 and -4-279 issued on July 16, 2014; 40 CFR §63.11225(b)]: (i) Company name and address.

(ii) Statement by a responsible official, with the official's name, title, phone

number, email address, and signature, certifying the truth, accuracy and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of this subpart. Your notification must include the following certification(s) of compliance, as applicable, and signed by a responsible official: a. “This facility complies with the requirements in §63.11223 to conduct a 5-

year tune-up of each boiler.”



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b. If the source experiences any deviations from the applicable requirements

during the reporting period, include a description of deviations, the time periods during which the deviations occurred, and the corrective action taken


• A11: One natural gas-fired boiler rated at 1.827 MMBtu/hr. • A12: One natural gas-fired boiler rated at 1.75 MMBtu/hr. • A14 and A17: Two natural gas-fired boilers, each rated at 2.836 MMBtu/hr. • A15: One natural gas-fired boiler rated at 1.664 MMBtu/hr. • A16: One natural gas-fired boiler rated at 2.163 MMBtu/hr. • A20-1: One natural gas fired boiler rated at 2.4 MMBTU/hr. • A21: One natural gas-fired boiler rated at 2.887 MMBTU/hr. • A23: One natural gas-fired boiler rated at 1.223 MMBTU/hr. • A24 and A25: Two natural gas-fired boilers, each rated at 2.7 MMBTU/hr. • A26 and A27: Two natural gas-fired boilers, each rated at 1.23 MMBTU/hr. • A28: One natural gas-fired boiler rated at 1.4 MMBTU/hr.

4.4.2 Applicable Standards/Limits: A. Visible Emissions Limitations

COMAR 26.11.09.05A(1) - states that “a person may not cause or permit the discharge of emissions from any fuel burning equipment, other than water in an uncombined form, which is greater than 20 percent.”

Exceptions. COMAR Section 26.11.09.05A(3)- “Section A(1) and (2) of this regulation do not apply to emissions during load changing, soot blowing, startup, or occasional cleaning of control equipment which do not exceed 40 percent opacity for a period or periods aggregating not more than 6 consecutive minutes in any 60 minutes.”

B. Control of Nitrogen Oxides

COMAR 26.11.09.08F – Requirements for Space Heaters. (1) “A person who owns or operates a space heater as defined in Regulation .01B of this

chapter shall:

(a) Submit to the Department a list of each affected installation on the premises and the types of fuel used in each installation;

(b) Develop an operating and maintenance plan to minimize NOx emissions based on the recommendations of equipment vendors and other information including the source’s operating and maintenance experience;

(c) Implement the operating and maintenance plan and maintain the plan at the premises for review upon request by the Department;




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(e) Prepare and maintain a record of training program attendance for each operator at the site, and make these records available to the Department upon request.”

(2) “A person who owns or operates an installation that no longer qualifies as a space

heater shall inform the Department no later than 60 days after the date when the fuel burning equipment did not qualify, and shall meet the applicable fuel-burning equipment RACT requirement in this regulation.

(3) COMAR 26.11.09.08B(6) – Operator Training.

(a) For the purpose of this regulation, the equipment operator to be trained may be

the person who maintains the equipment and makes the necessary adjustments for efficient operation.

(b) The operator training course sponsored by the Department shall include an in-house training course that is approved by the Department

Operational Limitations C. The Permittee shall burn only natural gas unless the Permittee applies for and receives an

approval or permit from the Department to burn an alternative fuel [Authority: COMAR 26.11.02.09A].

4.4.3 Testing Re quirements : See Monitoring Requirements.

4.4.4 Monitoring Requirements:

A. The Permittee shall properly operate and maintain the boilers in a manner to prevent

visible emissions [Authority: COMAR 26.11.03.06C(3) ]. B. The Permittee shall develop and implement an operations and maintenance plan

[Authority: COMAR 26.11.09.08F(1)]. C. See Recordkeeping and Reporting Requirements.

4.4.5 Record Keeping Requirements : NOTE: All records must be maintained for a period of 5 years [Authority: COMAR 26.11.03.06C(5)(g)]. A. The Permittee shall maintain an operations manual and preventive maintenance plan. The

Permittee shall maintain a log of maintenance performed that relates to combustion performance [Authority: COMAR 26.11.03.06C(3) ]

B. The Permittee shall maintain

(1) The operating and maintenance plan at the premises [Authority: COMAR 26.11.09.08F(1)(c)]

(2) Records of training program attendance for each operator on site for at least 5 years.

[Authority: COMAR 2611.09.08F(1)(e)]

(3) Records of fuel use that demonstrate the boiler meets the definition of a space heater.[Authority COMAR 26.11.09.08K(3) and COMAR 26.11.03.06C(3) ]



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C. The Permittee shall maintain a record of the quantity each type of fuel burned. [Authority: COMAR 26.11.02.19C(1)(c)]

4.4.6 Reporting Require ments:

A. The Permittee shall report incidents of visible emissions in accordance with permit

condition 4, Section III, Plant Wide Conditions, “Report of Excess Emissions and Deviations”

B. (1) The Permittee shall submit a list of trained operators and training program attendance

to the Department upon request. [Authority: COMAR 26.11.09.08E(5)]

(2) The Permittee shall inform the Department no later than 60 days after the date when the boilers no longer qualify as a space heater, and shall meet the requirements under COMAR 26.11.09.08E or identify an alternative NOx RACT requirement under COMAR 26.11.09.08 with which the source will comply [Authority: COMAR 26.11.09.08F(2)];

C. The Permittee shall submit a record of the quantity of each type of fuel burned with the

annual emissions certification report that is due April 1 of each year. [Authority: COMAR 26.11.02.19C(2)]


• B5 and B6: Two (2) hospital, medical, and infectious waste incinerators (HMIWI), each

rated at 1,000 lb/hr and each with a rotary atomizing scrubber, a pre-particulate filter, an activated carbon adsorption module, and a post-particulate filter, for PM, metals, dioxins/furans, and acid gas emissions control, and a waste heat recovery boiler.

4.5.2 Appl icable Standards/Limits :

A. COMAR 26.11.08.08-1A(2) - The source is subject to the following emission standards for

large HMIWIs as promulgated in the Federal Register on September 15, 1997, and remain applicable until the source comes into full and final compliance in accordance with regulation COMAR 26.11.08.08-2 and its related 111(d)/129 plan revision. COMAR 26.11.08.08-2A Notwithstanding the requirements of regulation COMAR 26.11.08.08-1, the emission standards of §B(1)-(7) of regulation COMAR 26.11.08.08-2 apply to a person who owns and operates an HMIWI subject to 40 CFR part 60, subpart Ce, as revised on October 6, 2009 . COMAR 26.11.08.08-2B(1) - The source is subject to the following emission standards for large HMIWIs as promulgated on October 6, 2009. [Authority: 40 CFR part 62, subpart HHH, §62.14411 -12(a)].

40 CFR part 62, subpart HHH, §62.14412(a) states: “Your HMIWI (regardless of size category) must not discharge into the atmosphere from the stack any gases that exhibit greater than 6 percent opacity (6-minute block average).”

The emission limits, stack opacity, and visible emissions of this subpart apply at all times [Authority: 40 CFR part 60 subpart Ec, §60.56c(a) and 40 CFR part 62, subpart HHH, §62.14413].



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Pollutant Units

(7 percent oxygen, dry basis)


10/06/2009* Emission Limits For Large HMIWI

PM milligrams per dry standard cubic meter (gr per dry standard gr/dscf)

34 (0.015) 25 (0.011)

Opacity 6 minute block average percent

10 6

CO ppm by volume 40 11

Dioxins/furans nanograms per dry standard cubic meter total dioxins/furans (gr per billion dscf) or nanograms per dry standard cubic meter TEQ (gr per billion dscm)

125 (55) or 2.3 (1.0)

9.3 (4.1) or 0.054 (0.024)


ppm by volume or percent reduction

100 or 93%

6.6

SO2 ppm by volume 55 9.0

NOx ppm by volume 250 140

Lead milligrams per dry standard cubic meter (gr per thousand dscf) or percent reduction

1.2 (0.52) or 70%

0.036 (0.016)

Cadmium milligrams per dry standard cubic meter (gr per thousand dscf) or percent reduction

0.16 (0.07) or 65%

0.0092 (0.0040)

Mercury milligrams per dry standard cubic meter (gr per thousand dscf) or percent reduction

0.55 (0.24) or 85%

0.018 (0.0079)

*On October 6, 2009 , revised Emission Guidelines for existing HMIWI were promulgated as a final rule in the Federal Register and are applicable to large HMIWI constructed before June 20, 1996.

B. COMAR 26.11.08.08-2B(3) [ §62.14430 – 32] Waste Management Plan. The Permittee

shall prepare a Waste Management Plan that identifies the feasibility and the approach to solid waste segregation or material substitution to reduce the amount of toxics emissions. The Waste Management Plan shall meet the requirements of 40 CFR §60.55c, Subpart Ec. A revised Waste Management Plan shall be submitted to the Department within 60 days of completion of the required initial compliance tests under this regulation.

C. COMAR 26.11.08.08-2D[ §62.14440 – 43] Initial and Annual Equipment and Control Device Inspection Requirements.

a. COMAR 26.11.08.08-2D(1)-(3) specifies the initial and subsequent annual inspection

requirements that each HMIWI undergo beginning June 15, 2012 and that all necessary repairs be completed within 10 operating days unless otherwise approved by the Department. The inspections shall include as a minimum the following [Ref: §62.14442(a)]:



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(a) Inspect all burners, pilot assemblies, and pilot sensing devices for proper

operation and clean pilot flame sensor, as necessary; (b) Ensure proper adjustment of primary and secondary chamber combustion air,

and adjust as necessary;

(c) Inspect hinges and door latches, and lubricate as necessary;

(d) Inspect dampers, fans, and blowers for proper operation;

(e) Inspect HMIWI door and door gaskets for proper sealing;

(f) Inspect motors for proper operation;

(g) Inspect primary chamber refractory lining; clean and repair or replace lining as necessary;

(h) Inspect incinerator shell for corrosion or hot spots, or both;

(i) Inspect secondary/tertiary chamber and stack and clean as necessary;

(j) Inspect mechanical loader, including limit switches, for proper operation, if applicable;

(k) Visually inspect waste bed (grates), and repair or seal, as appropriate;

(l) For the burn cycle that follows the inspection, document that the incinerator is operating properly and make any necessary adjustments;

(m) Inspect air pollution control device or devices for proper operation, if applicable;

(n) Inspect waste heat boiler systems to ensure proper operation, if applicable;

(o) Inspect bypass stack components;

(p) Ensure proper calibration of thermocouples, sorbent feed systems and any other monitoring equipment;

(q) Include inspection elements according to manufacturer’s recommendations [Ref: §62.14442(a)(17)]; and

(r) Generally observe that the equipment is maintained in good operating condition. b. COMAR 26.11.08.08-2D(4)-(5) specifies that beginning June 15, 2012, the control

devices of an HMIWI shall undergo an initial and subsequent annual inspections that include the following [Ref: §62.14442(b)]:

(a) Inspect air pollution control device(s) for proper operation;

(b) Ensure proper calibration of thermocouples, sorbent feed systems, and any

other monitoring equipment;



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(c) Include inspection elements according to manufacturer’s recommendations [Ref: §62.14442(b)(3)];

(d) Generally observe that the equipment is maintained in good operating

condition; and

(e) Within 10 operating days following an air pollution control device inspection, all necessary repairs shall be completed unless the owner or operator obtains written approval from the Department establishing a date whereby all necessary repairs of the designated facility shall be completed.

D. Operator Training Requirements [40 CFR part 62, subpart HHH, §62.14420- 21(a].

§62.14420: “You must have a fully trained and qualified operator, either at your facility or able to be at your facility within 1 hour. The trained and qualified HMIWI operator may operate the HMIWI directly or be the direct supervisor of one or more HMIWI operators.” §62.14421(a): “ The HMIWI operator can obtain training and qualification through a State-approved program or as provided in paragraph (b) of this section” COMAR 26.11.08.09B - Certification and Operation Requirement. “A person may not operate or allow an incinerator to be operated unless the owner certifies to the Department on a form provided by the Department that each incinerator operator:”

(1) has completed an initial training course approved by the Department which meets the requirements of section COMAR 26.11.08.09C or D of this regulation;

(2) annually, after initial certification, completes a review course approved by the

Department; and

(3) that a properly trained incinerator operator is present at all times whenever the incinerator is in operation.

COMAR 26.11.08.09C - Training Course for Operators of Special Medical Waste or Industrial Waste Incinerators

(1) For any incinerator operator who operates a special medical waste or industrial waste

incinerator, the training course shall be the “Hospital Incinerator Operator Training course” Volumes I—III (EPA-450/3-89-003, EPA-450/3-89-004, EPA-450/3-89-010, respectively), Control Technology Center, March 1989, which is incorporated by reference, and “Operation and Maintenance of Hospital Medical Waste Incinerators” (EPA-450/3-89-002), Control Technology Center, March 1989, which is incorporated by reference.

(2) For the operator of any special medical waste or an industrial waste incinerator,

completing a training course means:

(a) completing an initial training course approved by the Department of at least 3 days (24 hours) duration; and

(b) passing a written test approved by the Department.



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(3) The certified operator shall, after initial training, complete and pass an annual review course approved by the Department of at least 1 day (8 hours) duration.

(4) For an HMIWI subject to the requirements of this chapter, a person is qualified to

operate an HMIWI if the person passes the training course required in §C(2) and (3) of this regulation and complies with the requirements in 40 CFR §60.53c(d).

E. Plan for Compliance. The Permittee shall comply with the following milestones based on the Plan for Compliance submitted by the Permittee and as subsequently amended and specifying a final compliance date of October 6, 2014 in accordance with 40 CFR part 60, subpart Ce, §60.39e and COMAR 26.11.08.08-2E(2); 40 CFR part 62, subpart HHH, §62.14470(b), [Authority: COMAR 26.11.08.08-2E(2) and COMAR 26.11.03.06C]

Award contracts for control systems or process modifications or orders for purchase of components and; submit a signed copy of the contract(s) to the Department Initiate on-site construction or installation of the air pollution control devices; Complete on-site construction or installation of control equipment or process changes; By October 6, 2014, achieve final compliance. This includes incorporating all process changes and/or completing all retrofit construction as described in the final control plan, connecting the air pollution control equipment or process changes such that the HMIWI is brought on line, and ensuring that all necessary process changes and air pollution control equipment are operating properly By 180 days after October 6, 2014, demonstrate final compliance with the October 6, 2009 emission limits by conducting an initial performance test meeting 40 CFR §60.58c(b) requirements demonstrating final compliance with the October 6, 2009 limit. By 45 days after completing an initial performance test , submit an initial report including the results of the performance tests.

4.5.3 Testing Requirements :

A. The following emissions testing requirements apply:

(1) Except as provided in A(2) below, the Permittee shall demonstrate initial compliance with the October 6, 2009 emission limits for PM, opacity, CO, dioxin/furan, Pb, Cd, Hg, SO2, and NOx by conducting initial performance tests on each incinerator train no later than 180 days after the final compliance date October 6, 2014 on each incinerator train using the applicable procedures and test methods listed in §60.56c(b)(1) through (14) cited below. The use of the bypass stack during a performance test shall invalidate the performance test [Authority: 40 CFR part 62 subpart HHH, §62.14451(a) and §62.14452(r); COMAR 26.11.08.08-2B(4), which references §60.56c; §60.56c(b) –(c)].

(2) For opacity, CO, SO2,and NOx, the Permittee may use the results of previous

emissions tests to demonstrate compliance with the emission limits provided the emissions tests meet the criteria specified in paragraphs §60.37e(f) and §62.14451(e) [Authority: 40 CFR part 62, subpart HHH, §62.14451(a) and (e)]



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Pollutant or Parameter

40 CFR part 60 Subpart Ec Reference

40 CFR part 62 Subpart HHH Reference

Reference Method (40 CFR Part 60, Appendix A)

Sampling location and number of traverse points

§60.56c(b)(3) §62.14452(c) Method 1, Appendix A-1,

Gas composition analysis, including oxygen concentration

§60.56c(b)(4) §62.14452(d) Method 3, 3A or 3B, Appendix A-2,

Particulate Emissions (PM)

§60.56c(b)(6) §62.14452(f) Method 5, Appendix A-3, or Method 26A, Appendix A-8, or Method 29, Appendix A-8.

Stack Opacity §60.56c(b)(9) §62.14452(i) Method 9, Appendix A-4

Carbon Monoxide (CO) §60.56c(b)(10) §62.14452(j) Method 10 or 10B, Appendix A-4

Dioxins/Furans §60.56c(b)(11) §62.14452(k) Method 23, Appendix A-7.


§60.56c(b)(12) §62.14452(l) Method 26 or 26A, Appendix A-8.

Sulfur Dioxide (SO2) §60.56c(b)(8) §62.14452(g) Method 6 or 6C, Appendix A-4

Nitrogen Oxides (NOx) §60.56c(b)(7) §62.14452(h) Method 7 or 7E, Appendix A-4

Lead (Pb) Cadmium (Cd) Mercury (Hg)

§60.56c(b)(13) §62.14452(m) Method 29, Appendix A-8

(3) The following requirements apply to all performance tests used to determine compliance with emission limits:

(a) Prior to conducting any compliance stack test, the Permittee shall submit a test

protocol to the Department for approval at least 30 days prior to the scheduled test date. The Permittee shall submit a copy of the results of compliance stack tests to the Department within 45 days after the date the test was completed [Authority: condition E(4), Permit to Construct 021-0131-2-0066 & 0067 M issued on May 1, 2014]

(b) All performance tests shall consist of a minimum of three test runs conducted

under representative operating conditions [Authority: §62.14452(a) §60.56c(b)(1)]

(c) The minimum sample time must be one hour per test run unless otherwise

indicated in the applicable test method [Authority: §62.14452(b); §60.56c(b)(2)]. (d) EPA Reference Method 1 of 40 CFR Part 60, appendix A-1 shall be used to

select the sampling location and number of traverse points [Authority: §62.14452(c); §60.56c(b)(3)] .

(e) EPA Reference Method 3 or 3A, or 3B of 40 CFR Part 60 , appendix A -2 shall

be used for gas composition analysis, including measurement of oxygen concentration. EPA Reference Method 3. 3A, or 3B of 40 CFR Part 60, appendix A-2 shall be used simultaneously with each reference method.. The Permittee may use ASME PTC-19-10-1981-Part 10 (incorporated by



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reference in 40 CFR 60.17) as an alternative to EPA Reference Method 3B. [Authority: §62.14452(d); §60.56c(b)(4)].

(f) The pollutant concentrations shall be adjusted to 7 percent oxygen using the

following equation [Authority: §62.14452(e); §60.56c(b(5)].

Cadj = Cmeas (20.9 - 7.0)/(20.9 - %O2) where: Cadj = pollutant concentration adjusted to 7 percent oxygen; Cmeas = pollutant concentration measured on a dry basis (20.9 - 7.0) = 20.9 percent Oxygen - 7 percent oxygen (defined oxygen correction basis);

20.9 = Oxygen concentration in air, percent; and %O2 = Oxygen concentration measured on a dry basis, percent.

(4) The Permittee shall determine compliance with the emission limits for PM, CO, and

HCl by conducting an annual performance test (no more than 12 months following the previous performance test) using the applicable procedures and test methods listed in §60.56c(b)(1) –(14) above. (a) If all three performance tests over a 3-year period indicate compliance with the

emission limit for a pollutant (PM, CO, or HCl), the Permittee may forego a performance test for the next 2 years.

(b) At a minimum the Permittee must conduct a performance test for PM, CO, and

HCl every third year. (c) If a performance test every third year indicates compliance with the emission

limit for a pollutant (PM, CO or HCl), the Permittee may forego a performance test for that pollutant for an additional 2 years.

(d) If any performance test indicates noncompliance with the respective emission

limit, the Permittee must conduct a performance test for that pollutant annually until all performance tests over a 3-year period indicate compliance with the emission limit.

(e) The use of the bypass stack during a performance test shall invalidate the performance test

[Authority: 40 CFR part 62, subpart HHH, §62.14451(a), (b), and §62.14452; COMAR 26.11.08.08-2B(4), which references 40 CFR §60.56c; §60.56c(c)(2)].

(5) Additionally, the Permittee shall perform annual performance stack tests for

dioxins/furans and mercury in accordance with the following timing requirements [Authority: Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014]:

(a) The annual performance test shall be performed no later than 12 months

after the previous stack test, (b) The annual performance test shall be performed prior to the replacement

of the activated carbon in the adsorption system.



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(c) Condition (5)(a) above may be waived by the Department if the replacement of activated carbon is deferred beyond the 13 month period in accordance with condition D(5), Permit to Construct 021-0131-2-0066 and -0067 issued on May 1, 2014.

(d) Within 48 hours before each dioxins/furans and mercury performance test, verify the amount [volume or weight (cubic feet, pounds)] of activated carbon

(6) The Permittee shall establish during the initial and any subsequent performance tests

the following set of alternative site-specific operating parameters approved by the Department and EPA [Authority: 40 CFR part 62, subpart HHH, §62.14453(b)(2); 40 CFR §60.56c(j); letter from Diana Esher, Director, Air Protection Division, USEPA Region III, dated April 22, 2014; Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014]:

(a) Maximum charge rate - in accordance with 40 CFR §60.51c by the following :

For continuous and intermittent HMIWI, 110 percent of the lowest 3-hour average charge rate measured during the most recent performance test demonstrating compliance with all applicable emission limits.

(b) Minimum secondary chamber temperature - means 90 percent of the highest 3-hour average secondary chamber temperature (taken, at a minimum, once every minute) measured during the most recent performance test demonstrating compliance with the PM, CO, dioxin/furan, and NOx emissions limits.

(c) Minimum rotary atomizing scrubber amperage - 90 percent the highest 3-hour

average rotary atomizing scrubber amperage taken, at a minimum, once every minute, measured during the most recent performance test demonstrating compliance with all applicable emission limits.

(d) Minimum rotary atomizing scrubber pH – 90 percent of the highest 3-hour

average scrubber liquor pH (taken, at a minimum, once every minute) measured during the most recent performance test demonstrating compliance with the HCl emission limit.

(e) Maximum rotary atomizing scrubber temperature – for the purposes of this permit,

means 17 ºC (30.6 ºF) more than the lowest 3-hour average flue gas temperature at the outlet from the rotary atomizing scrubber prior to entering the steam coil re-heating unit (taken, at a minimum, once every minute) measured during the most recent performance tests demonstrating compliance with the dioxin/furans (D/F) and mercury (Hg) emission limits.

(f) Maximum carbon adsorption system inlet temperature - means 17 ºC (30.6 ºF)

more than the lowest 3-hour average flue gas temperature (taken, at a minimum, once every minute), at the inlet to the carbon adsorption system at a position after the steam coil re-heating unit but before the particulate pre-filter (T2), measured during the most recent performance test demonstrating compliance with the dioxin/furan (D/F) and mercury (Hg) emissions limit., whichever is lower.

(g) Maximum post-filter differential pressure - The greater differential pressure across

the MERV-12 or better second section of the post-filter determined during the most recent performance tests demonstrating compliance with the emission limitations for dioxins/furans, particulate matter, lead, cadmium, and mercury as



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determined by consideration of the following: (a) 0.5 inch of water column (WC) more than the highest 3-hour average differential pressure (inches WC) measured during the performance tests or (b) 110 percent of the highest 3-hour average differential pressure (inches WC) determined during the performance tests.

Post-filter means - a filter utilizing fiber particulate filters similar in design and function to a HVAC grade filter located after the activated carbon adsorption system and consists of two sections. The first section is a MERV-8 filter or better, or tested filters used during the most recent performance tests for PM, dioxins/furans, Pb, Cd, or Hg, for intercepting large diameter particles followed by a filter of MERV-12, or equivalent or better as determined during the most recent performance tests for PM, dioxins/furans, Pb, Cd, or Hg, for intercepting small diameter particles down to 1.0 micron in size or smaller.

(7) The Permittee may conduct a repeat performance test within 30 days of violation of

applicable operating parameter(s) to demonstrate that the HMIWI is not in violation of the applicable emissions limit(s). The Permittee must conduct repeat performance tests pursuant to this paragraph using the identical operating parameters that indicated a violation under or paragraphs (b), (c), (d), (e), or (f) of section §62.14455 (or paragraphs (e), (f), (g), or (h) of section §60.56c(i) [Authority: 40 CFR part 62, subpart HHH, §62.14452(g); COMAR 26.11.08.08-2B(4), §60.56c(i)].

(8) The Permittee may conduct a repeat performance test in accordance with §62.14452 [or §60.56c(k)] at any time to establish new values for the operating parameters [Authority: 40 CFR part 62, subpart HHH, §62.14455(i); COMAR 26.11.08.08-2B(4), §60.56c(k)].

(9) The EPA Administrator may request the Permittee to perform a repeat performance test at any time [Authority: 40 CFR part 62, subpart HHH, §62.14451(d); COMAR 26.11.08.08-2B(4), §60.56c(k)].

B- E. No emissions testing requirements under these paragraphs.

4.5.4 Monitoring Requirements: A. The Permittee shall comply with the monitoring requirements under 40 CFR §60.57c,

subpart Ec, subject to A(1) and A(2) below [Authority: §62.14453 and §62.14454; COMAR 26.11.08.08-2B(5)]: (1) Exemptions. A person may elect to use the exemptions listed under 40 CFR §§

60.56c(c)5)(ii) through (v), (c)(6), (c)(7), (e)(6) through (10), (f)(7) through (10), (g)(6) through (10) and (h) for HMIWI units subject to .08-2B(1) [Authority: COMAR 26.11.08.08-2B(5(a)].

(2) Alternative Compliance Option for CO. COMAR 26.11.08.08-2B(5(b) provides that,

“ A person may elect to use CO CEMS as specified under 40 CFR §60.56c(c)(4) …” Subpart HHH §62.14452(o) also provides that, if the Permittee is using a CEMS to demonstrate compliance with any of the emissions limits under §§62.14411 or 62.14412, the Permittee:: (a) Must determine compliance with the appropriate emissions limit(s) using a 12-

hour rolling average, calculated as specified in section 12.4.1 of EPA Reference Method 19 of 40 CFR part 60, appendix A-7. Performance tests



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using EPA Reference Methods are not required for pollutants monitored with CEMS [Ref: §62.14452(o)(1)]. Note: The more stringent averaging time from subpart HHH is being used. See fact sheet.

(b) Must operate a CEMS to measure oxygen concentration, adjusting pollutant concentrations to 7 percent oxygen as specified in §60.56c(b)(5) or §62.14452(e) [Ref: §62.14452(o)(2)].

(c) Must operate all CEMS in accordance with the applicable procedures under

appendices B and F of 40 CFR part 60 [Ref: §62.14452(o)(3)]. (d) May substitute use of a CO CEMS for the CO annual performance test and

minimum secondary chamber temperature to demonstrate compliance with the CO emissions limit.[Ref: §62.14452(o)(4)]

(3) If the Permittee elects to use a CO CEMS meeting the requirements of 40 CFR

part 60, appendices B and F to demonstrate compliance with the CO emissions limits and the CEMS indicates compliance with the CO emissions limit during periods when operating parameters indicate a violation of the CO emissions limit, then the Permittee is considered to be in compliance with the emissions limit and a repeat performance test is not required to demonstrate compliance [Authority: §62.14455(h) and §60.57c(c)].

(4) The Permittee shall obtain monitoring data at all times during HMIWI operation except during periods of monitoring equipment malfunction, calibration, or repair. At a minimum, valid monitoring data shall be obtained for 75 percent of the operating hours per day and for 90 percent of the operating days per calendar quarter that the affected facility is combusting hospital waste and/or medical/infectious waste [Authority: 40 CFR §62.14454(d) and §60.57c(e)]

(5) The Permittee shall comply with the requirement to monitor the bypass stack by using the following alternative methodology, which the Department deems as an acceptable alternative to continuously recording the status of the bypass stack [Authority: 40 CFR §62.14454(b) and §60.57c(c)]:

(a) The bypass stack shall be equipped with guillotine dampers to prevent exhaust

gases from leaking out through the bypass stack. [Authority: conditions C(6), Permits to Construct 10-2-0066 & 0067 N issued on June 6, 1995].

(b) The incinerator shall be equipped with an interlock to the waste feed system to prevent the loading of additional waste to the incinerator whenever the flue gases are diverted to the bypass stack. The bypass stack guillotine dampers shall be equipped with limit switches to detect when the dampers are open. The incinerators shall be equipped with an interlock device that will halt the ram feeders if the dampers are open [Authority: C(7), Permits to Construct 10-2-0066 & 0067 N issued on June 6, 1995].

(c) The incinerator shall be equipped with an audible alarm that sounds and a control panel indicator that displays a notification to the operator whenever the bypass stack is in use.

(d) The operator shall record in the daily operator log any use of the bypass stack

including date, time, and duration.



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(6) The Permittee shall continuously monitor and maintain the specified averages for the following operating parameters, 1-hour average and a 3-hour moving average, computed once each hour. The limits apply at all times except as noted in condition (7) below [Authority: condition E(6), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].

(a) Limit the 3-hour average HMIWI unit charge rate to no more than the maximum charge rate (110 percent of the lowest 3-hour average charge rate measured during the most recent performance tests demonstrating compliance with all applicable emission limits).

(b) Maintain the 3-hour average rotary atomizing (collision) scrubber flow rate

(GPM) and amperage at least at 90 percent of the highest level established during the most recent performance tests for all applicable emission limits.

(c) Maintain the 3-hour average rotary atomizing scrubber pH at least at 90

percent of the highest level established during the most recent performance test demonstrating compliance with the HCl emission limit.

(d) Maintain the 3-hour average secondary chamber temperature at least at 90

percent of highest secondary chamber temperature established during the most recent performance test demonstrating compliance with the PM, CO, dioxin/furan, and NOx emissions limits [Ref: 40 CFR §60.51c]

(e) Continuously limit the carbon filter outlet temperature (T3) at least 15 ºF or

more than the rotary atomizing scrubber outlet temperature (T1) to prevent condensation.

(f) The carbon filter outlet temperature (T3) shall not exceed 80 ºC. (g) Limit the 3-hour average activated carbon adsorption system inlet

temperature (T2) to no more than 17 ºC (30.6 ºF) more than the lowest 3-hour average flue gas temperature (taken, at a minimum, once every minute), at the inlet to the carbon adsorption system at a position after the steam coil re-heating unit but before the particulate pre-filter, measured during the most recent performance test demonstrating compliance with the dioxin/furan (D/F) and mercury (Hg) emissions limit.

(h) Limit the 3-hour average differential pressure across the post-filter second

section, rated at MERV 12, or equivalent or better, as determined during the performance tests, to no more than 0.5 inch WC greater than the highest level established during the most recent performance tests for dioxins/furans, PM, lead, cadmium, and mercury, or if this quantity is larger, 110 percent of the highest level established during the most recent performance tests for dioxins/furans, PM, lead, cadmium, and mercury.

(i) Record the pre-filter and post-filter specifications (Make, Model No., and

MERV rating), at every replacement period to demonstrate the operational use of replacement filters consistent with, or better than, those filters used during the most recent performance tests for PM, Pb, D/F Hg, and Cd.

(j) Limit the 3-hour average differential pressure drop across the activated carbon

adsorption unit to less than 7.2 inches WC.



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(7) The operating parameter limits stated in paragraphs (6)(a) through (d), (g), and (h) above do not apply during performance tests conducted to reestablish the operating parameter limits [Ref: 40 CFR §60.56c(d)(2)]. The operating parameter limits stated in paragraphs (6)(d) and (e) do not apply during startup, prior to the loading of the first charge to the HMIWI unit [Authority: condition E(7), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].

(8) The Permittee shall maintain a fixed bed activated carbon adsorption system totaling at least 3,800 pounds of activated carbon in each unit, and replace the entire amount of carbon with fresh carbon at intervals not to exceed 13 months, unless the Permittee can demonstrate to the satisfaction of the Department that a lesser replacement rate or a lesser amount of activated carbon will not lead to a violation of the emission standard for either dioxins/furans or mercury [Authority: condition D(5), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].

(9) The Permittee shall change the particulate pre-filter sections to the carbon

adsorption unit each operating day, unless the pressure drop across the pre-filter section is less than 1.0 inch WC at the end of the operating day [Authority: condition D(6), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].

(10) The Permittee shall change the, MERV-8, or equivalent or better, first section to the

post-filter each operating day, unless the pressure drop across that section is less than 1.0 inch WC at the end of the operating day [Authority: condition D(7), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].

(11) The Permittee shall change the MERV-12, or equivalent or better, second section of

the post-filter when the pressure drop across that section cannot be maintained less than the following: (a) 0.5 inch WC more than the highest 3-hour average pressure differential established during the applicable performance tests, or if this quantity is larger, 110 percent of the highest 3-hour average pressure differential established during the applicable performance tests [Authority: condition D(8). Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].

(12) The following surrogate indicators of compliance with emission limitations apply to this facility [Authority: 40 CFR §60.56c(j); letter from Diana Esher, Director, Air Protection Division, USEPA Region III, dated April 22, 2014; page 17, Permit to Construct 021-0131-2-0066 and -2-0067 M issued on May 1, 2014]:

Operating Parameter Violation(s) on 3-hour rolling averaged values

Related Pollutant Emission Violation(s)

1. Operation above the maximum charge rate and simultaneously below the minimum rotary atomizing scrubber amperage [Ref: §60.56c(f)(1)]

PM emission limit.

2. Operation above the maximum charge rate and simultaneously below the minimum secondary chamber temperature [Ref: §60.56c(f)(2)].

CO emission limit.

3. Operation above the maximum charge rate, below the minimum secondary chamber temperature, and below the minimum rotary

Dioxin/furan emission limit.



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� Ope

� Operational parameter requirements No. 1 through No. 4 and No 6. are from the existing Federal rule.

� Operational parameter requirements No. 5, No. 7, and No. 8 are new

additions . � The post-filter is comprised of a 2” thick HVAC-type pre-filter MERV-8 or better,

or tested filter used during the most recent performance tests, and 12” thick HVAC cartridge type final filter MERV-12 or equivalent or better, as determined during the most recent performance tests for PM, dioxin/furans, Pb, Cd, and Hg

� All operating parameters shall be evaluated for compliance on a 3-hour rolling

average except for use of the bypass stack. B. - D. No emissions monitoring requirements are included under these paragraphs. E. Plan for Compliance Requirements - The Permittee shall keep all of the test result

records necessary to establish evidence of compliance with the milestones.

atomizing scrubber liquor flow rate simultaneously [Ref: §60.56c(f)(3)]

4. Operation above the maximum charge rate, and below the minimum rotary atomizing scrubber liquor pH simultaneously [Ref: §60.56c(f)(4)].

HCl emission limit

5 . Operation above the maximum charge rate, the maximum rotary atomizing scrubber outlet temperature, and above the maximum activated carbon adsorption system inlet temperature simultaneously [Ref: §60.56c(e)(2) and §60.56c(f)(5)]

Dioxins/furans and mercury emission limits

6. Use of the bypass stack [Ref: §60.56c(f)(6)] . PM, dioxin/furan, HCl, Pb, Cd, and Hg emission limits

7. Minimum 30 ºF flue gas temperature rise across the steam reheat coil based on a 3-hour average of inlet versus outlet temperatures [i.e., T2 – T1 ≥ 30 ºF]

Dioxins/furans and mercury emission limits.

8. Operation above the maximum post-filter differential pressure (DP-4) [Ref: §60.56c(j)].

PM, dioxin/furan, Pb, and Cd, emission limits

4.5.5 Record Keeping Requirements : Generally applicable to A. – D;. All records specified under paragraph (b) of 40 CFR 60.58c, shall be maintained onsite in either paper copy or computer-readable format, unless an alternative format is approved by the Administrator [Authority: COMAR 26.11.08.08-2B(6), 40 CFR part 60, subpart Ec, §60.58c(f); 40 CFR part 62, subpart HHH, §62.14462 ]



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A. The Permittee shall maintain for at least five (5) years and shall make them available to the Department upon request, records of the following information, as applicable. [Authority: COMAR 26.11.08.08-2B(6), 40 CFR part 60, subpart Ec, §60.58c; and 40 CFR part 62, subpart HHH, §62.14460-62 condition F(1), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].


§60.58c(b) (2) Records of the following data:

(i) Concentrations of any pollutant listed in § 60.52c or measurements of opacity as determined by the continuous emission monitoring system (if applicable);

(iii) HMIWI charge dates, times, and weights and hourly charge rates;

Note: §60.58c(b)(2)(ii), (iv) – (viii), (x), (xii ), (xviii) and (xix) and §60.58c(b)(7) do not apply to this facility.

(ix) Secondary chamber temperatures recorded during each minute of operation;

(xi) Horsepower or amperage and recirculated flow rate (GPM) to the rotary atomizing (wet) scrubber during each minute of operation, as applicable;

(xiii) Temperature at the outlet from the rotary atomizing (wet) scrubber during each minute of operation (xiv) pH at the inlet to the rotary atomizing (wet) scrubber during each minute of operation.

(xv) Records indicating use of the bypass stack, including dates, times, and durations, and (xvi) For affected facilities complying with § 60.56c(j) and § 60.57c(d), the owner or operator shall maintain all operating parameter data collected; The following applies: (xvi)-1 Temperature of the flue gas leaving the wet scrubber at a point prior to the inlet of the steam reheat coil (T1), recorded once each minute. (xvi)-2 Temperature of the flue gas at a point leaving the steam re-heat coil and entering the activated carbon adsorption system (T2), recorded once each minute

(xvi)-3 Temperature of the flue gas leaving the activated carbon adsorption system at a point located after the particulate matter post-filter (T3), recorded once each minute.

(xvi)-4 Temperature rise across the reheat coil (T2 – T1), recorded once each minute. (xvi)-5 Temperature rise across the add-on control system (T3 –T1), recorded once each minute. (xvi)-6 Pressure drop across the activated carbon adsorption unit, in inches WC (DP-2), recorded at least at 5 minute intervals.



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(xvi)-7 Pressure drop across each pre-filter section in inches WC (DP-1A and DP-1B), (if more than one section is installed) recorded at least at 5 minute intervals. (xvi)-8 Pressure drop across the post-filter first section in inches WC, (DP-3) recorded at least at 5 minute intervals. (xvi)-9 Pressure drop across the post-filter second section in inches WC, (DP-4) recorded at least at 5 minute intervals. (xvi)-10 The pre-filter and post-filter specifications (Make, Model No., and MERV rating), shall be recorded at every replacement period to demonstrate the operational use of replacement filters consistent with, or better than, those filters used during the most recent performance tests for PM, Pb, D/F Hg, and Cd.

(xvi)-11 The activated carbon performance specifications (density, particle size, specific surface area (cm2/g ) from each activated carbon vendor. (xvi)-12 The amounts of activated carbon replaced, including the date and the hours of operation of the HMIWI unit since the previous replacement of carbon, including the vendor’s performance specifications.

§60.58c(b)(3): Identification of calendar days for which data on emission rates or operating parameters specified under paragraph (b)(2) of §60.58c, have not been obtained, with an identification of the emission rates or operating parameters not measured, reasons for not obtaining the data, and a description of corrective actions taken. §60.58c(b)(4): Identification of calendar days, times and duration of malfunctions, a description of the malfunction and the corrective action taken. §60.58c(b)(5): Identification of calendar days for which data on emission rates or operating parameters specified under paragraph (b)(2) of §60.58c exceeded the applicable limits, with a description of the exceedances, reasons for such exceedances, and a description of corrective actions taken. §60.58c(b)(6): The results of the initial, annual, and any subsequent performance tests conducted to determine compliance with the emission limits and/or to establish operating parameters, as applicable, and a description, including sample calculations, of how the operating parameters were established or re-established, if applicable. §60.58c(b)(7) siting requirements documentation not required §60.58c(b)(11): Records of calibration of any monitoring devices as required under §60.57c (a), (b), and (c),

B. Waste Management Plan. The Permittee shall keep the waste management plan on-site

and make it available authorized inspectors upon request [Authority: COMAR 26.11.03.06C(3)].

C. Equipment inspection records. The Permittee shall maintain for at least five (5) years

and shall make available to the Department upon request, records of the following information [Authority: COMAR 26.11.08.08-2B(6); 40 CFR part 62, subpart HHH, §62.14460-62; and condition F(1), Permit to Construct 021-0131-2-0066 and -0067 M issued on May 1, 2014].



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§60.58c(b(2)(xvii) Records of the annual air pollution control device inspections, any required maintenance and any repairs not completed within 10 days or the timeframe established by the EPA Administrator or the Department upon delegation of authority.

§62.14460(14) Records of the annual equipment inspections, any required maintenance and any repairs not completed within 10 days or the timeframe established by the EPA Administrator or the Department upon delegation of authority.

D. Operator Training Requirements.

(4) The Permittee shall keep the following records onsite for at least 5 years:

§60.58c(b)(1) Calendar date of each record; §60.58c(b)(8) Records showing the names of HMIWI operators who have completed review of the information in §60.53c(h) as required by §60.53c(i), including the date of the initial review and all subsequent annual reviews. §60.58c(b)(9) Records showing the names of the HMIWI operators who have completed the operator training requirements, including documentation of training and the dates of training; §60.58c(b)(10) Records showing the names of the HMIWI operators who have met the criteria under §60.53c and the dates of their qualification; and

(5) The Permittee shall maintain documentation of training (operator training manual) on site and update the documentation annually at the time of the annual review course. The documentation shall be as specified in 40 CFR §60.53c(h) [Authority: COMAR 26.11.08.09C(5)].

E. Plan for Compliance. The Permittee shall keep all of the records necessary to establish evidence of compliance with the milestone dates.

4.5.6 Reporting Requirements :

A. The Permittee shall report to the Department and the EPA in accordance with the requirements listed in 40 CFR §60.58c(b) through (g), excluding 40 CFR §60.58c(b)(2)(viii) and 60.58c(b)(2)(xvii) and (b)(2)(xix) [Authority: COMAR 26.11.08.08-2B(6); 40 CFR part 62, subpart HHH, §62.14463-65]. (1) In accordance with §60.58c(c), the Permittee shall submit the information

specified below no later than 60 days following the initial performance test. All reports shall be signed by the facilities manager:

(a) The initial performance test data as recorded under § 60.56c(b)(1)

through (14), as applicable;

(b) The values of the site specific operating parameters established pursuant to §60.56c(d), (h) or (j) as applicable.



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(2) In accordance with §60.58c(d) – (e), the Permittee shall submit semiannual reports no later than 60 days following the reporting period. The first semiannual reporting period ends 6 months following the submission of information in paragraph (c) of 40 CFR 60.58c. The semiannual report shall include the information specified in paragraphs (d)(1) through (d)(9) and (d)(11) of 40 CFR 60.58c. Subsequent reports shall be submitted no later than 6 calendar months following the previous report. All reports shall be signed by the facilities manager. (a) The values for the site-specific operating parameters established

pursuant to §60.56c(d), (h), or (j), as applicable [Ref: §60.58c(d)(1)]. (b) The highest maximum operating parameter and the lowest minimum

operating parameter, as applicable, for each operating parameter recorded for the calendar year being reported, pursuant to § 60.56c(d), (h), or (j), as applicable. [Ref: §60.58c(d)(2)]

(c) The highest maximum operating parameter and the lowest minimum

operating parameter, as applicable, for each operating parameter recorded pursuant to § 60.56c(d), (h), or (j) for the calendar year preceding the year being reported, in order to provide the Administrator with a summary of the performance of the affected facility over a 2-year period. [Ref: §60.58c(d)(3)]

(d) Any information recorded under paragraphs (b)(3) through (b)(5) of 40

CFR 60.58c, for the calendar year being reported. [Ref: §60.58c(d)(4)] (e) Any information recorded under paragraphs (b)(3) through (b)(5) of 40

CFR 60.58c, for the calendar year preceding the year being reported, in order to provide the Administrator with a summary of the performance of the affected facility over a 2-year period. [Ref: §60.58c(d)(5)]

(f) If a performance test was conducted during the reporting period, the

results of that test. [Ref: §60.58c(d)(6)] (g) If no exceedances or malfunctions were reported under paragraphs

(b)(3) through (b)(5) of 40 CFR §60.58c, for the calendar year being reported, a statement that no exceedances occurred during the reporting period. [Ref: §60.58c(d)(7)].

(h) Any use of the bypass stack, the duration, reason for malfunction, and

corrective action taken. [Ref: §60.58c(d)(8)].

(i) Concentrations of CO determined by a CO CEMS, if the Permittee elects to determine compliance with the CO emission limit using a CEMS [Ref: §60.58c(d)(11)] .

B. The Permittee shall submit a revised waste management plan as specified in §60.55c,

signed by the facilities manager, no later than 60 days following the initial performance tests required under regulation COMAR 26.11.08.08-2 [Authority: COMAR 26.11.08.08-2B(3) and 40 CFR §60.58c(c)(3)].



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C. The Permittee shall include in the semiannual reports referenced in A(2) above records of the annual equipment and air pollution control device inspection, any required maintenance, and any repairs not completed within 10 days of an inspection or the timeframe established by the EPA Administrator or the Department [Authority: §60.58c(d)(9) and §62.14463(12) –(13)].

D. No reporting requirements under this paragraph.

E. Plan for Compliance. The Permittee shall provide monthly progress reports to the

Department, due within 10 business days after the end of the calendar month, on the control implementation as stated in the Plan for Compliance. The reports shall include dates and projected dates for interim activities, such as ordering control devices, site preparation, initial startup, and initial compliance tests [Authority: condition E(1), Permit to Construct 021-0131-2-0066 and -0067 M].

4.6.1

Emissions Unit Number(s) : • B1 and B4: Two (2) small municipal waste combustion units, ECP Model 2500T, each rated

at 39 ton/day and each equipped with an emission control system and waste heat recovery boiler, located in Bldg. 393.

4.6.2 Applicable Standards/Limits : A. Visible Emissions/Opacity Limitations:

COMAR 26.11.08.04A(1) The Permittee may not cause or permit the discharge of emissions from any incinerator or hazardous waste incinerator, other than water in an uncombined form, which is greater than 20 percent opacity. COMAR 26.11.08.04A(1) does not apply to emissions during start-up, or adjustments or occasional cleaning of control equipment: (1) the visible emissions are not greater than 40 percent opacity; and (2) the visible emissions do not occur for more than 6 consecutive minutes in any 60 minute period [Ref: COMAR 26.11.08.04C]. COMAR 26.11.08.07 A person may not operate a municipal waste combustor that has a burning capacity of 35 tons or more per day and less than or equal to 250 tons per day that was constructed on or before August 30, 1999 which results in violation of the provisions of 40 CFR 62 Subpart JJJ [Ref: 40 CFR Part 62 , Subpart JJJ Table 4]. Opacity 10 percent Thirty 6-minute

averages

Fugitive ash Visible emissions Three 1-hour for no more than observation periods. 5 percent of hourly

observation period. B. Control of Particulate Matter [40 CFR Part 62 , Subpart JJJ Table 4]:

70 milligrams per dry stack test,

standard cubic meter. 3-run average (run duration (adjusted to 7 percent specified in test method)



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oxygen, dry basis) C. Control of Carbon Monoxide [40 CFR Part 62 , Subpart JJJ Table 5]

50 parts per million 4-hour block average,

by dry volume (adjusted to arithmetic mean 7 percent oxygen, dry basis) determined by CEM D. Control of Nitrogen Oxides [40 CFR Part 62, Subpart JJJ Table 4]

500 parts per million 24-hour daily block by dry volume (adjusted to arithmetic average 7 percent oxygen, dry basis) (no monitoring required) E. Control of Sulfur Dioxide [40 CFR Part 62, Subpart JJJ Table 4]

77 parts per million 24-hour daily block by dry volume (adjusted to geometric average concentration 7 percent oxygen, dry basis) determined by CEM -or- 75 percent reduction of 24-hour daily block potential sulfur dioxide geometric average emissions percent reduction determined by CEMs F. Control of Lead Emissions: [40 CFR Part 62, Subpart JJJ Table 4] (adjusted to 7 percent oxygen, dry basis)

1.6 milligrams stack test, per dry standard 3-run average (run duration cubic meter. specified in test method) G. Non-Criteria Pollutant Emissions Limits [40 CFR Part 62, Subpart JJJ Table 4] (adjusted to 7 percent oxygen, dry basis)

Dioxins/furans: 125 nanograms Stack test. 3- run average, (total mass basis) per dry standard (minimum run duration cubic meter. is 4 hours)

Cadmium 0.10 milligrams per Stack test. 3- run average, dry standard cubic (run duration specified meter in test method) Mercury 0.080 milligrams per Stack test. 3- run average, dry standard cubic (run duration specified meter in test method) -or- 85 percent reduction of potential mercury emissions Hydrogen 250 parts per million Stack test. 3-run average Chloride by dry volume (minimum run

-or- duration is 1 hour)



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50 percent reduction of potential hydrogen chloride emissions.

The following applies to the Subpart JJJ emission limits in 4.6.2 A. - G above.

§62.15165 What happens to the emission limits duri ng periods of startup, shutdown, and malfunction?

(a) The emission limits of this subpart apply at all times except during periods of municipal waste combustion unit startup, shutdown, or malfunction. (b) Each startup, shutdown, or malfunction must not last for longer than 3 hours. (c) A maximum of 3 hours of test data can be dismissed from compliance calculations during periods of startup, shutdown, or malfunction. (d) During startup, shutdown, or malfunction periods longer than 3 hours, emissions data cannot be discarded from compliance calculations and all provisions under § 60.11(d) of subpart A of 40 CFR part 60 apply.

Operational Limitations:

H. Operational Limits from 40 CFR 62, Subpart JJJ.

(1) No later than December 31, 2009, the Permittee must install and commence continuous operation of the quenching and acid gas absorption towers, rotary atomizing scrubbers, the carbon adsorption systems, and continuous emission monitoring systems (CEMS) to monitor opacity, sulfur dioxide, carbon monoxide and oxygen, and other such modifications and control technology as is necessary to achieve compliance with the emission standards of 40 CFR 62, Subpart JJJ. The CEMS must be installed in accordance with 40 CFR 62, Subpart JJJ [Authority: conditions C(2) and D(2), Permit to Construct 021-0131-2-0049 & - 0050, issued on January 30, 2009]. (2) By no later than December 31, 2010, the Permittee must be in compliance with all applicable operating requirements of 40 CFR Part 62, Subpart JJJ, including the alternative requirements approved by the EPA Administrator in accordance with §62.15405 [Authority: letter from Judith M. Katz, Director, Air Protection Division, U.S. EPA Region III and attached Federal Plan Subpart JJJ Rule Provision Alternatives for the U.S. Army (Owner/Operator) Ft. Detrick Facility, dated January 14, 2009; condition D(3), Permit to Construct 021-0131-2-0049 & - 0050, issued on January 30, 2009]. (3) The Permittee shall maintain the specified block averages for the following operating parameters [Authority: condition D(5), Permit to Construct 021-0131-2-0049 & -0050 issued on January 30, 2009].

(a) Maintain the 4-hour block average rotary atomizing scrubber amperage at least at 90

percent of the highest level established during the most recent performance tests for all §129 pollutants [Ref: Alternative requirement §62.15145(c)(2) and §62.15410].

(b) Maintain the 4-hour block average rotary atomizing scrubber pH at least at 90 percent

of the highest level established during the most recent performance test demonstrating compliance with the HCl emission limit [Ref: Alternative requirement



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§62.15145(c)(1) and §62.15410]. (c) Limit the 4-hour block averages of the rotary atomizing scrubber inlet temperature and

activated carbon adsorption system inlet temperature to no more than 17ºC (30.6ºF) above the highest level established during the most recent performance test demonstrating compliance with either the dioxins/furans or mercury emission limits, whichever is lower [Ref: Alternative requirements §62.15145(b) and §62.15145(c)(3)-(4) and the corresponding §62.15410 definitions].

(d) Limit the 4-hour block average activated carbon adsorption system outlet temperature

to no more than 110 percent of the highest level established during the most recent performance test demonstrating compliance with either the dioxins/furans or mercury emission limits, whichever is lower. However, in no case shall the 4-hour block average activated carbon adsorption system outlet temperature exceed 155 ºF or 68 ºC [Ref: Alternative requirements §62.15145(b) and §62.15145(c)(5) and the corresponding §62.15410 definitions].

(e) Limit the 4-hour block average differential pressure across the carbon adsorption

system to no more than 0.5 inches or water column greater than the highest level established during the most recent performance tests for dioxins/furans and mercury, or if this quantity is larger, 110 percent of the highest level established during the most recent performance tests for dioxins/furans and mercury [Ref: Alternative requirement §62.15145(c)(6) and the corresponding §62.15410 definition].

(f) Limit the 4-hour block average differential pressure across the HVAC grade pre-filter

and HVAC grade post-filter each to no more than 0.5 inches of water column greater than the highest level established during the most recent performance tests for dioxins/furans, PM, lead, cadmium, and mercury, or if this quantity is larger, 110 percent of the highest level established during the most recent performance tests for dioxins/furans, PM, lead, cadmium, and mercury [Ref: Alternative requirement §62.15145(c)(7)-(8) and the corresponding §62.15410 definition].

(g) Comply with §62.15145(a) by not operating the municipal waste combustion unit at

loads greater than 110 percent of the maximum demonstrated load of the municipal waste combustion unit as defined in §62.15410.

(h) In keeping with alternative condition §62.15145(e) approved by EPA, parts (a)-(g) above do not apply during the stack tests for particulate matter, dioxins/furans, or mercury emissions.

(4) In keeping with alternative requirement §62.15145(d) approved by EPA, the Permittee shall maintain a fixed bed activated carbon adsorption system, consisting of two beds, totaling at least 2800 pounds of carbon and replace the entire amount of carbon with fresh carbon at intervals not to exceed 13 months, unless the Permittee can demonstrate to the satisfaction of the Department and the EPA Administrator that a lesser replacement rate will not lead to a violation of the emission standard for either dioxins/furans or mercury [Authority: condition D(6), Permit to Construct 021-0131-2-0049 & -0050 issued on January 30, 2009]. (5) The following includes approved Federal Plan Subpart JJJ Rule Provision Alternatives for the U.S. Army (Owner/Operator) Ft. Detrick Facility, dated January 6, 2009. Letter from Judith M. Katz, Director, Air Protection Division, U.S. EPA Region III, dated January 14, 2009.



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[Added.] Indicates a new or additional requirement has been added to the original subpart JJJ requirement [Revised.] Indicates the original subpart JJJ requirement has been revised or amended.

§62.15410 Definitions [Added.]

Maximum demonstrated load of a municipal waste combustion unit means the highest 4-hour block arithmetic average municipal waste combustion unit load achieved during 4 consecutive hours in the course of the most recent dioxins/furans stack test that demonstrates compliance with the applicable emission limit for dioxins/furans specified in [Subpart JJJ].

Maximum demonstrated temperature of the particulate matter control device means the highest 4-hour block arithmetic average flue gas temperature measured at the inlet of the particulate matter control device during 4 consecutive hours in the course of the most recent stack test for dioxins/furans emissions that demonstrates compliance with the limits specified in [Subpart JJJ]. [Added.] Minimum rotary atomizing scrubber liquor pH means: 90 percent of the highest 4-hour average liquor pH at the inlet to the scrubber (taken, at a minimum, once every minute) measured during the most recent performance test demonstrating compliance with the HCl emission limit. [Added.] Minimum rotary atomizing scrubber pump flow rate (or rotary atomizing scrubber amperage) means: 90 percent the highest 4-hour average rotary atomizing scrubber liquor flow rate at the outlet of the pump (or rotary atomizing scrubber amperage) taken, at a minimum, once every minute, measured during the most recent performance test demonstrating compliance with all 129 pollutant emission limits. [Added.] Maximum activated carbon adsorption system exhaust temperature means: 110 percent of the highest 4-hour average system outlet temperature (Fahrenheit) measured during the most recent performance test demonstrating compliance with either the dioxins/furans limit or mercury emission limits, whichever is lower. In no case shall the exhaust temperature exceed 155 degrees Fahrenheit or 68 º Centigrade (4-hour average). [Added.] Maximum activated carbon adsorption system differential pressure means: The greater differential pressure determined during the most recent performance test demonstrating compliance with either the emission limitation for dioxins/furans, or mercury as determined by a consideration of the following: (a) 0.5 inch of water column (WC) more than the highest 4-hour average system differential pressure (inches WC) measured during the performance tests, or (b) 110 percent of the highest 4-hour average differential pressure (inches WC) determined during the performance tests. In no case shall the differential pressure exceed 7.2 inch WC . [Added.] Industrial Heating, Ventilating and Air Conditioning (HVAC) grade filter system means: A filter system utilizing fiber particulate filters similar in design and function to a HVAC grade filter that is located after the activated carbon adsorption system and consists of two stages, a pre-filter for intercepting large diameter particles followed by a post-filter for intercepting small diameter particles down to 1.0 micron in size.



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[Added.] Maximum pre-filter differential pressure means: The greater differential pressure determined during the most recent performance test demonstrating compliance with the emission limitations for dioxins/furans, particulate matter, lead, cadmium, and mercury, as determined by consideration of the following: (a) 0.5 inch of water column (WC) more than the highest 4-hour average pre-filter differential pressure (inches WC) measured during the performance tests, or (b) 110 percent of the highest 4-hour average differential pressure (inches WC) determined during the performance tests. [Added.] Maximum post-filter differential pressure means: The greater differential pressure determined during the most recent performance test demonstrating compliance with the emission limitations for dioxins/furans, particulate matter, lead, cadmium, and mercury as determined by consideration of the following: (a) 0.5 inch of water column (WC) more than the highest 4-hour average post-filter differential pressure (inches WC) measured during the performance tests or (b) 110 percent of the highest 4-hour average differential pressure (inches WC) determined during the performance tests. [Added.] Bypass stack means: A device used for discharging combustion gases to avoid severe damage to the air pollution control device or other equipment.

§62.15145 What are the operating practice requireme nts for my municipal waste combustion unit? (a) You must not operate your municipal waste combustion unit at loads greater than 110 percent of the maximum demonstrated load of the municipal waste combustion unit (4-hour block average), as specified under ``Definitions'' (§62.15410). (b) [Revised.] You must not operate your MWC unit so that the temperature at the inlet of the particulate control device, except for the Industrial Heating, Ventilating and Air Conditioning (HVAC) filter system described in §62.15145(f), exceeds 17 0 C (Centigrade) above the maximum demonstrated temperature of the particulate matter control device (4-hour block average), as specified under “Definitions”, §62.15410. (c) [Added.] For a MWC unit that uses a quench tower, rotary atomizing scrubber, and fixed activated carbon bed, and a HVAC grade filter system to control acid gases, heavy metals, and dioxins/furans, you must maintain a 4-hour block average for the following nine operating parameter levels, as defined in §62.15410, as amended below:

(1) Minimum rotary atomizing scrubber liquor pH; (2) Minimum rotary atomizing scrubber pump flow rate or minimum rotary atomizing scrubber amperage (The owner/operator must identify either flow rate or amperage as the operating parameter with submittal of the initial compliance test report.); (3) Maximum rotary atomizing scrubber inlet temperature; (4) Maximum activated carbon adsorption system inlet temperature; (5) Maximum activated carbon adsorption system exhaust temperature (6) Maximum activated carbon adsorption system differential pressure; (7) Maximum differential pressure across the pre-filter; (8) Maximum differential pressure across the post-filter; and (9) Maximum demonstrated load of the MWC unit.



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Surrogate Indicators of Compliance with Emission Li mitations

Operating Parameter Violation(s) Related Pollutant Emission Violation(s)

1. Minimum rotary atomizing scrubber liquor pH

HCl

2. Minimum rotary atomizing scrubber pump flow rate or rotary atomizing scrubber amperage

All 129 pollutants, except CO, NOx, and SO2

3. Maximum rotary atomizing scrubber inlet temperature plus 17 ºC *


4. Maximum activated carbon adsorption system inlet temperature plus 17 ºC *


5. Maximum activated carbon adsorption system exhaust temperature**


6. Maximum activated carbon adsorption system differential pressure


7. Maximum pre-filter differential pressure. Dioxins/furans, PM, lead, cadmium, and mercury

8. Maximum post-filter differential pressure. Dioxins/furans, PM, lead, cadmium, and mercury

9. Maximum demonstrated load of the MWC unit times 1.1

All 129 pollutants

(d) [Revised] Maintain a fixed bed activated carbon adsorption system, consisting of two beds, totaling at least 2,800 pounds of activated carbon. Replace the entire amount of carbon with fresh activated carbon at intervals not to exceed 13 months unless the owner/operator can demonstrate to the satisfaction of the Maryland Department of the Environment and EPA Administrator that a lesser replacement rate will not lead to a violation of the emissions standard for either dioxins/furans or mercury (e) [Revised] Your municipal waste combustion unit is exempt from limits on load level, temperature at the inlet of the particulate matter control device (.e., the rotary atomizing scrubber) , during any of five situations:

(1) During your annual tests for dioxins/furans. (2) [not applicable.] (3) During the 2 weeks preceding your annual tests for dioxins/furans. (4) [not applicable.] (5) Whenever the Administrator permits you to do any of five activities:

(i) Evaluate system performance. (ii) Test new technology or control technologies. (iii) Perform diagnostic testing. (iv) Perform other activities to improve the performance of your municipal waste combustion unit. (v) Perform other activities to advance the state of the art for emission controls for your municipal waste combustion unit.

(f) [Added.] The §62.15145(c) pre and post filter differential pressure operational requirements, parameters 7 and 8, will not be considered an indicator of SMWC unit compliance for a listed pollutant, except for particulate matter, providing the owner/operator demonstrates through three consecutive annual performance tests, as required under §62.15240, that each SMWC unit, when operating without the use of the HVAC grade pre-filter and post filter system, can achieve compliance with the emission



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standard for either dioxins/furans, lead, cadmium, or mercury. This provision is applicable only to the SMWC unit and pollutant for which compliance has been demonstrated for three consecutive annual performance tests. §62.15150 What happens to the operating requirement s during periods of startup, shutdown, and malfunction? (a) The operating requirements of [Subpart JJJ] apply at all times except during periods of municipal waste combustion unit startup, shutdown, or malfunction. (b) Each startup, shutdown, or malfunction must not last for longer than 3 hours.

I. Operator training requirements. 40 CFR §62.15100 through § 2.15140, COMAR

26.11.08.09A & D; and COMAR 26.11.09.08J(2), (3), and (5) - See Table “A”. Training Requirements.

J. Limits on the combustion of Hospital, Medical and Infectious Waste. If the MWC units

combust any amount of Hospital, Medical and Infectious Waste, the MWC units shall qualify as a co-fired combustor as defined in 40 CFR 60 Subpart Ec, §60.51c.

(1) The Permittee shall limit the combustion of hospital waste and/or medical

/infectious waste with municipal solid waste to 10 percent or less of the weight of which is comprised, in aggregate, of hospital waste and medical/infectious waste as measured on a calendar quarter basis [Authority: COMAR 26.11.02.09 and 40 CFR 60 Subpart Ec, §60.51c]

(2) Prior to combusting any amount of HMI waste in the MWC units, the Permittee

shall [Authority: 40 CFR 60 Subpart Ec, §60.50c}

(a) Notify the EPA Administrator and the Department of an exemption claim;

(b) Provides an estimate of the relative amounts of hospital waste, medical/infectious waste, and other fuels and wastes to be combusted; and

(c) Keep records on a calendar quarter basis of the weight of hospital waste and

medical/infectious waste combusted, and the weight of all other fuels and wastes combusted at the co-fired combustor.

K. COMAR 26.11.09.08J(1) and (4) Requirements for Industrial Furnaces and Other

Miscellaneous Installations that Cause Emissions of NOx. A person who owns or operates any installation other than fuel-burning equipment that causes NOx emissions shall:

(1) COMAR 26.11.09.08J(1) - Maintain good operating practices as recommended by the equipment vendor to minimize NOx emissions; (2) COMAR 26.11.09.08J(4) - Burn natural gas, where natural gas is available, during the period May 1 through September 30 of each year.

4.6.3

Testing Requirements : A.- H. General Testing Requirements.

(1) The Permittee shall conduct all testing at a reasonable time and with at least seven (7) days notice to the Department [Authority: COMAR 26.11.03.06C and Permit to Construct



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021-0131-2-0049 & -0050 issued on January 30, 2009]. (2) The Permittee shall submit a stack test protocol to the Department at least 30 days prior to the anticipated date of any emissions stack test to determine compliance with this permit [Authority: COMAR 26.11.03.06C and Permit to Construct 021-0131-2-0049 & -0050 issued on January 30, 2009]. (3) The Permittee shall submit a report detailing the stack test results, all pertinent operating data, and all other information required by 40 CFR §60.8 and §62.15245 within 60 days after the stack testing is complete [Authority: condition E(7), Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009].

A. Visible Emissions/Opacity.

(1) The Permittee shall conduct initial and annual Method 9 observations for opacity of stack emissions at intervals less than 13 months. The Permittee shall use a 3-hour observation period (thirty 6-minute averages). (cf. Table 8, 40 CFR Part 62, Subpart JJJ). Use the results of the observations of opacity to demonstrate compliance with the applicable emission limits in Table 4, 40 CFR Part 62, Subpart JJJ. (2) The Permittee shall conduct initial and annual Method 22 observations for fugitive ash at intervals less than 13 months. The Permittee shall make the three 1-hour observation periods for fugitive ash. The observations must include periods when the facility transfers fugitive ash from the municipal waste combustion unit to the area where the fugitive ash is stored or loaded into containers or trucks. The Permittee shall use results of the observations of fugitive ash to demonstrate compliance with the applicable emission limits in Table 4, 40 CFR Part 62, Subpart JJJ. [Authority: §§62.15230 through §62.15255, 40 CFR Part 62, Subpart JJJ].

B. Particulate Matter.

The Permittee shall conduct an initial stack test for particulate matter and subsequent annual stack tests, meeting the requirements of §§62.15230 through 62.15255, 40 CFR Part 62, Subpart JJJ. See G. – H. below [Authority: §§62.15230 through 62.15255, 40 CFR Part 62, Subpart JJJ].

C. Carbon Monoxide Emissions.

The Permittee must perform initial, daily, quarterly and annual evaluations of the CEM’s, which are described under Monitoring Requirements 4.7.4 C.- E. below

D. Nitrogen Oxides Emissions.

By December 31, 2016, the Permittee shall conduct a stack test to determine compliance with the NOx emission limit on at least one emission unit using the appropriate Appendix A methods or other procedures approved in writing by the Department. Unless otherwise approved by the Department, the stack test shall consist of three runs of at least one hour duration. A stack test protocol shall be submitted to the Department at least 30 days prior to the anticipated date of the stack test and the stack test results shall be submitted to the Department within 60 days of completion of the stack test [Authority: COMAR 26.11.03.06C(3)].



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E. Sulfur Dioxide Emissions. Same as C above. F. Lead Emissions. See G below. G. Non-Criteria Pollutant Emissions.

(1) The Permittee shall conduct initial stack tests on both MWC units to establish compliance with all emission limitations in 40 CFR Part 62, Subpart JJJ no later than December 31, 2010. Each stack test must be performed in accordance with the requirements of 40 CFR §§62.15230, 62.15235, 62.15240(b), 62.15245, and alternative requirements 62.15240(a) and (c) approved by EPA [Authority: condition E(4), Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009].

(2) The Permittee shall conduct initial and annual (at intervals less than 13 months) stack tests for dioxins/furans (total mass), cadmium, lead, mercury, and hydrogen chloride. The test shall be completed in accordance with §§62.15230 through 62.15255. [Authority: 40 CFR Part §§ 62.15230 through 62.15255].

§62.15230 What types of stack tests must I conduct? Conduct initial and annual stack tests to measure the emission levels of dioxins/furans, cadmium, lead, mercury, particulate matter, opacity, hydrogen chloride, and fugitive ash. §62.15235 How are the stack test data used? You must use results of stack tests for dioxins/furans, cadmium, lead, mercury, particulate matter, opacity, hydrogen chloride, and fugitive ash to demonstrate compliance with the applicable emission limits in Table 4 of [Subpart JJJ]. To demonstrate compliance for carbon monoxide, nitrogen oxides, and sulfur dioxide, see §62.15180.

(3) The following includes EPA approved Federal Plan 40 CFR 62 Subpart JJJ Rule Provision Alternatives for §62.15240(a) and (c) for the U.S. Army (Owner/Operator) Fort Detrick Facility. Additionally, condition E(5), Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009, requires the Permittee to perform the annual stack test for dioxins/furans and mercury in accordance with the following timing requirements:

(a) No later than 13 months after the previous stack test, in accordance with §62.15240(b);

(b) Within the period 60 days prior to the replacement of the activated carbon in the adsorption system in accordance with alternative requirement §62.15240(c); and

(c) Condition (b) above may be waived by the Department if the replacement of activated carbon is deferred beyond the 13 month period in accordance with §62.15145(d).

§62.15145 What are the operating practice requireme nts for my municipal waste combustion unit? … (d) [Revised] Maintain a fixed bed activated carbon adsorption system, consisting of two beds, totaling at least 2,800 pounds of activated carbon. Replace the entire amount of carbon with fresh activated carbon at intervals not to exceed 13 months unless the owner/operator can demonstrate to the satisfaction of the Maryland Department of the Environment and EPA Administrator that a lesser replacement rate will not lead to a violation of the emissions standard for either dioxins/furans or mercury



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§62.15240 What schedule must I follow for the stack testing? (a) Conduct initial stack tests for the pollutants listed in §62.15230 by 180 days after your final compliance date. [Added.] Also, conduct an initial stack test after installation of the rotary atomizer wet scrubber and fix bed carbon filtration system in order to demonstrate compliance with all emission limitations under part 62, subparts JJJ and V. The test shall be completed within 180 days after completion of control equipment installation or by December 31, 2010, whichever date is earlier. (b) Conduct annual stack tests for these pollutants after the initial stack test. Conduct each annual stack test no later than 13 months after the previous stack test. (c) [Added.] Except for the initial performance test with the rotary atomizer wet scrubber and fixed bed carbon adsorption system under paragraph (a), perform the annual stack tests for dioxins/furans and mercury within the period 60 days prior to replacement of the activated carbon in the adsorption system, as required in §62.15145 (d). §62.15245 What test methods must I use to stack tes t? (a) Follow table 8 of [Subpart JJJ] to establish the sampling location and to determine pollutant concentrations, number of traverse points, individual test methods, and other specific testing requirements for the different pollutants. (b) Make sure that stack tests for all these pollutants consist of at least three test runs, as specified in §60.8 (Performance Tests) of Subpart A of 40 CFR Part 60. Use the average of the pollutant emission concentrations from the three test runs to determine compliance with the applicable emission limits in table 4 of [ Subpart JJJ]. (c) Obtain an oxygen (or carbon dioxide) measurement at the same time as your pollutant measurements to determine diluent gas levels, as specified in §62.15175. (d) Use the equations in §62.15390(a) to calculate emission levels at 7 percent oxygen (or an equivalent carbon dioxide basis), the percent reduction in potential hydrogen chloride emissions, and the reduction efficiency for mercury emissions. See the individual test methods in table 6 of [Subpart JJJ] for other required equations. (e) You can apply to the Administrator for approval under §60.8(b) of Subpart A of 40 CFR Part 60 to:

(1) Use a reference method with minor changes in methodology; (2) Use an equivalent method; (3) Use an alternative method the results of which the Administrator has determined are adequate for demonstrating compliance; (4) Waive the requirement for a performance test because you have demonstrated by other means that you are in compliance; or (5) Use a shorter sampling time or smaller sampling volume.

§62.15250 May I conduct stack testing less often? (a) You may test less often if you own or operate a Class II municipal waste combustion unit and if all stack tests for a given pollutant over 3 consecutive years show you comply with the emission limit. In this case, you are not required to conduct a stack test for that pollutant for the next 2 years. However, you must conduct another stack test within 36 months of the anniversary date of the third consecutive stack test that shows you comply with the emission limit. Thereafter, you must perform stack tests every third year



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but no later than 36 months following the previous stack tests. If a stack test shows noncompliance with an emission limit, you must conduct annual stack tests for that pollutant until all stack tests over 3 consecutive years show compliance with the emission limit for that pollutant. This provision applies to all pollutants subject to stack testing requirements: dioxins/furans, cadmium, lead, mercury, particulate matter, opacity, hydrogen chloride, and fugitive ash. (b) You can test less often for dioxins/furans emissions if you own or operate a municipal waste combustion plant that meets two conditions. First, you have multiple municipal waste combustion units onsite that are subject to this subpart. Second, all these municipal waste combustion units have demonstrated levels of dioxins/furans emissions less than or equal to 30 nanograms per dry standard cubic meter (total mass) for Class II units, for 2 consecutive years. In this case, you may choose to conduct annual stack tests on only one municipal waste combustion unit per year at your plant. This provision only applies to stack testing for dioxins/furans emissions.

(1) Conduct the stack test no more than 13 months following a stack test on any municipal waste combustion unit subject to this subpart at your plant. Each year, test a different municipal waste combustion unit subject to this subpart and test all municipal waste combustion units subject to this subpart in a sequence that you determine. Once you determine a testing sequence, it must not be changed without approval by the Administrator. (2) If each annual stack test shows levels of dioxins/furans emissions less than or equal to … 30 nanograms per dry standard cubic meter (total mass) for Class II units, you may continue stack tests on only one municipal waste combustion unit subject to this subpart per year. (3) If any annual stack test indicates levels of dioxins/furans emissions greater than … 30 nanograms per dry standard cubic meter (total mass) for Class II units, conduct subsequent annual stack tests on all municipal waste combustion units subject to this subpart at your plant. You may return to testing one municipal waste combustion unit subject to this subpart per year if you can demonstrate dioxins/furans emission levels less than or equal to … 30 nanograms per dry standard cubic meter (total mass) for Class II units, for all municipal waste combustion units at your plant subject to this subpart for 2 consecutive years.

§62.15255 May I deviate from the 13-month testing s chedule if unforeseen circumstances arise? You may not deviate from the 13-month testing schedules specified in §§ 62.15240(b) and 62.15250(b)(1) unless you apply to the Administrator for an alternative schedule, and the Administrator approves your request for alternate scheduling prior to the date on which you would otherwise have been required to conduct the next stack test.

Operational Limitations: H. Operational Limits from 40 CFR Part 62, Subpart JJJ.

The Permittee shall determine the maximum or maximum value as appropriate of each parameter limit identified § 62.15145(a)-(c) as revised for the Fort Detrick facility and as defined in § 62.15410 as revised for the Fort Detrick facility during the appropriate initial or annual compliance stack tests required 4.7.3 G above.

I. Operator training requirements. See Table “A”, under 4.6.4a, Training Requirements. J. See 4.6.5 J. Record Keeping Requirements below.



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K. See 4.6.5 K. Record Keeping Requirements below.

4.6.4 Monitoring Requirements: A. Visible Emissions/Opacity

(1) Opacity Monitor Requirements:

(a) No later than December 31, 2009, install, and commence continuous operation of each continuous opacity monitoring system (COMS) according to §60.13 of Subpart A 40 CFR part 60 [Authority: Permit to Construct 021-0131-2-0049 & -0050 issued on January 30, 2009]. (b) No later than December 31, 2015, complete a satisfactory initial evaluation of the COMS meeting the requirements of Performance Specification 1 in Appendix B of 40 CFR Part 60 [Authority: § 62.15170(d) and §62.15215, 40 CFR Part 62, Subpart JJJ, and Permit to Construct 021-0131-2-0049 & -0050 issued on January 30, 2009]. (c) Use the required span values and applicable performance specifications in Table 7 of Subpart JJJ. Note: Table 7 specifies a span value of 100 percent opacity and Performance Specification 1, Appendix B, 40 CFR Part 60. Table 7 also specifies alternate methods for collecting data when these systems malfunction or when repairs, calibration checks, or zero and span checks keep you from collecting the minimum amount of data [Authority: § 62.15220 and § 62.15225, 40 CFR Part 62, Subpart JJJ]. §62.15170 What types of continuous emission monitoring must I perform? … (d) Install a continuous opacity monitoring system. § 62.15215 What is required for my continuous opacity monitori ng system and how are the data used?

(a) Install, calibrate, maintain, and operate a continuous opacity monitoring system. (b) Install, evaluate, and operate each continuous opacity monitoring system according to § 60.13 of subpart A 40 CFR part 60.

(c) Complete an initial evaluation of your continuous opacity monitoring system according to Performance Specification 1 in appendix B of 40 CFR part 60. Complete this evaluation by 180 days after your final compliance date. (d) Complete each annual evaluation of your continuous opacity monitoring system no more than 13 months after the previous evaluation. (e) Use tests conducted according to EPA Reference Method 9, as specified in § 62.15245, to determine compliance with the applicable opacity limit in table … 4 of [ Subpart JJJ] The data obtained from your continuous opacity monitoring system are not used to determine compliance with the opacity limit.

B. Particulate Matter Emissions Same as A. above.



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C. - E. Carbon Monoxide and Sulfur Dioxide Emissions.

(1) The Permittee shall use any of the quality assurance procedures specified in Appendix F to test the CEMs once each calendar quarter. The Permittee shall have a Relative Accuracy Test Audit (RATA), in accordance with Appendix F of 40 CFR Part 60 performed on each CEM at least once per calendar year [Authority: §60.13 of Subpart A of 40 CFR Part 60].

(2) By December 31, 2009, the Permittee shall install and commence continuous operation CEMS for carbon monoxide, sulfur dioxide, and oxygen meeting 40 CFR Part 62, Subpart JJJ requirements stated in §§62.15170 through 62.15225 [Authority: Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009]

(3) By June 30, 2010, the Permittee must complete an initial evaluation of each CEM meeting the requirements of §62.15175(b), §§62.15185 through 62.15200 [Authority: §62.15170 - 62.15225, 40 CFR Part 62, Subpart JJJ and Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009].

§62.15170 What types of continuous emission monit oring must I perform? To continuously monitor emissions, you must perform four tasks: (a) Install continuous emission monitoring systems for certain gaseous pollutants. (b) Make sure your continuous emission monitoring systems are operating correctly. (c) Make sure you obtain the minimum amount of monitoring data. §62.15175 What continuous emission monitoring syst ems must I install for gaseous pollutants? (a) You must install, calibrate, maintain, and operate continuous emission monitoring systems for oxygen (or carbon dioxide), sulfur dioxide, and carbon monoxide.… Install the continuous emission monitoring system for sulfur dioxide, … and oxygen (or carbon dioxide) at the outlet of the air pollution control device. (b) You must install, evaluate, and operate each continuous emission monitoring system according to the “Monitoring Requirements” in §60.13 of Subpart A of 40 CFR Part 60. (c) You must monitor the oxygen (or carbon dioxide) concentration at each location where you monitor sulfur dioxide and carbon monoxide…. (d) You may choose to monitor carbon dioxide instead of oxygen as a diluent gas. If you choose to monitor carbon dioxide, then an oxygen monitor is not required and you must follow the requirements in §62.15200. (e) If you choose to demonstrate compliance by monitoring the percent reduction of sulfur dioxide, you must also install a continuous emission monitoring system for sulfur dioxide and oxygen (or carbon dioxide) at the inlet of the air pollution control device. (f) If you prefer to use an alternative sulfur dioxide monitoring method, such as parametric monitoring, or cannot monitor emissions at the inlet of the air pollution control device to determine percent reduction, you can apply to the Administrator for approval to use an alternative monitoring method under § 60.13(i) of Subpart A of 40 CFR Part 60.



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§62.15180 How are the data from the continuous emi ssion monitoring systems used ? You must use data from the continuous emission monitoring systems for sulfur dioxide, … and carbon monoxide to demonstrate continuous compliance with the applicable emission limits specified in Tables …4 and 5 of [Subpart JJJ]. §62.15185 How do I make sure my continuous emissio n monitoring systems are operating correctly? (a) Conduct initial, daily, quarterly, and annual evaluations of your continuous emission monitoring systems that measure oxygen (or carbon dioxide), sulfur dioxide, … and carbon monoxide. (b) Complete your initial evaluation of the continuous emission monitoring systems within 180 days after your final compliance date. (c) For initial and annual evaluations, collect data concurrently (or within 30 to 60 minutes) using your oxygen (or carbon dioxide) continuous emission monitoring system, your sulfur dioxide, … or carbon monoxide continuous emission monitoring systems, as appropriate, and the appropriate test methods specified in table 6 of [Subpart JJJ]. Collect these data during each initial and annual evaluation of your continuous emission monitoring systems following the applicable performance specifications in Appendix B of 40 CFR Part 60. Table 7 of [Subpart JJJ] shows the performance specifications that apply to each continuous emission monitoring system. (d) Follow the quality assurance procedures in Procedure 1 of Appendix F of 40 CFR Part 60 for each continuous emission monitoring system. These procedures include daily calibration drift and quarterly accuracy determinations.

§62.15190 Am I exempt from any 40 CFR Part 60 Appe ndix B or Appendix F requirements to evaluate continuous emission monito ring systems? Yes, the accuracy tests for your sulfur dioxide continuous emission monitoring system require you to also evaluate your oxygen (or carbon dioxide) continuous emission monitoring system. Therefore, your oxygen (or carbon dioxide) continuous emission monitoring system is exempt from two requirements: (a) Section 2.3 of Performance Specification 3 in Appendix B of 40 CFR Part 60 (relative accuracy requirement). (b) Section 5.1.1 of Appendix F of 40 CFR Part 60 (relative accuracy test audit). §62.15195 What is my schedule for evaluating conti nuous emission monitoring systems? (a) Conduct annual evaluations of your continuous emission monitoring systems no more than 13 months after the previous evaluation was conducted. (b) Evaluate your continuous emission monitoring systems daily and quarterly as specified in Appendix F of 40 CFR Part 60. §62.15200 What must I do if I choose to monitor ca rbon dioxide instead of oxygen as a diluent gas? You must establish the relationship between oxygen and carbon dioxide during the initial evaluation of your continuous emission monitoring system. You may reestablish the relationship during annual evaluations. To establish



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the relationship use three procedures: (a) Use EPA Reference Method 3A or 3B in Appendix A of 40 CFR Part 60 to determine oxygen concentration at the location of your carbon dioxide monitor. (b) Conduct at least three test runs for oxygen. Make sure each test run represents a 1-hour average and that sampling continues for at least 30 minutes in each hour. (c) Use the fuel-factor equation in EPA Reference Method 3B to determine the relationship between oxygen and carbon dioxide. §62.15205 What minimum amount of monitoring data m ust I collect with my continuous emission monitoring systems and is this requirement enforceable? (a) Where continuous emission monitoring systems are required, obtain 1-hour arithmetic averages. Make sure the averages for sulfur dioxide, … and carbon monoxide are in parts per million by dry volume at 7 percent oxygen (or the equivalent carbon dioxide level). Use the 1-hour averages of oxygen (or carbon dioxide) data from your continuous emission monitoring system to determine the actual oxygen (or carbon dioxide) level and to calculate emissions at 7 percent oxygen (or the equivalent carbon dioxide level). (b) Obtain at least two data points per hour in order to calculate a valid 1-hour arithmetic average. Section 60.13(e)(2) of Subpart A of 40 CFR Part 60 requires your continuous emission monitoring systems to complete at least one cycle of operation (sampling, analyzing, and data recording) for each 15-minute period. (c) Obtain valid 1-hour averages for 75 percent of the operating hours per day for 90 percent of the operating days per calendar quarter. An operating day is any day the unit combusts any municipal solid waste or refuse-derived fuel. (d) If you do not obtain the minimum data required in paragraphs (a) through (c) of this section, you are in violation of this data collection requirement regardless of the emission level monitored, and you must notify the Administrator according to §62.15340(e). (e) If you do not obtain the minimum data required in paragraphs (a) through (c) of this section, you must still use all valid data from the continuous emission monitoring systems in calculating emission concentrations and percent reductions in accordance with §62.15210. §62.15210 How do I convert my 1-hour arithmetic av erages into appropriate averaging times and units? (a) Use the equation in §62.15390(a) to calculate emissions at 7 percent oxygen. C7% = Cunc * 13.9/(20.9 - CO2) C7% = concentration corrected to 7 percent oxygen. Cunc = uncorrected pollutant concentration CO2 = %O2 (b) Use EPA Reference Method 19 in Appendix A of 40 CFR Part 60, section 4.3, to calculate the daily geometric average concentrations of sulfur dioxide emissions. If you



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are monitoring the percent reduction of sulfur dioxide, use EPA Reference Method 19, section 5.4, to determine the daily geometric average percent reduction of potential sulfur dioxide emissions. (c) (not applicable). (d) Use EPA Reference Method 19, section 4.1, to calculate the 4-hour daily block averages for concentrations of carbon monoxide.

§62.15220 What additional requirements must I meet for the operation of my continuous emission monitoring systems ? Use the required span values and applicable performance specifications in Table 7 of [Subpart JJJ]

§62.15225 What must I do if my continuous emission monitoring system is temporarily unavailable to meet the data collection requirements? Refer to Table 7 of [Subpart JJJ]. It shows alternate methods for collecting data when these systems malfunction or when repairs, calibration checks, or zero and span checks keep you from collecting the minimum amount of data.

F. – G. Lead and Non-Criteria Pollutants See 4.6.4 Part H. below.

H. Operational Limits from 40 CFR Part 62, Subpart JJJ.

(1) The following includes EPA approved Federal Plan Subpart JJJ Rule Provision Alternatives for §62.15260(b) and (c) for the U.S. Army (Owner/Operator) Fort Detrick Facility. §62.15260 What other requirements must I meet for continuous monitoring ? The owner/operator shall obtain 1-hour arithmetic averages for the following parameters: (a) Load level of each municipal waste combustion unit. (b) [Revised.] The temperature of the flue gases at the inlet s of the following particulate matter control devices:

(1) The rotary atomizing scrubber; and (2) The activated carbon adsorption system.

(c) [Revised] Record the dates and amounts of activated carbon replaced and the hours of operation of the MWC unit since the previous replacement of carbon

(d) [Added.] The rotary atomizing scrubber pump flow rate or rotary atomizing scrubber amperage. (e) [Added.] The rotary atomizing scrubber inlet temperature; (f) [Added.] The pH of the recirculation rotary atomizing scrubber solution; and (g) [Added.] The activated carbon adsorption system exhausts temperature, and system differential pressure. (h) [Added.] The HVAC grade pre-filter differential pressure (inch water column); and



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(i) [Added.] The HVAC grade post-filter differential pressure (inch water column).

(2) The Permittee shall install, calibrate, maintain, and operate a steam flowmeter meeting the requirements of §62.15265(a). In the event of failure of the steam monitoring system, or if steam production is discontinued, the Permittee may, on approval by the Department, continuously monitor the feed rate of municipal solid waste (MWS) in accordance with §62.15265(b) by:

(a) Weighing on a calibrated scale each increment of MWS and recording in an

automatic data processing system the weight of MSW increment measured adjusting for the tare weight of the container;

(b) Recording the time into the automatic data processing system that the MSW

increment is loaded into the incinerator; (c) Employing an automatic data processing system that, from the data entered,

calculates and records 1–hour block and 4-hour block averages of the weight of MSW loaded; and

(d) Calibrating the equipment according to the manufacturer instructions before each

dioxins/furans stack test, or at least once a year.

(e) Have determined the maximum demonstrated load as defined in §62.15410 in terms of the mass rate of MSW combustion during the most recent dioxins/furans stack test.

§62.15265 How do I monitor the load of my municipa l waste combustion unit?

(a) If your municipal waste combustion unit generates steam, you must install, calibrate, maintain, and operate a steam flowmeter or a feed water flowmeter and meet five requirements:

(1) Continuously measure and record the measurements of steam (or feed water) in kilograms per hour (or pounds per hour).

(2) Calculate your steam (or feed water) flow in 4-hour block averages.

(3) Calculate the steam (or feed water) flow rate using the method in “American Society of Mechanical Engineers (ASME PTC 4.1—1964): Test Code for Steam Generating Units, Power Test Code 4.1-1964 (Reaffirmed 1991),” section 4. The Director of the Federal Register approves this incorporation by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. You may obtain a copy from the American Society of Mechanical Engineers, Service Center, 22 Law Drive, Post Office Box 2900, Fairfield, NJ 07007. You may inspect a copy at the Office of Air Quality Planning and Standards Air Docket, EPA, 109 T.W. Alexander Drive, Room C521C, RTP, NC 27709 or at the National Archives and Records Administration (NARA). For information on the availability of this material at NARA, call 202-741-6030, or go to: http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html.

(4) Design, construct, install, calibrate, and use nozzles or orifices for flow rate measurements, using the recommendations in “American Society of Mechanical Engineers Interim Supplement 19.5 on Instruments and Apparatus: Application, Part II of Fluid Meters”, 6th Edition (1971), chapter 4. The Director of the Federal Register



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approves this incorporation by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. You may obtain a copy from the American Society of Mechanical Engineers, Service Center, 22 Law Drive, Post Office Box 2900, Fairfield, NJ 07007. You may inspect a copy at the Office of Air Quality Planning and Standards Air Docket, EPA, 109 T.W. Alexander Drive, Room C521C, RTP, NC 27709 or at the National Archives and Records Administration (NARA). For information on the availability of this material at NARA, call 202-741-6030, or go to: http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html.

(5) Before each dioxins/furans stack test, or at least once a year, calibrate all signal conversion elements associated with steam (or feed water) flow measurements according to the manufacturer instructions.

(b) If your municipal waste combustion unit does not generate steam, or, if your municipal waste combustion units have shared steam systems and steam load cannot be estimated per unit, you must determine, to the satisfaction of the Administrator, one or more operating parameters that can be used to continuously estimate load level (for example, the feed rate of municipal solid waste or refuse-derived fuel). You must continuously monitor the selected parameters.

(3) In accordance with §62.15270, the Permittee shall for each incinerator continuously monitor the flue gas temperature at the inlet of each particulate matter control device:

§62.15270 How do I monitor the temperature of flue gases at the inlet of my particulate matter control device? You must install, calibrate, maintain, and operate a device to continuously measure the temperature of the flue gas stream at the inlet of each particulate matter control device.

(4) The following includes EPA approved Federal Plan Subpart JJJ Rule Provision

Alternatives for §62.15275 (a), (b), and (c) for the U.S. Army (Owner/Operator) Fort Detrick Facility. §62.15275 [Revised.] How do I monitor operations of the rotary atomizer wet scrubber and fixed bed carbon filtration system? The owner/operator shall: (a) [Revised.] Select, during the initial or annual compliance test, a rotary atomizer operating parameter, either rotary atomizing scrubber pump flow rate or rotary atomizing scrubber amperage, as an indicator of compliance; (b) [Revised.] Within 48 hours before each dioxins/furans and mercury stack test, verify the amount [volume or weight (cubic feet, pounds)] of activated carbon in each fixed bed; and (c) [Revised.] Continuously monitor the §62.15145(c) operating parameters during all periods when the municipal waste combustion unit is operating and combusting waste and calculate the 1-hour and 4-hour arithmetic block averages, excluding hours when the unit is in a shutdown, startup, or malfunction mode of operation.


Alternatives for §62.15280(a) for the U.S. Army (Owner/Operator) Fort Detrick Facility.



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§62.15280 What minimum amount of monitoring data m ust I collect with my continuous parameter monitoring systems and is this requirement enforceable? The owner/operator shall: (a) Where continuous parameter monitoring systems are used, obtain 1-hour and 4-hour block arithmetic averages for the following parameters:

(1) Load level of the municipal waste combustion unit. (2) [Revised.] Temperature of the flue gases at the inlet of each of the particulate control devices – rotary atomizer and activated carbon adsorption system. (3) [Revised.]

(i) The pH of the rotary atomizing scrubber solution; (ii) The rotary atomizing scrubber pump flow rate (or rotary atomizing scrubber amperage); (iii) The rotary atomizer scrubber inlet temperature; (iv) The carbon adsorption system exhaust temperature; and (v) The carbon adsorption system differential pressure (i.e., inches water column). (vi) The pre-filter differential pressure (inch water column); and (vii) The post-filter differential pressure (inch water column).

(b) Obtain at least two data points per hour in order to calculate a valid 1-hour arithmetic average. (c) Obtain valid 1-hour averages for at least 75 percent of the operating hours per day for 90 percent of the operating days per calendar quarter. An operating day is any day the unit combusts any municipal solid waste or refuse-derived fuel. (d) If you do not obtain the minimum data required in paragraphs (a) through (c) of this section, you are in violation of this data collection requirement and you must notify the Administrator according to §62.15340(e).

I. Operator training requirements. See Table “A”, under 4.6.4a. Training Requirements. J. See 4.6.5 J Record Keeping Requirements below.

K. See 4.6.5 K. Record Keeping Requirements below.

4.6.5 Record Keeping Requirements :

A. – H. General

(1) The Permittee shall maintain on site for at least five (5) years, and must make available

to the Department upon request, all records of the information required by 40 CFR Part 62, Subpart JJJ as modified by EPA for the Fort Detrick facility, including §§62.15285, 62.15290, §62.15300, §62.15305, and 62.15310 [Authority: 40 CFR part 62, subpart JJJ; condition F(1), Permit to Construct 021-0131- 2-0049 & -0050 issued on January 30, 2009]:



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(2) The following includes EPA approved Federal Plan Subpart JJJ Rule Provision Alternatives for §62.15285(d) for the U.S. Army (Owner/Operator) Fort Detrick Facility. §62.15285 What records must I keep? The owner/operator shall retain the following records: (a) [See Table “A” , Section 4.7.5a.] (b) Stack tests. (c) Continuously monitored pollutants and parameters. (d) [Revised.]

(1) The activated carbon performance specifications (e.g., density, particle size, ignition temperature) from each activated carbon vendor; (2) The dates and amounts of carbon replaced and the hours of operation of the MWC unit since the previous replacement of carbon; and (3) The dates and times when use of the bypass stack commences and ends, and the reason for its use.

§62.15290 Where must I keep my records and for how long? (a) Keep all records onsite in paper copy or electronic format unless the Administrator approves another format. (b) Keep all records on each municipal waste combustion unit for at least 5 years. (c) Make all records available for submittal to the Administrator, or for onsite review by an inspector.

(3) The following includes EPA approved Federal Plan Subpart JJJ Rule Provision Alternatives for §62.15300(c) for the U.S. Army (Owner/Operator) Fort Detrick Facility. §62.15300 What records must I keep for the stack t ests? The owner/operator shall: (a) The results of the stack tests for eight pollutants or parameters recorded in the appropriate units of measure specified in Table 2 of [Subpart JJJ]:

(1) Dioxins/furans. (2) Cadmium. (3) Lead. (4) Mercury. (5) Opacity. (6) Particulate matter. (7) Hydrogen chloride. (8) Fugitive ash.

(b) Test reports including supporting calculations that document the results of all stack tests.

(c) [Revised.] The maximum and minimum operating parameter levels listed under 62.15145 (c); the amount of activated carbon in each fixed bed as required under 62.15145(d) and 62.15275 (b); the selected rotary atomizing operating parameter (flow



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rate or amperage); and a copy of the activated carbon vendor specifications. (d) The calendar date of each record. §62.15305 What records must I keep for continuousl y monitored pollutants or parameters? You must keep records of eight items. (a) Records of monitoring data. Document six parameters measured using continuous monitoring systems:

(1) All 6-minute average levels of opacity. (2) All 1-hour average concentrations of sulfur dioxide emissions. (3) (not applicable). (4) All 1-hour average concentrations of carbon monoxide emissions. (5) All 1-hour average load levels of your municipal waste combustion unit. (6) All 1-hour average flue gas temperatures at the inlet[s] of the particulate matter control devices.

(b) Records of average concentrations and percent reductions. Document five parameters:

(1) All 24-hour daily block geometric average concentrations of sulfur dioxide emissions or average percent reductions of sulfur dioxide emissions. (2) (not applicable). (3) All 4-hour block arithmetic average concentrations of carbon monoxide emissions. (4) All 4-hour block arithmetic average load levels of your municipal waste combustion unit. (5) All 4-hour block arithmetic average flue gas temperatures at the inlet[s] of the particulate matter control device[s].

(c) Records of exceedances. Document three items:

(1) Calendar dates whenever any of the five pollutants or parameter levels recorded in paragraph (b) of this section or the opacity level recorded in paragraph (a)(1) of this section did not meet the emission limits or operating levels specified in [Subpart JJJ]. (2) Reasons you exceeded the applicable emission limits or operating levels. (3) Corrective actions you took, or are taking, to meet the emission limits or operating levels.

(d) Records of minimum data. Document three items:

(1) Calendar dates for which you did not collect the minimum amount of data required under §§ 62.15205 and 62.15280. Record these dates for five types of pollutants and parameters:

(i) Sulfur dioxide emissions. (ii) (not applicable) (iii) Carbon monoxide emissions. (iv) Load levels of your municipal waste combustion unit. (v) Temperature[s] of the flue gases at the inlet [s] of the particulate matter control device[s].

(2) Reasons you did not collect the minimum data. (3) Corrective actions you took or are taking to obtain the required amount of data.

(e) Records of exclusions. Document each time you have excluded data from your calculation of averages for any of the following five pollutants or parameters and the



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reasons the data were excluded: (1) Sulfur dioxide emissions. (2) (not applicable.) (3) Carbon monoxide emissions. (4) Load levels of your municipal waste combustion unit. (5) Temperatures of the flue gases at the inlet[s] of the particulate matter control device[s].

(f) Records of drift and accuracy. Document the results of your daily drift tests and quarterly accuracy determinations according to Procedure 1 of Appendix F of 40 CFR Part 60. Keep these records for the sulfur dioxide and carbon monoxide continuous emissions monitoring systems.

(g) Records of the relationship between oxygen and carbon dioxide. If you choose to monitor carbon dioxide instead of oxygen as a diluent gas, document the relationship between oxygen and carbon dioxide, as specified in §62.15200. (h) Records of calendar dates. Include the calendar date on each record.


Alternatives for §62.15310(a), (b) and (c) for the U.S. Army (Owner/Operator) Fort Detrick Facility. §62.15310 [Revised.] What records must I keep for municipal waste combustion units that use a rotary atomizing wet scrubber and fixed bed carbon filtration system? The owner/operator shall maintain the following: (a) [Revised.] 1-hour and 4-hour block average records for each of the following operating parameters:

(1) The rotary atomizing scrubber pump flow rate (or rotary atomizing scrubber amperage); (2) Temperature (Centigrade) of the flue gases at the inlet to each of the particulate control devices - rotary atomizer and activated carbon adsorption system; (3) The pH of the rotary atomizing scrubber solution; (4) The carbon adsorption system exhausts temperature; (5) Carbon adsorption system differential pressure (inch water column); (6) Differential pressure (inch water column) across the pre-filter; and (7) Differential pressure (inch water column) across the post-filter.

(b) [Revised] Supporting calculations and identification of the minimum and maximum required 4- hour block average operating limits as defined in §62.15410. (c) [Revised.] The amounts of activated carbon use:

(1) The amounts of activated carbon replaced, including the date and the hours of operation of the MWC unit since the previous replacement of carbon; and (2) The total amount of activated carbon purchased and delivered to the facility for each calendar quarter, including the vendor’s performance specification.



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(d) Records of exclusions. Document each time you have excluded data from your calculation of average carbon feed rate and the reasons the data were excluded [not applicable].

(5) In lieu of §62.15310(d) above, the Permittee shall document each time data were

excluded from the calculation of the averages required by §62.15310(a)[revised] (e) Records of calendar dates. Include the calendar date on each record.

I. See Table “A”. 4.6.5a Training Requirements. J. The Permittee shall maintain records on a calendar quarter basis of the weight of hospital

waste and medical/infectious waste (HMIW) combusted, and the weight of all other fuels and wastes combusted at the co-fired combustor necessary to demonstrate compliance with the 10 percent HMIW limit [Authority: 40 CFR 60 Subpart Ec, §60.50c(c)].

K. In keeping with COMAR 26.11.09.08J(4), the Permittee shall maintain a record of the

amounts of natural gas and No.2 fuel oil auxiliary fuel combusted each day during the summer months and an explanation as to why the reason No, 2 fuel was combusted during the summer months [Authority: COMAR 26.11.03.06C(3)].

4.6.6 Reporting Requirements :

A. – H. General

(1) The Permittee shall comply with all applicable notification and reporting requirements of

§62.15315 through 62.15360 [Authority: 40 CFR Part 62, Subpart JJJ]: §62.15315 What reports must I submit and in what f orm? (a) Submit an initial report and annual reports, plus semiannual reports for any emission or parameter level that does not meet the limits specified in [Subpart JJJ]. (b) Submit all reports on paper, postmarked on or before the submittal dates in §§ 62.15325, 62.15335, and 62.15350. If the Administrator agrees, you may submit electronic reports. (c) Keep a copy of all reports required by §§ 62.15330, 62.15340, and 62.15355 onsite for 5 years. §62.15320 What are the appropriate units of measur ement for reporting my data? See Tables … 4 and 5 of [Subpart JJJ] for appropriate units of measurement.

(2) The following includes EPA approved Federal Plan Subpart JJJ Rule Provision Alternatives for §62.15325(b) for the U.S. Army (Owner/Operator) Fort Detrick Facility. §62.15325 When must I submit the initial report? The owner/operator shall maintain the following: (a) As specified in §60.7(c) of Subpart A of 40 CFR Part 60, submit your initial report within 180 days after your final compliance date. (b) [Added] The initial compliance stack test report required after installation of the operating rotary atomizing wet scrubber and fix bed carbon filtration system is 60 days



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after completion of the test required under §62.15240(a)

(3) The following includes EPA approved Federal Plan Subpart JJJ Rule Provision Alternatives for §62.15330(a) and (f) for the U.S. Army (Owner/Operator) Fort Detrick Facility. §62.15330 What must I include in the initial repor t? The owner/operator shall maintain the following. You must include seven items: (a) [Revised] The emission levels measured on the date of the initial performance test under 62.15325(b) for continuous emission monitoring systems for all of the following five pollutants or parameters as recorded in accordance with §62.15305(b).

(1) The 24-hour daily geometric average concentration of sulfur dioxide emissions or the 24-hour daily geometric percent reduction of sulfur dioxide emissions. (2) (not applicable) (3) The 4-hour block arithmetic average concentration of carbon monoxide emissions. (4) The 4-hour block arithmetic average load level of your municipal waste combustion unit. (5) The 4-hour block arithmetic average flue gas temperatures at the inlet[s] of the particulate matter control device[s].

(b) The results of the initial stack tests for eight pollutants or parameters (use appropriate units as specified in Table 2 of [Subpart JJJ]):


(c) The test report that documents the initial stack tests including supporting calculations.

(d) The initial performance evaluation of your continuous emissions monitoring systems. Use the applicable performance specifications in Appendix B of 40 CFR Part 60 in conducting the evaluation. (e) The maximum demonstrated load of your municipal waste combustion unit and the maximum demonstrated temperature of the flue gases at the inlet of the particulate matter control device. Use values established during your initial stack test for dioxins/furans emissions and include supporting calculations. (f) [Revised] The following additional operating parameters and information:

(1) The weight and volume of the initial charge of carbon and the hours of operation prior to the initial stack tests for dioxins/furans or mercury. See §62.15275. (2) The activated carbon vendor performance specifications (e.g., density, particle size, BET surface area (cm2/gram), etc.). (3) Complete pre-filter and post-filter vendor performance specifications; (4) The 4-hour block averages for the following operating parameters

(i) The temperature at the inlet of the rotary atomizing scrubber (a particulate matter control device);



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(ii) The temperature at the inlet of the activated carbon adsorption system (a particulate matter control device); (iii) The carbon adsorption system exhaust temperature (inlet to the HVAC grade particulate filter system); (iv) The rotary atomizing scrubber pump flow rate (or rotary atomizing scrubber amperage); (v) The pH of the rotary atomizing scrubber solution; (vi) The carbon adsorption system differential pressure. (vii) Differential pressure across the pre-filter;. (viii) Differential pressure across the post-filter; and.

(5) The maximum and minimum operating parameter limits for all §62.15145(c) parameters determined during the most recent compliance test demonstrating compliance:

(g) If you choose to monitor carbon dioxide instead of oxygen as a diluent gas, documentation of the relationship between oxygen and carbon dioxide, as specified in §62.15200.

§62.15335 When must I submit the annual report? Submit the annual report no later than February 1 of each year that follows the calendar year in which you collected the data. (As with all other requirements in [Subpart JJJ], the requirement to submit an annual report does not modify or replace the operating permits requirements of 40 CFR Parts 70 and 71.)


Alternatives for §62.15340(d) for the U.S. Army (Owner/Operator) Fort Detrick Facility. §62.15340 What must I include in the annual report ? The owner/operator shall maintain the following: (a) The results of the annual stack test, using appropriate units, for eight pollutants or parameters, as recorded under §62.15300(a):


(b) A list of the highest average emission levels recorded, in the appropriate units. List these values for five pollutants or parameters:

(1) Sulfur dioxide emissions. (2) (not applicable) (3) Carbon monoxide emissions. (4) Load level of the municipal waste combustion unit. (5) Temperature[s] of the flue gases at the inlet [s] of the particulate matter air pollution control device[s] (4-hour block average).

(c) The highest 6-minute opacity level measured. Base this value on all 6-minute average opacity levels recorded by your continuous opacity monitoring system (§62.15305(a)(1)).



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(d) [Revised.] For MWC units that use a rotary atomizing scrubber and fixed bed activated carbon adsorption bed for controlling dioxins/furans and mercury emissions, include the following records:

(1) The 4-hour block averages of each of the §62.15145(c) operating parameters during the most recent dioxins/furans and mercury tests demonstrating compliance; (2) The lowest or highest 4-hour block averages, as applicable, recorded during the year for the for each §62.15145(c) operating parameter; (3) Dates when the activated carbon is replaced, the amount replaced, and the MWC operating hours since the last replacement; (4) The total amount of activated carbon purchased and delivered to the facility during the previous calendar year; (5) Changes to the activated carbon specifications and vendor; (6) Changes to the pre-filter and post-filter specifications and vendor(s); and (7) The total number of days that the minimum number of data hours, as stipulated under §62.15280, were not obtained for each §62.15145(c) operating parameter. Include the reason that the data were not obtained and discuss corrective actions taken to obtain it. (8) The maximum and minimum operating parameter limits for all §62.15145(c) parameters determined during the most recent compliance test demonstrating compliance.

(e) The total number of days that you did not obtain the minimum number of hours of data for six pollutants or parameters. Include the reasons you did not obtain the data and corrective actions that you have taken to obtain the data in the future. Include data on:

(1) Sulfur dioxide emissions. (2) (not applicable). (3) Carbon monoxide emissions. (4) Load level of the municipal waste combustion unit. (5) Temperature[s] of the flue gases at the inlet of the particulate matter air pollution control device [s]. (6) Carbon feed rate [not applicable].

(f) The number of hours you have excluded data from the calculation of average levels (include the reasons for excluding it). Include data for six pollutants or parameters:

(1) Sulfur dioxide emissions. (2) (not applicable). (3) Carbon monoxide emissions. (4) Load level of the municipal waste combustion unit. (5) Temperature[s] of the flue gases at the inlet[s] of the particulate matter air pollution control device[s]. (6) Carbon feed rate [not applicable].

(5) The following additional items were added to the requirements of §62.15340(f) by the

Department [Authority: COMAR 26.11.03.06C]:

(i) The pH of the rotary atomizing scrubber solution; (ii) The rotary atomizing scrubber pump flow rate (or rotary atomizing scrubber amperage); (iii) The rotary atomizer scrubber inlet temperature; (iv) The carbon adsorption system exhausts temperature; and (v) The carbon adsorption system differential pressure (i.e., inches water column). (vi) The pre-filter differential pressure (inch water column); and



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(vii) The post-filter differential pressure (inch water column). (g) A notice of your intent to begin a reduced stack testing schedule for dioxins/furans emissions during the following calendar year if you are eligible for alternative scheduling (§62.15250(a) or (b). (h) A notice of your intent to begin a reduced stack testing schedule for other pollutants during the following calendar year if you are eligible for alternative scheduling (§62.15250(a)). (i) A summary of any emission or parameter level that did not meet the limits specified in [Subpart JJJ].

(j) A summary of the data in paragraphs (a) through (d) of this section from the year preceding the reporting year. This summary gives the Administrator a summary of the performance of the municipal waste combustion unit over a 2-year period. (k) If you choose to monitor carbon dioxide instead of oxygen as a diluent gas, documentation of the relationship between oxygen and carbon dioxide, as specified in §62.15200. (l) [See Table “A” , under 4.6.6a, Reporting Requirements.]

§62.15345 What must I do if I am out of compliance with these standards? You must submit a semiannual report on any recorded emission or parameter level that does not meet the requirements specified in [Subpart JJJ]. §62.15350 If a semiannual report is required, when must I submit it? (a) For data collected during the first half of a calendar year, submit your semiannual report by August 1 of that year. (b) For data you collected during the second half of the calendar year, submit your semiannual report by February 1 of the following year. §62.15355 What must I include in the semiannual ou t-of-compliance reports? As the alternative to compliance with §62.15355(c), the owner/operator shall maintain the following: (a) For any of the following six pollutants or parameters that exceeded the limits specified in [Subpart JJJ]. Include the calendar date they exceeded the limits, the averaged and recorded data for that date, the reasons for exceeding the limits, and your corrective actions:

(1) Concentration or percent reduction of sulfur dioxide emissions. (2) (not applicable) . (3) Concentration of carbon monoxide emissions. (4) Load level of your municipal waste combustion unit. (5) Temperature of the flue gases at the inlet[s] of your particulate matter air pollution control device[s]. (6) Average 6-minute opacity level. The data obtained from your continuous opacity monitoring system are not used to determine compliance with the limit on opacity emissions.



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(b) If the results of your annual stack tests (as recorded in §62.15300(a)) show emissions above the limits specified in table 2 or 4 of [Subpart JJJ] as applicable for dioxins/furans, cadmium, lead, mercury, particulate matter, opacity, hydrogen chloride, and fugitive ash, include a copy of the test report that documents the emission levels and your corrective actions. (c) For MWC units that use a rotary atomizing scrubber and fixed bed activated carbon adsorption bed for controlling dioxins/furans and mercury emissions, include the following:

(1) The parameter levels that exceeded the operational limits of §62.15145(c); (2) The date of the exceedance; (3) The reason for each exceedance; (4) Corrective actions taken, including date, to mitigate or eliminate an exceedance; (5) A copy of any vendor revised or new specification for the activated carbon; (6) Dates when the activated carbon is replaced, the amount replaced, and the MWC operating hours since the last replacement; and (7) The total amount of activated carbon purchased and delivered to the facility during the reporting period.

§62.15360 Can reporting dates be changed? (a) If the Administrator agrees, you may change the semiannual or annual reporting dates. (b) See §60.19(c) in Subpart A of 40 CFR part 60 for procedures to seek approval to change your reporting date.

I. See Table “A”, training, section 4.6.6a I.

J. Prior to combusting any amount of hospital, medical/infectious waste (HMIW) in the MWC units, the Permittee shall [Authority: 40 CFR 60 Subpart Ec, §60.50c(c)]

Notify the EPA Administrator and the Department of an exemption claim; and

Provides an estimate of the relative amounts of hospital waste, medical/infectious waste, and other fuels and wastes to be combusted.

K. A person subject to [regulation COMAR 26.11.09.08] shall maintain annual fuel use records on site for not less than 3 years, and make these records available to the Department upon request [Authority: COMAR 26.11.09.08K(3)].

TABLE “A” - Training Requirements 4.6.1a Emissions Unit Number(s)

• B1 and B4: Two (2) Small Municipal Waste Combustion units, each rated at 39 ton/day,

each equipped an emission control system, and heat recovery boilers.

4.6.2a Applicable Standards/Limits : Operator Certification and Training Requirements

COMAR 26.11.08.09B Certification and Operation. A person may not operate or allow an incinerator to be operated unless the owner certifies to the Department on a form approved by the Department that the incinerator operator: (1) has completed an initial training course approved by the Department which meets the requirements of COMAR 26.11.08.09D; (2) annually, after initial certification, completes a review course approved by the Department; (3) is present at all times whenever the incinerator is in operation



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TABLE “A” - Training Requirements COMAR 26.11.08.09D Training Course Requirements:

(1) For any incinerator operator who operates a municipal waste combustor (MWC), the training course shall address the following subjects in detail [Authority: COMAR 26.11.08.09D(1)]: (a) Overall operation, maintenance, and performance of the facility; (b) Start-up and shut-down of the facility; (c) Applicable federal, State, and local environmental regulations, and sanctions

for violations; (d) Policies and procedures for proper and safe plant operation; (e) Maintaining records of facility operations; (f) Actions to correct upsets or emergencies; (g) Control room operations; (h) Ash handling and disposal; (i) Combustion theory; (j) Air pollution control technology; and (k) Continuous emission monitors and their calibration, and quality assurance

requirements.

(2) For the operator of any municipal waste combustor (MWC) completing a training course means: (a) completing an initial training course approved by the Department of at least 5 days (40 hours) duration; (b) passing a written test approved by the Department [Authority: COMAR 26.11.08.09D(2)].

(3) (not applicable)

(4) The certified operator shall, after initial training, complete and pass an annual review course approved by the Department of at least 1 day (8 hours) duration [Authority: COMAR 26.11.08.09D(4)].

COMAR 26.11.09.08J(2), (3) and (5) – NOx RACT Train ing Requirements .


(2) Maintain and make available to the Department upon request the

written in-house training program; (3) Maintain operator training records at the site for at least 2 years and

make these records available to the Department.

The Permittee is subject to the operator training and certification requirements stated in 40 CFR Part 62, Subpart JJJ, which include paragraphs 40 CFR Part 62, Subpart JJJ requirements §62.15100 through §62.15140. With regard to the plant-specific operator training and the plant specific operating manual required by §62.15110 - §62.15125, the Department recognizes that the site-specific training given of each type employee may be limited to training appropriate to the employee’s respective areas of responsibility which affect the operation of the municipal waste combustion unit. For example, the training given ash handlers, or load handlers would not include the same topics as maintenance personnel, shift supervisors, or the chief facility operator.



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TABLE “A” - Training Requirements §62.15100 What types of training must I do? There are two types of required training: (a) Training of operators of municipal waste combustion units using the EPA or a State-approved training course. (b) Training of plant personnel using a plant-specific training course. §62.15105 Who must complete the operator training course? By when? (a) Three types of employees must complete the EPA operator training course:

(1) Chief facility operators. (2) Shift supervisors. (3) Control room operators.

(b) These employees must complete the operator training course by the later of three dates:

(1) One year after the effective date of [Subpart JJJ]. (2) Six months after your municipal waste combustion unit starts up. (3) The date before an employee assumes responsibilities that affect operation of the municipal waste combustion unit.

(c) The requirement in paragraph (a) of this section does not apply to chief facility operators, shift supervisors, and control room operators who have obtained full certification from the American Society of Mechanical Engineers on or before the effective date of [Subpart JJJ]. (d) You may request that the EPA Administrator waive the requirement in paragraph (a) of this section for chief facility operators, shift supervisors, and control room operators who have obtained provisional certification from the American Society of Mechanical Engineers on or before the effective date of [Subpart JJJ]. §62.15110 Who must complete the plant-specific tra ining course? All employees with responsibilities that affect how a municipal waste combustion unit operates must complete the plant-specific training course. Include at least six types of employees: (a) Chief facility operators. (b) Shift supervisors. (c) Control room operators. (d) Ash handlers. (e) Maintenance personnel. (f) Crane or load handlers. §62.15115 What plant-specific training must I prov ide? For plant-specific training, you must do four things: (a) For training at a particular plant, develop a specific operating manual for that plant by the later of two dates:

(1) Six months after your municipal waste combustion unit starts up. (2) One year after the effective date of [Subpart JJJ].



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TABLE “A” - Training Requirements (b) Establish a program to review the plant-specific operating manual with people whose responsibilities affect the operation of your municipal waste combustion unit. Complete the initial review by the later of three dates:

(1) One year after the effective date of [Subpart JJJ]. (2) Six months after your municipal waste combustion unit starts up. (3) The date before an employee assumes responsibilities that affect operation of the municipal waste combustion unit.

(c) Update your manual annually. (d) Review your manual with staff annually. §62.15120 What information must I include in the p lant-specific operating manual? You must include 11 items in the operating manual for your plant: (a) A summary of all applicable standards in [Subpart JJJ]. (b) A description of the basic combustion principles that apply to municipal waste combustion units. (c) Procedures for receiving, handling, and feeding municipal solid waste. (d) Procedures to be followed during periods of startup, shutdown, and malfunction of the municipal waste combustion unit. (e) Procedures for maintaining a proper level of combustion air supply. (f) Procedures for operating the municipal waste combustion unit within the standards contained in [Subpart JJJ]. (g) Procedures for responding to periodic upset or off-specification conditions. (h) Procedures for minimizing carryover of particulate matter. (i) Procedures for handling ash. (j) Procedures for monitoring emissions from the municipal waste combustion unit. (k) Procedures for record keeping and reporting. §62.15125 Where must I keep the plant-specific ope rating manual? You must keep your operating manual in an easily accessible location at your plant. It must be available for review or inspection by all employees who must review it and by the Administrator. §62.15130 What types of operator certification mu st the chief facility operator and shift supervisor obtain and by when must they o btain it?

(a) Each chief facility operator and shift supervisor must obtain and maintain a current provisional operator certification from either the American Society of Mechanical Engineers QRO-1-1994 or a State certification program in Connecticut and Maryland (if the affected facility is located in either of the respective States). If ASME certification is



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TABLE “A” - Training Requirements chosen, proceed in accordance with ASME QRO-1-1994. Standard for the Qualification and Certification of Resource Recovery Facility Operators. The Director of the Federal Register approves this incorporation by reference in accordance with 5 U.S.C.552(a) and 1 CFR part 51. You may obtain a copy from the American Society of Mechanical Engineers, Service Center, 22 Law Drive, Post Office Box 2900, Fairfield, NJ 07007. You may inspect a copy at the Office of Air Quality Planning and Standards Air Docket, EPA, 109 T.W. Alexander Drive, Room C521C, RTP, NC 27709 or at the Office of the Federal Register, 800 North Capitol Street, NW., Suite 700, Washington, DC. (b) Each chief facility operator and shift supervisor must obtain a provisional certification by the later of three dates

(1) For Class II units, 18 months after the effective date of [Subpart JJJ]. (2) Six months after the municipal waste combustion unit starts up. (3) Six months after they transfer to the municipal waste combustion unit or 6 months after they are hired to work at the municipal waste combustion unit.

(c) Each chief facility operator and shift supervisor must take one of three actions:

(1) Obtain a full certification from the American Society of Mechanical Engineers or a State certification program in your State [Authority: 40 CFR 60 Subpart AAAA §60. 1185(c)(1) or §62.15295(b)(1)] . (2) Schedule a full certification exam with the American Society of Mechanical Engineers (QRO-1-1994 (incorporated by reference in §60.17 (h)(1)). (3) Schedule a full certification exam with your State certification program [Authority: 40 CFR 60 Subpart AAAA, §60.1185(c)(3) or §62.15295(b)(1)].

(d) The chief facility operator and shift supervisor must obtain the full certification or be scheduled to take the certification exam by the later of the following dates:

(1)…. For Class II units, 18 months after the effective date of [Subpart JJJ]. (2) Six months after the municipal waste combustion unit starts up. (3) Six months after they transfer to the municipal waste combustion unit or 6 months after they are hired to work at the municipal waste combustion unit.

§62.15135 After the required date for operator certification, who may operate the municipal waste combustion unit? After the required date for full or provisional certification, you must not operate your municipal waste combustion unit unless one of four employees is on duty: (a) A fully certified chief facility operator. (b) A provisionally certified chief facility operator who is scheduled to take the full certification exam. (c) A fully certified shift supervisor. (d) A provisionally certified shift supervisor who is scheduled to take the full certification exam.

§62.15140 What if all the certified operators must be tempora rily offsite? If the certified chief facility operator and certified shift supervisor both are unavailable, a provisionally certified control room operator at the municipal waste combustion unit may fulfill the certified operator requirement. Depending on the length of time that a certified chief facility operator and certified shift supervisor is away, you must meet one



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TABLE “A” - Training Requirements of three criteria: (a) When the certified chief facility operator and certified shift supervisor are both offsite for 12 hours or less and no other certified operator is onsite, the provisionally certified control room operator may perform those duties without notice to, or approval by, the Administrator. (b) When the certified chief facility operator and certified shift supervisor are offsite for more than 12 hours, but for 2 weeks or less, and no other certified operator is onsite, the provisionally certified control room operator may perform those duties without notice to, or approval by, the Administrator. However, you must record the periods when the certified chief facility operator and certified shift supervisor are offsite and include this information in the annual report as specified under §62.15340(l). (c) When the certified chief facility operator and certified shift supervisor are offsite for more than 2 weeks and no other certified operator is onsite, the provisionally certified control room operator may perform those duties without notice to, or approval by, the Administrator. However, you must take two actions:

(1) Notify the Administrator in writing. In the notice, state what caused the absence and what you are doing to ensure that a certified chief facility operator or certified shift supervisor is onsite. (2) Submit a status report and corrective action summary to the Administrator every 4 weeks following the initial notification. If the Administrator notifies you that your status report or corrective action summary is disapproved, the municipal waste combustion unit may continue operation for 90 days, but then must cease operation. If corrective actions are taken in the 90-day period such that the Administrator withdraws the disapproval, municipal waste combustion unit operation may continue.

4.6.3a

Testing Requirements : See Record Keeping and Reporting Requirements..

4.6.4a

Monitoring Requirements :

The Permittee shall incorporate into the operations manual good operating practices procedures necessary to implement good operating practices as recommended by the equipment vendor to minimize NOx emissions [Authority: COMAR 26.11.09.08J(1)] and prepare and implement a written in-house training program for all operators. [Authority: COMAR 26.11.09.08J(2)]

4.6.5a Record Keeping Requir ements :

The Permittee shall obtain and maintain on site copies the certificate provided to each incinerator operator who has satisfactorily completed the approved incinerator operator training course and has passed the required examination and shall make them available to the Department upon request [Authority: COMAR 26.11.03.06C]. The Permittee shall maintain records of initial training and review courses completed by the incinerator operators. [Authority: COMAR 26.11.03.06C(3)].



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TABLE “A” - Training Requirements The Permittee shall maintain the following records [Authority: §62.15285(a), §62.15295, 40 CFR Part 62, Subpart JJJ].

§62.15285 What records must I keep? You must keep four types of records: (a) Operator training and certification. (b) –(d) [not applicable] §62.15295 What records must I keep for operator tr aining and certification? You must keep records of six items: (a) Records of provisional certifications. Include three items:

(1) For your municipal waste combustion plant, names of the chief facility operator, shift supervisors, and control room operators who are provisionally certified by the American Society of Mechanical Engineers [or an equivalent State-approved certification program [Authority: 40 CFR 62 Subpart JJJ, §62.15130]. (2) Dates of the initial provisional certifications. (3) Documentation showing current provisional certifications.

(b) Records of full certifications. Include three items:

(1) For your municipal waste combustion plant, names of the chief facility operator, shift supervisors, and control room operators who are fully certified by the American Society of Mechanical Engineers or an equivalent State-approved certification program. (2) Dates of initial and renewal full certifications. (3) Documentation showing current full certifications.

(c) Records showing completion of the operator training course. Include three items:

(1) For your municipal waste combustion plant, names of the chief facility operator, shift supervisors, and control room operators who have completed the EPA or State municipal waste combustion operator training course. (2) Dates of completion of the operator training course. (3) Documentation showing completion of operator training course.

(d) Records of reviews for plant-specific operating manuals. Include three items:

(1) Names of persons who have reviewed the operating manual. (2) Date of the initial review. (3) Dates of subsequent annual reviews.

(e) Records of when a certified operator is temporarily offsite. Include two main items:

(1) If the certified chief facility operator and certified shift supervisor are offsite for more than 12 hours but for 2 weeks or less and no other certified operator is onsite, record the dates that the certified chief facility operator and certified shift supervisor were offsite. (2) When all certified chief facility operators and certified shift supervisors are offsite for more than 2 weeks and no other certified operator is onsite, keep records of four items:

(i) Your notice that all certified persons are offsite. (ii) The conditions that cause these people to be offsite. (iii) The corrective actions you are taking to ensure a certified chief facility operator or certified shift supervisor is onsite. (iv) Copies of the written reports submitted every 4 weeks that summarize the actions taken to ensure that a certified chief facility operator or certified shift



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TABLE “A” - Training Requirements supervisor will be onsite.

(f) Records of calendar dates. Include the calendar date on each record.

COMAR 26.11.09.08J requires that the Permittee keep the following records: (1) A copy of the good operating practices manual; (2) A copy of the in-house training program; and (3) Operator training attendance records for each operator on site.

4.6.6a Reporting Requirements :

The Permittee shall certify to the Department on a form approved by the Department that the incinerator operator: (1) has completed an initial training course approved by the Department which meets the requirements of COMAR 26.11.08.09D; (2) annually, after initial certification, completes a review course approved by the Department; and (3) is present at all times whenever the incinerator is in operation [Authority: COMAR 26.11.08.09B]

Within 10 days after training is complete, the person who conducts an approved incinerator operator training course shall notify the Department in writing, of the names, employee identification numbers, and employer of those incinerator operators who have successfully complete the training course [Authority: COMAR 26.11.08.09G(1)]

§62.15340 What must I include in the annual report ? Summarize data collected for all pollutants and parameters regulated under [Subpart JJJ]. Your summary must include 12 items: Item 12 is: §62.15340 (l) Documentation of periods when all certified chief facility operators and certified shift supervisors are offsite for more than 12 hours.


The following emergency diesel generators • C1 and C2 Two 993 kW diesel fuel oil-fired generators. • C3 thru C6: Four 2,000 kW diesel fuel oil-fired generators. • C7: One 900 kW diesel fuel oil-fired generator. • C8: One 880 kW diesel fuel oil fired generator. • C9: One 1,502 BHP (1000 kW) diesel fuel-fired generator • C10: One 2,876 BHP (2000 kw) diesel fuel oil fired generator • C13: One 685 BHP (511 kW) diesel fuel oil fired generator.

4.7.2 Applicable Standards/Limits :

A. Visible Emissions Limitations

COMAR 26.11.09.05E(2) - Visible Emissions during Idle Mode. A person may not cause or permit the discharge of emissions from any engine, operating at idle, greater than 10



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percent opacity.

COMAR 26.11.09.05E(3) - Visible Emissions during Operating Mode. A person may not cause or permit the discharge of emissions from any engine, operating at other than idle conditions, greater than 40 percent opacity Exceptions: COMAR 26.11.09.05E(2) does not apply for a period of 2 consecutive minutes after a period of idling of 15 minutes for the purpose of clearing the exhaust system. COMAR 26.11.09.05E(2) does not apply to emissions resulting directly from cold engine start-up and warm-up for the following maximum periods: (a) engines that are idled continuously when not in service: 30 minutes; (b) all other engines: 15 minutes. COMAR 26.11.09.05E(2) and E(3) do not apply while maintenance, repair, or testing is being performed by qualified mechanics [Authority: COMAR 26.11.09.05E(4)] .

B. Control of Sulfur Oxides from Fuel Burning Equipment.

COMAR 26.11.09.07A(1)(c) - A person may not burn, sell, or make available for sale any distillate fuel with a sulfur content by weight in excess of 0.3 percent. 40 CFR part 63 subpart ZZZZ, §63.6604(b, beginning January 1, 2015 limits the diesel fuel sulfur content to 15 ppm maximum if an engine operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in §63.6640(f)(2)(ii) and (iii)

§63.6640(f)(2)(ii): Emergency stationary RICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see §63.14), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3. §63.6640(f)(2)(iii): Emergency stationary RICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency.



(1) Provide certification of the capacity factor of the equipment to the Department in

writing;

(2) For fuel-burning equipment that operates more than 500 hours during a calendar year, perform a combustion analysis and optimize combustion at least once annually;

(3) Maintain the results of the combustion analysis at the site for at least 2 years and

make these results available to the Department and the EPA upon request;



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(4) Require each operator of an installation, except combustion turbines, to attend operator training programs at least once every 3 years, on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and

(5) Maintain a record of training program attendance for each operator at the site and


NOTE: COMAR 26.11.09.08B(5) states that; (a) for the purpose of COMAR 26.11.09.08, the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation; and (b) that the operator training course sponsored by the Department shall include an in-house training course that is approved by the Department.

Operational Limitations

D. The following apply:

(1) The Permittee shall combust only No. 2 diesel fuel oil unless the Permittee applies for and receives an approval or permit from the Department to burn alternative fuels [Authority: COMAR 26.11.02.09A].

(2) 40 CFR part 63, subpart ZZZZ, §63.6603, Table 2d; §63.6604(b); §63.6605;

§63.6625(e), (f), and (h); and §63.6640(f) : § 63.6603 What emission limitations, operating li mitations, and other requirements must I meet if I own or operate an existing station ary RICE located at an area source of HAP emissions? §63.6603(a). If you own or operate an existing stationary RICE located at an area source of HAP emissions, you must comply with the requirements in Table 2d to this subpart and the operating limitations in Table 2b to this subpart that apply to you. §63.6603(b) through (f) - apply only to non-emergency engines. TABLE 2b TO SUBPART ZZZZ OF PART 63—OPERATING LIMITATIONS FOR … EXISTING CI STATIONARY RICE >500 HP Table 2b requirements: (No applicable Table 2b requirements for existing CI emergency engines at area sources). TABLE 2d TO SUBPART ZZZZ OF PART 63—REQUIREMENTS FOR EXISTING STATIONARY RICE LOCATED AT AREA SOURCES OF HAP EMISSIONS

As stated in §§63.6603 and 63.6640, you must comply with the following requirements for existing stationary RICE located at area sources of HAP emissions:

Table 2d requirements, item 4 - Emergency stationary CI RICE and black start stationary CI RICE.:

(a) Change oil and filter every 500 hours of operation or annually whichever comes first (b) Inspect air cleaner every 1,000 hours operation or annually, whichever comes first,

and replace as necessary;



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(c) Inspect all hoses and belts every 500 hours of operation or annually, and replace as necessary.

§63.6625(i) … you have the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Table … 2d to this subpart. The oil analysis must be performed at the same frequency specified for changing the oil in Table … 2d to this subpart. The analysis program must at a minimum analyze the following three parameters: Total Base Number, viscosity, and percent water content. The condemning limits for these parameters are as follows: Total Base Number is less than 30 percent of the Total Base Number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If all of these condemning limits are not exceeded, the engine owner or operator is not required to change the oil. If any of the limits are exceeded, the engine owner or operator must change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analysis are received, the engine owner or operator must change the oil within 2 business days or before commencing operation, whichever is later. The owner or operator must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine. §63.6604 What fuel requirements must I meet if I ow n or operate a stationary CI RICE? §63.6604(b) Beginning January 1, 2015, if you own or operate an existing emergency CI stationary RICE with a site rating of more than 100 brake HP and a displacement of less than 30 liters per cylinder that uses diesel fuel and operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in §63.6640(f)(2)(ii) and (iii) or that operates for the purpose specified in §63.6640(f)(4)(ii), you must use diesel fuel that meets the requirements in 40 CFR 80.510(b) for nonroad diesel fuel, except that any existing diesel fuel purchased (or otherwise obtained) prior to January 1, 2015, may be used until depleted.

§80.510(b) …. Except as otherwise specifically provided in this subpart, all NR [non-road] …diesel fuel is subject to the following per-gallon standards:

(1) Sulfur content.

(i) 15 ppm maximum for NR diesel fuel. (ii) (omitted) .

(2) Cetane index or aromatic content, as follows:

(i) A minimum cetane index of 40; or (ii) A maximum aromatic content of 35 volume percent.

§63.6605 What are my general requirements for compl ying with this subpart?

§63.6605(a) You must be in compliance with the emission limitations, operating limitations, and other requirements in this subpart that apply to you at all times. §63.6605(b) At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions.



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The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source.

§63.6625 What are my monitoring, installation, coll ection, operation, and maintenance requirements?

§63.6625(e)(3) If you own or operate [an existing emergency … stationary RICE located at an area source of HAP emissions], you must operate and maintain the stationary RICE and after-treatment control device (if any) according to the manufacturer's emission-related written instructions or develop your own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions: §63.6625(f) If you own or operate … an existing emergency stationary RICE located at an area source of HAP emissions, you must install a non-resettable hour meter if one is not already installed. §63.6640 How do I demonstrate continuous complian ce with the … operating limitations, and other requirements?

§63.6640(f) If you own or operate an emergency stationary RICE, you must operate the emergency stationary RICE according to the requirements in paragraphs (f)(1) through (4) of this section. In order for the engine to be considered an emergency stationary RICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in paragraphs (f)(1) through (4) of this section, is prohibited. If you do not operate the engine according to the requirements in paragraphs (f)(1) through (4) of this section, the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines. §63.6640(f)(1) There is no time limit on the use of emergency stationary RICE in emergency situations. §63.6640(f)(2) You may operate your emergency stationary RICE for any combination of the purposes specified in paragraphs (f)(2)(i) through (iii) of this section for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by paragraphs (f)(3) and (4) of this section counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2).

(i) Emergency stationary RICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency RICE beyond 100 hours per calendar year.

(ii) Emergency stationary RICE may be operated for emergency demand response for



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periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see §63.14), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3.

(iii) Emergency stationary RICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency. Note: The Permittee currently does not have a permit from the Department to operate the emergency diesel generators in the non-emergency situations described in paragraphs §63.6640(f)(3) and (f)(4), which are subject to emission limitations under regulation COMAR 26.11.36.

4.7.3 Testing Requirements:

A. - B. See Monitoring Requirements. C. The Permittee shall perform a combustion analysis and optimize combustion at least

annually for any engine that operates more than 500 hours during a calendar year. [Authority: COMAR 26.11.09.08G(1)(b)]

D. There are no testing requirements under 40 CFR part 63, subpart ZZZZ for existing

emergency CE IC engines at area sources of HAPs.

4.7.4 Monitoring Requirements: A. The Permittee shall properly operate and maintain the engines in a manner to minimize

visible emissions. [Authority: COMAR 26.11.03.06C(3) ] B. The Permittee shall obtain a certification from the fuel supplier indicating that the oil

complies with the limitation on the sulfur content of fuel oil [Authority: COMAR 26.11.03.06C(3) ].

C. The Permittee shall:

(1) Monitor the hours of operation of each installation and perform a combustion analysis at least once each year for any installation that exceeds 500 hours per year of operation and optimize combustion based on the analysis [Authority: COMAR 26.11.09.08J].

(2) Calculate the capacity factor of the engine at the end of each month and determine

whether an engine’s operations exceeded the 15 percent capacity factor on a rolling 12 month basis. [Authority: COMAR 26.11.03.06C(3)].

(3) The Permittee shall notify the Department not later than 60 days after the date when

the fuel burning equipment no longer meets the 15 percent capacity limitation on a rolling 12 month basis and shall meet the applicable fuel-burning RACT requirement of COMAR 26.11.09.08. [Authority: COMAR 26.11.03.06C(3)].


(1) See 4.7.5 D(1) recordkeeping requirements.



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(2) 40 CFR part 63, subpart ZZZZ, §63.6640, Table 6

§ 63.6640 How do I demonstrate continuous complia nce with the … operating limitations, and other requirements? §63.6640(a) You must demonstrate continuous compliance with each … operating limitation, and other requirements in … Table 2d to this subpart that apply to you according to methods specified in Table 6 to this subpart. Item 9 of Table 6 requires existing emergency stationary RICE located at an area source of HAP, to demonstrate continuous compliance by either: (1) operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions; or (2) developing and following the Permittee’s own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions.

4.7.5 Record Keeping Requirements: NOTE: All records shall be maintained for a period of 5

years [Authority: COMAR 26.11.03.06.C(5)(g)]. A. The Permittee shall maintain on site an operations manual and preventive maintenance

plan that relates to combustion performance, and maintain records of preventive maintenance that relates to combustion performance. [Authority: COMAR 26.11.03.06C(3)]

B. The Permittee shall maintain records of fuel supplier’s certification and shall make records

available to the Department upon request [Authority: COMAR 26.11.03.06C(3)]. C. The Permittee shall:

(1) Retain records of hours of operation on a monthly basis for all engines. At the end of

each month, the Permittee shall calculate the total hours for the calendar year. [Authority: COMAR 26.11.03.06C(3) ].

(2) Maintain the results of any combustion analysis (if required) at the site and make

these results available to the Department and the EPA upon request. [Authority: COMAR 26.11.09.08G(1)(c) & COMAR 26.11.03.06C(3)].

(3) Retain records of training program attendance for each operator at the site and make

these records available to the Department upon request. [Authority: COMAR 26.11.09.08G(1)(e) and COMAR 26.11.03.06C(3)].

(4) Records of the calculated monthly capacity factors [Authority: COMAR 26.11.03.06C]


(1) The Permittee shall maintain records of the type and quantity of fuel burned in each engine;

(2) The Permittee shall comply with the applicable recordkeeping requirements of 40

CFR part 63, subpart ZZZZ

§63.6625(i) you have the option of utilizing an oil analysis program in order to extend the specified oil change requirement in Table … 2d to this subpart…. The owner or operator must keep records of the parameters that are analyzed as part of the program, the results



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of the analysis, and the oil changes for the engine. §63.6655(a) If you must comply with the … operating limitations, you must keep the records described in paragraphs (a)(1) through (a)(5), (b)(1) through (b)(3) and (c) of this section §63.6655(a)(1) A copy of each notification and report that you submitted to comply with this subpart, including all documentation supporting any Initial Notification or Notification of Compliance Status that you submitted, according to the requirement in §63.10(b)(2)(xiv). §63.6655(a)(2) – (5) and §63.6655(b) and (c) – not applicable. See fact sheet. §63.6655(d) You must keep the records required in Table 6 to this subpart to show continuous compliance with each … operating limitation that applies to you..

Item 9 of Table 6 applies to “ … existing emergency and black start stationary RICE located at an area source of HAP,… “ Accordingly, the Permittee must keep the records necessary to demonstrate that the Permittee is operating and maintaining the stationary RICE according to the manufacturer's emission-related operation and maintenance instructions; or the Permittee has developed and is following their own maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions.

§63.6655(e)(2) You must keep records of the maintenance conducted on the stationary RICE in order to demonstrate that you operated and maintained the stationary RICE and after-treatment control device (if any) according to your own maintenance plan if you own or operate any of the following stationary RICE: … (2) An existing stationary emergency RICE.

§63.6655(f)(2) If you own or operate … [an existing emergency stationary RICE located at an area source of HAP emissions that does not meet the standards applicable to non-emergency engines] you must keep records of the hours of operation of the engine that is recorded through the non-resettable hour meter. The owner or operator must document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non-emergency operation. If the engine is used for the purposes specified in §63.6640(f)(2)(ii) or (iii) …, the owner or operator must keep records of the notification of the emergency situation, and the date, start time, and end time of engine operation for these purposes. ….

4.7.6 Reporting Requirements: A. The Permittee shall report incidents of visible emissions in accordance with permit

condition 4, Section III, Plant Wide Conditions, “Report of Excess Emissions and Deviations.”

B. The Permittee shall report fuel supplier certification to the Department upon request

[Authority: COMAR 26.11.09.07C]. C. The Permittee shall:

(1) Submit a list of operator training attendance to the Department upon request



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[Authority: COMAR 26.11.09.08E(5)]. (2) Submit the results of combustion analysis to the Department upon request whenever

the engine operates more than 500 hours in a calendar year. [Authority: COMAR 26.11.09.08G(1)(c)]

(3) Submit a certification of the annual capacity factor for the engine with the annual

emissions certification report. [Authority: COMAR 26.11.09.08G(1)(a) and COMAR 26.11.03.06C(3) ]


(1) Permittee shall submit a record of the quantity of each type of fuel burned with the annual emissions certification report that is due April 1 of each year [Authority: COMAR 26.11.02.19C(2)].

(2) 40 CFR part 63, subpart ZZZZ.

§63.6640(a) referencing Table 2d, the following reporting requirement in footnote 2 to Table 2d: If an emergency engine is operating during an emergency and it is not possible to shut down the engine in order to perform the management practice requirements on the schedule required in Table 2d of this subpart, or if performing the management practice on the required schedule would otherwise pose an unacceptable risk under federal, state, or local law, the management practice can be delayed until the emergency is over or the unacceptable risk under federal, state, or local law has abated. The management practice should be performed as soon as practicable after the emergency has ended or the unacceptable risk under federal, state, or local law has abated. Sources must report any failure to perform the management practice on the schedule required and the federal, state or local law under which the risk was deemed unacceptable.

§63.6640(e) You must report each instance in which you did not meet the requirements in Table 8 to this subpart that apply to you, with the exception of the following items: §§63.7(b) and (c), 63.8(e), (f)(4) and (f)(6), 63.9(b) through (e), and (g) and (h) [Ref: §63.6645(a)(5)] §63.6645(a) not applicable to an existing stationary emergency RICE. [Ref: §63.6645(a)(5)]

§63.6650(a) You must submit each report in Table 7 of this subpart that applies to you. TABLE 7 TO SUBPART ZZZZ OF PART 63—REQUIREMENTS FOR REPORTS As stated in §63.6650, you must comply with the following requirements for reports: Table 7, Item 4 requirements. For each emergency stationary RICE that operate or are contractually obligated to be available for more than 15 hours per year for the purposes specified in §63.6640(f)(2)(ii) and (iii) …. You must submit a report, which must contain the information in 63.6650(h)(1). The report must be submitted annually according to the requirements in 63.6650(h)(2) – (3).



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§63.6650(b) Unless the Administrator has approved a different schedule for submission of reports under §63.10(a), you must submit each report by the date in Table 7 of this subpart and according to the requirements in paragraphs (b)(1) through (b)(9) of this section.

§63.6650(b)(1) For semiannual Compliance reports, the first Compliance report must cover the period beginning on the compliance date that is specified for your affected source in §63.6595 and ending on June 30 or December 31, whichever date is the first date following the end of the first calendar half after the compliance date that is specified for your source in §63.6595.

§63.6650(b)(2) For semiannual Compliance reports, the first Compliance report must be postmarked or delivered no later than July 31 or January 31, whichever date follows the end of the first calendar half after the compliance date that is specified for your affected source in §63.6595. §63.6650(b)(3) For semiannual Compliance reports, each subsequent Compliance report must cover the semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. §63.6650(b)(4) For semiannual Compliance reports, each subsequent Compliance report must be postmarked or delivered no later than July 31 or January 31, whichever date is the first date following the end of the semiannual reporting period. §63.6650(b)(5) For each stationary RICE that is subject to permitting regulations pursuant to 40 CFR part 70 …, and if the permitting authority has established dates for submitting semiannual reports pursuant to 40 CFR 70.6(a)(3)(iii)(A) [State Title V program]… you may submit the first and subsequent Compliance reports according to the dates the permitting authority has established instead of according to the dates in paragraphs (b)(1) through (b)(4) of this section. Note: Section III, part 4d. of this permit requires that semiannual monitoring reports be submitted within 30 days of the end of the reporting period specified in §63.6650(b)(1)and (b)(3) above. §63.6650(b)(6) For annual Compliance reports, the first Compliance report must cover the period beginning on the compliance date that is specified for your affected source in §63.6595 and ending on December 31. §63.6650(b)(7) and (b)(9): The reporting dates specified in paragraphs (b)(7) and (b)(9) are not applicable to facilities with a Title V permit. Section III, part 9. of this permit requires that annual Compliance Certification reports covering the previous calendar year be submitted by April 1 of each year. See §63.6650(f) below. §63.6650(b)(8) For annual Compliance reports, each subsequent Compliance report must cover the annual reporting period from January 1 through December 31. §63.6650(c) The Compliance report must contain the information in paragraphs (c)(1) through (6) of this section.

§63.6650(c)(1) Company name and address.

§63.6650(c)(2) Statement by a responsible official, with that official's name, title, and signature, certifying the accuracy of the content of the report.



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§63.6650(c)(3) Date of report and beginning and ending dates of the reporting period.

§63.6650(c)(4) If you had a malfunction during the reporting period, the compliance report must include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report must also include a description of actions taken by an owner or operator during a malfunction of an affected source to minimize emissions in accordance with §63.6605(b), including actions taken to correct a malfunction.

§63.6650(c)(5) If there are no deviations from … operating limitations that apply to you, a statement that there were no deviations from the … operating limitations during the reporting period.

§63.6650(c)(6) not applicable. No CEMS or CPMS not required.

§63.6650(d) For each deviation from an… operating limitation that occurs for a stationary RICE …. , the Compliance report must contain the information in paragraphs (c)(1) through (4) of this section and the information in paragraphs (d)(1) and (2) of this section.

§63.6650(d)(1) The total operating time of the stationary RICE at which the deviation occurred during the reporting period.

§63.6650(d)(2) Information on the number, duration, and cause of deviations (including unknown cause, if applicable), as applicable, and the corrective action taken. §63.6650(e) – not applicable. Not required to have a CMS

§63.6650(f) Each affected source that has obtained a title V operating permit pursuant to 40 CFR part 70 … must report all deviations as defined in this subpart in the semiannual monitoring report required by 40 CFR 70.6 (a)(3)(iii)(A) …. If an affected source submits a Compliance report pursuant to Table 7 of this subpart along with, or as part of, the semiannual monitoring report required by 40 CFR 70.6(a)(3)(iii)(A) … , and the Compliance report includes all required information concerning deviations from any emission or operating limitation in this subpart, submission of the Compliance report shall be deemed to satisfy any obligation to report the same deviations in the semiannual monitoring report. However, submission of a Compliance report shall not otherwise affect any obligation the affected source may have to report deviations from permit requirements to the permit authority.

§63.6650(g) - not applicable. Not new or reconstructed RICE

§63.6650(h) If you own or operate an emergency stationary RICE with a site rating of more than 100 brake HP that operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in §63.6640(f)(2)(ii) and (iii) or that operates for the purpose specified in §63.6640(f)(4)(ii), you must submit an annual report according to the requirements in paragraphs (h)(1) through (3) of this section.

§63.6650(h)(1) The report must contain the following information:



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(vii) Hours spent for operation for the purpose specified in §63.6640(f)(4)(ii), including the date, start time, and end time for engine operation for the purposes specified in §63.6640(f)(4)(ii). The report must also identify the entity that dispatched the engine and the situation that necessitated the dispatch of the engine.

(viii) If there were no deviations from the fuel requirements in §63.6604 that apply to the engine (if any), a statement that there were no deviations from the fuel requirements during the reporting period.

(ix) If there were deviations from the fuel requirements in §63.6604 that apply to the engine (if any), information on the number, duration, and cause of deviations, and the corrective action taken.

§63.6650(h)(2) The first annual report must cover the calendar year 2015 and must be submitted no later than March 31, 2016. Subsequent annual reports for each calendar year must be submitted no later than March 31 of the following calendar year.

§63.6650(h)(3) The annual report must be submitted electronically using the subpart specific reporting form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, the written report must be submitted to the Administrator at the appropriate address listed in §63.13.


The following emergency diesel generators firing diesel fuel oil, subject to New Source Performance Standard 40 CFR part 60, subpart IIII and 40 CFR part 63, subpart ZZZZ as new or reconstructed sources.. • C11: One 600 kW Kohler Model 600REOZv located in Bldg 693 • C12: One 764 BHP (570 kW) Caterpillar Model 3456 located at Bldg 190 (boiler plant) • C14: One 1000 kW Kohler Model 1000REOZMB located in Bldg 568. • C15: One 2000 kW Caterpillar Model SR45/3516C located in Bldg 8100. • C16: One 500 kW Kohler Model 500REOZJ located in Bldg 1419.



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4.8.2 Applicable Standards/Limits : A. Visible Emissions Limitations

COMAR 26.11.09.05E(2) - Visible Emissions during Idle Mode. A person may not cause or permit the discharge of emissions from any engine, operating at idle, greater than 10 percent opacity.

COMAR 26.11.09.05E(3) - Visible Emissions during Operating Mode. A person may not cause or permit the discharge of emissions from any engine, operating at other than idle conditions, greater than 40 percent opacity Exceptions: COMAR 26.11.09.05E(2) does not apply for a period of 2 consecutive minutes after a period of idling of 15 minutes for the purpose of clearing the exhaust system. COMAR 26.11.09.05E(2) does not apply to emissions resulting directly from cold engine start-up and warm-up for the following maximum periods: (a) engines that are idled continuously when not in service: 30 minutes; (b) all other engines: 15 minutes. COMAR 26.11.09.05E(2) and E(3) do not apply while maintenance, repair, or testing is being performed by qualified mechanics [Authority: COMAR 26.11.09.05E(4)] .

B. Control of Sulfur Oxides from Fuel Burning Equipment.

The Permittee shall not combust fuel oil in the engines with a sulfur content in excess of 15 parts per million by weight [Authority: §60.4207, 40 CFR part 60, subpart IIII]



(1) Provide certification of the capacity factor of the equipment to the Department in

writing; (2) For fuel-burning equipment that operates more than 500 hours during a calendar

year, perform a combustion analysis and optimize combustion at least once annually;

(3) Maintain the results of the combustion analysis at the site for at least 2 years and

make these results available to the Department and the EPA upon request; (4) Require each operator of an installation, except combustion turbines, to attend

operator training programs at least once every 3 years, on combustion optimization that are sponsored by the Department, the EPA, or equipment vendors; and

(5) Maintain a record of training program attendance for each operator at the site and


NOTE: COMAR 26.11.09.08B(5) states that; (a) for the purpose of COMAR 26.11.09.08, the equipment operator to be trained may be the person who maintains the equipment and makes the necessary adjustments for efficient operation; and (b) that the operator training course sponsored by the Department shall include an in-house training course that is



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approved by the Department.

Operational Limitations D. The Permittee shall:

(1) Combust only No. 2 diesel fuel oil unless the Permittee applies for and receives an approval or permit from the Department to burn alternative fuels [Authority: COMAR 26.11.02.09A].

Note: The engines are also nominally subject to 40 CFR part 63, subpart ZZZZ, but meet all of the requirements by being subject to the requirements 40 CFR part 60, subpart IIII [Ref: 40 CFR 63.6590(c)(1)

(2) For any diesel generator whose engine was manufactured after April 1, 2006 and

was ordered by the Permittee on or after July 11, 2005, and therefore subject to 40 CFR 60 Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines:

(a) Pre-2007 model year emergency stationary CI ICE with a displacement of less

than 10 liters per cylinder must comply with the emission standards in Table 1 to Subpart IIII of Part 60 [Authority: §60.4205(a), 40 CFR part 60, subpart IIII].

(b) 2007 model year and later emergency stationary CI ICE with a displacement of less than 30 liters per cylinder must comply with the emission standards for new nonroad CI engines in §60.4202, for all pollutants, for the same model year and maximum engine power for their 2007 model year and later emergency stationary CI ICE. [Authority: §60.4205(b), 40 CFR part 60, subpart IIII]. §60.4202(a) Stationary CI internal combustion engine manufacturers must certify their 2007 model year and later emergency stationary CI ICE with a maximum engine power less than or equal to 2,237 KW (3,000 HP) and a displacement of less than 10 liters per cylinder to the emission standards specified in §60.4202(a)(2).

§60.4202(a)(2) For engines with a maximum engine power greater than or equal to 37 KW (50 HP), the certification emission standards for new nonroad CI engines for the same model year and maximum engine power in 40 CFR 89.112 and 40 CFR 89.113 for all pollutants beginning in model year 2007.

(c) The Permittee shall combust only diesel fuel meeting the requirements of 40 CFR §80.510(b) [Authority: §60.4207, 40 CFR part 60, subpart IIII]: (i) The maximum sulfur content shall not exceed 15 ppm by weight;

(ii) Either the minimum cetane index shall be at least 40 or the maximum

aromatic content shall not exceed 40 percent by volume.

(d) In keeping with §60.4211(f)(2) through (f)(2)(iii), the Permittee shall limit the hours of operation for nonemergency use to 100 hours per year or less unless prior approval is obtained from the Department [Authority: §60.4211(f), 40 CFR part 60, subpart IIII].



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§60.4211(f) If you own or operate an emergency stationary ICE, you must operate the emergency stationary ICE according to the requirements in paragraphs (f)(1) through (3) of this section. In order for the engine to be considered an emergency stationary ICE under this subpart, any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non-emergency situations for 50 hours per year, as described in paragraphs (f)(1) through (3) of this section, is prohibited. If you do not operate the engine according to the requirements in paragraphs (f)(1) through (3) of this section, the engine will not be considered an emergency engine under this subpart and must meet all requirements for non-emergency engines.

§60.4211(f)(1) There is no time limit on the use of emergency stationary ICE in emergency situations.

§60.4211(f)(2) You may operate your emergency stationary ICE for any combination of the purposes specified in paragraphs (f)(2)(i) through (iii) of this section for a maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by paragraph (f)(3) of this section counts as part of the 100 hours per calendar year allowed by this paragraph (f)(2).

§60.4211(f)(2)(i) Emergency stationary ICE may be operated for maintenance checks and readiness testing, provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar year.

§60.4211(f)(2)(ii) Emergency stationary ICE may be operated for emergency demand response for periods in which the Reliability Coordinator under the North American Electric Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy Emergencies (incorporated by reference, see §60.17), or other authorized entity as determined by the Reliability Coordinator, has declared an Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-002-3. §60.4211(f)(2)(iii) Emergency stationary ICE may be operated for periods where there is a deviation of voltage or frequency of 5 percent or greater below standard voltage or frequency.

4.8.3 Testing Requirements: A. – B. See Monitoring and Record Keeping Requirements. . C. The Permittee shall perform a combustion analysis and optimize combustion at least

annually for any engine that operates more than 500 hours during a calendar year. [Authority: COMAR 26.11.09.08G(1)(b)]



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D. See Monitoring and Record Keeping Requirements.

4.8.4 Monitoring Requirements: A. The Permittee shall properly operate and maintain the engines in a manner to minimize

visible emissions. [Authority: COMAR 26.11.03.06C(3) ] B. The Permittee shall obtain a certification from the fuel supplier indicating that the oil

complies with the limitation on the sulfur content of fuel oil [Authority: COMAR 26.11.03.06C(3)].


(1) Monitor the hours of operation of each installation and perform a combustion analysis at least once each year for any installation that exceeds 500 hours per year of operation and optimize combustion based on the analysis [Authority: COMAR 26.11.09.08J].

(2) Calculate the capacity factor of the engine at the end of each month and determine

whether an engine’s operations exceeded the 15 percent capacity factor on a rolling 12 month basis. [Authority: COMAR 26.11.03.06C(3)].

(3) The Permittee shall notify the Department not later than 60 days after the date when

the fuel burning equipment no longer meets the 15 percent capacity limitation on a rolling 12 month basis and shall meet the applicable fuel-burning RACT requirement of COMAR 26.11.09.08. [Authority: COMAR 26.11.03.06C(3)].


(1) The Permittee must operate and maintain, over the entire life of the source, each emergency diesel generator and control devices according to the manufacturer’s written instructions or according to procedures developed by the Permittee that are approved by the manufacturer. Additionally, the Permittee may change only those settings that are permitted by the manufacturer. The Permittee must also meet the requirements of 40 CFR parts 89, 94 and/or 1068 as they may apply to an owner or operator [Authority: 40 CFR part 60, subpart IIII, §60.4211(a)].

(2) The Permittee must install non-resettable hour meter on each engine prior to the startup of engine [Authority: 40 CFR part 60, subpart IIII, §60.4209(a)].

(3) The Permittee shall record the operation of each emergency diesel generator in

emergency and non-emergency service that are recorded through the non-resettable hour meter. The Permittee must record the time of operation of each emergency diesel generator and the reason the emergency diesel generator was in operation during that time [Authority: 40 CFR part 60, subpart IIII, §60.4214(b)].

4.8.5 Record Keeping Requirements: NOTE: All records shall be maintained for a period of 5 years [Authority: COMAR 26.11.03.06.C(5)(g)]. A. The Permittee shall maintain on site an operations manual and preventive maintenance

plan that relates to combustion performance, and maintain records of preventive maintenance that relates to combustion performance. [Authority: COMAR 26.11.03.06C(3)]



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B. The Permittee shall maintain records of fuel supplier’s certification and shall make records available to the Department upon request [Authority: COMAR 26.11.03.06C(3)].


(1) Retain records of hours of operation on a monthly basis for all engines. At the end of

each month, the Permittee shall calculate the total hours for the calendar year. [Authority: COMAR 26.11.03.06C(3) ].

(2) Maintain the results of any combustion analysis (if required) at the site and make

these results available to the Department and the EPA upon request. [Authority: COMAR 26.11.09.08G(1)(c) & COMAR 26.11.03.06C(3)].

(3) Retain records of training program attendance for each operator at the site and make

these records available to the Department upon request. [Authority: COMAR 26.11.09.08G(1)(e) and COMAR 26.11.03.06C(3)].

(4) Records of the calculated monthly capacity factors [Authority: COMAR 26.11.03.06C]


(1) The Permittee shall maintain on site for the life of the source the following records for the emergency diesel generators [Authority: condition E(2), Permit to Construct 021-0131-9-0353 issued by the Department on November 13, 2012, COMAR 26.11.03.06C(3)]: (a) The installation date of each emergency generator; and

(b) The certifications of compliance or manufacturer engine test data required by 40

CFR §60.4211 and §60.4214(b).

(2) The Permittee shall keep records of the operation of each emergency diesel generator in emergency and non-emergency service that are recorded through the non-resettable hour meter. The Permittee must keep records of the time of operation of each emergency diesel generator and the reason the emergency diesel generator was in operation during that time [Authority: 40 CFR part 60, subpart IIII, §60.4214(b)].

(3) The Permittee shall, for each delivery of fuel to be used in the emergency diesel generators, obtain from the fuel supplier a fuel supplier certification consisting of the name of the oil supplier, the date of delivery, the amount of fuel delivered, and a statement from the fuel supplier that the diesel fuel oil complies with the specifications of 40 CFR §80.510(b) [Authority: condition E(3), Permit to Construct 021-0131-9-0353 issued by the Department on November 13, 2012, COMAR 26.11.03.06C(3)].

4.8.6 Reporting Requirements: A. The Permittee shall report incidents of visible emissions in accordance with permit

condition 4, Section III, Plant Wide Conditions, “Report of Excess Emissions and Deviations.”

B. The Permittee shall report fuel supplier certification to the Department upon request

[Authority: COMAR 26.11.09.07C].



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(1) Submit a list of operator training attendance to the Department upon request [Authority: COMAR 26.11.09.08E(5)].

(2) Should an engine ever operate more than 500 hours in a calendar year, submit the results of combustion analysis to the Department for that engine [Authority: COMAR 26.11.09.08G(1)(c)].

(3) Submit a certification of the annual capacity factor for the engine with the annual emissions certification report. [Authority: COMAR 26.11.09.08G(1)(a) and COMAR 26.11.03.06C(3) ]

D. The Permittee shall:

(1) Submit a record of the quantity of each type of fuel burned with the annual

emissions certification report that is due April 1 of each year [Authority: COMAR 26.11.02.19C(2)].

(2) 40 CFR part 60, subpart IIII reporting requirements:

§60.4214(d) If you own or operate an emergency stationary CI ICE with a maximum engine power more than 100 HP that operates or is contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in §60.4211(f)(2)(ii) and (iii) or that operates for the purposes specified in §60.4211(f)(3)(i), you must submit an annual report according to the requirements in paragraphs (d)(1) through (3) of this section.

§60.4214(d) (1) The report must contain the following information:







(vii) Hours spent for operation for the purposes specified in §60.4211(f)(3)(i), including the date, start time, and end time for engine operation for the purposes specified in §60.4211(f)(3)(i). The report must also identify the entity that dispatched the engine and the situation that necessitated the dispatch of the engine.

§60.4214(d)(2) The first annual report must cover the calendar year 2015 and must be



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submitted no later than March 31, 2016. Subsequent annual reports for each calendar year must be submitted no later than March 31 of the following calendar year.

§60.4214(d)(3) The annual report must be submitted electronically using the subpart specific reporting form in the Compliance and Emissions Data Reporting Interface (CEDRI) that is accessed through EPA's Central Data Exchange (CDX) (www.epa.gov/cdx). However, if the reporting form specific to this subpart is not available in CEDRI at the time that the report is due, the written report must be submitted to the Administrator at the appropriate address listed in §60.4.


F1: Two 12,000 gallon underground gasoline storage tanks, using Stage I vapor recovery

systems, fuel feed to 6 dispensers which use Stage II vapor recovery systems.

4.9.2 Applicable Standards/Limits: A. Loading Operations – COMAR 26.11.13.04

(1) Small Storage Tanks:

(a) COMAR 26.11.13.04C(1) - Applicability. This section applies to a person who owns or operates: (a) a gasoline storage tank that has a tank capacity greater than 2,000 gallons but less than 40,000 gallons; or (b) a gasoline tank truck used to transfer gasoline into a storage tank that is listed in §C(1)(a) of this regulation.

(b) COMAR 26.11.13.04C(2) - Stage I Vapor Recovery. An owner or operator of a

gasoline tank truck or an owner or operator of a stationary storage tank subject to this regulation may not cause or permit gasoline to be loaded into a stationary tank unless the loading system is equipped with a vapor balance line that is properly installed, maintained and used.

(2) General Standards:

COMAR 26.11.13.04D(1)–(2) A person may not cause or permit gasoline or VOC having a TVP of 1.5 psia (10.3 kilonewtons/square meter) or greater to be loaded into any tank truck, railroad tank car, or other contrivance unless the:

(a) Loading connections on the vapor lines are equipped with fittings that have no

leaks and that automatically and immediately close upon disconnection to prevent the release of gasoline or VOC from these fittings; and

(b) Equipment is maintained and operated in a manner to prevent release of

gasoline or VOC from these fittings.” B. 40 CFR part 63 subpart CCCCCC - National Emission Standards for Hazardous Air

Pollutants - Gasoline Dispensing Facilities (GDF). As an existing affected source with a monthly throughput of more than 100,000 gallons per month, that commenced construction prior to November 9, 2006, the Permittee must comply with the requirements of §63.11118 as applicable [Authority: 40 CFR §63.11111 and §63.11113(b)-(c)].



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§63.11113 When do I have to comply with this subpa rt? §63.11113(b) If you have an existing affected source, you must comply with the standards in this subpart no later than January 10, 2011. §63.11118 Requirements for facilities with monthly throughput of 100,000 gallons of gasoline or more. §63.11118(a) You must comply with the requirements in §§63.11116(a) and 63.11117(b).

§63.11116(a) provides that you must not allow gasoline to be handled in a manner that would result in vapor releases to the atmosphere for extended periods of time. Measures to be taken include, but are not limited to, the following: (1) Minimize gasoline spills; (2) Clean up spills as expeditiously as practicable; (3) Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when not in use; (4) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to reclamation and recycling devices, such as oil/water separators.

§63.11117((b )provides that, except as specified in paragraph §63.11117( (c), you must only load gasoline into storage tanks at your facility by utilizing submerged filling, as defined in §63.11132, and as specified in paragraph (b)(1) or paragraph (b)(2) of this section. (1) Submerged fill pipes installed on or before November 9, 2006, must be no more than 12 inches from the bottom of the storage tank. (2) Submerged fill pipes installed after November 9, 2006, must be no more than 6 inches from the bottom of the storage tank. (3) Submerged fill pipes not meeting the specifications of paragraphs (b)(1) or (b)(2) of this section are allowed if the owner or operator can demonstrate that the liquid level in the tank is always above the entire opening of the fill pipe. Documentation providing such a demonstration must be made available for inspection by the Administrator’s delegated representative during the course of the site visit.

§63.11118((b) Except as provided in paragraph (c) of this section, you must meet the requirements of either paragraph (b)(1) or paragraph (b)(2) of this section.

(1) Each management practice in Table 1 to this subpart that applies to your gasoline dispensing facility (GDF). (2) If prior to January 10, 2008, you satisfy the requirements in both paragraphs (b)(2)(i) and (ii) of this section, you will be deemed in compliance with this subsection.

(i) You operate a vapor balance system at your GDF that meets the requirements of either paragraph (b)(2)(i)(A) or paragraph (b)(2)(i)(B) of this



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section

(A) Achieves emissions reduction of at least 90 percent.

(B) Operates using management practices at least as stringent as those in Table 1 to this subpart.

(ii) Your gasoline dispensing facility is in compliance with an enforceable State, local, or tribal rule or permit that contains requirements of either paragraph (b)(2)(i)(A) or paragraph (b)(2)(i)(B) of this section.

Note: In keeping with §63.11118(b)(2)(ii), the Department deems gasoline storage tanks operating in compliance with a permit that was issued by the Department before January 10, 2008 to be in compliance with §63.11118(b).

§63.11118(d) Cargo tanks unloading at GDF must comply with the management practices in Table 2 to Subpart CCCCCC of Part 63 – Applicability Criteria and Management Practices for Gasoline Cargo Tanks Unloading at Gasoline Dispensing Facilities With Monthly Throughput of 100,000 Gallons of Gasoline or More. Table 2 specifies the following requirements:

(i) All hoses in the vapor balance system are properly connected, (ii) The adapters or couplers that attach to the vapor balance line on the storage tank have closures that seal upon disconnect, (iii) All vapor return hoses, couplers, and adapters used in the gasoline delivery are vapor-tight, (iv) All tank truck vapor return equipment is compatible in size and forms a vapor-tight connection, and (v) All hatches on the tank truck are closed and securely fastened. (vi) The filling of storage tanks at GDF shall be limited to unloading by vapor-tight gasoline cargo tanks. Documentation that the cargo tank has met the specifications of EPA Method 27 shall be carried on the cargo tank .

§63.11118(e) - (g) See testing, recordkeeping, notification, and reporting requirements. .

C. Stage II Regulations (1) COMAR 26.11.24.03 - General Requirements

(a) New Gasoline Dispensing Facilities. After May 15, 1993, an owner or operator of a new gasoline dispensing facility may not operate the gasoline dispensing facility unless it is equipped and operated with an approved system [Authority: COMAR 26.11.24.03A].

(b) An operator may not use or allow the use of defective equipment associated

with the transfer of gasoline from a stationary gasoline storage tank to motor vehicle fuel tanks [Authority: COMAR 26.11.24.03E].

(c) The operator may not install or use a replacement part in an approved system



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unless that part has been certified by CARB or approved by the Department for the approved system [Authority: COMAR 26.11.24.03F].

(d) Gasoline storage tanks serving a gasoline dispensing facility that is subject to

this chapter shall be equipped with a properly designed and installed pressure and vacuum valve with minimum pressure and vacuum settings as specified in the CARB Executive Order for that system [Authority: COMAR 26.11.24.03H].

(e) If an approved system is certified under more than one Executive Order, the

most recent Executive Order shall apply [Authority: COMAR 26.11.24.03I]. (2) COMAR 26.11.24.06 - Training Requirements for Operation and Maintenance of

Approved Systems

(a) General. An operator shall ensure that: (1) at least one employee at each facility subject to this regulation is trained in accordance with the requirements of §B of regulation COMAR 26.11.24.06; and (2) the trained employee assists in the training of each of the other employees at that facility who are involved in the operation or maintenance of the approved system [Authority: COMAR 26.11.24.06A].

(b) Approved Training Course Contents and Duration.

(i) An approved training course shall contain, at a minimum, a discussion of the

following: (a) purposes and effects of Stage II vapor recovery; (b) Stage II vapor recovery equipment design, function, operation and maintenance; (c) daily inspection requirements and development and maintenance of records and files; and (d) equipment warranties and spare parts [Authority: COMAR 26.11.24.06B(1)].

(ii) The approved training course shall be of a duration sufficient to properly train

persons in the requirements of chapter 24 [Authority: COMAR 26.11.24.06B(2)].

(3) COMAR 26.11.24.08 - Instructional Signs

(a) An operator who is subject to this chapter shall place instructional signs in

conspicuous locations at each gasoline dispenser. (b) The instructional signs shall include:

(i) Instructions, with illustrations, on how to insert the nozzle, dispensing

gasoline, and how to remove the nozzle; (ii) A warning against attempts to continue refueling after automatic shutoff of

the gasoline (that is, topping off); and

(iii) The Department’s toll-free telephone number which may be used for complaints or comments concerning the use of the Stage II vapor recovery systems.”

4.9.3 Testing Requirements:

A. See Monitoring Requirements.



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B. 40 CFR 63 Subpart CCCCCC Testing Requirements [Authority: 40 CFR §63.11120].

§63.11120 What testing and monitoring requirements must I meet? §63.11120(a) Each owner or operator, at the time of installation of a vapor balance system required under §63.11118(b)(1), and every 3 years thereafter, must comply with the requirements in paragraphs (a)(1) and (2) of this section.

Not applicable - as an existing source issued a permit by the Department prior to January 10, 2008, the installations are exempt from testing under this paragraph.

C. COMAR 26.11.24.04-Testing Requirements.

(1) Except as provided in §§F and G of this regulation, an owner subject to this chapter shall perform the following CARB-approved tests:

(a) A leak test in accordance with the Vapor Recovery Test Procedure TP-201.3

referenced in Regulation .01-1B(1) of this chapter; (b) An air to liquid volume ratio test in accordance with the Vapor Recovery Test

Procedure TP-201.5 referenced in Regulation .01-1B(2) of this chapter; (c) A dynamic pressure performance test in accordance with the Vapor Recovery

Test Procedure TP-201.4 referenced in Regulation .01-1B(3) of this chapter; (d) A vapor return line vacuum integrity test for the Healy Model 400 ORVR System

in accordance with Executive Order G-70-186, Exhibit 4 referenced in Regulation .01-1B(4) of this chapter; and

(e) A vapor return line vacuum integrity test for the Healy Model 600 System in

accordance with Executive Order G-70-165 Exhibit 4 referenced in Regulation .01-1B(5) of this chapter.

(2) The leak and liquid blockage tests required in §A of this regulation shall be performed

on each approved system before the gasoline dispensing facility is initially used to refuel motor vehicles, or by the applicable dates in Regulation .03 of this chapter, whichever occurs later.

(3) Stage II Vapor Recovery System [Authority: COMAR 26.11.24.04C].

(a) An owner of a Stage II vapor recovery system subject to this chapter shall repeat

the required tests:

(i) In accordance with the test schedule in §C(2) of regulation COMAR 26.11.24.04; and

(ii) Upon replacement of 75 percent or more of an approved system.

(b) Test Schedule:

Type of Stage II Vapor Recovery System

Initial Test Frequency of Retest

(a) Vapor Balance System

Dynamic Back Pressure 12 months Leak Test 12 months



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Liquid Blockage Test 5 years (b) Vapor Assist System – Type 1

Air to Liquid Ratio Test 12 months Leak Test 12 months Nozzle Regulation Test 5 years

(c) Vapor Assist System - Type 2 . Model 400

Nozzle Regulation Test 12 months Air to Liquid Ratio Test 12 months

(d) Vapor Assist System -Type 2 . Model 600

Air to Liquid Ratio Test 12 months Vapor Return Line Integrity Test 12 months

(4) The owner shall test the automatic shutoff and flow prohibiting mechanisms upon

installation and at least monthly after to ensure that they operate properly [Authority: COMAR 26.11.03.06C].

(5) If a gasoline dispensing facility fails any test required by this chapter, the owner shall

notify the Department of the failure in writing within 5 working days after the test and before retesting [Authority: COMAR 26.11.24.04D].

(6) Alternative test methods approved by CARB may be used in place of the test methods

specified in §A of regulation COMAR 26.11.24.04, if the alternative test methods are approved by the U.S. EPA as a revision to the SIP, which is Maryland’s plan for meeting National Ambient Air Quality Standards [Authority: COMAR 26.11.24.04E].

(7) Test methods and the frequency of testing required by this regulation may be modified

for vapor assist systems, if the test methods and testing frequency are approved by the Department and the EPA [Authority: COMAR 26.11.24.04F].

4.9.4 Monitoring Requirements: A. The following apply:

(1) At least once a month, the Permittee shall monitor a fuel drop to verify that the Stage

1 vapor balance system is used. [Authority: COMAR 26.11.03.06C(3)]

(2) At least once a month during a delivery, the Permittee shall monitor the fuel drop for liquid spills and check the hose fittings and connections for leaks and proper operation.[Authority: COMAR 26.11.03.06C(3)]

B. 40 CFR 63 Subpart CCCCCC Monitoring Requirements [Authority: 40 CFR §63.11120].

See 4.9.3 B above C. Stage II Requirements –

(1) Inspection Requirements [Authority: COMAR 26.11.24.05].

(a) An operator subject to this chapter shall ensure that each approved system is inspected at least once each day of operation to verify that it is working properly [Authority: COMAR 26.11.24.05A].

(b) Except as provided in §C of this regulation, the Department shall consider an

operator of a gasoline dispensing facility to be in violation of Regulation .03E of this chapter during periods of time when defective equipment at the facility is placed in operation.



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(c) The operator is not in violation of Regulation .03E of this chapter during any

period of time that the operator establishes, to the satisfaction of the Department, that nozzles associated with defective equipment were tagged out of service and that no nozzle associated with the defective equipment was actually used.

(d) For any defective equipment identified by the Department, the operator shall

affect necessary repairs before placing the equipment in service, and shall inform the Department by telephone within 72 hours after the repair or replacement of the defective equipment has been affected.

(2) Inspection Requirements by a Certified Inspector [Authority: COMAR 26.11.24.05-1] .

(a) A person that operates a gasoline dispensing facility or a gasoline storage tank with a vapor recovery system shall ensure that a certified inspector performs an inspection of each vapor recovery system [Authority: COMAR 26.11.24.05-1A(1)]

(b) Each vapor recovery system shall be inspected by a certified inspector in

accordance with the schedules set forth in COMAR 26.10.03.10 [Authority: COMAR 26.11.24.05-1A(2)].

(c) The certified inspector shall inspect each vapor recovery system to confirm that

[Authority: COMAR 26.11.24.05-1B(1)]:

(i) All the necessary equipment has been installed; (ii) The equipment is functioning properly; and (iii) There is no defective equipment in use.

(d) The certified inspector shall review the facility files to confirm that [Authority:

COMAR 26.11.24.05-1B(2)]:

(i) All testing required by COMAR 26.11.24 has been completed;

(ii) The operator has performed daily inspections of the Stage II equipment;

(iii) The records required by COMAR 26.11.24 are complete and maintained onsite; and

(iv) All other requirements of COMAR 26.11.24 are being met.

(e) The certified inspector shall complete an inspection form provided by the

Department and submit the completed form to the Department within 30 days after completing the inspection [Authority: COMAR 26.11.24.05-1B(3)].

4.9.5 Record Keeping Requirements: A. The Permittee shall maintain a record of the results of the monthly observations for use of

the Stage I vapor balance system and results of the monthly observations for leaks and spills. [Authority: COMAR 26.11.03.06C(3)]



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B. 40 CFR 63 Subpart CCCCCC Recordkeeping Requirements [Authority: 40 CFR §63.11125].

§63.11125 What are my recordkeeping requirements? §63.11125(a) Each owner or operator subject to the management practices in §63.11118 must keep records of all tests performed under §§63.11120(a) and (b).

The facility is exempt from testing requirements under §63.11120. §63.11125(b) (not applicable)

C. Stage II Recording Keeping Requirements- COMAR 26.11.24.07

(1) An operator subject to this chapter shall create and maintain a record file at the facility or at an alternative site approved by the Department [Authority: COMAR 26.11.24.07A].

(2) The record file shall contain copies of all test reports, permits, violation notices,

correspondence with the Department, equipment maintenance records, training records, and other information pertinent to the requirements of this chapter. Verification of training shall be maintained in the record file. Equipment maintenance records shall be maintained for at least 2 years. Test records shall be maintained for at least 5 years [Authority: COMAR 26.11.24.07B].

(3) The equipment maintenance records shall include:

(a) The date on which defective equipment was found, a description of each defect, a

description of the corrective action and the date on which the defect was corrected, and the probable cause of the defect [Authority: COMAR 26.11.24.07C(1)].

(b) If parts are replaced, the location within the approved system of the part, the part

number, and assurance that the replacement part does not degrade the efficiency of the system [Authority: COMAR 26.11.24.07C(2)]; and

(c) Inspection reports and any other information relating to maintenance or care of

the system [Authority: COMAR 26.11.24.07C(3)] .

4.9.6 Reporting Requirements: A. See Record Keeping Requirements. B. 40 CFR 63 Subpart CCCCCC Notification and Reporting Requirements [Authority: 40

CFR §63.11124 and §63.11126].

§63.11124 What notifications must I submit and when ? §63.11124(a) Each owner or operator subject to the control requirements in §63.11117 must comply with paragraphs (a)(1) through (3) of this section.

(1) (not applicable)



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(2) (not applicable) (3) If, prior to January 10, 2008, you are operating in compliance with an enforceable State, local, or tribal rule or permit that requires submerged fill as specified in §63.11117(b), you are not required to submit an Initial Notification or a Notification of Compliance Status under paragraph (a)(1) or paragraph (a)(2) of this section.

§63.11124(b) Each owner or operator subject to the control requirements in §63.11118 must comply with paragraphs (b)(1) through (5) of this section.

(1) (not applicable) (2) (not applicable) (3) If, prior to January 10, 2008, you satisfy the requirements in both paragraphs (b)(3)(i) and (ii) of this section, you are not required to submit an Initial Notification or a Notification of Compliance Status under paragraph (b)(1) or paragraph (b)(2) of this subsection.

(i) You operate a vapor balance system at your gasoline dispensing facility that meets the requirements of either paragraphs (b)(3)(i)(A) or (b)(3)(i)(B) of this section.

(A) Achieves emissions reduction of at least 90 percent. (B) Operates using management practices at least as stringent as those in Table 1 to this subpart.

(ii) Your gasoline dispensing facility is in compliance with an enforceable State, local, or tribal rule or permit that contains requirements of either paragraphs (b)(3)(i)(A) or (b)(3)(i)(B) of this section.

Note: In keeping with §§63.11124(a)(2) and 63.11124(b)(3)(ii), owners or operators of gasoline storage tanks operating in compliance with a permit that was issued by the Department before January 10, 2008 are not required to submit an Initial Notification or a Notification of Compliance Status under §63.11124 (a)(1)-(2) or paragraph §63.11124 (b)(1)-(2) .

(4) (not applicable) . (5) (not applicable)

§63.11126 What are my reporting requirements? Each owner or operator subject to the management practices in §63.11118 shall report to the Administrator the results of all volumetric efficiency tests required under §63.11120(b). Reports submitted under this paragraph must be submitted within 180 days of the completion of the performance testing.

The facility is exempt from testing requirements under §63.11120. No reports are required.

C. The following reporting requirements apply to a test under this chapter [Authority: COMAR

26.11.24.07E] :

(1) The Department shall be notified 21 days before a test is to be conducted [Authority: COMAR 26.11.03.06C];



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(2) A test protocol shall be available at the test site during testing;

(3) Copies of results shall be forwarded to the Department; and

(4) Test failures shall be reported to the Department in writing within 5 days following the

date of the failure.



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SECTION V INSIGNIFICANT ACTIVITIES This section provides a list of insignificant emissions units that were reported in the Title V permit application. The applicable Clean Air Act requirements, if any, are listed below the insignificant activity. (1) No. 172 Fuel burning equipment using gaseous fuels or no. 1 or no. 2 fuel oil,

and having a heat input less than 1,000,000 Btu (1.06 gigajoules) per hour;

(Applicable to Air Quality Control Area II )

The boilers are subject to the following requirements: COMAR 26.11.09.05A(1), which establishes that the Permittee may

not cause or permit the discharge of emissions from any fuel burning equipment, other than water in an uncombined form, which is greater than 20 percent opacity.

Exceptions: COMAR 26.11.09.05A(2) does not apply to emissions

during load changing, soot blowing, start-up, or adjustments or occasional cleaning of control equipment if:

(a) The visible emissions are not greater than 40 percent

opacity; and

(b) The visible emissions do not occur for more than 6 consecutive minutes in any sixty minute period.

COMAR 26.11.09.07A(1)(c), which establishes that the Permittee may not burn, sell, or make available for sale any distillate fuel with a sulfur content by weight in excess of 0.3 percent.

(2) No. 0 Fuel-burning equipment using solid fuel and having a heat input of

less than 350,000 Btu (0.37 gigajoule) per hour; (3) No. 18 Stationary internal combustion engines with an output less than 500

brake horsepower (373 kilowatts) and which are not used to generate electricity for sale or for peak or load shaving;

The emergency diesel generators rated at less than 500 brake horsepower are subject to the following requirements:

(A) COMAR 26.11.09.05E(2), Emissions During Idle Mode: The

Permittee may not cause or permit the discharge of emissions from any engine, operating at idle, greater than 10 percent opacity.



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(B) COMAR 26.11.09.05E(3), Emissions During Operating Mode: The Permittee may not cause or permit the discharge of emissions from any engine, operating at other than idle conditions, greater than 40 percent opacity.

(C) Exceptions:

(i) COMAR 26.11.09.05E(2) does not apply for a period of 2

consecutive minutes after a period of idling of 15 consecutive minutes for the purpose of clearing the exhaust system.

(ii) COMAR 26.11.09.05E(2) does not apply to emissions

resulting directly from cold engine start-up and warm-up for the following maximum periods:

(a) Engines that are idled continuously when not in

service: 30 minutes

(b) all other engines: 15 minutes.

(iii) COMAR 26.11.09.05E(2) & (3) do not apply while maintenance, repair or testing is being performed by qualified mechanics.

(4) 0 Space heaters utilizing direct heat transfer and used solely for comfort

heat; (5) �� Water cooling towers and water cooling ponds unless used for

evaporative cooling of water from barometric jets or barometric condensers, or used in conjunction with an installation requiring a permit to operate;

(6) No. 18 Unheated VOC dispensing containers or unheated VOC rinsing

containers of 60 gallons (227 liters) capacity or less; The containers are subject to COMAR 26.11.19.09D, which requires that the

Permittee control emissions of volatile organic compounds (VOC) from cold degreasing operations by meeting the following requirements:

(a) COMAR 26.11.19.09D(2)(b), which establishes that the Permittee shall

not use any VOC degreasing material that exceeds a vapor pressure of 1 mm Hg at 20 ° C;

(b) COMAR 26.11.19.09D(3)(a—d), which requires that the Permittee

implement good operating practices designed to minimize spills and evaporation of VOC degreasing material. These practices, which shall be established in writing and displayed such that they are clearly visible to operators, shall include covers (including water covers), lids, or other



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methods of minimizing evaporative losses, and reducing the time and frequency during which parts are cleaned;

(c) COMAR 26.11.19.09D(4), which prohibits the use of any halogenated

VOC for cold degreasing.

The Permittee shall maintain on site for at least five (5) years, and shall make available to the Department upon request, the following records of operating data:

(i) Monthly records of the total VOC degreasing materials used; and (ii) Written descriptions of good operating practices designed to minimize spills and evaporation of VOC degreasing materials.

(7) 0 Commercial bakery ovens with a rated heat input capacity of less than

2,000,000 Btu per hour; (8) 0 Kilns used for firing ceramic ware, heated exclusively by natural gas,

liquefied petroleum gas, electricity, or any combination of these; (9) 0 Confection cookers where the products are edible and intended for

human consumption; (10) 0 Die casting machines; (11) �� Photographic process equipment used to reproduce an image upon

sensitized material through the use of radiant energy; (12) �� Equipment for drilling, carving, cutting, routing, turning, sawing, planing,

spindle sanding, or disc sanding of wood or wood products; (13) �� Brazing, soldering, or welding equipment, and cutting torches related to

manufacturing and construction activities that emit HAP metals and not directly related to plant maintenance, upkeep and repair or maintenance shop activities;

(14) 0 Equipment for washing or drying products fabricated from metal or glass,

provided that no VOC is used in the process and that no oil or solid fuel is burned;

(15) 0 Containers, reservoirs, or tanks used exclusively for electrolytic plating

work, or electrolytic polishing, or electrolytic stripping of brass, bronze, cadmium, copper, iron, lead, nickel, tin, zinc, and precious metals;

(16) Containers, reservoirs, or tanks used exclusively for:

(a) 0 Dipping operations for applying coatings of natural or synthetic resins that contain no VOC;



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(b) 0 Dipping operations for coating objects with oils, waxes, or greases, and where no VOC is used;

(c) �� Storage of butane, propane, or liquefied petroleum, or natural

gas;

(d) No. 75 Storage of lubricating oils;

(e) No. 0 Unheated storage of VOC with an initial boiling point of 300 °F (149 °C) or greater;

(f) No. 14 Storage of Numbers 1, 2, 4, 5, and 6 fuel oil and aviation jet

engine fuel;

(g) No. 0 Storage of motor vehicle gasoline and having individual tank capacities of 2,000 gallons (7.6 cubic meters) or less;

(h) No. 2500 The storage of VOC normally used as solvents, diluents,

thinners, inks, colorants, paints, lacquers, enamels, varnishes, liquid resins, or other surface coatings and having individual capacities of 2,000 gallons (7.6 cubic meters) or less;

(17) 0 Gaseous fuel-fired or electrically heated furnaces for heat treating glass

or metals, the use of which does not involve molten materials; (18) Crucible furnaces, pot furnaces, or induction furnaces, with individual capacities

of 1,000 pounds (454 kilograms) or less each, in which no sweating or distilling is conducted, or any fluxing is conducted using chloride, fluoride, or ammonium compounds, and from which only the following metals are poured or in which only the following metals are held in a molten state:

(a) 0 Aluminum or any alloy containing over 50 percent aluminum, if

no gaseous chloride compounds, chlorine, aluminum chloride, or aluminum fluoride is used;

(b) 0 Magnesium or any alloy containing over 50 percent magnesium;

(c) 0 Lead or any alloy containing over 50 percent lead;

(d) 0 Tin or any alloy containing over 50 percent tin;

(e) 0 Zinc or any alloy containing over 50 percent zinc;

(f) 0 Copper;

(g) 0 Precious metals;

(19) �� Charbroilers and pit barbecues as defined in COMAR 26.11.18.01 with a

total cooking area of 5 square feet (0.46 square meter) or less;



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(20) �� First aid and emergency medical care provided at the facility, including

related activities such as sterilization and medicine preparation used in support of a manufacturing or production process;

(21) �� Certain recreational equipment and activities, such as fireplaces,

barbecue pits and cookers, fireworks displays, and kerosene fuel use; (22) �� Potable water treatment equipment, not including air stripping equipment; (23) 0 Firing and testing of military weapons and explosives; (24) 0 Emissions resulting from the use of explosives for blasting at quarrying

operations and from the required disposal of boxes used to ship the explosive; (25) �� Comfort air conditioning subject to requirements of Title VI of the Clean

Air Act; (26) 0 Grain, metal, or mineral extrusion presses; (27) 0 Breweries with an annual beer production less than 60,000 barrels; (28) �� Natural draft hoods or natural draft ventilators that exhaust air pollutants

into the ambient air from manufacturing/industrial or commercial processes (Permittee enumerated 41) ;

(29) �� Laboratory fume hoods and vents (Permittee enumerated 263) (30) No. 0 Sheet-fed letter or lithographic printing press(es) with a cylinder width

of less than 18 inches; For the following, attach additional pages as necessary: (31) any other emissions unit, not listed in this section, with a potential to emit less

than the “de minimis” levels listed in COMAR 26.11.02.10X (list and describe units): (none identified)

(32) any other emissions unit at the facility which is not subject to an applicable

requirement of the Clean Air Act (list and describe): No. 2 Usage of paraformaldehyde to decontaminate biological research suites,

SSP and equipment. No. 1 Usage of ethylene oxide to decontaminate laboratory research equipment

and supplies



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SECTION VI. STATE-ONLY ENFORCEABLE CONDITIONS The Permittee is subject to the following State-only enforceable requirements: 1. FACILITY-WIDE

COMAR 26.11. 06.08 and .09 which generally prohibit the discharge of emissions beyond the property line in such a manner that a nuisance or air pollution is created. COMAR 26.11.15.05 which requires the installation and operation of T-BACT for new installations or sources discharging a toxic air pollutant to the atmosphere. COMAR 26.11.15.06 which prohibits the discharge of toxic air pollutants to the extent that the emissions will unreasonably endanger human health. The Permittee shall certify in writing to the Department the results of an air toxics analysis for the previous calendar year by April 1 of each year during the term of this permit. The air toxics analysis shall include either:

(a) a statement that the previously submitted toxics compliance demonstrations remain valid; or

(b) a new toxics compliance demonstration developed in accordance with the

requirements set forth under COMAR 26.11.15, if the Permittee has made changes to its operations that make the last submitted compliance demonstration invalid.

2. EMISSION UNITS B5 AND B6

Two (2) medical waste incinerators, each rated at 1,000 lbs/hr, located in Bldg. 393. 1. The incinerator may charge up to 400 pounds per charge of animal bedding materials.

Under this circumstance, the incinerator cannot be loaded within the next 24 minutes after such a charge.

2. Radioactive waste shall not be incinerated without having in current effect all required

permits from the Department. The following requirements are from Permit to Construct number 10-2-0066 & 0067 issued by the Department on June 6, 1995:

3. To meet the T-BACT requirement for HCl emissions, the incinerators shall be equipped wet

collision caustic scrubbers, or equivalent. The scrubbers shall be designed to achieve a removal efficiency of at least 95 percent unless the HCl concentration does not exceed 50 parts per million (ppm) by volume in the dry scrubber exhaust gases corrected to 7 percent oxygen (O2).

4. To meet the T-BACT requirement for incomplete combustion products:

(a) The incinerators shall be equipped with secondary combustion chambers designed to meet a minimum retention time of 2 seconds at 1,800 deg F.

(b) The carbon monoxide (CO) concentration in the secondary combustion chamber

exhaust gas shall not exceed 100 ppm corrected to 7% O2.



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5. The incinerators shall be constructed with the following design specifications:

(a) The primary combustion chamber shall have a minimum interior volume of 568 cubic feet;

(b) The secondary combustion chamber shall have a minimum interior volume of

604 cubic feet to meet the T-BACT requirement of a 2 second retention time at 1,800 deg. F.

(c) The incinerators shall be equipped with electronic devices to continuously

monitor and record the temperature of the flue gases exiting the primary and secondary combustion chamber

(d) Continuous emission monitors and recorders shall be installed to continuously

monitor and record the CO and O2. 6. Auxiliary burners shall be used to raise the temperature in the secondary combustion

chamber to greater than 1,700 deg. F prior to charging any special medical waste [T-BACT]. 7. The secondary combustion chambers shall be maintained at a temperature of not less than

1,700 deg. F while the incinerators are charging any special medical waste [T-BACT]. 8. The weight of each charge and the time it is fed into the primary combustion chamber shall

be recorded. 9. The weight of each charge may not exceed one-fifth of the rated hourly burn. The time

interval between two succeeding charges may not be less than the time (T) in minutes determined as follows: T = 60 * (charge/hourly burn rate)

10. Each incinerator shall not burn more than 1,000 pounds per hour. 11. The scrubbing solution exiting the wet collision scrubber, or equivalent, shall be kept at a pH

of not less than 7.0 while the incinerator is in operation. 12. The temperature of the gas leaving the secondary combustion chamber shall be maintained

at least 1,500 deg. F for at least two hours when the temperature of the gas leaving the primary combustion chamber drops below 1, 400 deg. F.

13. The incinerators and the scrubbers shall be properly maintained and visually inspected daily

to ensure the integrity and good working conditions for each unit operation. Each inspection shall be recorded and maintained on-site.

14. The Permittee shall not use the incinerators to dispose of any waste generated off-site. The Permittee shall retain an outside contractor to haul its special medical waste away for a proper off-site disposal when its incineration system has been shut down for more than four (4) days.

15. Ash shall be visually inspected to assure the complete combustion of infectious waste.



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3. EMISSION UNITS B1 AND B4 Two (2) Small Municipal Waste Combustion units, each rated at 39 ton/day, each equipped an emission control system, and heat recovery boilers. The following State-only terms of the Consent Order signed by Fort Detrick on October 12, 2007 and by the Department on October 22, 2007 remain in effect.

"4. Fort Detrick shall complete the Supplemental Environmental Project (SEP) described below, which the parties agree is intended to secure significant environmental and public health benefits through the reduction of emissions of carbon monoxide, hydrocarbons, particulate, and air toxics. The SEP shall be completed as follows:

"(b) Subject to Subparagraph 4(c), commencing with the first full year following the date upon which construction of the 20,000-gallon tank is completed pursuant to Paragraph 4(a) of this Consent Order, Fort Detrick shall utilize a minimum of 60,000 gallons of B-20 biodiesel in each calendar year.

"(c) Commencing with the calendar year beginning January 1, 2010, Fort Detrick shall

utilize a minimum of 100,000 gallons of B-20 biodiesel in that year and in each calendar year thereafter.

4. EMISSION UNITS C1 THROUGH C16 16 Emergency diesel generators 500 kW – 2000 kW firing diesel fuel oil.

COMAR 26.11.36.03A(1). The owner or operator of an emergency generator may not operate the generator except for emergencies, testing, and maintenance purposes. COMAR 26.11.36.03A(5). The owner or operator of an emergency generator or load shaving unit may not operate the engine for testing and engine maintenance purposes between 12:01 a.m. and 2:00 p.m. on any day on which the Department forecasts that the air quality will be a code orange, code red, or code purple unless the engine fails a test and engine maintenance and a re-test are necessary.

Documents

PART 70 OPERATING PERMIT FACT SHEET