NORTH CAROLINA DIVISION OF - NC

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NORTH CAROLINA DIVISION OF AIR QUALITY

20BApplication Review Issue Date:

Region: Wilmington Regional Office County: Onslow NC Facility ID: 6700011 Inspector’s Name: Mark Hedrick Date of Last Inspection: 07/27/2017 Compliance Code: 5 / In Physical Compliance

10BFacility Data 0BApplicant (Facility’s Name): MCIEAST-Marine Corps Base Camp Lejeune Facility Address: 1BMCIEAST-Marine Corps Base Camp Lejeune 12 Post Lane 2BMarine Corps Base Camp Lejeune, NC 28547 SIC: 9711 / National Security NAICS: 92811 / National Security Facility Classification: Before: Title V After: Fee Classification: Before: Title V After:

11BPermit Applicability (this application only) 7BSIP: 02D .0516, 0521, .0524, 0530, .1111 NSPS: IIII, JJJJ NESHAP: ZZZZ, GG PSD: NA PSD Avoidance: YES NC Toxics: Yes 112(r): NA Other:

12BContact Data 13BApplication Data 3BApplication Number: 6700011.16A, 17A 8BDate Received: 12/05/2016, 05/22/2017 Application Type: Modification Application Schedule: TV-Significant, Minor 14BExisting Permit Data 9BExisting Permit Number: 06591/T38 Existing Permit Issue Date: 01/08/2016 Existing Permit Expiration Date: 03/31/2019

15BFacility Contact Stanislav Ohrablo Air Quality Manager (910) 451-5836 G-F/EMD/EQB; MCB CAMLEJ Camp Lejeune, NC 28547

16BAuthorized Contact John Townson Director, Environmental Management Div. (910) 451-5003 G-F/EMD/EQB; MCB CAMLEJ Camp Lejeune, NC 28547

17BTechnical Contact Stanislav Ohrablo Air Quality Manager (910) 451-5836 G-F/EMD/EQB; MCB CAMLEJ Camp Lejeune, NC 28547

Total Actual emissions in TONS/YEAR: CY SO2 NOX VOC CO PM10 Total HAP Largest HAP

2015 665.69 370.28 122.51 53.42 13.45 25.31 7.12 [Hydrogen chloride (hydrochlori]





Review Engineer: Joseph Voelker Review Engineer’s Signature: Date:

6BComments / Recommendations: Issue 06591/T39 Permit Issue Date: Permit Expiration Date:

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I. Introduction and Purpose of Application

Marine Corps Base Camp Lejeune (MCB CAMLEJ) and Marine Corps Air Station (MCAS) New River currently hold a Title V Operating Permit issued by the State of North Carolina, Department of Environmental Quality (DEQ), Division of Air Quality (DAQ). Title V Permit Number 06591T38. This review document addresses two applications: 6700011.16A and 670011.17A and applicability determination no. 3127.

Application No. 6700011.16A The primary purpose of this permit application package is to allow the construction and operation of the emission sources identified in Table 1. This modification will not contravene or conflict with any conditions in the existing permit. As this significant modification, as defined at 15A NCAC 02Q .0516, will be subjected to public notice procedures, the permit reviews for the minor modifications that resulted in permit nos. T34, T35, T36 and T37 will also be included as attachments to this permit review document and hence be incorporated fully into the TV permit.

Table 1. Emission Sources to be added to permit

Emission Source ID No. Emission Source Description

Internal Combustion Engines -Non-Emergency Generator

A-FC-280-26 Diesel-fired generator (40 kW)

Engine Test Stands

A-FC-280-07 Diesel, JP-5, JP-8, or F-24-fired turbine engine test stand (1,500 hp)

A-FC-280-25 Diesel, JP-8, or F-24-fired IC engine test stand (525 hp)

Second, MCB CAMLEJ requests that the emission sources in Table 2 be added to Title V Permit Number 06591T38 as insignificant activities per 15A NCAC 02Q .0503(8) The emissions calculations submitted with the application supports this request. No regulatory discussion is needed for these changes to the air permit.

Table 2. Insignificant Activities to be added to permit Emission Source ID No. Emission Source Description Water Heaters* l-A-NH-200-1 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) l-A-NH-200-2 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-A-NH-200-3 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-A-NH-200-4 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-A-NH-200-5 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-C-AS-120-1 Natural gas-fired water heater (0.21 million Btu per hour heat input capacity) I-C-AS-120-2 Natural gas-fired water heater (0.05 million Btu per hour heat input capacity) I-C-AS-120-3 Natural gas-fired water heater (0.05 million Btu per hour heat input capacity) I-C-AS-710-04 Natural gas-fired water heater (0.6 million Btu per hour heat input capacity) I-C-AS-710-05 Natural gas-fired water heater (0.6 million Btu per hour heat input capacity) I-C-AS-710-06 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) Internal Combustion Engines -Emergency Generators I-A-FC-69-01 Diesel-fired emergency generator (83 kW) (133 hp) I-A-HP-125-04 Diesel-fired emergency generator (200 kW) (325 hp) I-A-HP-127-01 Diesel-fired emergency generator (80 kW) (145 hp) I-A-PG-S981A-01 Diesel-fired emergency generator (l 50 kW) (203 hp) I-C-AS-SAS120L-01 Natural gas-fired emergency generator (36 kW) (60 hp) Miscellaneous I-A-FC-286-16 Dry ice blasting cleaning operation I-A-PG-978-01 Diesel-fired expended ordnance deformer (80 hp)

Page 3 of 19 Emission Source ID No. Emission Source Description I-A-PG-978-02 Propane-fired safety certification unit (16 hp propane-fired generator with propane burner) I-A-FC-SFC553A-01 Undercoat tent I-C-AS-4100-01 Aircraft fuselage panel repair curing table I-C-AS-516-02 Aircraft fuselage panel repair curing table I-C-AS-SAS4596-01 Ex-situ pump-and-treat system *Units designated as water heaters possess heat input capacities of less than 1.6 million Btu per hour. As such, they are included in the definition of a hot water heater in accordance with 40 CFR 63.7575. Third, MCB CAMLEJ requests that numerous changes be made to Title V Permit Number 06591T38 as part of this permit modification process. These changes, which include deleting sources, revising source ID numbers, and revising source descriptions, are listed in Table 3. No regulatory discussion is needed for these changes to the air permit.

Table 3 – Miscellaneous revisions to Permitted emission sources Source ID Description Requested Change Revised Description Boilers A-BM-5400-80 No.2 fuel oil-fired boiler (2.5 million Btu per

hour heat input capacity) Delete. Boiler removed, building demolished.

--

A-BM-5400-81 No.2 fuel oil-fired boiler (2.5 million Btu per hour heat input capacity)

Delete. Boiler removed, building demolished.

--

A-MP-625-72 A-MP-625-73 A-MP-625-74

Three No. 2 fuel oil/natural gas-fired boilers (29.94 million Btu per hour heat input capacity each)

Delete. Boilers taken offline and scheduled to be demolished.

--

B-BB-9-53B No. 2 fuel oil/natural gas-fired, 'water tube design" replacement boiler (26.0 million Btu per hour heat input capacity when firing No. 2 fuel oil and 25.3 million Btu per hour heat input capacity when firing natural gas)

Delete. Boiler taken offline and scheduled to be demolished.

--

B-BB-9-54 No. 2 fuel oil/natural gas-fired boiler (25.2 million Btu per hour heat input capacity when firing No. 2 fuel oil and 26.1 million Btu per hour heat input capacity when firing natural gas)


--

B-BB-9-55 No. 2 fuel oil/natural gas-fired boiler (18.6 million Btu per hour heat input capacity when firing No. 2 fuel oil and 19.3 million Btu per hour heat input capacity when firing natural gas)


--

C-AS-4151-16 C-AS-4151-17A C-AS-4151-18

Three No. 2 fuel oil/JP-5/JP-8/natural gas- fired boilers (48.0 million Btu per hour heat input capacity each)


--

C-CG-650-83B C-CG-650-84B

Two No. 2 fuel oil/natural gas-fired, "water tube design" replacement boilers (50.0 million Btu per hour heat input capacity each)


--

C-CG-650-85 No. 2 fuel oil/natural gas-fired boiler (30.6 million Btu per hour heat input capacity when firing No. 2 fuel oil and 31.6 million Btu per hour heat input capacity when firing natural gas)

Delete. Boiler taken offline and scheduled to be

--

demolished.

Water Heaters A-TT-2457-66 No. 2 fuel oil-fired water heater (0.99 million

Btu per hour heat input capacity) Delete. Water heater removed. --

C-AS-710-03 No. 2 fuel oil-fired water heater (2.05 million Btu per hour heat input capacity)

Delete. Water heater removed. --

Internal Combustion Engines -Emergency Generators A-BM-5400-02 Diesel-fired emergency generator (50 kW) Delete. Generator removed. -- A-FC-300-01 Diesel-fired emergency generator (75 kW) Delete. Generator removed. -- A-HP-20-02 Diesel-fired emergency generator (175 kW) Delete. Generator removed. --

Page 4 of 19 Source ID Description Requested Change Revised Description A-HP-671-02 Diesel-fired emergency generator (350 kW) Delete. Generator removed. -- A-HP-855-01 Diesel-fired emergency generator (30 kW) Delete. Generator removed. -- A-MP-167-01 Diesel-fired emergency generator (135 kW) Change Source ID. Generator

relocated to building AS-122. C-AS-122-04

B-BB-190-01 Diesel-fired emergency generator (300 kW) Delete. Generator removed. -- B-SA88-0l Diesel-fired emergency generator (60 kW) Delete. Generator removed. -- B-SBB-180-01 Diesel-fired emergency generator (230 kW) Delete. Generator removed. -- C-AS-122-02 Diesel-fired emergency generator (100 kW) Delete. Generator removed. -- C-AS-428-01 Diesel-fired emergency generator (230 kW) Delete. Generator removed. -- I-A-HP-S1140B-01 Diesel-fired emergency generator (40 kW) Delete. Generator removed. -- Paint Booth I-A-HP-S1124-01 Paint booth Delete. Booth removed. -- Parts Ovens A-FC-280-21 LPG-fired parts oven (0.41 million Btu per

hour heat input capacity) Delete. Oven removed

A-FC-280-22 LPG-fired parts oven (0.26 million Btu per hour heat input capacity)

Delete. Oven removed

Remediation Systems A-TT-2463-73 Bio sparge soil vapor extraction system Delete. No longer in operation

and has been granted No Further Action (NFA).

-

B-BB-190-05 Bio sparge soil vapor extraction system Delete. No longer in operation and has been granted NFA.

-

C-AS-139-01 Ex-situ pump-and-treat system Delete. No longer in operation and has been granted NFA.

--

Storage Tanks I-A-BM-5400-0 lA Storage tank (fuel oil, AST) Delete. Tank removed. -- I-A-MP-625-0I A Storage tank (fuel oil, AST) Delete. Tank offline and

scheduled to be removed. --

I-A-MP-625-02A Storage tank (fuel oil, AST) Delete. Tank offline and scheduled to be removed.

--

I-A-TT-2457-01 A Storage tank (diesel fuel, AST) Delete. Tank offline and scheduled to be removed.

--

I-B-BB-9-01A Storage tank (fuel oil, AST) Delete. Tank offline and scheduled to be removed.

--


--


--

I-C-AS-4151-01A Storage tank (diesel fuel, AST) Delete. Tank offline and scheduled to be removed.

--

I-C-AS-710-01A Storage tank (fuel oil, AST) Delete. Tank offline and scheduled to be removed.

--

I-C-CG-SG650-01A Storage tank (fuel oil, AST) Delete. Tank offline and scheduled to be removed.

--

I-C-CG-SG650-02A Storage tank (fuel oil, AST) Delete. Tank offline and scheduled to be removed.

--

Miscellaneous

I-A-HP-257-01 Screen printing Change Source ID. Operation relocated to building HP-84.

I-A-HP-84-02

I-A-HP-1880-05 Welding, arc Change description to reflect all welding ops (arc, actyl, mig, and tig).

Welding

Page 5 of 19 Fourth, Permit No. T38 at Section 2.2.F.2, required the submittal of a TV application to subject the PSD avoidance condition for CO2e at section 2.2 F.1 to public notice procedures.

Application No. 6700011.17A The primary purpose of this permit application to allow the construction and operation of the emission sources identified in Table 1A.

Table 1A. Emission Sources Included in this Permit Application


C-AS-514-01 Plastic media blasting system

C-AS-514-02 Depainting operation

MCB CAMLEJ requests that the emission sources in Table 2A be added to the permit as insignificant activities per 15A NCAC 02Q .0503(8). The emissions calculations submitted with the application supports this request. No regulatory discussion is needed for these changes to the air permit.

Table 2A. Insignificant Activities Included in this Permit Application


Water Heaters and Furnaces1

I-A-PG-TP454-01 Propane gas-fired furnace (0.11 million Btu per hour heat input capacity)

I-C-AS-235-01 Natural gas-fired water heater (0.125 million Btu per hour heat input capacity)





Table 2. (continued)


Water Heaters (continued)


I-C-RR-280-01 LPG-fired water heater (0.12 million Btu per hour heat input capacity)




I-C-TC-1500-02 Natural gas-fired water heater (0.75 million Btu per hour heat input capacity)


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Internal Combustion Engines – Emergency Generators

I-A-FC-116-01 Diesel-fired emergency generator (25 kW) (34 hp) Not NSPS

I-A-HP-S1450K-01 Diesel-fired emergency generator (80 kW) (130 hp)

I-C-AS-256-02 Diesel-fired emergency generator (750 kW) (1214 hp)

Miscellaneous

I-C-RR-13-01 Woodworking operation 1 Units designated as water heaters possess heat input capacities of less than 1.6 million Btu per hour. As such, they are included in the definition of a hot water heater in accordance with 40 CFR 63.7575.

Finally, MCB CAMLEJ requests that three changes be made to Title V Permit Number 06591T38 as part of this permit modification process. These changes, which includes revising a source ID number, updating a fuel type and revising a source description are listed in Table 3.

Table 3. Requested Change to Title V Permit Number 06591T38

Source ID Description Requested Change Revised Description

Miscellaneous

A-MP-455-02B Diesel-fired emergency generator (400 kW) (5591 hp)

Change source description from 5591 hp to 591 hp.

Diesel-fired emergency generation (400 kW) (591 hp)

C-RR-440-01B Natural gas-fired water heater (0.39 million Btu per hour heat input capacity)

Change source description to LPG-fired water heater (0.39 million Btu per hour heat input capacity).

LPG-fired water heater (0.39 million Btu per hour heat input capacity)

I-A-HP-1880-05 Welding, arc Change Source ID. Operation relocated to building FC-40. I-A-FC-40-03

Page 7 of 19 Applicability Determination No. 3127 On September 7, 2017, the Permittee requested that additional insignificant sources be added to the permit. These sources were included in an applicability determination request that was, upon review of administrative records, never formally received by the DAQ. The Permittee submitted a PDF copy of the “original” submittal dated July 18, 2016. As a result, the applicability request was assigned applicability determination no. 3127 on September 8, 2017. The request includes the following 233 small natural gas or LPG fired boilers or water heaters and one epoxy curing bench/fiberglass repair operation. Upon review, all the sources meet the definition of insignificant activities pursuant to 15A NCAC 02Q .0503(8). No regulatory discussion is needed for these changes to the air permit. The sources that will be added to the insignificant list are as follows:

Emission Source ID No. Emission Source Description I-A-FC-286-25 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-FC-286-26 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-FC-286-27 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-FC-303-1 Natural gas-fired water heater (1.595 million Btu per hour heat input capacity) I-A-FC-303-2 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-A-FC-303-3 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-A-FC-371-1 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity) I-A-FC-371-2 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity) I-A-FC-371-3 Natural gas-fired water heater (0.999 million Btu per hour heat input capacity) I-A-FC-371-4 Natural gas-fired water heater (0.999 million Btu per hour heat input capacity) I-A-FC-420-1 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-A-FC-420-2 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-A-FC-420-3 Natural gas-fired water heater (1.595 million Btu per hour heat input capacity) I-A-FC-420-4 Natural gas-fired water heater (1.595 million Btu per hour heat input capacity) I-A-FC-420-5 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-A-FC-420-6 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-A-FC-484-1 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity) I-A-FC-484-2 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity) I-A-FC-484-3 Natural gas-fired water heater (1.5 million Btu per hour heat input capacity) I-A-FC-484-4 Natural gas-fired water heater (1.5 million Btu per hour heat input capacity) I-A-FC-484-5 Natural gas-fired water heater (1.5 million Btu per hour heat input capacity) I-A-FC-510-1 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity) I-A-FC-510-2 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity) I-A-FC-510-3 Natural gas-fired water heater (1.5 million Btu per hour heat input capacity) I-A-FC-510-4 Natural gas-fired water heater (1.5 million Btu per hour heat input capacity) I-A-FC-510-5 Natural gas-fired water heater (1.5 million Btu per hour heat input capacity)

I-A-H-1-1 Natural gas-fired boiler (6 million Btu per hour heat input capacity)[MACT DDDDD] I-A-H-1-2 Natural gas-fired boiler (6 million Btu per hour heat input capacity)[MACT DDDDD] I-A-H-1-3 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-A-H-1-4 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity)

I-A-HP-106-1 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-A-HP-106-2 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-A-HP-106-3 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-A-HP-116-1 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-116-2 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-116-3 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-117-1 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-A-HP-117-2 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-A-HP-117-3 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-A-HP-118-1 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-A-HP-118-2 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-A-HP-118-3 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity)

Page 8 of 19

Emission Source ID No. Emission Source Description I-A-HP-119-1 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-A-HP-119-2 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-A-HP-119-3 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity)

I-A-HP-1231-1 Natural gas-fired boiler (3 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-1231-2 Natural gas-fired boiler (3 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-127-1 Natural gas-fired boiler (1.75 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-127-2 Natural gas-fired boiler (1.75 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-128-1 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-A-HP-128-2 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-A-HP-128-3 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-A-HP-128-4 Natural gas-fired water heater (1.595 million Btu per hour heat input capacity) I-A-HP-128-5 Natural gas-fired water heater (1.595 million Btu per hour heat input capacity) I-A-HP-128-6 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-A-HP-128-7 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-A-HP-136-1 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-136-2 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-136-3 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-140-1 Natural gas-fired boiler (1.75 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-140-2 Natural gas-fired boiler (1.75 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-146-1 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-146-2 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-146-3 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-156-1 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-156-2 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-156-3 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity)

I-A-HP-1601-1 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity) I-A-HP-1601-2 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity) I-A-HP-1601-3 Natural gas-fired water heater (0.2 million Btu per hour heat input capacity) I-A-HP-1601-4 Natural gas-fired water heater (0.2 million Btu per hour heat input capacity) I-A-HP-166-1 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-166-2 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-166-3 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-170-1 Natural gas-fired boiler (2.5 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-170-2 Natural gas-fired boiler (2.5 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-176-1 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-176-2 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-176-3 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity)

I-A-HP-1854-12 Natural gas-fired boiler (3 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-1854-13 Natural gas-fired boiler (3 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-1854-14 Natural gas-fired water heater (0.15 million Btu per hour heat input capacity) I-A-HP-1854-15 Natural gas-fired water heater (0.15 million Btu per hour heat input capacity)

I-A-HP-186-1 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-186-2 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-186-3 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-A-HP-210-1 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity) I-A-HP-210-2 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity) I-A-HP-210-3 Natural gas-fired water heater (0.85 million Btu per hour heat input capacity) I-A-HP-210-4 Natural gas-fired water heater (0.85 million Btu per hour heat input capacity) I-A-HP-227-1 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-A-HP-227-2 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-A-HP-227-3 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-A-HP-227-4 Natural gas-fired water heater (1.595 million Btu per hour heat input capacity) I-A-HP-227-5 Natural gas-fired water heater (1.595 million Btu per hour heat input capacity)

Page 9 of 19

Emission Source ID No. Emission Source Description I-A-HP-227-6 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-A-HP-227-7 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-A-HP-237-1 Natural gas-fired boiler (1.75 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-237-2 Natural gas-fired boiler (1.75 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-237-3 Natural gas-fired water heater (0.2 million Btu per hour heat input capacity) I-A-HP-250-1 Natural gas-fired water heater (1 million Btu per hour heat input capacity) I-A-HP-250-2 Natural gas-fired water heater (1 million Btu per hour heat input capacity) I-A-HP-250-3 Natural gas-fired water heater (0.2 million Btu per hour heat input capacity) I-A-HP-267-1 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-267-2 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-276-1 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-A-HP-276-2 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-A-HP-276-3 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-A-HP-276-4 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-A-HP-286-1 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-A-HP-286-2 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-A-HP-286-3 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-A-HP-286-4 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-A-HP-305-1 Natural gas-fired boiler (1.75 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-305-2 Natural gas-fired boiler (1.75 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-305-3 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-305-4 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-407-5 Natural gas-fired boiler (2.5 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-407-6 Natural gas-fired boiler (2.5 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-407-7 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-407-8 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-476-1 Natural gas-fired boiler (3.5 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-476-2 Natural gas-fired boiler (3.5 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-476-3 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-476-4 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-502-4 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-502-5 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-502-6 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-502-7 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-510-1 Natural gas-fired water heater (0.642 million Btu per hour heat input capacity) I-A-HP-510-2 Natural gas-fired water heater (0.642 million Btu per hour heat input capacity) I-A-HP-510-3 Natural gas-fired water heater (0.2 million Btu per hour heat input capacity) I-A-HP-511-5 Natural gas-fired boiler (1.75 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-511-6 Natural gas-fired boiler (1.75 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-511-7 Natural gas-fired water heater (1.5 million Btu per hour heat input capacity) I-A-HP-511-8 Natural gas-fired water heater (1.5 million Btu per hour heat input capacity) I-A-HP-511-9 Natural gas-fired water heater (1.5 million Btu per hour heat input capacity) I-A-HP-514-1 Natural gas-fired water heater (0.642 million Btu per hour heat input capacity) I-A-HP-514-2 Natural gas-fired water heater (0.642 million Btu per hour heat input capacity) I-A-HP-514-3 Natural gas-fired water heater (0.2 million Btu per hour heat input capacity) I-A-HP-515-1 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity) I-A-HP-515-2 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity) I-A-HP-515-3 Natural gas-fired water heater (1.5 million Btu per hour heat input capacity) I-A-HP-515-4 Natural gas-fired water heater (1.5 million Btu per hour heat input capacity) I-A-HP-519-1 Natural gas-fired water heater (0.642 million Btu per hour heat input capacity) I-A-HP-519-2 Natural gas-fired water heater (0.642 million Btu per hour heat input capacity) I-A-HP-519-3 Natural gas-fired water heater (0.2 million Btu per hour heat input capacity) I-A-HP-523-1 Natural gas-fired water heater (0.642 million Btu per hour heat input capacity)

Page 10 of 19

Emission Source ID No. Emission Source Description I-A-HP-523-2 Natural gas-fired water heater (0.642 million Btu per hour heat input capacity) I-A-HP-523-3 Natural gas-fired water heater (0.2 million Btu per hour heat input capacity) I-A-HP-527-1 Natural gas-fired water heater (0.642 million Btu per hour heat input capacity) I-A-HP-527-2 Natural gas-fired water heater (0.642 million Btu per hour heat input capacity) I-A-HP-527-3 Natural gas-fired water heater (0.2 million Btu per hour heat input capacity) I-A-HP-575-1 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-575-2 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-A-HP-575-3 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-A-HP-84-2 Natural gas-fired water heater (1 million Btu per hour heat input capacity) I-A-HP-84-3 Natural gas-fired water heater (1 million Btu per hour heat input capacity) I-A-HP-84-4 Natural gas-fired water heater (0.2 million Btu per hour heat input capacity) I-A-HP-84-5 Natural gas-fired water heater (0.2 million Btu per hour heat input capacity)

I-B-BB-118-1 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-B-BB-118-2 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-B-BB-118-3 Natural gas-fired water heater (0.199 million Btu per hour heat input capacity) I-B-BB-2-1 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-B-BB-2-2 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-B-BB-2-3 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) I-B-BB-2-4 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity)

I-B-BB-255-1 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-B-BB-255-2 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-B-BB-255-3 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-B-BB-255-4 Natural gas-fired boiler (1.8 million Btu per hour heat input capacity)[MACT DDDDD] I-B-BB-255-5 Natural gas-fired boiler (1.8 million Btu per hour heat input capacity)[MACT DDDDD] I-B-BB-274-1 Natural gas-fired water heater (0.6 million Btu per hour heat input capacity) I-B-BB-274-2 Natural gas-fired water heater (0.6 million Btu per hour heat input capacity) I-B-BB-274-3 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-B-BB-274-4 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-B-BB-275-1 Natural gas-fired water heater (0.6 million Btu per hour heat input capacity) I-B-BB-275-2 Natural gas-fired water heater (0.6 million Btu per hour heat input capacity) I-B-BB-275-3 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-B-BB-275-4 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-B-BB-329-1 Natural gas-fired water heater (0.7 million Btu per hour heat input capacity) I-B-BB-329-2 Natural gas-fired water heater (0.7 million Btu per hour heat input capacity) I-B-BB-329-3 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-B-BB-330-1 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-B-BB-330-2 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-B-BB-330-3 Natural gas-fired boiler (2 million Btu per hour heat input capacity)[MACT DDDDD] I-C-AS-265-1 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-C-AS-265-2 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-C-AS-265-3 Natural gas-fired water heater (0.15 million Btu per hour heat input capacity)

I-C-AS-3900-1 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-C-AS-3905-1 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-C-AS-3905-2 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-C-AS-3905-3 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-C-AS-3905-4 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-C-AS-4100-1 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-C-AS-4106-1 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-C-AS-4106-2 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-C-AS-4106-3 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-C-AS-4108-1 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-C-AS-4108-2 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-C-AS-4108-3 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity)

Page 11 of 19

Emission Source ID No. Emission Source Description I-C-AS-4108-4 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-C-AS-4108-5 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-C-AS-4108-6 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-C-AS-515-1 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-C-AS-515-2 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-C-AS-515-3 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity) I-C-AS-515-4 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-C-AS-515-5 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-C-AS-515-6 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-C-AS-518-1 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-C-AS-518-2 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) I-C-AS-518-3 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity) I-C-M-107-1 Natural gas-fired water heater (1 million Btu per hour heat input capacity) I-C-M-107-2 Natural gas-fired water heater (1 million Btu per hour heat input capacity) I-C-M-107-3 Natural gas-fired water heater (0.125 million Btu per hour heat input capacity) I-C-M-107-4 Natural gas-fired water heater (0.125 million Btu per hour heat input capacity) I-C-M-285-1 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity) I-C-M-285-2 Natural gas-fired water heater (0.4 million Btu per hour heat input capacity)

I-C-M-79-1 Natural gas-fired boiler (1.75 million Btu per hour heat input capacity)[MACT DDDDD]

I-C-M-79-2 Natural gas-fired boiler (1.75 million Btu per hour heat input capacity)[MACT DDDDD] I-C-M-79-3 Natural gas-fired water heater (0.2 million Btu per hour heat input capacity) I-C-M-79-4 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity)

I-C-RR-526-1 LPG-fired water heater (0.076 million Btu per hour heat input capacity) I-C-RR-612-1 LPG-fired water heater (0.399 million Btu per hour heat input capacity) I-C-RR-612-2 LPG-fired water heater (0.399 million Btu per hour heat input capacity) I-C-RR-612-3 LPG-fired water heater (0.104 million Btu per hour heat input capacity) I-C-RR-614-1 LPG-fired water heater (0.399 million Btu per hour heat input capacity) I-C-RR-614-2 LPG-fired water heater (0.399 million Btu per hour heat input capacity) I-C-RR-614-3 LPG-fired water heater (0.399 million Btu per hour heat input capacity) I-C-RR-616-1 LPG-fired water heater (0.399 million Btu per hour heat input capacity) I-C-RR-616-2 LPG-fired water heater (0.399 million Btu per hour heat input capacity) I-C-RR-616-3 LPG-fired water heater (0.399 million Btu per hour heat input capacity) I-C-AS-255-07 Epoxy curing bench/fiberglass repair operation

Page 12 of 19

II. Chronology

Date Description 12/05/2016 Application received and assigned application no. 6700011.16A

01/26/2017 Email sent to Permittee as an ADD INFO email requesting among other things calculations to justify the insignificant status of some of the emission sources.

03/20/2017 Info requested on 01/26/2017 was received with an amended permit application. This addendum serves as the second step application required by Section 2.2 F.2 in permit no. T38.

05/22/2017 A permit application was received and assigned application no. 6700011.17A. It was requested by the Permittee to consolidate this application with the existing application no. 6700011.16A.

08/17/2017 Draft permit was sent to permittee 09/08/2017 Applicability determination no. 3127 was received by the DAQ. 09/12/2017 Email was received by Permittee stating that they had no further comments MM/DD/YYYY Public Notice published on NCDEQ DAQ website; concurrent public/EPA comment period begins MM/DD/YYYY Public comment period ends MM/DD/YYYY EPA comment period ends

III. Project description Application No. 6700011.16A Eleven (11) of the new insignificant emission sources that are being requested be added to Title V Permit Number 06591T38 are the result of Marine Corps Military Construction (MLCON) program projects. Each of these MLCON projects has been funded separately with an independent funding mechanism. The remaining new emission sources are the result of separately funded projects not associated with the MLCON program. Projects and their associated equipment are described in Section 2.3 of the application. Only one project needs to be discussed explicitly as it will need operating restrictions to avoid triggering PSD. Application No. 6700011.17A Fifteen (15) of the new insignificant emission sources and the two significant emission sources that are being requested to be added to Title V Permit Number 06591T38 are the result of Marine Corps Military Construction (MLCON) program projects. Each of these MLCON projects has been funded separately with an independent funding mechanism. The remaining four (4) new insignificant emission sources are the result of separately funded projects not associated with the MLCON program. Based on potential emission estimates, none of these projects would be considered significant modifications under PSD nor do they rely on projected actual emission estimates to avoid PSD rule. IV. Regulatory Review The sources to be added to the permit will be grouped to facilitate regulatory review. The sources being removed or revised in the permit will not be subject to discussion. One permitting request, the submittal of a TV application to subject the PSD avoidance condition for CO2e at section 2.2.F.1 to public notice procedures, will be discussed separately. IV.A. non-emergency engines App. 16A Emission Source ID No. Emission Source Description Internal Combustion Engines -Non-Emergency Generator

A-FC-280-26 Diesel-fired generator (40 kW)

15A NCAC 02D .0524: NEW SOURCE PERFORMANCE STANDARDS 40 CFR Part 60 Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines The Permittee will purchase a certified engine and be required to meet all applicable operating restrictions including the combustion of fuel with less than 15 ppm sulfur content, recordkeeping and reporting requirements.

Page 13 of 19 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY - 40 CFR Part 63, Subpart ZZZZ, National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. In accordance with 40 CFR 63.6590(c)(6), sources that have a rating less than or equal to 500 HP must meet the requirements of Subpart ZZZZ by meeting the requirements of 40 CFR Part 60, Subpart IIII. There are no other requirements for these sources under Subpart ZZZZ. 15A NCAC 02D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES This rule states:

(b) A source subject to an emission standard for sulfur dioxide in Rules .0524, .0527, .1110, .1111, .1205, .1206, .1210, or .1211 of this Subchapter shall meet the standard in that particular rule instead of the standard in Paragraph (a) of this Rule.

Because the engine is subject to 02D .0524 NSPS Subpart IIII which has a sulfur standard (i.e., fuel sulfur content limited to 15 ppm) it is not subject to this rule. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS Under this rule, each source is subject to a 20 percent opacity limit when averaged over a 6-minute period (with some exceptions). Consistent with current DAQ policy, internal combustion engines burning natural gas or distillate oil are not subject to any monitoring, recordkeeping or reporting requirements. IV.B. Test stands App 16A Emission Source ID No. Emission Source Description

Engine Test Stands

A-FC-280-07 Diesel, JP-5, JP-8, or F-24-fired turbine engine test stand (1,500 hp)

A-FC-280-25 Diesel, JP-8, or F-24-fired IC engine test stand (525 hp)

15A NCAC 02D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES Under this rule, these combustion sources are subject to a SO2 emission limit of 2.3 pounds per million Btu heat input. Consistent with current DAQ policy, distillate fuel-fired engines do not have any required M/R/R with respect to this regulation given the relatively low sulfur content of the fuels. National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) - 15A NCAC 02D .1111 and 40 CFR Part 63, Subpart ZZZZ RICE being tested at an engine test stand are excluded from this regulation in accordance with 40 CFR 63.6590(a). National Emission Standards for Hazardous Air Pollutants for Engine Test Cells/ Stands- 15A NCAC 02D .1111 and 40 CFR Part 63, Subpart PPPPP Engine test stand A-FC-280-07 will be used exclusively for testing combustion turbine engines. In accordance with 40 CFR 63.9290(d), this engine test stand is not subject to requirements under Subpart PPPPP. Engine test stand A-FC-280-25 will be used exclusively for testing IC engines. However, in accordance with 40 CFR 63.9290(a), the affected source for Subpart PPPPP includes 25 existing engine test stands that are located aboard MCB CAMLEJ. The installation of engine test stand A-FC-280-07 will not trigger reconstruction as defined by 40 CFR 63.2. Therefore, this engine test stand is not subject to requirements under Subpart PPPPP. 15A NCAC 02D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION As discussed in Section III, one project needs to be discussed explicitly with respect to PSD applicability; the project described as “2nd Maintenance Battalion Engine Test Stands.” MCB CAMLEJ is in the process of installing one diesel, JP-5, JP-8, or F-24-fired turbine engine test stand and one diesel, JP-8, or F-24-fired internal combustion (IC) engine test stand at Building FC-280, which is located in the French Creek area. A non-

Page 14 of 19 emergency generator is associated with the IC engine test stand and will also be installed as part of this project. MCB CAMLEJ is requesting that the new emission sources be permitted as significant activities. The engine test stands and associated non-emergency generator are anticipated to be used less than 30 hours per year. However, assuming the units were to operate 8,760 hours per year, potential emissions from the units would exceed the PSD significant emission rate (SER) for nitrogen oxides (NOx). As a result, MCB CAMLEJ is requesting that the operation of these sources be limited to avoid PSD applicability. To avoid applicability of l 5A NCAC 02D .0530(g) for major sources and major modifications, MCB CAMLEJ is requesting that the operation of each of these sources (A-FC-280-07, A-FC-280-25, and A-FC-280-26) be limited to 500 hours per year. The Permittee supplied calculations to show the emissions of NOx at 500 hours per year are well under 40 tpy (i.e. 6.7 tpy, see calculations in permit application. Taking the hourly restriction into account, potential emission increases from the emission sources included in this application are less than the PSD SERs for all other pollutants. To demonstrate compliance with this regulation, MCB CAMLEJ will record the number of hours the engine test stands and generator operate each month. MCB CAMLEJ will also submit a summary of these records in a semi-annual report. IV.C MILCON Project P674 App 17A

Emission Source ID No. Emission Source Description Control Device

ID No. Control Device Description

C-AS-514-01 Plastic media blasting system CD-17-A, -B, -C three cartridge filter systems (16, 800 square feet of filter area each) each in series with a HEPA filter

C-AS-514-02 Depainting operation NA NA Under MLCON project P674, MCB CAMLEJ will construct a corrosion control hangar (Building AS-514) aboard the MCAS New River portion of the installation. This hangar will serve to facilitate the cleaning, depainting, and inspection process required to prepare aerospace vehicles for painting. Subsequent painting will be conducted in an existing paint booth located in Building AS-3900. The corrosion control hangar will include two hangar bays. One bay will include a plastic media blast (PMB) system (C-AS-514-01) to remove paint and similar coatings from aerospace vehicles and components. Particulate emissions from the PMB system will be controlled using three identical dust collector systems, each of which will consist of a cartridge filter (i.e., baghouse) followed by a high efficiency particulate air (HEPA) filter. A flow diagram for this system is included as Appendix B of the application and the control device specifications are included as Appendix C of the application. Each dust collector system handles 40,000 CFM of hangar air for a total of 120,000 CFM. The air from the hangar passes through a set of cartridge-style celluloid-polyester filters. The filters are cleaned with a reverse pulse compressed air system and the particulate is deposited into drums for disposal or recycling. After passing through the cartridge filters, the air then passes through a set of HEPA filters that remove particulate down to the 0.3-micron size. Eighty percent (80%) of the cleaned air is returned to the hangar and twenty percent (20%) is discharged to the atmosphere. The 20% air discharged to the atmosphere is replaced with makeup air that can be heated when required. Differential pressure gauges will be installed across the filter banks and monitored continuously. In addition, particulate monitors will be located downstream of the HEPA filters to alarm if any particulate is in the air that is being discharge to the atmosphere. The second corrosion control hangar bay will house a depainting operation (C-AS-514-02) in which aircraft will be washed, parts will be steam cleaned, and coatings will be removed using both hand sanding techniques and chemical strippers. Emissions from the depainting operation will not be controlled and will be emitted indoors. 15A NCAC 02D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES Emissions of particulate matter from the PMB system shall not exceed an allowable emission rate as calculated by the following equations: [15A NCAC 02D .0515(a)]

Page 15 of 19

E = 4.10 x P 0.67 for process rates less than or equal to 30 tons per hour or E = 55.0 x P 0.11 for process rates greater than 30 tons per hour Where E = allowable emission rate in pounds per hour; P = process rate in tons per hour

The Prmittee estimates controlled emissions from the process to be 4.8 e-03 lb/hr. The process rate is unknown but the PMB system will be used to remove coatings from various aircraft. Assuming a conservative process rate of 1 tph, the allowable emissions rate is 4.1 lb/hr. Compliance with rule is expected by a wide margin. Typical M/R/R for filter systems will be placed into the permit. No PM emissions are expected from the depainting operation (C-AS-514-02) as it will emit any PM emissions directly into the workspace (i.e., indoors). 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS Under this rule, each source is subject to a 20 percent opacity limit when averaged over a 6-minute period (with some exceptions). Given the level of PM control being installed on the PMB system operation, no visible emissions are expected. Consistent with permitted similar sources relying on filter systems, the following monitoring will be required:

To ensure compliance, once a month the Permittee shall observe the emission points of this source for any visible emissions above normal. The monthly observation must be made for each month of the calendar year period to ensure compliance with this requirement. The Permittee shall establish “normal” for the source in the first 30 days following the effective date of the permit or after first operation. If visible emissions from this source are observed to be above normal, the Permittee shall either: i. take appropriate action to correct the above-normal emissions as soon as practicable and within the

monitoring period and record the action taken as provided in the recordkeeping requirements below, or ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A

NCAC 02D .2610 (Method 9) for 12 minutes is below the 20% opacity limit

Typical; recordkeeping and reporting will also be required. For the depainting operation, no PM emissions are estimated from the hand sanding operation and the VOC/HAP emissions will be fugitive in nature. NO visible emissions are expected from this source. As with the similarly permitted fugitive sources at the facility, 02D .0521 does not apply. 15A NCAC 02D .1111 "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY" as promulgated in 40 CFR PART 63, SUBPART GG, “NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR AEROSPACE MANUFACTURING AND REWORK FACILITIES, including Subpart A “GENERAL PROVISIONS The PMB system and depainting operations system will be subject to the provisions of Subpart GG. In accordance with 40 CFR 63.746(a), these provisions apply to the depainting (including the use of the PMB system) of the outer surface areas of completed aerospace vehicles, including the fuselage, wings, and vertical and horizontal stabilizers of the aircraft, and the outer casing and stabilizers of missiles and rockets. Subpart GG requirements applicable to the depainting operations are already summarized in Table 2.1.P.4-2. of the current permit. No changes to the permit are necessary. IV.D – CO2 PSD applicability Discussion relating to the requirement in Permit No. T38 at Section 2.2.F.2 for the submittal of a TV application to subject the PSD avoidance condition for CO2e at section 2.2.F.1 to public notice procedures. Permit No. T38, issued on January 1, 2016 as the result of application no. 6700011.15A, received on December 30, 2015 contained a new permit condition at Section 2.2.F.1, which was a recordkeeping condition for CO2e to avoid the applicability of 15A NCAC 02D .0544 “Prevention of Significant Deterioration Requirements for Greenhouse Gases.” Because it was a condition that met the definition of a significant modification at 15A NCAC 02Q .0516(b)(3), but did not contradict or conflict with the existing permit, the Permittee could avail itself of 15A NCAC 02Q .0516(d) and request that the permit modification be processed as the 1st step of the two-step significant modification process as allowed under 15A NCAC 02Q .0501(c)(2) and .0504. The Prmittee submitted the “second step” TV application as required by permit condition 2.2.F.2 on March 20, 2017. The application requested the following two changes to the original application:

Page 16 of 19

1. Correct a typographical error in Condition 2.2.F.l.b. This condition should reference the pollutants identified in Table 2.2.F.1.c rather than those in Table 2.1.B.4.1. Table 2.1.B.4.1 does not exist. 2. Correct a typographical error in Table 2.2.F.1.c. The projected actual carbon dioxide equivalent (CO2e) emissions should be 167,345 tons per year (tpy) rather than 53,413 tpy. The 53,413 tpy value represents the net CO2e emission increase from the installation of the new boilers and hot water heaters identified in Table 2.2.F. This value does not include projected actual CO2e emissions from the five (5) existing boilers located in Building 1700 (113,932 tpy), which are also identified in Table 2.2.F. The corrected value includes both the net emission increase from the new units and the projected actual emissions from the existing units.

Upon receipt of the two questions above, the emission calculations were reviewed. Projects that are conducted at the same time but have different funding mechanisms do not need necessarily need to be aggregated for PSD applicability. The original application review showed that the aggregated projects were significant for NOx and CO2e. However, upon consideration of the projects individually, only CO2e was shown to be above its Significant Emission Rate (SER). As a result, a PSD avoidance condition for CO2e was added at Section 2.2 F.1. Predating the permit application, on June 23, 2014 the Supreme Court decided that PSD permits are not required for a source that exceeds threshold emissions only for GHGs and not for other pollutants. This concept was incorporated into 02D .0544 at paragraph (a) on September 1, 2015 which predates the issuance of permit no. T38 on January 1, 2016. Hence, the permit condition should not have been included at all. Section 2.2 F.2 will be removed from the revised permit. The review for permit no. T38 is included as attachment E. V. Facility-wide regulatory considerations State Enforceable Only 15A NCAC 02D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS The addition of these new sources not expected to affect compliance with this rule. MCBCL already has similar sources and has such a large facility footprint that it is not expected to create off-site odor problems. 15A NCAC 02D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION PSD applicability for these projects are fully described in Section IV above. State Enforceable Only 15A NCAC 02D .1100 - CONTROL OF TOXIC AIR POLLUTANTS This application represents the tenth time the facility has been modified to add and remove combustion sources (and a few other small sources) since the facility had conducted a facility-wide modeling demonstration. During each of the permitting actions since the last facility-wide modeling demonstration (permit no. T27), a justification was made that each of the modifications would not pose an unacceptable risk to human health. This was done primarily by showing the removal of older and larger combustion sources being replaced with newer, cleaner (subject to NSPS and MACT) combustion sources. During this permitting process, the net heat input from external combustion sources being removed from the permit exceeds the new to be constructed permitted capacity. In addition, the sources removed burn No. 2 fuel oil and are being replaced by newer smaller natural gas fired sources. Thus, it is reasonable to assume that with respect to this subset of sources there will be a net decrease in TAP emissions. Similarly, the internal combustion engine horsepower capacity being removed exceeds the new capacity being added. In addition, the new engines will be subject to the more rigorous emission standards of NSPS IIII, which are also used for compliance with MACT ZZZZ. Thus, it is reasonable to assume that with respect to this subset of sources there will be a net decrease in TAP emissions. Regarding the other miscellaneous sources being added, they emit very small amounts of TAPs or none. Given these types of changes to the expected emissions of TAPs, these sources included in the modifications considered here can be exempted from 02D .1100 because it is highly unlikely their operation poses an “unacceptable risk to human health”:

Page 17 of 19 15A NCAC 02D .0958: WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC COMPOUNDS On November 1, 2016, amendments to 15A NCAC 02D .0902 were finalized to narrow applicability of work practice standards in 15A NCAC 02D .0958 from statewide to the maintenance area for the 1997 8-hour ozone standard. Facilities outside the maintenance area counties for the 1997 8-hour ozone standard would no longer be required to comply with the work practice standards in 15A NCAC 02D .0958. Onslow County has never been in nonattainment for ozone, and 15A NCAC 02D .0958 is no longer applicable to facilities, including MCB Camp Lejeune, within the county. The permit condition for 15A NCAC 02D .0958 will be removed from the permit under this modification. VI. Changes to Existing Air Permit

Existing Condition No.

18BNew Condition No.

19BChanges

Cover Letter Same • Used current shell language, updated permit numbers, dates, etc.

Insignificant activities list Same • Updated as described in Section I. of the permit review

Permit page 1 Same • Updated permit numbers, dates, etc.

Table of Contents Same • Added a somewhat more specific Table of Contents at the request of the Permittee

Section 1. Permitted Equipment List

Same • Removed all indicators (, ** or ***) of the minor modifications that resulted in permit nos.

T34, T35 and T36 • Updated as described in Section I. of the permit review

2.1 C RESERVED • Removed entire section as all referenced sources have been removed from the air permit. Section is now indicated as RESERVED.

2.1 D RESERVED • Removed entire section as all referenced sources have been removed from the air permit. Section is now indicated as RESERVED.

2.1 E RESERVED • Removed entire section as all referenced sources have been removed from the air permit. Section is now indicated as RESERVED.

2.1 H RESERVED • Removed entire section as all referenced sources have been removed from the air permit. Section is now indicated as RESERVED.

2.1 I RESERVED • Removed entire section as all referenced sources have been removed from the air permit. Section is now indicated as RESERVED.

2.1 O same • Added reference to A-FC-280-07 and -25

2.1 P Same • Added reference to C-AS-514-01 and -02 • Revised Table 2.1 P into Tables 2.1 P.1 and P2. Revised “Fugitive Painting Operations”

descriptor to” Fugitive Emissions Operations” to better reflect the different emission sources

2.1 P.1 same 02D .0515 condition

a same • Added reference to the plastic media blasting system (ID No. C-AS-514-01)

Page 18 of 19

Existing Condition No.

18BNew Condition No.

19BChanges

c same • added reference to paint spray booths to clarify to which sources condition c applies

NA d and e • Added typical monitoring and recordkeeping for the new filter systems (ID Nos. CD-17-A, -B and -C)

NA f and g • Added typical reporting requirement for the new filter systems (ID Nos. CD-17-A, -B and -C)

2.1 P.2 same 02D .0521 condition

a and c same • Added reference to the plastic media blasting system (ID No. C-AS-514-01). The Permittee

shall establish “normal” VE reading within 30 days of startup and conduct monthly VE readings thereafter.

2.1 P.3 RESERVED • Removed 02D .0958 condition. This rule now only applies only in non-attainment or maintenance areas.

2.1. P.4 Same • Revised Table 2.1 P4-1 into Tables 2.1 4-1.A and -1.B • Added reference to C-AS-514-01 and -02

2.1 V same • Added reference to A-FC-280-26

2.2 F.1 2.2 F.1 • Removed the recordkeeping and reporting requirement pursuant to 15A NCAC 02D

.0544(m) • Added a PSD avoidance condition for new sources A-FC-280-26, -07 and -25

2.2 F.2 NA • Removed the permit application submittal requirement pursuant to 15A NCAC 2Q .0504.

Section 3 General

Conditions Same

• Revision to current version (5.1, 08/03/2017) Changes include: • Minor typographical errors • Mailing address corrections • Condition LL was substantially worded to clarify intent • Condition MM was revised to remove STATE ENFORCEABLE ONLY •

VII. Compliance History The DAQ has reviewed the compliance status of this facility. In the most recent inspection report for the inspection performed on 03/09/2017and 05/11/2017 by Mr. Mark Hedrick, of the Wilmington Regional Office, the following 5-year violation history is noted:

Page 19 of 19 VIII. Public Notice A notice of the DRAFT Title V Permit shall be made pursuant to 15A NCAC 02Q .0521. The notice will provide for a 30-day comment period, with an opportunity for a public hearing. Consistent with 15 A NCAC 02Q .0525, the EPA will have a concurrent 45-day review period. Copies of the public notice shall be sent to persons on the Title V mailing list and EPA. Pursuant to 15A NCAC 02Q .0522, a copy of each permit application, each proposed permit and each final permit pursuant shall be provided to EPA. Also, pursuant to 02Q .0522, a notice of the DRAFT Title V Permit shall be provided to each affected State at or before the time notice provided to the public under 02Q .0521 above.

IX. Comments and Conclusions TBD

X. Recommendations It is recommended that permit no. 06591T37 be issued. TBD

Attachment A

Permit review for Application No. 6700011.14A resulting in the issuance of Permit No. T34

NORTH CAROLINA DIVISION OF

AIR QUALITY

Air Permit Review

Permit Issue Date: September 5, 2014

Region: Wilmington Regional Office

County: Onslow

NC Facility ID: 6700011

Inspector’s Name: Mark Hedrick

Date of Last Inspection: 03/27/2014

Compliance Code: 3 / Compliance - inspection

Facility Data

Applicant (Facility’s Name): MCIEAST-Marine Corps Base Camp Lejeune

Facility Address: MCIEAST-Marine Corps Base Camp Lejeune

12 Post Lane

Camp Lejeune, NC 28547

SIC: 9711 / National Security

NAICS: 92811 / National Security

Facility Classification: Before: Title V After: Title V

Fee Classification: Before: Title V After: Title V

Permit Applicability (this application only)

SIP: YES

NSPS: IIII

NESHAP: MACT ZZZZ

PSD: NA

PSD Avoidance: NA

NC Toxics: S.L. 2012-91

112(r):

Other:

Contact Data Application Data

Application Number: 6700011.14A

Date Received: 03/10/2014

Application Type: Modification

Application Schedule: TV-Minor

Existing Permit Data

Existing Permit Number: 06591/T33

Existing Permit Issue Date: 04/25/2014

Existing Permit Expiration Date: 03/31/2019

Facility Contact

Lisa Gideon

I&E/EMD/EQB Contact

(910) 451-5836

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547

Authorized Contact

John Townson

Director, Environmental

Management Div.

(910) 451-5003

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547

Technical Contact

Lisa Gideon

I&E/EMD/EQB Contact

(910) 451-5836

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547

Total Actual emissions in TONS/YEAR:

CY SO2 NOX VOC CO PM10 Total HAP Largest HAP

2012 604.18 431.78 151.05 43.50 14.34 42.58 18.24

[Hydrogen chloride]

2011 664.72 497.13 49.79 44.53 16.18 33.53 17.87

2010 731.05 525.65 34.08 51.88 16.36 35.61 17.57

2009 653.09 460.22 58.95 38.93 14.09 35.77 16.73

2008 642.70 455.74 57.13 41.58 13.96 39.32 18.29

Review Engineer: Joseph Voelker

Review Engineer’s Signature: Date:

Comments / Recommendations:

Issue 06591/T34

Permit Issue Date: September 5, 2014

Permit Expiration Date: March 31, 2019

Page 2 of 14

I. Introduction

Camp Lejeune Marine Corp Base (MCBCL) is located in Onslow County. MCBCL is requesting to construct and operate a

number of new combustion sources, remediation systems and modify woodworking operations as described in Section III of this

review. This application will also address an applicability determination for a portable incinerator.

The application will be processed as a minor modification per 2Q .0515.

II. Chronology

Date Description

03/10/2014 Application received and assign application no. 6700011.14A

04/25/2014 Permit No. T33 issued

05/15/2014 An applicability determination for a portable incinerator was received and assigned no. 2444

III. Project description

The following text is from the application. It is useful to include these full project descriptions given the sheer size of the permitted

“facility” and it also describes which projects are “separately funded,” which is key for the PSD applicability discussion found

elsewhere in this review document.

Thirty-four (34) of the new emission sources that MCIEAST-MCB CAMLEJ is requesting be added are the result of

Marine Corps Military Construction (MLCON) program projects. Each of these MLCON projects has been funded

separately with an independent funding mechanism. The remaining four ( 4) new or modified emission sources are the

result of separately funded projects not associated with the MLCON program. Projects and their associated equipment are

described below.

MLCON Projects 683/687

Under these projects, MCIEAST-MCB CAMLEJ is constructing Buildings AS-850, AS-863, and AS-890 at MCAS New

River. The construction of these buildings will include installation of four new diesel-fired emergency generators and

eight new natural gas-fired water heaters. Specifically,

• One 80 kilowatt diesel-fired emergency generator (ID No. C-AS-SAS850G-01)

will be installed in Building AS-850.

• One 40 kilowatt diesel-fired emergency generator (ID No. C-AS-SAS863G-01)

will be installed in Building AS-863.

• Two 500 kilowatt diesel-fired emergency generators (ID Nos. C-AS-SAS890G-01 and C-AS-SAS890G-02), four natural

gas-fired water heaters with a heat input capacity of0.5 million Btu per hour (ID Nos. C-AS-890-01, C-AS-890-02, C-AS-

890-03, and C-AS-890-04), and four natural gas-fired water heaters with a heat input capacity of 0.285 million Btu per

hour (ID Nos. C-AS-890-05, C-AS-890- 06, C-AS-890-07, and C-AS-890-08) will be installed in Building AS-890.

MLCON Projects 1249/1322/1323

Under these projects, MCIEAST-MCB CAMLEJ plans to construct Buildings WC-300, WC-304, and WC-320 in the

Wallace Creek area. The construction of these buildings will include installation of one new diesel-fired emergency

generator and twelve new natural gas-fired water heaters. Specifically,

• Ten natural gas-fired water heaters with a heat capacity of 0.399 million Btu per hour (ID Nos. A-WC-300-01 through

A-WC-300-10) will be installed in Building WC-300.

• One 250 kilowatt diesel-fired emergency generator (ID No. A-WC-SWC304A-01) will be installed at Building WC-

304.

Page 3 of 14

• One natural gas-fired water heater with a heat input capacity of0.21 million Btu per hour (ID No. A-WC-320-01) will be

installed in Building WC-320.

• One natural gas-fired water heater with a heat input capacity of0.12 million Btu per hour (ID No. 1-A-WC-320-02) will

be installed in Building WC-320.

MLCON Projects 1286/12868

Under these projects, MCIEAST-MCB CAMLEJ is constructing Buildings RR-122, RR-123, and RR-160 in the Rifle

Range area. These projects include the installation of one new diesel-fired emergency generator and eight new LPG-

fired water heaters. Specifically,

• One 80 kilowatt diesel-fired emergency generator (ID No. C-RR-SRR160D-01) will be installed at Building RR-160.

• Four LPG-fired water heaters with a heat capacity of 0.399 million Btu per hour (ID Nos. C-RR-122-01 through C-RR-

122-04) will be installed in Building RR-122.

• Four LPG-fired water heaters with a heat capacity of 0.399 million Btu per hour (ID Nos. C-RR-123-01 through C-

RR-123-04) will be installed in Building RR-123.

Courthouse Bay Water Heaters

MCIEAST-MCB CAMLEJ has installed two LPG/natural gas-fired water heaters with heat input capacities of 0.399

million Btu per hour each (ID Nos. B-BB-49-53 and B-BB-49-54) at Building BB-49 in the Courthouse Bay area. These

two water heaters are currently LPG-fired, but will be converted to natural gas-fired when natural gas becomes available.

This permit application also includes the removal of one No.2 fuel oil-fired water heater with a heat input capacity of

1.159 million Btu per hour (ID No. B-BB-49-52) and one No.2 fuel oil above-ground storage tank (ID No. I-B-BB-49-0lA)

previously located at Building BB-49.

Wallace Creek Marine Mart Emergency Generator

MCIEAST-MCB CAMLEJ is constructing a new Marine Mart in the Wallace Creek area. One 400 kilowatt diesel-fired

emergency generator (ID No. A-HP-99-01) will be installed at Building 99.

Remediation Systems

MCIEAST-MCB CAMLEJ has installed an ex-situ pump-and-treat system (ID No.C-TC-341-01) at the TC-341 Pipeline

in the Camp Geiger area. In addition, the Base has installed an air sparge soil vapor extraction system (ID No. A-HP-31-

01) at Gottschalk Marina in the Hadnot Point area. Control devices are not installed on either remediation system.

Hadnot Point Dust Collector Modification

MCIEAST-MCB CAMLEJ is modifying the control device on one woodworking operation (ID No. A-HP-915-06) in the

Hadnot Point area. The existing control device for this emission source is a simple cyclone which is 30 inches in diameter

(CD-15). It is being replaced with a new cartridge filter dust collection system (CD-15A). MCIEAST MCB CAMLEJ

plans to operate both control devices until the old duct system is completely removed and the new dust collection system is

fully operational.

Page 4 of 14

Facility-wide projects summary

The above projects can be summarized for further discussion with respect to regulatory applicability as presented below:

Removed sources

The following sources will be removed from the permit:

Emission Source ID Source Description Control

Device

B-BB-49-52 No.2 fuel oil-fired water heater (1.159 million Btu per hour heat input capacity) None

I-B-BB-49-01A Storage tank (fuel oil, AST) None

Modified sources

The following source will be modified from:

Emission Source

ID No.

Source Description Control Device ID No. Control Device Description

A-HP-915-06 Woodworking operation CD-15 One simple cyclone (30 inches in diameter)

to the following:

Emission Source

ID No.

Source Description Control Device ID No. Control Device Description

A-HP-915-06 Woodworking operation CD-15A One cartridge-type filter system (2.03:1 air to

cloth ratio)

Added sources

The following sources will be added to the permit:

Count Project no. Emission Source ID No. Source Description

1 1249/1322 A-WC-300-1 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity)











12 1249/1322 A-WC-SWC304A-01 Diesel-fired emergency generator (250 kW) (398 hp)

13 1249/1322 I-A-WC-320-02 Natural gas-fired water heater (0.12 million Btu per hour heat input capacity)

14 683/687 C-AS-890-1 Natural gas-fired water heater (0.5 million Btu per hour heat input capacity)





Page 5 of 14

Count Project no. Emission Source ID No. Source Description




22 683/687 C-AS-SAS850G-1 Diesel-fired emergency generator (80 kW) (133 hp)




26 1286/12868 C-RR-122-1 LPG-fired water heater (0.399 million Btu per hour heat input capacity)








34 1286/12868 C-RR-SRR160D-1 Diesel-fired emergency generator (80 kW) (130 hp)

35 WCMM A-HP-99-01 Diesel-fired emergency generator (400 kW) (755 hp)

36 CBWH B-BB-49-53

LPG/natural gas-fired water heater (0.399 million Btu per hour heat input

capacity)

37 CBWH B-BB-49-54

LPG/natural gas-fired water heater (0.399 million Btu per hour heat input

capacity)

38 RS A-HP-31-1 Air sparge soil vapor extraction system

39 RS C-TC-341-1 Ex-situ pump-and-treat system

Portable incinerator

The Permittee requested an applicability determination for portable incinerator to be used for drug disposal of drugs confiscated as

a result of law enforcement activities on the base. This device is essentially a cyclonic barrel burner that uses charcoal as a starter

fuel. The Permittee estimates that the program will collect and destroy up to 12 pounds of material per month. Using emission

factors provided by USEPA AP- 42 for domestic single chamber incinerators, criteria pollutant emissions will be below 5 tons per

year. These emissions are tabulated in the attached table.

The DAQ had previously processed applicability determination for a similar incinerator at the Naval Hospital and in a letter

data November 20, 2013 determined that since:

“ the potential uncontrolled emissions for any criteria pollutants are less than 5 tons/yr and assuming the

potential hazardous air pollutants are less than 1,000 lbs/yr, the portable incinerator can be deemed as

"Insignificant activities because of size or production rate" under 15A NCAC 2Q .0503(8)”

This engineer agrees with this statement and agrees that the statement applies to the incinerator in question at this time as well.

However, current DAQ policy requires the application of the rule 15A NCAC 2Q .0102 “ACTIVITIES EXEMPTED FROM

PERMIT REQUIREMENTS” in determining if a sources applicable requirements need to be included in the permit as well. The

Permittee has not supplied any information with respect to whether or not toxics air pollutants as defined in 2D .1100 are emitted.

If they were emitted, the regulatory requirements would need to be included in the permit pursuant to 2Q .0102(b)(7) which states:

(b)If a source is subject to any of the following rules, then the source is not exempted from permit

requirements:

* * *

(7) sources at facilities subject to Section .1100 of Subchapter 02D. (If a source qualifies for an exemption

in Subparagraphs (a)(1) through (a)(24) of 15A NCAC 02Q .0702, or does not emit a toxic air pollutant for

which the facility at which it is located has been modeled, it shall be exempted from needing a permit if it

qualifies for one of the exemptions in Paragraph (c) of this Rule).

Page 6 of 14

Note that facility is subject to 2D .1100 for numerous TAPS, including those from products of combustion. Clearly this small

incinerator will have at least TAPS associated with products of combustion. However, it is extremely unlikely that this source will

generate TAPs in any appreciable quantities that would pose any increases in ambient concentrations not already accounted for in

the previous facility-wide modeling demonstration (See Section IV for 2D .1100 discussion).

Additionally, as incinerator, it would meet the definition of an “other solid waste incineration (OSWI) unit” which is regulated

under 15A NCAC 02D .1111 OTHER SOLID WASTE INCINERATION UNITS. The rule states at (b)(12):

(b) Exemptions. The following types of incineration units are exempted from this Rule:

(12) incinerators that combust contraband or prohibited goods if owned or operated by a government

agency, such as police, customs, agricultural inspection, or a similar agency, to destroy only illegal or

prohibited goods, such as illegal drugs, or agricultural food products that cannot be transported into the

country or across state lines to prevent biocontamination. The exclusion does not apply to items either

confiscated or incinerated by private, industrial, or commercial entities;

Thus, as an incinerator exempt from any incinerator regulation, would for all practical purposes, not have any substantive

requirements. As such, this incinerator will simply be added to the insignificant activity list. The one at the Naval Hospital was

never installed and will not be included in the insignificant activity list.

IV. Regulatory Review

External combustion sources (water heaters)

15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES

All the water heaters will combust natural gas and or LPG and are subject to this 2.3 pounds per million Btu heat input

limitation Using AP-42 emission factors, the combustion of natural gas or LPG is expected to result in SO2 emissions on the

order of 5.9E-04 and 1.1 E-04 lb/MMBtu respectively. Given the expected margin of compliance, and consistent with current

DAQ policy, no M/R/R will be required.

15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

The combustion of natural gas or LPG usually results (based on experience of other permitted sources at the subject facility and

in general) in visible emissions well below the 20% allowed by this rule. Given the expected margin of compliance, and

consistent with current DAQ policy, no M/R/R will be required.

15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS

2D .0503 states:

For residential facilities or institutions (such as military and educational) whose primary fuel burning capacity is for

comfort heat, only those fuel burning indirect heat exchangers located in the same power plant or building or otherwise

physically interconnected (such as common flues, steam, or power distribution line) shall be used to determine the total

heat input.

With the above considerations, each project and in general, each installation, can be evaluated independently.

Combustion of natural gas and LPG, based on AP-42 emission factors, is expected to produce PM emissions much less than those

allowed by this rule.

Consistent with current DAQ policy, no M/R/R will be required.

15A NCAC 2D .0524: NEW SOURCE PERFORMANCE STANDARDS

40 CFR Part 60, Subpart Dc, New Source Performance Standards for Small Industrial-Commercial-Institutional Steam Generating

Units is potentially applicable to these sources. However, all of the water heaters have heat input capacities of less than 10 million

Btu per hour, the applicability threshold pursuant to 40CFR 60.40c(a). Thus, this rule does not apply.

15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY

Page 7 of 14

40 CFR Part 63, Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources:

Industrial, Commercial, and Institutional Boilers and Process Heaters

MCIEAST-MCB CAMLEJ is classified as a major source of HAPs. However, the water heaters identified in Table 1 have heat

input capacities of less than 1.6 million Btu per hour and, as such, are classified as hot water heaters in accordance with 40 CFR

63.7575. These hot water heaters are not subject to the MACT for Boilers and Process Heaters in accordance with 40 CFR

63.7491(d).

Internal combustion sources (emergency generators)

Applicable to Non-NSPS Subpart IIII affected sources only


Under this rule, the combustion sources are subject to a SO2 emission limit of 2.3 pounds per million Btu heat input.

All the emergency generators will combust diesel fuel . Using AP-42 emission factors, the combustion of diesel fuel is not

expected to exceed this limitation unless the diesel fuel has a sulfur content of approximately 2.3%. As will be shown below NSPS

Subpart IIII requires diesel fuel with a sulfur content not to exceed 15 ppm.

2D .0516 states:

(b) A source subject to an emission standard for sulfur dioxide in Rules .0524, .0527, .1110, .1111, .1205, .1206, .1210,

or .1211 of this Subchapter shall meet the standard in that particular rule instead of the standard in Paragraph (a) of

this Rule.

These engines are subject to 2D .0524 NSPS Subpart IIII which has a sulfur standard. Thus, this rule does not apply to these

emergency engines.


15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS Under this rule, each source is subject to a 20 percent opacity limit when averaged over a 6-minute period ( with some exceptions).

2D .0521(b) states (paraphrased):

(b) Scope. This Rule shall apply to all fuel burning sources and to other processes that may have a visible emission.

However, sources subject to a visible emission standard in Rules .0506, .0508, .0524, .0543, .0544, .1110, .1111, .1205,

.1206, .1210, .1211, or .1212 of this Subchapter shall meet that standard instead of the standard contained in this Rule.

These engines are subject to 2D .0524 NSPS Subpart IIII which has a “smoke standard.” Thus, this rule does not apply to these

emergency engines.

15A NCAC 2D .0524: NEW SOURCE PERFORMANCE STANDARDS 40 CFR Part 60 Subpart IIII - Standards of

Performance for Stationary Compression Ignition Internal Combustion Engines

As stated in the permit application:

The emergency generators are subject to this regulation and comply with the emission standards for new non-road

compression ignition (CI) engines in 40 CFR 60.4202. All of these units are classified as emergency stationary internal

combustion engines in accordance with 40 CFR 60.4219. Each generator has been issued a certificate of conformity by

EPA; these certificates are presented in Appendices B through G.

Each generator is equipped with a non-resettable hour meter and each unit has a displacement ofless than 30 liters per

cylinder. In addition, the units burn ULS diesel fuel with a maximum sulfur content of 15 ppm and a minimum cetane

index of 50 or a maximum aromatic content of35 volume percent. None ofthe units are equipped with diesel particulate

filters to comply with emission standards.

To demonstrate compliance with Subpart IIII, MCIEAST-MCB CAMLEJ operates and maintains the generators per the

manufacturers' specifications. Each generator will be operated for less than 100 hours per year during maintenance

checks and readiness testing. The results of inspections and maintenance are maintained in logbooks. MCIEAST-MCB

CAMLEJ also submits a summary of these inspection and maintenance activities in the semi-annual report.

This engineer agrees with these statements. These engines have identical requirements to engines already in the permit. These

engines will simply be added to the appropriate listing in the air permit.

Page 8 of 14

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY - 40 CFR Part 63, Subpart ZZZZ, National Emissions

Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines.


The emergency generators are also subject to this regulation and meet the definition of new stationary RICE in

accordance with 40 CFR 63.6590(a)(2). The generators that have a rating greater than 500 hp are subject to limited

requirements in accordance with 40 CFR 63 .65900(b )(1 ). Specifically, an initial notification must be submitted for

these sources; there are no other requirements for these sources under Subpart ZZZZ. MCIEAST-MCB CAMLEJ will

notify DAQ no later than 120 calendar days after the startup of these emergency generators to comply with this

regulation.

In accordance with 40 CFR 63.6590( c)(6), sources that have a rating less than or equal to 500 hp must meet the

requirements of Subpart ZZZZ by meeting the requirements of 40 CFR Part 60, Subpart IIII. There are no other

requirements for these sources under Subpart ZZZZ.



Hadnot Point Dust Collector Modification

15A NCAC 2D .0512: PARTICULATES FROM MISCELLANEOUS WOOD PRODUCTS FINISHING PLANTS

This rule requires:

The Permittee shall not cause, allow, or permit particulate matter caused by the working, sanding, or finishing of wood to

be discharged from any stack, vent, or building into the atmosphere without providing, as a minimum for its collection,

adequate duct work and properly designed collectors.

The existing cyclone will be replaced by a new dust collector and associated duct work designed to capture greater than 99 percent

of the particulate matter generated by the woodworking operation. According to Form C1 and the equipment specifications, the

system is designed to capture and control 10,540 acfm at an air to cloth ratio of 2.03 to 1. The Permittee claims 99.9% control

efficiency for PM/PM10/PM2.5 and a capture efficiency of 99% for PM/PM10/PM2.5 for an overall efficiency of 98.9%. A PE

sealed the application with respect to the design of the cartridge filter system. Compliance is expected with this rule.

The permit already contains M/R/R for the various woodworking operations, including one that already utilizes a cartridge filter

system. The existing conditions will be revised to reflect the replacement of the cyclone with the bagfilter system.


This source is already subject ot a 20% opacity limit. Given that the source will be controlled with a more efficient control device,

it is excepted that it will have lower visible emissions than before. To date, their have been no compliance issues with respect to

this rule and this source. Continued compliance is expected.

This source, as are the other woodworking operations, is already subject to M/R/R which includes monthly visible emissions

readings. No substantial changes will be made to the air permit.

Page 9 of 14

Remediation Systems

15A NCAC 2D .1111: MAXIMUM ACHEIVABLE CONTROL TECHNOLOGY

40 CFR Part 63, Subpart GGGGG “National Emission Standards For Hazardous Air Pollutants: Site Remediation


MCIEAST-MCB CAMLEJ is classified as a major source ofHAPs and the installation's remediation systems are subject

to Subpart GGGGG. The remediation systems identified in Table 4 of the application are being used to treat materials

with average total volatile organic hazardous air pollutant (VOHAP) concentrations that are less than 10 parts per million

by weight (ppmw). Therefore, these remediation systems are not subject to control requirements for process vents,

remediation material management units, or equipment leaks [40 CFR 63.7885(b)(2) and 40 CFR 63.7886(b)(2)].

VOHAP concentrations are re-calculated annually. Records of data and calculations are maintained on-site and are

available for review.

MCIEAST-MCB CAMLEJ will continue to meet the emission limitations for remediation systems by limiting facility-

wide total emissions ofthe HAPs listed in Table 1 of Subpart GGGGG to a level less than 3.0 pounds per hour and 3.1

tons per year in accordance with 40 CFR 63.7890(b)(l).

This engineer agrees with these statements. These systems have identical requirements to systems already in the permit. These

systems will simply be added to the appropriate listing in the air permit.

V. Facility-wide regulatory considerations

15A NCAC 2D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS

The addition of the combustion sources and remediation systems and change in the woodworking control system is not expected to

affect compliance with this rule. MCBCL already has similar sources and has such a large facility footprint it is not expected to

create off-site odor problems.

15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION


MCIEAST-MCB CAMLEJ is a major source of emissions as defined under the PSD rule and all of the combustion

sources are subject to the requirements under this rule. However, the increases in emissions associated with the requested

changes are less than the PSD significant emission rates (SER) for carbon monoxide (CO), nitrogen oxides (NOx), sulfur

dioxide (S02), total particulate matter (PM), volatile organic compounds (VOC), lead (Pb), and green house gasses

(measured as carbon dioxide equivalent [C02e].

As indicated in the project descriptions provided, the emission sources being permitted by this modification have been

funded separately, each with an independent funding mechanism. As a result, the projects should not be combined for

PSD analyses. In addition, since the projects are spread out over the installation, air quality impacts from the projects are

further minimized.

This engineer agrees with this statement. To date, projects with separate finding at military bases have been used as justification to

not considers all contemporaneous modifications as a single PSD project. Each project discussed in Section III above have PTEs

less PSD significance levels for each NSR pollutant.

Page 10 of 14

15A NCAC 02D .1100 - CONTROL OF TOXIC AIR POLLUTANTS

All the new sources that emit toxics air pollutants as defined in 15A NCAC 2D .1100 are subject to a MACT rule as discussed in

Section IV with the exception of the water heaters. As such, pursuant to 15A NCAC 2Q .0703, they are not subject to 2D .1100.

However pursuant to North Carolina Session Law 2012-91 :

Upon receipt of a permit application for a new source or facility, or for the modification of an

existing source or facility, that would result in an increase in the emission of toxic air pollutants, the

Department shall review the application to determine if the emission of toxic air pollutants from the

source or facility would present an unacceptable risk to human health.

Then, if a determination is made that these sources do not pose a risk as described above, the sources are not subject to 15A NCAC

2Q .0700 or 2D .1100.

This application represents the fifth time the facility has been modified to add and remove sources that are subject to a standard

under 40 CFR 63 since the facility had last conducted a facility-wide modeling demonstration. The permit review for permit no.

T32 discussed the first four modifications. The following discussion then only addresses the current modification.

The current modification involves three types of TAP emitting sources, external combustion (boilers, water heaters), internal

combustion (emergency engines) and remediation systems. For purposes of discussion, the external and internal combustion

sources will be grouped together and the remediation systems will be discussed separately.

See Appendix A for the calculations supporting the discussions below.

Remediation systems

With respect to the remediation systems, the last facility-wide modeling analysis determined that three TAPS were emitted

potentially above their respective TPER: benzene, toluene and xylene. To address if these new remediation systems will pose an

unnecessary risk, one may consider the approach of:

1) comparing the previously modeled emission rates to the actual reported annual emissions over the past few years;

2) consider the new sources’ emissions;

3) consider the removal of any sources’ emissions

4) determine from a “screening level” perspective if it is possible to reach a conclusion that the new remediation systems will

pose no unnecessary risk without a dispersion modeling analysis

Zone A

Benzene

In zone A, benzene was modeled at an overall rate of 32,360.6 lb/yr to result in a maximum ambient impact of 98% of the AAL.

Since that time, the greatest amount of benzene reported facility-wide, not just in zone A, was 1398 pounds in 2012. Assuming that

the data in the emissions inventory is reliable or at least representative, this means that since the modeling analysis, the facility has

been emitting benzene at a level no more than 4.3% of the level necessary to reach 98% of the benzene AAL in zone A.

Toluene

In zone A, toluene was modeled at an overall rate of 182,763 lb/day and 5490 lb/hr to result in a maximum ambient impact of 98%

of the AAL (daily and hourly). Since that time, the greatest amount of toluene reported facility-wide, not just in zone A, was 2829

pounds in 2013. Assuming that the data in the emissions inventory is reliable or at least representative, this means that since the

modeling analysis, the facility has been emitting toluene at a level no more than 0.004% of the level necessary to reach 98% of the

toluene AAL in zone A.

Xylene

In zone A, xylene was modeled at an overall rate of 99,226.94 lb/day and 11,291.4 lb/hr to result in a maximum ambient impact of

98% of the AAL (daily and hourly). Since that time, the greatest amount of xylene reported facility-wide, not just in zone A, was

1339 pounds in 2012. Assuming that the data in the emissions inventory is reliable or at least representative, this means that since

the modeling analysis, the facility has been emitting xylene at a level no more than 0.004% of the level necessary to reach 98% of

the xylene AAL in zone A.

It is also important to note that two remediation systems in zone A were shutdown since the modeling analysis.

Page 11 of 14

Assuming that the new system will emit these TAPs at levels comparable to the existing remediation systems (over time, given

these sources generally have decreasing emissions over time), one would expect that removing two sources and adding one source

with similar emissions (on a potential basis) would result in a net decrease. In conjunction with the reported actual emissions being

much lower than allowable (modeled) emissions, it seems clear that one can conclude that the construction of one new remediation

system would not require a revised dispersion modeling analysis to determine if the respective AAL for each TAP above is likely

to be exceeded on an actual basis.

Zone C

Benzene

In zone C, benzene was modeled at an overall rate of 7,423.3 lb/yr to result in a maximum ambient impact of 98% of the AAL.

Since that time, the greatest amount of benzene reported facility-wide, not just in zone C, was 1398 pounds in 2012. Assuming that

the data in the emissions inventory is reliable or at least representative, this means that since the modeling analysis, the facility has

been emitting benzene at a level no more than 18.8% of the level necessary to reach 98% of the benzene AAL in zone C.

Toluene

In zone C, toluene was modeled at an overall rate of 98,413 lb/day and 6,019 lb/hr to result in a maximum ambient impact of 98%

of the AAL (daily and hourly). Since that time, the greatest amount of toluene reported facility-wide, not just in zone C, was 2829


modeling analysis, the facility has been emitting toluene at a level no more than 2.9% of the level necessary to reach 98% of the

toluene AAL in zone C.

Xylene

In zone C, xylene was modeled at an overall rate of 54,671 lb/day and 6,662 lb/hr to result in a maximum ambient impact of 98%

of the AAL (daily and hourly). Since that time, the greatest amount of xylene reported facility-wide, not just in zone C, was 1339


modeling analysis, the facility has been emitting xylene at a level no more than 2.4% of the level necessary to reach 98% of the

xylene AAL in zone C.

It is also important to note that one remediation system in zone A were shutdown since the modeling analysis.

Assuming that the new system will emit these TAPs at levels comparable to the existing remediation systems (over time, given

these sources generally have decreasing emissions over time), one would expect that removing one source and adding one source

with similar emissions (on a potential basis) would result in a net decrease. In conjunction with the reported actual emissions being

much lower than allowable (modeled) emissions, it seems clear that one can conclude that the construction of one new remediation

system would not require a revised dispersion modeling analysis to determine if the respective AAL for each TAP above is likely

to be exceeded on an actual basis.

Page 12 of 14

Combustion sources

With respect to the combustion sources, an approach similar to that taken in the analysis for permit No. T32 can be considered.

1) consider the new sources potential emissions;

2) consider the removal of any sources potential emissions

3) determine from a “screening level” perspective if it is possible to reach a conclusion that the combustion sources will pose no

unnecessary risk without a dispersion modeling analysis

Consider the following table which summarizes the current modification involving just the combustion sources.

No. of Boilers added 30

No. of Boilers removed 26

Total NG-Fired Boiler heat input added 11.45 MMBtu/hr

Total No. 2-Fired Boiler heat input added 0 MMBtu/hr

Total NG-Fired Boiler heat input removed 9.68 MMBtu/hr

Total No.2-Fired Boiler heat input removed 39.94 MMBtu/hr

No. of Engines added 7

No. of Engines removed 11

Total engine HP added 3018.00 MMBtu/hr

Total engine HP removed 3008.39 MMBtu/hr

Note that although more boilers were added than removed (30 vs. 26), on a total heat input basis, more capacity was removed (49.6

MMBtu/hr) than is being added (11.45 MMBtu/hr).

Note that for the engines, only a slight increase in net capacity is being added (3018 BHP vs 3009 BHP).

On the following sheet, the net potential emissions increase was calculated for each TAP emitted by the combustion sources. Note

that the increase in a TAP emitted as a % of the TAP emissions removed was at the most 100%. Thus, for all TAPS, there is a net

decrease or an unchanging amount of TAPS (on a potential emissions basis) as a result of this modification.

SUMMARY

Based on the discussions above, the proposed modifications will not pose an unacceptable risk to human health.

Page 13 of 14

Net Increase in TAP emissions from combustion sources as a result of this modification

Page 14 of 14

VI. Changes to Existing Air Permit

Existing

Condition No.

New

Condition

No.

Changes

Cover Letter Same

Used current shell language, updated permit numbers, dates, etc.

Revised facility name

Added the 2Q .0515 minor modification language

Permit page 1 Same Updated permit numbers, dates, etc.


Insignificant

activities list Same

Added 1 water heaters

Added 1 portable incinerators

SECTION 1 -

Permitted

equipment list

Same

Removed control device CD-15

Removed B-BB-49-52

Removed I-BB-49-01A

Added control device CD-15A


Added 7 emergency generators

Added 2 remediation systems

Added the 2Q .0515 minor modification footnote

2.1.F. applicable

regulations table Same

Corrected 2D .1100 reference to 2.2.A.1. During the permit revisions that occurred during the renewal

process that resulted in the issuance of permit no. T33 the boilers in 2.1.W. were moved to 2.1.F Table

2.1.F.1 . This reference reestablishes the regulatory link. This change does not impact the active

compliance requirements on behalf of the Permittee.

2.1.M. Same Added 3 emergency generators to Table 2.1.M.-1

Added 4 emergency generators to Table 2.1.M.-2

2.1.M.

applicable

regulations table

same Added reference to the 7 new emergency engines that are not subject to 2D .1100 pursuant to SB-2012-91

(see permit review)

2.1.M.7 Same Added 7 emergency generators to Table 2.1.M.7-1

2.1.Q. Same Named the listed equipment table 2.1.Q

Removed reference to CD-15 and added Cd-15A

2.1.Q.1 b. Added annual internal inspection to new filter system CD-15A

2.1.Q.2 c. Added “establish normal” language for CD-15A

2.1.U. Same Added 2 remediation system

2.1.W.

applicable

regulations table

Same

Added reference to “new” condition 2.2.A.2. During the permit revisions that occurred during the renewal

process that resulted in the issuance of permit no. T33 the “reopen for cause condition” was orphaned from

the non MACT affected water heater/boilers when the sources moved from 2.1.F. to 2.1.W. This reference

reestablishes the regulatory link. This change does not impact the active compliance requirements on

behalf of the Permittee.

2.1.F.5 2.2.A.2 Relocated the “reopen for cause” 2D .1100 condition

VII. Compliance History

The DAQ has reviewed the compliance status of this facility. On its latest inspection, performed on 03/27/2014 by Mr. Mark

Hedrick, of the Wilmington Regional Office, the facility appeared to be in compliance with all applicable requirements.

VIII. Public Notice NA

IX. Comments and Conclusions NA

X. Recommendations It is recommended that permit no. 06591T34 be issued.

Attachment B

Permit review for Application No. 6700011.14B resulting in the issuance of Permit No. T35

Page 1 of 19


AIR QUALITY

Air Permit Review

Permit Issue Date: October 3, 2014


County: Onslow





Facility Data



12 Post Lane







SIP:

NSPS:

NESHAP:

PSD:

PSD Avoidance:

NC Toxics:

112(r):

Other:


Application Number: 6700011.14B








Facility Contact

Lisa Gideon

I&E/EMD/EQB Contact

(910) 451-5836

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547

Authorized Contact

John Townson


Management Div.

(910) 451-5003

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547

Technical Contact

Lisa Gideon

I&E/EMD/EQB Contact

(910) 451-5836

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547



2012 604.18 431.78 151.05 43.50 14.34 42.58 18.24

[Hydrogen chloride (hydrochlori]

2011 664.72 497.13 49.79 44.53 16.18 33.53 17.87


2010 731.05 525.65 34.08 51.88 16.36 35.61 17.57


2009 653.09 460.22 58.95 38.93 14.09 35.77 16.73


2008 642.70 455.74 57.13 41.58 13.96 39.32 18.29





Issue 06591/T34

Permit Issue Date: October 3, 2014


Page 2 of 19

I. Introduction

Camp Lejeune Marine Corp Base (MCBCL) is located in Onslow County. MCBCL is requesting to construct and

operate 428 new combustion sources as described in Section III of this review.

The application will be processed as a minor modification pursuant to 15 A NCAC 2Q .0515.

II. Chronology

Date Description

05/23/2014 Application received and assign application no. 6700011.14B

09/12/2014 Draft permit sent to applicant

10/02/2014 Response from Permittee stating “No issues with the permit once you reorder the equipment list.”


The following text is from the application. It is useful to include these full project descriptions given the sheer size

of the permitted “facility” and it also describes which projects are “separately funded,” which is key for the PSD

applicability discussion found elsewhere in this review document. Given the large number of sources involved,

Tables 1 2 and 3 of the permit application will be included as APPENDIX A to this review document.

MCIEAST-MCB CAMLEJ currently operates six central heating (i.e., steam) plants that provide steam

and/or hot water to various portions of the base. Executive Orders have mandated reductions in the energy

usage intensity aboard the installation. To meet these energy reduction goals, MCIEAST -MCB CAMLEJ

is implementing several projects to replace the steam plants with small natural gas-fired boilers, process

heaters, and hot water heaters that will be located in buildings currently served by the steam plants. Upon

finalization of the decentralization efforts, the base will decommission the steam plants. In addition to

reducing the energy usage intensity aboard the installation, these decentralization efforts will substantially

reduce air pollution emissions generated aboard MCIEAST-MCB CAMLEJ.

Each of the 428 external combustion sources identified in Tables 1 through 3 that MCIEAST-MCB

CAMLEJ is requesting be added to Title V Permit Number 06591 T33 is associated with a steam plant

decentralization project Specific projects and their associated equipment are described below. Each of these

projects has been funded separately with an independent funding mechanism.

Project CP 12-0104

Under this project, MCIEAST-MCB CAMLEJ is making heating-system modifications at various locations

within the Hadnot Point area. Eighty-two natural gas-fired external combustion sources are being installed

in 23 buildings located within the area as part of the installation's effort to replace the Building HP-1700

steam plant.

Project P1422


within the Camp Geiger area. One hundred-one natural gas-fired external combustion sources are being

installed in 24 buildings located within the area as part of the installation's effort to replace the Building

CG-650 steam plant.

Project P1422B


within the Camp Johnson area. One hundred-seven natural gas-fired external combustion sources are being

installed in 42 buildings located within the area as part ofthe installation's effort to replace the Building

MP-625 steam plant

Page 3 of 19

Project P1422C


within the MCAS New River area. One hundred thirty-eight natural gasfired external combustion sources

are being installed in 38 buildings located within the area as part of the installation's effort to replace the

Building AS-4151 steam plant.


All combustion sources (water heaters, pool heaters and boilers)


All the sources will combust natural gas and are subject to this 2.3 pounds per million Btu heat input limitation.

Using AP-42 emission factors, the combustion of natural gas or LPG is expected to result in SO2 emissions on

the order of 5.9E-04 and 1.1 E-04 lb/MMBtu respectively. Given the expected margin of compliance, and



The combustion of natural gas usually results (based on experience of other permitted sources at the subject

facility and in general) in visible emissions well below the 20% allowed by this rule. Given the expected margin

of compliance, and consistent with current DAQ policy, no M/R/R will be required.


2D .0503 states:

For residential facilities or institutions (such as military and educational) whose primary fuel burning

capacity is for comfort heat, only those fuel burning indirect heat exchangers located in the same power

plant or building or otherwise physically interconnected (such as common flues, steam, or power

distribution line) shall be used to determine the total heat input.

With the above considerations, each project and in general, each installation can be evaluated independently.

Combustion of natural gas, based on AP-42 emission factors, is expected to produce PM emissions much less than

those allowed by this rule.



40 CFR Part 60, Subpart Dc, New Source Performance Standards for Small Industrial-Commercial-Institutional

Steam Generating Units is potentially applicable to these sources. However, all of these source have heat input

capacities of less than 10 million Btu per hour, the applicability threshold pursuant to 40CFR 60.40c(a). Thus, this

rule does not apply.

Page 4 of 19


40 CFR Part 63, Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major

Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters

MCIEAST-MCB CAMLEJ is classified as a major source of HAPs.

As stated in the application:

The boilers and process heaters identified in Table 1 (of the application) are similar to those covered by

permit condition number 2.1.F in that they burn natural gas, have heat input capacities of less than 10.0

million Btu per hour each, and are categorized as new sources. As a result, they are subject to the same

requirements with respect to the MACT for Boilers and Process Heaters as the combustion sources

currently covered by permit condition 2.1.F.

Specifically, the units are subject to work practice standards, recordkeeping requirements, and reporting

requirements as described in permit condition number 2.l.F. As new sources, they will comply with

applicable requirements upon startup as required by permit condition number 2.1.F .4.d.

The water heaters identified in Tables 2 and 3 (of the application) have heat input capacities of less than 1.6

million Btu per hour and, as such, are classified as hot water heaters in accordance with 40 CFR 63.7575.

These hot water heaters are not subject to the MACT for Boilers and Process Heaters in accordance with 40

CPR 63.7491(d).

This engineer agrees with these statements. The Permit will simply be updated with references to the new equipment

as necessary,



The addition of the combustion is not expected to affect compliance with this rule. MCBCL already has similar

sources and has such a large facility footprint that it is not expected to create off-site odor problems.


The subject facility is considered a major source for PSD applicability purposes. To date, separate funding of

projects at military bases has been used as justification to not consider all contemporaneous modifications as a single

PSD project. This modification consists of 4 separate projects. Each project consists of the addition of natural gas

fired external combustion sources. The project with the largest total heat input is project no. P1422B. The total heat

input for 107 sources in this project sum to 47.6 mmBtu/hr. The following table shows the potential emissions

(based on AP-42 emission factors) compared to the PSD significance levels. Note that PSD will not be triggered for

this project, and by extension the other three projects as well.

Pollutant Potential Emissions, tpy PSD significance Levels, tpy

PM/PM10/PM2.5 1.55 25/15/10

Sulfur dioxide 0.12 40

Nitrogen Oxides 20.43 40

Carbon Monoxide 17.16 100

VOCs 1.12 40

CO2e 24394 75000


This modification consists of the construction and operation of 428 boilers, process heaters and hot water heaters all

fired by natural gas and all with heat input capacities that do not exceed 3.78 mmBtu/hr. The overall total heat input

for these sources is 162 mmBtu/hr.

Page 5 of 19

As stated in the application, these external combustion units are being installed under projects intended to reduce

energy usage intensity across the installation. Upon finalization of these efforts, the base will decommission the

central heating (i.e., steam) plants that provide steam and/or hot water to various portions of the base.

As a result, the use of these new combustion sources will result in a decrease on the demand of the centralized

boilers. Given the energy losses associated with the transport of steam and hot water, it is reasonable to assume that

the air emissions associated with the generation of steam or hot water from one of these newer combustion sources,

which will be located close to the demand location, will be less than those that would be emitted from a centralized

boiler on a per unit of supplied steam/hot water basis.

The centralized boilers are permitted to burn natural gas, No. 2 fuel oil, and for the four largest boilers, coal.

Utilizing AP-42 emission factors, natural gas is shown to have lower TAP emissions on a pound per million Btu

basis than No.2 fuel oil for all TAPs with the exception of acetaldehyde, acrolein, ammonia, benzopyrene and

hexane. The largest difference is for ammonia, which is 0.003 lb/mmBtu larger for natural gas, which is still a small

difference. Natural gas combustion also does not have any metal TAP emissions. Although the dispersion

characteristics can be expected to be different between the widely dispersed small sources and the centralized

boilers, this modification can arguably be considered neutral with respect to any increase in TAP emissions or

expected ambient impacts.

This modification represents the sixth modification involving TAP emitting sources since the last facility-wide

modeling demonstration (see Application 11C that resulted in the issuance of permit no. T27). All previous

modifications have been shown to not be expected to have “an unacceptable risk to human health” pursuant to

pursuant to North Carolina Session Law 2012-91 or the projects resulted in emission increases that did not justify

any revised facility-wide modeling demonstration.

Under the current 2D .1100 toxics rules, sources subject to a MACT or GACT standard are not subject to 2D .1100

if they are shown to not pose “an unacceptable risk to human health.” Of the 428 sources discussed in this

modification, only the sources in Table1 of the permit application (9 out of the 428) are subject to a MACT (Subpart

DDDDD) and can therefore be considered exempt from 2D.1100. The remaining sources do not meet any other

exemptions to 2D .1100 pursuant to 2Q .0702. For these other sources , a permit condition will indicate that these

sources are technically subject to 2D .1100, but to date have not been included in a compliance (modeling)

demonstration.


Existing

Condition

No.

New

Condition

No.

Changes

Cover Letter Same



Added the 2Q .0515 minor modification language

Permit page

1 Same

Updated permit numbers, dates, etc.


Insignificant

activities list Same Added 63 small water heaters

SECTION 1

- Permitted

equipment

list

Same

Added 9 boilers and pool heaters



2..1.F.,

Table

2.1.F.2

Same Added reference to 9 boilers and pool heaters

Page 6 of 19

Existing

Condition

No.

New

Condition

No.

Changes

2.2.D. Same

Changed reference from

ALL propane, natural gas, and No. 2 fuel oil-fired boilers (less than 10.0 million

Btu per hour) and process heaters

to

facility-wide

This descriptors is misleading as it only applies to those sources addressed in the

112(j) application6700111.10C. The applicability of this condition is addressed in

Section 2.1.


The DAQ has reviewed the compliance status of this facility. On its latest inspection, performed on 03/27/2014 by

Mr. Mark Hedrick, of the Wilmington Regional Office, the facility appeared to be in compliance with all applicable

requirements.




APPENDIX A

Listing of Equipment Addressed in this modification

Note that ID nos. in the permit and the IBEAM database only show 1 digit for numbers less than 10. (e.g, ID No.

XY-03 is in the permit and database as ID No. XY-1)

Appendix A Table 1 Boilers and Process Heaters Included in this Permit Application

Page 1 of 12

Table 1 Boilers and Process Heaters Included in this Permit Application

Emission source ID

No. Emission Source Description Project #

A-M-139-06 Natural gas-fired pool heater (0.399 million Btu per hour heat input capacity) P1422B



A-M-455-06 Natural gas-fired boiler (3.780 million Btu per hour heat input capacity) P1422B



C-G-640-08 Natural gas-fired boiler (2.100 million Btu per hour heat input capacity) P1422



Appendix A Table 2 Water Heaters Included in this Permit Application

Page 2 of 12

Table 2 Water Heaters Included in this Permit Application

Emission

source ID

No.

Emission Source Description Project

#

A-HP-10-

01

Natural gas-fired water heater (0.399

million Btu per hour heat input

capacity)

CP 12-

0104

A-HP-10-

02



capacity)

CP 12-

0104

A-HP-

101A-01



capacity)

CP 12-

0104

A-HP-

101A-02



capacity)

CP 12-

0104

A-HP-

102A-01



capacity)

CP 12-

0104

A-HP-

102A-02



capacity)

CP 12-

0104

A-HP-

111A-01



capacity)

CP 12-

0104

A-HP-

111A-02



capacity)

CP 12-

0104

A-HP-12-

01



capacity)

CP 12-

0104

A-HP-12-

02



capacity)

CP 12-

0104

A-HP-

205A-01



capacity)

CP 12-

0104

A-HP-

205A-02



capacity)

CP 12-

0104

A-HP-

213A-01



capacity)

CP 12-

0104

A-HP-

213A-02



capacity)

CP 12-

0104

A-HP-308-

01



capacity)

CP 12-

0104

A-HP-308-

02



capacity)

CP 12-

0104

A-HP-309-

01



capacity)

CP 12-

0104

A-HP-309-

02



capacity)

CP 12-

0104

A-HP-

312A-01



capacity)

CP 12-

0104

A-HP-

312A-02



capacity)

CP 12-

0104

A-HP-

313A-01



capacity)

CP 12-

0104

A-HP-

313A-02



capacity)

CP 12-

0104

A-HP-316-

01



capacity)

CP 12-

0104

A-HP-316-

02



capacity)

CP 12-

0104

A-HP-

318A-01



capacity)

CP 12-

0104

A-HP-

318A-02



capacity)

CP 12-

0104

A-HP-321-

01



capacity)

CP 12-

0104

A-HP-321-

02



capacity)

CP 12-

0104

A-HP-323-

01



capacity)

CP 12-

0104

A-HP-323-

02



capacity)

CP 12-

0104

A-HP-

407A-01



capacity)

CP 12-

0104

A-HP-

407A-02



capacity)

CP 12-

0104

A-HP-

417A-01



capacity)

CP 12-

0104

A-HP-

417A-02



capacity)

CP 12-

0104

A-HP-

507A-01



capacity)

CP 12-

0104

A-HP-

507A-02



capacity)

CP 12-

0104


Page 3 of 12

A-HP-511-

01



capacity)

CP 12-

0104

A-HP-511-

02



capacity)

CP 12-

0104

A-HP-59-

01



capacity)

CP 12-

0104

A-HP-59-

02



capacity)

CP 12-

0104

A-HP-59-

03



capacity)

CP 12-

0104

A-HP-59-

04



capacity)

CP 12-

0104

A-HP-59-

05



capacity)

CP 12-

0104

A-HP-59-

06



capacity)

CP 12-

0104

A-HP-6-01



capacity)

CP 12-

0104

A-HP-6-02



capacity)

CP 12-

0104

A-HP-63-

01



capacity)

CP 12-

0104

A-HP-63-

02



capacity)

CP 12-

0104

A-HP-8-01



capacity)

CP 12-

0104

A-HP-8-02



capacity)

CP 12-

0104

A-M-128-

02



capacity)

P1422B

A-M-128-

03



capacity)

P1422B

A-M-128-

04



capacity)

P1422B

A-M-128-

05



capacity)

P1422B

A-M-129-

01



capacity)

P1422B

A-M-129-

02



capacity)

P1422B

A-M-129-

03



capacity)

P1422B

A-M-129-

04



capacity)

P1422B

A-M-129-

05



capacity)

P1422B

A-M-130-

01



capacity)

P1422B

A-M-130-

02



capacity)

P1422B

A-M-130-

03



capacity)

P1422B

A-M-131-

02



capacity)

P1422B

A-M-131-

03



capacity)

P1422B

A-M-132-

01



capacity)

P1422B

A-M-132-

02



capacity)

P1422B

A-M-139-

01



capacity)

P1422B

A-M-139-

02



capacity)

P1422B

A-M-139-

03



capacity)

P1422B

A-M-139-

04



capacity)

P1422B

A-M-139-

05



capacity)

P1422B

A-M-303-

01



capacity)

P1422B

A-M-309-

01



capacity)

P1422B

A-M-316-

01



capacity)

P1422B

A-M-318-

01



capacity)

P1422B

A-M-321-

01



capacity)

P1422B

A-M-324-

01



capacity)

P1422B

A-M-324-

02



capacity)

P1422B


Page 4 of 12

A-M-324-

03



capacity)

P1422B

A-M-324-

04



capacity)

P1422B

A-M-424-

01



capacity)

P1422B

A-M-424-

02



capacity)

P1422B

A-M-424-

03



capacity)

P1422B

A-M-424-

04



capacity)

P1422B

A-M-424-

05



capacity)

P1422B

A-M-424-

06



capacity)

P1422B

A-M-424-

07



capacity)

P1422B

A-M-424-

08



capacity)

P1422B

A-M-424-

09



capacity)

P1422B

A-M-435-

01



capacity)

P1422B

A-M-435-

02



capacity)

P1422B

A-M-435-

03



capacity)

P1422B

A-M-435-

04



capacity)

P1422B

A-M-435-

05



capacity)

P1422B

A-M-435-

06



capacity)

P1422B

A-M-435-

07



capacity)

P1422B

A-M-440-

01



capacity)

P1422B

A-M-440-

02



capacity)

P1422B

A-M-440-

03



capacity)

P1422B

A-M-440-

04



capacity)

P1422B

A-M-440-

05



capacity)

P1422B

A-M-440-

06



capacity)

P1422B

A-M-440-

07



capacity)

P1422B

A-M-445-

01



capacity)

P1422B

A-M-445-

02



capacity)

P1422B

A-M-445-

03



capacity)

P1422B

A-M-445-

04



capacity)

P1422B

A-M-445-

05



capacity)

P1422B

A-M-445-

06



capacity)

P1422B

A-M-445-

07



capacity)

P1422B

A-M-450-

01



capacity)

P1422B

A-M-450-

02



capacity)

P1422B

A-M-450-

03



capacity)

P1422B

A-M-450-

04



capacity)

P1422B

A-M-450-

05



capacity)

P1422B

A-M-450-

06



capacity)

P1422B

A-M-450-

07



capacity)

P1422B

A-M-455-

03



capacity)

P1422B

A-M-455-

04



capacity)

P1422B

A-M-455-

05



capacity)

P1422B


Page 5 of 12

A-M-457-

01



capacity)

P1422B

A-M-457-

02



capacity)

P1422B

A-M-457-

03



capacity)

P1422B

A-M-457-

04



capacity)

P1422B

A-M-457-

05



capacity)

P1422B

A-M-457-

06



capacity)

P1422B

A-M-458-

01



capacity)

P1422B

A-M-458-

02



capacity)

P1422B

A-M-458-

03



capacity)

P1422B

A-M-458-

04



capacity)

P1422B

A-M-458-

05



capacity)

P1422B

A-M-458-

06



capacity)

P1422B

A-M-508-

01



capacity)

P1422B

A-M-508-

02



capacity)

P1422B

A-M-508-

03



capacity)

P1422B

A-M-508-

04



capacity)

P1422B

A-M-614-

01



capacity)

P1422B

A-M-614-

02



capacity)

P1422B

A-M-614-

03



capacity)

P1422B

A-M-616-

01



capacity)

P1422B

A-M-616-

02



capacity)

P1422B

A-M-616-

03



capacity)

P1422B

C-AS-205-

01



capacity)

P1422C

C-AS-205-

02



capacity)

P1422C

C-AS-208-

01



capacity)

P1422C

C-AS-208-

02



capacity)

P1422C

C-AS-211-

02



capacity)

P1422C

C-AS-211-

03



capacity)

P1422C

C-AS-211-

04



capacity)

P1422C

C-AS-211-

05



capacity)

P1422C

C-AS-212-

02



capacity)

P1422C

C-AS-212-

03



capacity)

P1422C

C-AS-212-

04



capacity)

P1422C

C-AS-212-

05



capacity)

P1422C

C-AS-213-

01



capacity)

P1422C

C-AS-213-

02



capacity)

P1422C

C-AS-213-

03



capacity)

P1422C

C-AS-213-

04



capacity)

P1422C

C-AS-214-

01



capacity)

P1422C

C-AS-214-

02



capacity)

P1422C

C-AS-214-

03



capacity)

P1422C

C-AS-214-

04



capacity)

P1422C


Page 6 of 12

C-AS-216-

01



capacity)

P1422C

C-AS-216-

02



capacity)

P1422C

C-AS-216-

03



capacity)

P1422C

C-AS-216-

04



capacity)

P1422C

C-AS-217-

01



capacity)

P1422C

C-AS-217-

02



capacity)

P1422C

C-AS-217-

03



capacity)

P1422C

C-AS-217-

04



capacity)

P1422C

C-AS-222-

01



capacity)

P1422C

C-AS-222-

02



capacity)

P1422C

C-AS-255-

02



capacity)

P1422C

C-AS-255-

03



capacity)

P1422C

C-AS-255-

04



capacity)

P1422C

C-AS-255-

05



capacity)

P1422C

C-AS-255-

06



capacity)

P1422C

C-AS-312-

01



capacity)

P1422C

C-AS-312-

02



capacity)

P1422C

C-AS-318-

01



capacity)

P1422C

C-AS-318-

02



capacity)

P1422C

C-AS-318-

03



capacity)

P1422C

C-AS-318-

04



capacity)

P1422C

C-AS-318-

05



capacity)

P1422C

C-AS-

4002-01



capacity)

P1422C

C-AS-

4002-02



capacity)

P1422C

C-AS-

4002-03



capacity)

P1422C

C-AS-

4002-04



capacity)

P1422C

C-AS-

4004-01



capacity)

P1422C

C-AS-

4004-02



capacity)

P1422C

C-AS-

4004-03



capacity)

P1422C

C-AS-

4004-04



capacity)

P1422C

C-AS-

4004-05



capacity)

P1422C

C-AS-

4004-06



capacity)

P1422C

C-AS-

4004-07



capacity)

P1422C

C-AS-

4004-08



capacity)

P1422C

C-AS-

4004-09



capacity)

P1422C

C-AS-

4006-01



capacity)

P1422C

C-AS-

4006-02



capacity)

P1422C

C-AS-

4006-03



capacity)

P1422C

C-AS-

4006-04



capacity)

P1422C

C-AS-

4006-05



capacity)

P1422C

C-AS-

4006-06



capacity)

P1422C

C-AS-

4006-07



capacity)

P1422C


Page 7 of 12

C-AS-

4007-01



capacity)

P1422C

C-AS-

4007-02



capacity)

P1422C

C-AS-

4007-03



capacity)

P1422C

C-AS-

4007-04



capacity)

P1422C

C-AS-

4007-05



capacity)

P1422C

C-AS-

4007-06



capacity)

P1422C

C-AS-

4007-07



capacity)

P1422C

C-AS-

4020-01



capacity)

P1422C

C-AS-

4020-02



capacity)

P1422C

C-AS-

4020-03



capacity)

P1422C

C-AS-

4020-04



capacity)

P1422C

C-AS-

4020-05



capacity)

P1422C

C-AS-

4020-06



capacity)

P1422C

C-AS-

4020-07



capacity)

P1422C

C-AS-

4020-08



capacity)

P1422C

C-AS-

4025-01



capacity)

P1422C

C-AS-

4025-02



capacity)

P1422C

C-AS-

4025-03



capacity)

P1422C

C-AS-

4025-04



capacity)

P1422C

C-AS-

4025-05



capacity)

P1422C

C-AS-

4025-06



capacity)

P1422C

C-AS-

4025-07



capacity)

P1422C

C-AS-

4025-08



capacity)

P1422C

C-AS-

4030-01



capacity)

P1422C

C-AS-

4030-02



capacity)

P1422C

C-AS-

4030-03



capacity)

P1422C

C-AS-

4030-04



capacity)

P1422C

C-AS-

4030-05



capacity)

P1422C

C-AS-

4110-01



capacity)

P1422C

C-AS-

4110-02



capacity)

P1422C

C-AS-

4120-01



capacity)

P1422C

C-AS-

4120-02



capacity)

P1422C

C-AS-

4135-04



capacity)

P1422C

C-AS-

4135-05



capacity)

P1422C

C-AS-

4135-06



capacity)

P1422C

C-AS-

4146-07



capacity)

P1422C

C-AS-

4146-08



capacity)

P1422C

C-AS-

4146-09



capacity)

P1422C

C-AS-

4157-01



capacity)

P1422C

C-AS-

4157-02



capacity)

P1422C

C-AS-

4158-05



capacity)

P1422C

C-AS-

4158-06



capacity)

P1422C


Page 8 of 12

C-AS-

4158-07



capacity)

P1422C

C-AS-

4158-08



capacity)

P1422C

C-AS-

4158-09



capacity)

P1422C

C-AS-

4171-01



capacity)

P1422C

C-AS-

4171-02



capacity)

P1422C

C-AS-

4171-03



capacity)

P1422C

C-AS-

4188-01



capacity)

P1422C

C-AS-

4188-02



capacity)

P1422C

C-AS-

4188-03



capacity)

P1422C

C-AS-427-

01



capacity)

P1422C

C-AS-427-

02



capacity)

P1422C

C-AS-510-

01



capacity)

P1422C

C-AS-510-

02



capacity)

P1422C

C-AS-510-

03



capacity)

P1422C

C-AS-510-

04



capacity)

P1422C

C-AS-541-

01



capacity)

P1422C

C-AS-541-

02



capacity)

P1422C

C-AS-545-

01



capacity)

P1422C

C-AS-545-

02



capacity)

P1422C

C-AS-545-

03



capacity)

P1422C

C-G-520-

01



capacity)

P1422

C-G-520-

02



capacity)

P1422

C-G-520-

03



capacity)

P1422

C-G-520-

04



capacity)

P1422

C-G-520-

05



capacity)

P1422

C-G-520-

06



capacity)

P1422

C-G-520-

07



capacity)

P1422

C-G-520-

08



capacity)

P1422

C-G-520-

09



capacity)

P1422

C-G-520-

10



capacity)

P1422

C-G-525-

01



capacity)

P1422

C-G-525-

02



capacity)

P1422

C-G-525-

03



capacity)

P1422

C-G-525-

04



capacity)

P1422

C-G-530-

01



capacity)

P1422

C-G-530-

02



capacity)

P1422

C-G-530-

03



capacity)

P1422

C-G-530-

04



capacity)

P1422

C-G-530-

05



capacity)

P1422

C-G-530-

06



capacity)

P1422

C-G-530-

07



capacity)

P1422

C-G-530-

08



capacity)

P1422


Page 9 of 12

C-G-530-

09



capacity)

P1422

C-G-530-

10



capacity)

P1422

C-G-540-

01



capacity)

P1422

C-G-540-

02



capacity)

P1422

C-G-540-

03



capacity)

P1422

C-G-540-

04



capacity)

P1422

C-G-540-

05



capacity)

P1422

C-G-540-

06



capacity)

P1422

C-G-540-

07



capacity)

P1422

C-G-540-

08



capacity)

P1422

C-G-540-

09



capacity)

P1422

C-G-540-

10



capacity)

P1422

C-G-550-

01



capacity)

P1422

C-G-550-

02



capacity)

P1422

C-G-550-

03



capacity)

P1422

C-G-550-

04



capacity)

P1422

C-G-550-

05



capacity)

P1422

C-G-550-

06



capacity)

P1422

C-G-550-

07



capacity)

P1422

C-G-550-

08



capacity)

P1422

C-G-550-

09



capacity)

P1422

C-G-550-

10



capacity)

P1422

C-G-615-

01



capacity)

P1422

C-G-615-

02



capacity)

P1422

C-G-615-

03



capacity)

P1422

C-G-617-

01



capacity)

P1422

C-G-617-

02



capacity)

P1422

C-G-617-

03



capacity)

P1422

C-G-617-

04



capacity)

P1422

C-G-640-

02



capacity)

P1422

C-G-640-

03



capacity)

P1422

C-G-640-

04



capacity)

P1422

C-G-640-

05



capacity)

P1422

C-G-640-

06



capacity)

P1422

C-G-640-

07



capacity)

P1422

C-G-644-

01



capacity)

P1422

C-G-644-

02



capacity)

P1422

C-G-644-

03



capacity)

P1422

C-G-644-

04



capacity)

P1422

C-G-709-

01



capacity)

P1422

C-G-709-

02



capacity)

P1422

C-G-709-

03



capacity)

P1422


Page 10 of 12

C-G-710-

01



capacity)

P1422

C-G-710-

02



capacity)

P1422

C-G-713-

01



capacity)

P1422

C-G-713-

02



capacity)

P1422

C-G-713-

03



capacity)

P1422

C-G-713-

04



capacity)

P1422

C-G-713-

05



capacity)

P1422

C-G-713-

06



capacity)

P1422

C-G-713-

07



capacity)

P1422

C-G-713-

08



capacity)

P1422

C-G-713-

09



capacity)

P1422

C-G-770-

02



capacity)

P1422

C-G-770-

03



capacity)

P1422

C-G-770-

04



capacity)

P1422

C-G-770-

05



capacity)

P1422

C-G-920-

01



capacity)

P1422

C-G-920-

02



capacity)

P1422

C-G-920-

03



capacity)

P1422

C-G-920-

04



capacity)

P1422

C-G-920-

05



capacity)

P1422

C-G-930-

01



capacity)

P1422

C-G-930-

02



capacity)

P1422

C-G-930-

03



capacity)

P1422

C-G-930-

04



capacity)

P1422

C-G-930-

05



capacity)

P1422

C-G-930-

06



capacity)

P1422

Appendix A Table 3 Insignificant Activities Included in this Permit Application

Page 11 of 12

Table 3 Insignificant Activities Included in this Permit Application

Emission

Source ID

No.

Emission Source Description Project

No.

I-A-HP-10-

03



capacity)

CP 12-

0104

I-A-HP-10-

04



capacity)

CP 12-

0104

I-A-HP-

101A-03



capacity)

CP 12-

0104

I-A-HP-

101A-04



capacity)

CP 12-

0104

I-A-HP-

102A-03



capacity)

CP 12-

0104

I-A-HP-

102A-04



capacity)

CP 12-

0104

I-A-HP-

111A-03



capacity)

CP 12-

0104

I-A-HP-

111A-04



capacity)

CP 12-

0104

I-A-HP-12-

03



capacity)

CP 12-

0104

I-A-HP-12-

04



capacity)

CP 12-

0104

I-A-HP-

205A-03



capacity)

CP 12-

0104

I-A-HP-

205A-04



capacity)

CP 12-

0104

I-A-HP-

213A-03



capacity)

CP 12-

0104

I-A-HP-

213A-04



capacity)

CP 12-

0104

I-A-HP-

312A-03



capacity)

CP 12-

0104

I-A-HP-

312A-04



capacity)

CP 12-

0104

I-A-HP-

313A-03



capacity)

CP 12-

0104

I-A-HP-

313A-04



capacity)

CP 12-

0104

I-A-HP-

318A-03



capacity)

CP 12-

0104

I-A-HP-

318A-04



capacity)

CP 12-

0104

I-A-HP-

407A-03



capacity)

CP 12-

0104

I-A-HP-

407A-04



capacity)

CP 12-

0104

I-A-HP-

417A-03



capacity)

CP 12-

0104

I-A-HP-

417A-04



capacity)

CP 12-

0104

I-A-HP-

507A-03



capacity)

CP 12-

0104

I-A-HP-

507A-04



capacity)

CP 12-

0104

I-A-HP-511-

03



capacity)

CP 12-

0104

I-A-HP-511-

04



capacity)

CP 12-

0104

I-A-HP-6-03



capacity)

CP 12-

0104

I-A-HP-6-04



capacity)

CP 12-

0104

I-A-HP-8-03



capacity)

CP 12-

0104

I-A-HP-8-04



capacity)

CP 12-

0104

I-A-M-301-

01



capacity)

P1422B

I-A-M-313-

01



capacity)

P1422B

I-A-M-416-

03



capacity)

P1422B

I-A-M-418-

01



capacity)

P1422B

I-A-M-420-

01



capacity)

P1422B

Appendix A Table 3 Insignificant Activities Included in this Permit Application

Page 12 of 12

I-A-M-422-

01



capacity)

P1422B

I-A-M-607-

01



capacity)

P1422B

I-A-M-609-

01



capacity)

P1422B

I-A-M-611-

01



capacity)

P1422B

I-C-AS-118-

01



capacity)

P1422C

I-C-AS-122-

03



capacity)

P1422C

I-C-AS-205-

03



capacity)

P1422C

I-C-AS-208-

03



capacity)

P1422C

I-C-AS-318-

06



capacity)

P1422C

I-C-AS-

4120-03



capacity)

P1422C

I-C-AS-

4122-01



capacity)

P1422C

I-C-AS-

4122-02



capacity)

P1422C

I-C-AS-

4122-03



capacity)

P1422C

I-C-AS-

4157-03



capacity)

P1422C

I-C-AS-425-

01



capacity)

P1422C

I-C-AS-502-

02



capacity)

P1422C

I-C-AS-502-

03



capacity)

P1422C

I-C-AS-541-

03



capacity)

P1422C

I-C-TC-701-

01



capacity)

P1422

I-C-TC-804-

01



capacity)

P1422

I-C-TC-805-

01



capacity)

P1422

I-C-TC-806-

01



capacity)

P1422

I-C-TC-807-

01



capacity)

P1422

I-C-TC-808-

01



capacity)

P1422

I-C-TC-809-

01



capacity)

P1422

I-C-TC-813-

01



capacity)

P1422

Attachment C

Permit review for Application No. 6700011.14C resulting in the issuance of Permit No. T36

Page 1 of 13


AIR QUALITY

Air Permit Review

Permit Issue Date: April 22, 2015


County: Onslow





Facility Data



12 Post Lane







SIP:

NSPS:

NESHAP:

PSD:

PSD Avoidance:

NC Toxics:

112(r):

Other:


Application Number: 6700011.14C








Facility Contact

Robert Lowder

(910) 451-9607

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547

Authorized Contact

John Townson


Management Div.

(910) 451-5003

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547

Technical Contact

Robert Lowder

(910) 451-9607

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547



2013 656.67 465.26 125.23 43.43 15.14 46.39 21.21


2012 604.18 431.78 151.05 43.50 14.34 42.58 18.24


2011 664.72 497.13 49.79 44.53 16.18 33.53 17.87


2010 731.05 525.65 34.08 51.88 16.36 35.61 17.57


2009 653.09 460.22 58.95 38.93 14.09 35.77 16.73





Issue 06591/T36

Permit Issue Date: April 22, 2015

Permit Expiration Date: 03/31/2015

Page 2 of 13

I. Introduction

Camp Lejeune Marine Corp Base (MCBCL) is located in Onslow County. MCBCL is requesting to construct and operate

numerous new combustion sources as described in Section III of this review.

The application will be processed as a minor modification pursuant to 15 A NCAC 2Q .0515.

II. Chronology

Date Description

09/09/2014 Application received and assigned application no. 6700011.14C. Acknowledgement letter sent requesting a

valid responsible official signature. Application placed on HOLD.

09/26/2014 Revised application forms received in the RCO. Application accepted for processing.

12/10/2014 Email sent to Permittee requesting an electronic listing of the modified sources and requested changes

02/01/2015 Info requested on 12/10/2014 was received via email


The following text is from the application. It is useful to include these full project descriptions given the sheer size of the

permitted “facility” and it also describes which projects are “separately funded,” which is key for the PSD applicability

discussion found elsewhere in this review document.

MCIEAST -MCB CAMLEJ (MCBCL) currently operates six central heating (i.e., steam) plants that provide

steam and/or hot water to various portions of the base. Executive Orders have mandated reductions in the

energy usage intensity aboard the installation. To meet these energy reduction goals, MCBCL is implementing

several projects to replace the steam plants with small natural gas-fired boilers, process heaters, and hot water

heaters that will be located in buildings currently served by the steam plants. Upon finalization of the

decentralization efforts, the base will decommission the steam plants. In addition to reducing the energy usage

intensity aboard the installation, these decentralization efforts will substantially reduce air pollution emissions

generated aboard MCBCL.

Each decentralization project has been funded separately with an independent funding mechanism. Seventy-

seven (77) of the new emission sources that MCBCL is requesting to be added to Title V Permit Number 06591

T33 are the result of one decentralization project.

Thirteen (13) of the new emission sources that MCBCL is requesting to be added to Title V Permit Number

06591 T33 are the result of Marine Corps Military Construction (MLCON) program projects. Each of these

MLCON projects has been funded separately with an independent funding mechanism.

The remaining fourteen (14) new emission sources are the result of separately funded projects not associated

with the MLCON program. Projects and their associated equipment are described below.

The following sources will be added to the permit; mostly to the insignificant activities list. Note that at the time of permit

application submittal, DAQ permitting policy was such that the “State-only” permitting filters found at 15A NCAC 2Q

.0102 were used to assess whether or not insignificant sources as defined at 15A NCAC 2Q .0503 were required to be on

the permit explicitly (i.e. in Section 1 of the permit). The DAQ has since changed its policy. As a result, most of the

sources requested to be added to the permit, which are insignificant activities under 2Q .0503, do not need to be added to

Section 1 of the permit. Whether a source is on Section 1 of the permit or the attached insignificant activities list, it is still

subject to the same rules. The benefit to the facility however, will be with respect to future facility modifications. That is,

a permit application would no longer be required to be submitted for most of the sources that are included in this

application.

Page 3 of 13

ID No. EMISSION SOURCE DESCRIPTION

I-A-FC-400-1 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity)
































I-A-FC-500A-1 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity)










Page 4 of 13


































I-A-CR-SCR120C-1 Diesel-fired emergency generator (25 kW) (49 hp)

A-HP-411-2 Diesel-fired emergency generator (500 kW) (755 hp) [MACT ZZZZ] [NSPS IIII]

I-A-HP-883-1 Natural gas-fired water heater (1.25 million Btu per hour heat input capacity)

A-HP-1230-3 Diesel-fired emergency generator (1,000 kW) (1,474 hp) [MACT ZZZZ] [NSPS IIII]

I-A-HP-1501-1 LPG-fired water heater (0.75 million Btu per hour heat input capacity)

I-A-HP-1501-2 LPG-fired water heater (0.75 million Btu per hour heat input capacity)

I-A-HP-S1140B-1 Diesel-fired emergency generator (40 kW) (80 hp) [MACT ZZZZ] [NSPS IIII]

I-A-HP-ST82-1 Diesel-fired emergency generator (35 kW) (56 hp) [MACT ZZZZ] [NSPS IIII]

I-A-LCH-SLCH4041B-1 Diesel-fired emergency generator (25 kW) (49 hp) [MACT ZZZZ] [NSPS IIII]

I-A-M-SM160B-1 Diesel-fired emergency generator (25 kW) (49 hp) [MACT ZZZZ] [NSPS IIII]

Page 5 of 13


I-A-TT-STT15B-1 Diesel-fired emergency generator (25 kW) (49 hp) [MACT ZZZZ] [NSPS IIII]

I-A-TT-STT16B-1 Diesel-fired emergency generator (25 kW) (49 hp) [MACT ZZZZ] [NSPS IIII]

I-A-WC-195-1 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity)



I-B-A-SA7C-1 Diesel-fired emergency generator (25 kW) (49 hp) [MACT ZZZZ] [NSPS IIII]



I-C-AS-SAS4109G-1 Diesel-fired emergency generator (150 kW) (237 hp) [MACT ZZZZ] [NSPS IIII]

I-C-G-483-1 Natural gas-fired water heater (0.8 million Btu per hour heat input capacity)



I-C-G-ST83-1 Diesel-fired emergency generator (35 kW) (56 hp) [MACT ZZZZ] [NSPS IIII]






l-C-AS-4109-5 Natural gas-fired water heater (0.199 million Btu per hour heat input capacity)


The following sources will be removed from the permit:


A-FC-116-01 Diesel-fired emergency generator (25 kW)



A-FC-S511-01 Diesel-fired emergency generator (50 kW)

A-HP-411-01 Diesel-fired emergency generator (500 kW)

A-HP-1230-02 Diesel-fired emergency generator (1000 kW) (1341 bhp)

A-HP-1776-01 Diesel-fired emergency generator (50 kW)

A-HP-S1761-01 Diesel-fired emergency generator (25 kW)

A-HP-S1881-01 Diesel-fired emergency generator (30 kW)

The Permittee is also requesting the following descriptors be changed for existing equipment:

Page 6 of 13

Page 7 of 13

Decentralization Project CP 12-0121

Under this project, MCBCL is making heating-system modifications at various locations within the French

Creek area. Seventy-four natural gas-fired water heaters with heat input capacities of 0.399 million Btu per hour

are being installed in 17 buildings located within the area as part of the installation's efforts to replace the

Building HP-1700 steam plant. The combustion sources identified in Table 1 of the application are associated

with this steam plant decentralization project.

Page 8 of 13

Also as part of this project, MCBCL is requesting to install three emission sources that we request to be added

to Title V Permit Number 06591 T33 as insignificant activities per 15A NCAC 2Q .0503(7)(d) and 15A NCAC

2Q .0702(a)(2). These emissions sources (I-A-FC-400-03, I-A-FC-SOOA-03, and I-A-FC-500A-04) are

identified in Table 2 of the application.

MLCON Project 138

Under this project, MCTEAST-MCB CAMLEJ plans to construct Building WC-195 in the Wallace Creek area.

The construction of this building will include installation of three new natural gas-fired water heaters with a

heat input capacity of 0.8 million Btu per hour each (ID Nos. A-WC-195-01, A-WC-195-02, and A-WC-195-

03).

MLCON Project 705

Under this project, MCIEAST -MCB CAMLEJ is constructing Building AS-41 09 in the MCAS New River

area. This project includes the installation of five new natural gas-fired water heaters and one new diesel-fired

emergency generator. Specifically,

Two natural gas-fired water heaters with a heat input capacity of 0.3999 million Btu per hour each (ID Nos.

C-AS-4109-01 and C-AS-4109-02).

One 150 kilowatt diesel-fired emergency generator (ID No. C-AS-SAS4109G-0l).

Three natural gas-fired water heaters with a heat input capacity of 0.199 million Btu per hour each (ID No.

I-C-AS-4109-03, I-C-AS-4109-04, and I-C-AS-4109-05).

MLCON Project 1268

Under this project, MCIEAST-MCB CATvfLEJ is constructing Buildings G-483, G-484, and G-484 in the

Camp Geiger area. The construction of these buildings will include installation of four new natural gas-fired

water heaters. Specifically,

Two natural gas-fired water heaters with a heat capacity of 0.8 million Btu per hour, each (ID Nos. C-G-

483-01 and C-G-483-02) will be installed in Building G-483.

One natural gas-fired water heater with a heat capacity of 0.199 million Btu per hour (ID No. I-C-G-484-

01) will be installed in Building G-484.

One natural gas-fired water heater with a heat input capacity of 0.8 million Btu per hour (ID No. C-G-485-

01) will be installed in Building G-485.

Building 411 Generator

MCBCL is replacing an existing generator with a new generator at Building 411 in the Hadnot Point area. One

new 500 kilowatt diesel-fired emergency generator (ID No. A-HP-411-02) will be installed at Building 411.

The existing 500 kilowatt diesel-fired emergency generator (ID No. A·HP-411-01) will be removed from the

building.

Building 883 Water Heater

MCBCL is installing a new natural gas-fired water heater (ID No.A-HP-883-01) in Building 883 in the Hadnot

Point area. The natural gas-fired water heater has a heat input capacity of 1.25 million Btu per hour.


MCBCL is installing a new generator (ID No. A-HP-S1140B-01) at Building 1140 in the Hadnot Point area.

The new unit is a 40 kilowatt diesel-fired emergency generator.


MCBCL is replacing an existing generator with a new generator at Building 1230 in the Hadnot Point area. One

new 1,000 kilowatt diesel-fired emergency generator (ID No. A-HP-1230-03) will be installed at Building 1230.

The existing 1,000 kilowatt diesel-fired emergency generator (ID No. A-HP-1230-02) has been removed from

the building.

Building 1501 Water Heaters

Page 9 of 13

MCBCL is installing two new liquefied propane gas (LPG)-fired water heaters (ID Nos. A-HP-1501-01 and A-

HP-1501-02) in Building 1501 in the Hadnot Point area. The two new LPG-fired water heaters have a heat input

capacity of 0.75 million Btu per hour each.

Communication Tower Generators

MCBCL is installing two new generators at communication towers in the Camp Geiger and Hadnot Point areas.

One new 35 kilowatt diesel-fired emergency generator (ID No. A-HP-ST82-0l)·will be installed at Structure

ST82 in the Hadnot Point area. Another new 35 kilowatt diesel-fired emergency generator (ID No. C-G-ST83-

01) will be installed at Structure ST83 in the Camp Geiger area.

Gate House Generators

MCBCL is installing six new generators at gate houses in the Amphibious Area, Camp Johnson, Midway Park,

Tarawa Terrace, and Triangle Outpost areas. Specifically,

One new 25 kilowatt diesel-fired emergency generator (ID No. A-CR-SCR120C-01) will be installed at

Building CR-120 in the Triangle Outpost area.

One new 25 kilowatt diesel-fired emergency generator (ID No. A-LCH-SLCH4041B-01) will be installed

at Building LCH -4041 in the Midway Park area.

One new 25 kilowatt diesel-fired emergency generator (ID No. A-M-SM160B-01) will be installed at

Building M-160 in the Camp Johnson area.

One new 25 kilowatt diesel-fired emergency generator (ID No. A-TT-STT15B-01) will be installed at

Building TT-15 and another new 25 kilowatt diesel-fired emergency generator (ID No. A- TT-STT16B-01)

will be installed at Building TT-16 in the Tarawa Terrace area.

One new 25 kilowatt diesel-fired emergency generator (ID No. B-A-SA 7C-01) will be installed at

Building A-7 in the Amphibious Area.


External combustion sources (water heaters)

15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES All the water heaters will combust natural gas and or LPG and are subject to the 2.3 pounds per million Btu heat input

limitation Using AP-42 emission factors, the combustion of natural gas or LPG is expected to result in SO2 emissions

on the order of 5.9E-04 and 1.1 E-04 lb/MMBtu respectively. Given the expected margin of compliance, and



The combustion of natural gas or LPG usually results (based on experience of other permitted sources at the subject

facility and in general) in visible emissions well below the 20% allowed by this rule. Given the expected margin of

compliance, and consistent with current DAQ policy, no M/R/R will be required.


2D .0503 states:

For residential facilities or institutions (such as military and educational) whose primary fuel burning capacity

is for comfort heat, only those fuel burning indirect heat exchangers located in the same power plant or building

or otherwise physically interconnected (such as common flues, steam, or power distribution line) shall be used to

determine the total heat input.


Combustion of natural gas and LPG, based on AP-42 emission factors, is expected to produce PM emissions much less

than those allowed by this rule.


Page 10 of 13


40 CFR Part 60, Subpart Dc, New Source Performance Standards for Small Industrial-Commercial-Institutional Steam

Generating Units is potentially applicable to these sources. However, all of the water heaters have heat input capacities of

less than 10 million Btu per hour, the applicability threshold pursuant to 40CFR 60.40c(a). Thus, this rule does not apply.




MCIEAST-MCB CAMLEJ is classified as a major source of HAPs. However, the water heaters identified in this

application have heat input capacities of less than 1.6 million Btu per hour and, as such, are classified as hot water heaters

in accordance with 40 CFR 63.7575. These hot water heaters are not subject to the MACT for Boilers and Process

Heaters in accordance with 40 CFR 63.7491(d).

Internal combustion sources (generators)



2D .0516 states:

(b) A source subject to an emission standard for sulfur dioxide in Rules .0524, .0527, .1110, .1111, .1205,

.1206, .1210, or .1211 of this Subchapter shall meet the standard in that particular rule instead of the standard

in Paragraph (a) of this Rule.

These engines are subject to 2D .0524 NSPS Subpart IIII which has a more stringent sulfur standard. Thus, this rule

does not apply to these emergency engines.

15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS Under this rule, each source is subject to a 20 percent opacity limit when averaged over a 6-minute period (with some

exceptions).


(b) Scope. This Rule shall apply to all fuel burning sources and to other processes that may have a visible

emission. However, sources subject to a visible emission standard in Rules .0506, .0508, .0524, .0543, .0544,

.1110, .1111, .1205, .1206, .1210, .1211, or .1212 of this Subchapter shall meet that standard instead of the

standard contained in this Rule.

These engines are subject to 2D .0524 NSPS Subpart IIII which has a “smoke” standard. Thus, this rule does not apply to

these emergency engines.

15A NCAC 2D .0524: NEW SOURCE PERFORMANCE STANDARDS 40 CFR Part 60 Subpart IIII - Standards

of Performance for Stationary Compression Ignition Internal Combustion Engines


The emergency generators are subject to this regulation and comply with the emission standards for new non-

road compression ignition (CI) engines in 40 CFR 60.4202. All of these units are classified as emergency

stationary internal combustion engines in accordance with 40 CFR 60.4219. Each generator has been issued a

certificate of conformity by EPA; these certificates are presented in Appendices B through G of the application.

Each generator is equipped with a non-resettable hour meter and each unit has a displacement of less than 30

liters per cylinder. In addition, the units burn ULS diesel fuel with a maximum sulfur content of 15 ppm and a

Page 11 of 13

minimum cetane index of 50 or a maximum aromatic content of 35 volume percent. None of the units are

equipped with diesel particulate filters to comply with emission standards.

To demonstrate compliance with Subpart IIII, MCIEAST-MCB CAMLEJ operates and maintains the generators

per the manufacturers' specifications. Each generator will be operated for less than 100 hours per year during

maintenance checks and readiness testing. The results of inspections and maintenance are maintained in

logbooks. MCBCL also submits a summary of these inspection and maintenance activities in the semi-annual

report.

This engineer agrees with these statements. These engines have identical requirements to engines already in the permit.

These engines will simply be added to the appropriate listing in the air permit.

15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY - 40 CFR Part 63, Subpart

ZZZZ, National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal

Combustion Engines.


The emergency generators are also subject to this regulation and meet the definition of new stationary RICE in

accordance with 40 CFR 63.6590(a)(2). The generators that have a rating greater than 500 hp are subject to

limited requirements in accordance with 40 CFR 63 .6590(b)(1 ). Specifically, an initial notification must be

submitted for these sources; there are no other requirements for these sources under Subpart ZZZZ. MCIEAST-

MCB CAMLEJ will notify DAQ no later than 120 calendar days after the startup of these emergency generators

to comply with this regulation.

In accordance with 40 CFR 63.6590(c)(6), sources that have a rating less than or equal to 500 hp must meet the



This engineer agrees with these statements. These engines have identical requirements to engines already in the permit.

These engines will simply be added to the appropriate listing in the air permit.


State Enforceable Only


The addition of the combustion is not expected to affect compliance with this rule. MCBCL already has similar sources

and has such a large facility footprint that it is not expected to create off-site odor problems.


The subject facility is considered a major source for PSD applicability purposes. To date, separate funding of projects at

military bases has been used as justification to not consider all contemporaneous modifications as a single PSD project.

This modification consists of 11 separate projects. Each project consists of the addition of natural gas fired external

combustion sources and or diesel fuel fired emergency generators. In each case, the potential emissions from each of the

projects will result in increase in emissions less than the PSD significance rates for all applicable pollutants. The

calculations are documented in the spreadsheet “Permit App Forms.xls.”


This modification consists of the construction and operation of 92 boilers, process heaters and hot water heaters all fired

by natural gas and all with heat input capacities that do not exceed 1.25 mmBtu/hr. The overall total heat input for these

sources is 39.3 mmBtu/hr. This modification also includes the addition of 12 diesel-fuel fired emergency generators with

a total BHP of 2952 BHP and the removal of 9 diesel-fuel fired emergency generators with a total BHP of 2946 BHP.

Page 12 of 13

As stated in the application, these external combustion units are being installed under projects intended to reduce energy

usage intensity across the installation. Upon finalization of these efforts, the base will decommission the central heating

(i.e., steam) plants that provide steam and/or hot water to various portions of the base.

As a result, the use of these new combustion sources will result in a decrease on the demand of the centralized boilers.

Given the energy losses associated with the transport of steam and hot water, it is reasonable to assume that the air

emissions associated with the generation of steam or hot water from one of these newer combustion sources, which will

be located close to the demand location, will be less than those that would be emitted from a centralized boiler on a per

unit of supplied steam/hot water basis.

The existing centralized boilers are permitted to burn natural gas, No. 2 fuel oil, and for the four largest boilers, coal.

Utilizing AP-42 emission factors, natural gas is shown to have lower TAP emissions on a pound per million Btu basis

than No.2 fuel oil for all TAPs with the exception of acetaldehyde, acrolein, ammonia, benzopyrene and hexane. The

largest difference is for ammonia, which is 0.003 lb/mmBtu larger for natural gas, which is still a small difference.

Natural gas combustion also does not have any metal TAP emissions. Although the dispersion characteristics can be

expected to be different between the widely dispersed small sources and the centralized boilers, this modification can

arguably be considered neutral with respect to any increase in TAP emissions or expected ambient impacts from the

proposed modifications to the external combustion sources.

Note that the total BHP (2952 BHP) of the emergency generators being constructed is comparable to the total BHP (2946

BHP) of the emergency generators being removed. These new engines are also subject to MACT ZZZZ and NSPS

Subpart IIII. These newer engines are expected to have much lower emissions as they must meet more stringent emission

standards. Thus, it is reasonable to assume that there will be no net increase in emissions associated with the emergency

engines modifications at the facility.

In summary, the proposed modification is not expected to have “an unacceptable risk to human health” pursuant to North

Carolina Session Law 2012-91.

This modification represents the seventh modification involving TAP emitting sources since the last facility-wide

modeling demonstration (see Application 11C that resulted in the issuance of permit no. T27). All previous modifications

have been shown to not be expected to have “an unacceptable risk to human health” pursuant to North Carolina Session

Law 2012-91 or the projects resulted in emission increases that did not justify any revised facility-wide modeling

demonstration.

Under the current 2D .1100 toxics rules, sources subject to a MACT or GACT standard are not subject to 2D .1100 if they

are shown to not pose “an unacceptable risk to human health.” Of the 104 sources discussed in this modification, only the

emergency engines are subject to a MACT (Subpart ZZZZ) and can therefore be considered exempt from 2D.1100. The

remaining sources do not meet any other exemptions to 2D .1100 pursuant to 2Q .0702. For these other sources , a permit

condition will indicate that these sources are technically subject to 2D .1100, but to date have not been included in a

compliance (modeling) demonstration.

Page 13 of 13


Existing

Condition

No.

New

Condition

No.

Changes

Cover Letter Same



Revised the 2Q .0515 minor modification language to address this modification

application

Permit page

1 Same

Updated permit numbers, dates, etc.


Insignificant


Added 92 small water heaters*

Added 10 emergency generators*

Section 1 -

Permitted

equipment

list

Same

Removed 9 engines*

Added 2 emergency engines*

Revised the descriptors for numerous sources*


2..1.F., Table

2.1.F.2 Same The water heater C-AS-100-02 is really a boiler and hence was added to Table 2.1.F.2.

Table

2.1.M.-1 Same

Removed one engine*

Added two emergency engines*

Revised 6 descriptors*

Table

2.1.M.-2 Same

Removed two engines*


Table

2.1.M.-3 Same Removed one engine*

Table

2.1.M.-4 Same

Removed4 engines*


Section

2.1M,

Applicable

Regulations

Table

Same Added reference to A-HP-1230-3 and A-HP-411-2 for the Section 2.2.A.1. 2D.1100

condition

Table

2.1.M.7-1 Same

Removed one engine*

Added two engines*


2.2.B., Table

2.2.B.1 Same Revised 3 descriptors*


The DAQ has reviewed the compliance status of this facility. On its latest inspection, performed on 09/29/2014 by Mr.

Mark Hedrick, of the Wilmington Regional Office, the facility appeared to be in compliance with all applicable

requirements.




Attachment D

Permit review for Application No. 6700011.14D resulting in the issuance of Permit No. T37

Page 1 of 10


AIR QUALITY

Air Permit Review

Permit Issue Date: May 22, 2015


County: Onslow





Facility Data



12 Post Lane







SIP:

NSPS:

NESHAP:

PSD:

PSD Avoidance:

NC Toxics:

112(r):

Other:


Application Number: 6700011.14D








Facility Contact

Robert Lowder

(910) 451-9607

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547

Authorized Contact

John Townson


Management Div.

(910) 451-5003

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547

Technical Contact

Robert Lowder

(910) 451-9607

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547



2013 656.67 465.26 125.23 43.43 15.14 46.39 21.21


2012 604.18 431.78 151.05 43.50 14.34 42.58 18.24


2011 664.72 497.13 49.79 44.53 16.18 33.53 17.87


2010 731.05 525.65 34.08 51.88 16.36 35.61 17.57


2009 653.09 460.22 58.95 38.93 14.09 35.77 16.73


Page 2 of 10




Issue 06591/T37

Permit Issue Date: May 22, 2015


I. Introduction


numerous new combustion sources as described in Section III of this review. The application will be processed as a minor

modification pursuant to 15 A NCAC 2Q .0515.

II. Chronology

Date Description

12/19/2014 Application received and assigned application no. 6700011.14D.

12/31/2014 Email sent to Permittee requesting an electronic listing of the modified sources and requested changes

02/01/2015 Info requested on 12/31/2014 was received via email

04/08/2015 ADD INFO email sent requesting concurrence with permit layout

05/04/2015 Response to email sent on 04/08/2015 was received.


The following text is from the application.

The installation recently conducted an internal tank inventory in order to update its Spill Prevention, Control and

Countermeasure (SPCC) Plan. Numerous unpermitted diesel-fired emergency generators, located throughout the

installation's 150,000 acres, were identified during this process. Notification regarding the installation of these

units had not been provided to the MCIEAST-MCB CAMLEJ Environmental Management Division for air

permitting purposes. In some cases, emergency generators that had previously been permitted appear to have

been removed from service and the Title V permit, placed in temporary storage, and then put back into service at

a different location.

Based on the installation's updated inventory, MCIEAST-MCB CAMLEJ is requesting that forty-three (43) “new”

emission sources be added to Title V Permit.

The following table (Table 1 of the application) includes the original date of installation as well as the NSPS/NESHAP

applicability (to be discussed later in this review document).

Page 3 of 10

Page 4 of 10

The sources in Table 1 above will be added to the permit; all to the insignificant activities list (See below). Note that at the time

of permit application submittal, DAQ permitting policy was such that the “State-only” permitting filters found at 15A NCAC

2Q .0102 were used to assess whether or not insignificant sources as defined at 15A NCAC 2Q .0503 were required to be on

the permit explicitly (i.e. in Section 1 of the permit). The DAQ has since changed its policy. As a result, most of the sources

requested to be added to the permit, which are insignificant activities under 2Q .0503, do not need to be added to Section 1 of

the permit. Whether a source is on Section 1 of the permit or the attached insignificant activities list, it is still subject to the

same rules. The benefit to the facility however, will be with respect to future facility modifications. That is, a permit application

would no longer be required to be submitted for the sources that are included in this application.

For consistency, AP-42 emission factors will be used to determine which engines meet the 5tpy threshold of 15A NCAC 2Q

.0503. All emergency engines less than 830 BHP (since PTE is based on 500 hours per year per current DAQ/EPA policy)

meet the 5 tpy threshold. Thus, all the engines addressed in this modification will be added to the insignificant activities list.


Internal combustion sources (emergency generators)




All the emergency generators will combust diesel fuel. Using AP-42 emission factors, the combustion of diesel fuel is not

expected to exceed this limitation unless the diesel fuel has a sulfur content of approximately 2.3%. As will be shown below

NSPS Subpart IIII requires diesel fuel with a sulfur content not to exceed 15 ppm.

2D .0516 states:

(b) A source subject to an emission standard for sulfur dioxide in Rules .0524, .0527, .1110, .1111, .1205, .1206,

.1210, or .1211 of this Subchapter shall meet the standard in that particular rule instead of the standard in

Paragraph (a) of this Rule.

Thus the engines are subject to 2D .0524 NSPS Subpart IIII which has a sulfur standard. Thus, this rule only applies to the non-

NSPS affected engines. The NSPS applicability is summarized in Table 1 above. Consistent with current DAQ policy, diesel

fired emergency engines do not have any required M/R/R with respect to this regulation. The engines will be identified in the

permit as necessary.


15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS Under this rule, each source is subject to a 20 percent opacity limit when averaged over a 6-minute period (with some

exceptions).


(b) Scope. This Rule shall apply to all fuel burning sources and to other processes that may have a visible emission.

However, sources subject to a visible emission standard in Rules .0506, .0508, .0524, .0543, .0544, .1110, .1111,

.1205, .1206, .1210, .1211, or .1212 of this Subchapter shall meet that standard instead of the standard contained in

this Rule.

Thus, the engines that are subject to 2D .0524 NSPS Subpart IIII, which has a “smoke standard,” are not subject to this rule.

Thus, this rule only applies to the non-NSPS affected engines. The NSPS applicability is summarized in Table 1 above.

Consistent with current DAQ policy, diesel fired emergency engines do not have any required M/R/R with respect to this

regulation. The engines will be identified in the permit as necessary.

Page 5 of 10

15A NCAC 2D .0524: NEW SOURCE PERFORMANCE STANDARDS 40 CFR Part 60 Subpart IIII - Standards of

Performance for Stationary Compression Ignition Internal Combustion Engines


Thirty-seven (37) of the emergency generators are subject to this regulation and comply with the emission

standards for new non-road compression ignition (CI) engines in 40 CFR 60.4202. All of these units are classified

as emergency stationary internal combustion engines in accordance with 40 CFR 60.4219. Each generator has

been issued a certificate of conformity by EPA; these certificates are presented in Appendices B through GG.

As noted in Table 1: five (5) emergency generators and the back-up pump are not subject to this regulation. These

units were manufactured prior to 2006 and installed at MCIEAST-MCB CAIVILEJ during the same time period.

Because the units were manufactured prior to the applicability date for Subpart IIII (1 April 2006), in accordance

with 40 CFR 60.4200(a)(2) they are not subject to the regulation.

All of the generators (including those not subject to 40 CFR 60, Subpart IIII) and the backup pump are equipped

with a non-resettable hour meter and each unit has a displacement of less than 30 liters per cylinder. In addition,

the units burn ULS diesel fuel with a maximum sulfur content of 15 ppm and a minimum cetane index of 50 or a

maximum aromatic content of 35 volume percent. None of the units are equipped with diesel particulate filters to

comply with emission standards.

To demonstrate compliance with Subpart IIII, MCIEAST-MCB CAMLEJ operates and maintains the generators

per the manufacturers' specifications. Each generator is operated for less than 100 hours per year during

maintenance checks and readiness testing. The results of inspections and maintenance are maintained in logbooks.

MCIEAST –MCB CAMLEJ also submits a summary of these inspection and maintenance activities in the semi-

annual report.



MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY - 40 CFR Part 63, Subpart ZZZZ, National Emissions

Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines.


All of the emergency generators and the back-up pump are subject to this regulation. Five (5) emergency

generators and the back-up pump meet the definition of existing stationary RICE in accordance with 40 CFR.

63.6590(a)(1). These units are identified in Table 1 as not being subject to the NSPS requirements of 40 CFR

60Subpart IIII.

Emergency generator A-BM-883-01 has a site rating greater than 500 horsepower and was installed prior to

December 2002. In accordance with 40 CPR 63.6590(b)(3)(iiii), there are no requirements applicable to this unit

under Subpart ZZZZ.

The other five (5) existing RICE have site ratings of less than or equal to 500 horsepower. As such, these

emergency generators are subject to operating and maintenance, monitoring, recordkeeping, and reporting

requirements. The requirements applicable to these emergency generators are specified in Title V permit

condition 2.l.M.4.

The remaining thirty-seven (37) emergency generators meet the definition of new stationary RICE in accordance

with 40 CFR 63.6590(a)(2). The two (2) generators that have a site rating greater than 500 HP are subject to

limited requirements in accordance with 40 CFR 63.65900(b)(l). Specifically, an initial notification must be

submitted for these sources; there are no other requirements for these sources under Subpart ZZZZ. Initial

notification for emergency generators A-PP-5-01 and C-AS-498-01 is presented in Appendix HH.

In accordance with 40 CFR 63.6590(c)(6), sources that have a rating less than or equal to 500 HP must meet the





Page 6 of 10




The addition of the combustion is not expected to affect compliance with this rule. MCBCL already has similar sources and has

such a large facility footprint that it is not expected to create off-site odor problems.


The subject facility is considered a major source for PSD applicability purposes. To date, separate funding of projects at

military bases has been used as justification to not consider all contemporaneous modifications as a single PSD project. This

“modification” is in reality an update to the accuracy of the air permit. Thus, each of these engines is really tied to projects that

happened in the past. The Permittee claims that these engines if considered one “project” would not trigger PSD since:

… the increases in emissions associated with the requested changes are less than the PSD significant emission

rates (SER) for carbon monoxide (CO), nitrogen oxides (NOx), sulfur dioxide (SO2), total particulate matter

(PM), volatile organic compounds (VOC), lead (Pb), and greenhouse gasses (measured as carbon dioxide

equivalent [CO2e]).

This engineer agrees with this statement. In general, NOx is the controlling pollutant when considering PSD applicability for

IC engines. This project involves the net “addition” of 6279 BHP (adding 6528 BHP and removing 249 BHP) of

emergency/backup capacity. Utilizing the AP-42 emission factor for NOx (0.0242 lb/HP-hr) results in an “increase” of 39 tpy

of NOx. Note that most of these engines are certified to meet the applicable NSPS IIII NOx emission limit which differs for

different years/sizes of engines but at its greatest is 6.9 g/HP-hr (or 0.0152 lb/HP-hr), much less than the AP-42 factor. The

permit application does include each engine’s emissions estimates but the above discussion provides a much more succinct

summary.

Given each engines relatively small contribution to each project in which it should have been accounted it seems unnecessary

to revisit each previous project’s PSD applicability. Note that most projects have had separate finding mechanism which

resulted in most projects having emissions much less than the PSD significance thresholds anyway. No further review is

necessary.


IMPORTANT NOTE: - The following analysis includes sources subject to a MACT as well as some sources that have

subsequently been determined to be exempt from the MACT (i.e. certain boilers not used to generate steam) and hence subject

to toxics. Given that this presented analysis would be considered more conservative, reaches the same conclusion and would

be less confusing to the lay reader than to understand the difference between a source subject to 2D .1100 but not included in

an analysis per 2Q .0701(c) versus a source subject to MACT and exempt from 2D .1100 per NC Session law 2012-91, the

original analysis will remain unchanged.

On 28 June 2012, North Carolina Session Law 2012-91 was enacted. This law requires the DAQ to


existing source or facility, that would result in an increase in the emission of toxic air pollutants,

the Department shall review the application to determine if the emission of toxic air pollutants

from the source or facility would present an unacceptable risk to human health.

Then, if a determination is made that these sources do not pose a risk as described above, the sources are not subject to 15A

NCAC 2Q .0700 or 2D .1100.

This application represents the ninth time the facility has been modified to add and remove combustion sources that are subject

to a standard under 40 CFR 63 since the facility had conducted a facility-wide modeling demonstration. During each of the

permitting actions since the last facility-wide modeling demonstration (permit no. T27), a justification was made that each of

the modifications would not pose an unacceptable risk to human health. The following table describes the strategy taken during

each permitting action.

Page 7 of 10

Table 1

Permit

No. Description

T27 2D .1100 facility-wide modeling demonstration

T28 The modification involved 22 new external natural gas fired external combustion sources for a total heat input of 11

MMBtu/hr and 2 new diesel-fired emergency engines with a total brake horsepower of 938 BHP. This was prior to

the passing of SL 2012-91. Given that:

1.the modeling demonstration was fairly recent and very conservative; and

2. the modification was relatively small;

placeholder language was simply included in the permit to include these sources in any future modeling analysis.

T29 This application was a “PART II” application addressing modifications prior to T27. Hence, the requirements of SL

2012-91 did not need to be addressed.

T30 The modification involved 25 new external natural gas fired external combustion sources for a total heat input of

23.8 MMBtu/hr and 11 new diesel-fired emergency engines with a total brake horsepower of 4136 BHP.

A zone by zone analysis was conducted, comparing the addition of the new sources with the emissions modeled in

T27. It was shown that the increases in emissions associated with this modification as well as those discussed in

T28) were small.

T31 The modification involved 37 new external natural gas fired external combustion sources for a total heat input of

16.2 MMBtu/hr, 9 new diesel-fired emergency engines with a total brake horsepower of 1267 BHP and the removal

of 28 diesel-fired emergency engines with a total brake horsepower of 4103 BHP. It was shown that there was a net

decrease in emissions associated with this modification alone and therefore NC Toxics review was not triggered..

T32 The modification involved 24 new external natural gas fired external combustion sources for a total heat input of 17

MMBtu/hr, the removal of 5 No.2 fuel oil fired combustion sources with a total heat input of 7.5 MMBtu/hr, 31 new

diesel-fired emergency engines with a total brake horsepower of 11599 BHP and the removal of 1 diesel-fired

emergency engine with a total brake horsepower of 55.44 BHP. Given the size of this modification, the net changes

in each TAP for each zone since the last modeling analysis (permit no. T27) were compared to the allowable

emission rates. Thus, the modifications addressed in permit nos. T28, T30 and T31 were considered.

T33 This was a renewal application. It resulted in the removal of 14 No.2 fuel oil-fired external combustion sources for a

total heat input of 39.9 MMBtu/hr, and the removal of 11diesel-fired emergency engines with a total brake

horsepower of 2538 BHP. Thus, there was a net decrease in the potential emissions of all TAPs related to the

combustion sources and therefore NC Toxics review was not triggered. No “unacceptable risk” analysis was

conducted or necessary.

T34 This modification involved the removal of 26 boilers and the addition of 30 boilers with a net decrease in heat input

capacity of 38 MMBtu/hr and the removal of 11 engines and the addition of 7 engines with a net increase of 9 BHP.

It was concluded there was essentially no net change in TAP emissions.

T35 This modification involved the addition of 428 boilers, process heaters and hot water heaters all fired by natural gas

and all with heat input capacities that do not exceed 3.78 MMBtu/hr. The overall total heat input for these sources is

162 MMBtu/hr. Since the intent of these units is to supplant steam demand from the centralized No.2 and coal fired

boilers, which have higher TAP emission rates on a per heat input basis, it was reasoned that there would be no net

increase in TAP emissions associated with this modification.

T36 This modification consisted of the construction and operation of 92 boilers, process heaters and hot water heaters all

fired by natural gas and all with heat input capacities that do not exceed 1.25 MMBtu/hr. The overall total heat input

for these sources is 39.3 MMBtu/hr. This modification also includes the addition of 12 diesel-fuel fired emergency

generators with a total BHP of 2952 BHP and the removal of 9 diesel-fuel fired emergency generators with a total

BHP of 2946 BHP.

Similar to T35, the heat input of the boilers is intended to supplant steam demand from the centralized No.2 and coal

fired boilers, which have higher TAP emission rates on a per heat input basis. With respect to the engines there was

only a net gain of 6 BHP. Thus, the net increases in TAP emissions were very small and certainly not enough to pose

“an unacceptable risk to human health.”

In summary then, only the emissions decreases associated with the removal of emergency engine capacity and boiler capacity

in permit no. T33 has not been used to support any assertion of ‘unacceptable risk to human health” associated with any one

modification.

The “proposed” project “effectively” will result in an increase in 6279 BHP of emergency engine capacity. If one takes into

consideration the “reductions” achieved in T33 (2538 BHP) there is still an increase in capacity of the emergency engines of

3741 BHP. Thus, some further analysis is warranted.

Page 8 of 10

Since as shown in Table 1 above, the modifications in permit nos. T34, T35 and T36 were shown to pose no unacceptable risk

individually, those emissions were not included in this analysis. Thus, this analysis includes the modifications addressed in T28

through T33 and the current modification. Table 2 summarizes the sources included in this analysis.

Table 2

In the most recent modeling demonstration the MCBCL facility was divided into four zones. Hence this review will consider

any emissions increase and decreases on a “per zone” basis.

All emissions calculations are based on AP-42 emission factors, which is consistent with the emission rates previously

modeled. All engines are assumed to operate 500 hours per year given current EPA permitting policy for emergency engines.

All boilers assumed to operate 8760 hours per year. The emissions were then compared to the emission rates previously

modeled for the specific pollutants appropriate averaging period (e.g. formaldehyde 1-hour basis, benzene annual basis). These

calculations are included in the spreadsheet “AppNo.6700011.14D-5B –Analysis-Calculations.xls.”

The first step in this review is to determine for which pollutants there was an increase in emissions previously modeled. Then

for these pollutants, further examination will be made to determine if the emissions increases are likely to cause the given

pollutant’s Acceptable Ambient Level (AAL) to be exceeded.

Table 3 below shows the change in the PTE for each TAP as a percentage of the modeled allowable emissions. For example, in

Zone A, since the last modeling demonstration (permit No. T27) the potential hourly formaldehyde emissions have increased

by 1.4 % on an hourly basis and the potential annual benzene emissions have increased in Zone B by 0.24%.

Page 9 of 10

Table 3

Note that for the majority of pollutants, the increases in emissions over those modeled were well under 0.1% and in many cases

potential emissions went down. So, to focus further review let’s consider the pollutants, that as a result of the modifications

considered, have increases in emissions of at least 1/10 of 1 percent over those previously modeled. These are formaldehyde,

benzene, arsenic, and non-specific chromium compounds as CrVI.

The following excerpt is from the review for permit no. T27, issued on 2/20/2012.

All sources were modeled operating at their maximum capacity. In most cases, this occurred over 8760 hours

per year, with the exceptions being emergency generators, which operated over 500 hours per year.

All requested permitted emission rates were the result of increasing each sources’ PTE of a specific TAP by an

optimization factor such that 98% of the AAL guideline was obtained.

Consider the following optimization factors used in the previous modeling analysis:

Zone A: formaldehyde: 1.64

Zone A: benzene: 1.06

Zone B: arsenic: 1.04

Zone B: benzene: 1.00

Zone B: non-specific chromium (vi) compounds, as chromium (vi) equivalent 1.07

Thus, for example, the potential emissions of arsenic in zone B could be increased by 4% before the model would

underestimate the impact with respect to the Arsenic AAL that would result from the true potential emissions. Although the

impacts of a source’s emissions are a function of the dispersion parameters and location (e.g., location to the “fenceline”) it

also must be noted this discussion here centers on potential emissions. Thus, ALL the boilers must operate 8760 hours per year

and (even less likely) ALL the emergency generators must operate 500 hours per year. Such a scenario is highly unlikely and

certainly would be indicative of an emergency of catastrophic proportions. Thus, for example, even though benzene was not

optimized, its’ increase in potential emissions of 0.14% in Zone A is highly unlikely to cause an issue with the AAL.

Page 10 of 10

The most likely scenario would be a short term emergency. Assume an emergency lasting only 1-hour. If such was the case

that all sources on site were operating, including all the emergency generators, the model suggests that all the formaldehyde

emissions in Zone A could be increased by 64% before 98% of the AAL would even be achieved.

Based on the following, the MACT affected sources (and indeed any of the combustion sources considered) included in the

modifications considered here since the last modeling demonstration can be exempted from 2D .1100 because it is highly

unlikely their operation poses an “unacceptable risk to human health”:

Most increases in potential TAP emissions were less than 1/10 of 1 percent or decreased over the previously modeled

emission rates

Only four TAPs increased their potential emissions greater than at least 1/10 of 1 percent over those previously

modeled rates

With the exception of benzene in Zone A, all had their potential emissions optimized such that a modeled 98% of the

AAL impact was achieved.

The actual emissions of these pollutants are much less than the potential emissions, most notably because they result

significantly from emergency engines.


Existing

Condition

No.

New

Condition

No.

Changes

Cover Letter Same Used current shell language, updated permit numbers, dates, etc.

Permit page 1 Same Updated permit numbers, dates, etc.

Insignificant

activities list Same Added 43 emergency generators*

Section 1,

permitted

equipment list

Same Removed 2 emergency generators

Table 2.1.M.-

4 Same Removed 2 emergency generators



Hedrick, of the Wilmington Regional Office, the facility appeared to be in compliance with all applicable requirements.




Attachment E

Permit review for Application No. 6700011.15A resulting in the issuance of Permit No. T38

Page 1 of 16


AIR QUALITY

Air Permit Review

Permit Issue Date: January 8, 2016


County: Onslow




Compliance Code: B / Violation - emissions

Facility Data



12 Post Lane

Marine Corps Base Camp Lejeune, NC 28547






SIP:

NSPS:

NESHAP:

PSD:

PSD Avoidance:

NC Toxics:

112(r):

Other: 2D .0544(m) – GHG recordkeeping


Application Number: 6700011.15A



Application Schedule: TV-Sign-501(c)(2) Part I





Facility Contact

Travis Voorhees

Acting Air Program

Manager

(910) 451-9120

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547

Authorized Contact

John Townson


Management Div.

(910) 451-5003

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547

Technical Contact

Travis Voorhees

Acting Air Program

Manager

(910) 451-9120

G-F/EMD/EQB;

MCIEAST-MCB

CAMLEJ

Camp Lejeune, NC

28547



2014 732.23 412.89 118.95 57.38 14.80 33.30 12.23


2013 656.67 465.26 125.23 43.43 15.14 46.39 21.21


2012 604.18 431.78 151.05 43.50 14.34 42.58 18.24


2011 664.72 497.13 49.79 44.53 16.18 33.53 17.87


2010 731.05 525.65 34.08 51.88 16.36 35.61 17.57


Page 2 of 16




Issue 06591/T38

Permit Issue Date: January 8, 2016


I. Introduction


numerous new combustion sources as described in Section III of this review. Because the modification is significant, but will

not contradict or contravene with a condition in the existing permit, the Permittee has requested the application to be processed

in two steps as allowed pursuant to 15A NCAC 2Q .0504. This application represents step 1, which will follow the 15A NCAC

2Q .0300 (State Only) procedures. The permittee shall have one year from the date of beginning operation of the sources to file

an amended application following the TV permitting procedures (15A NCAC 2Q .0500). A permit condition will be placed in

the construction and operation permit issued under the 2Q .0300 procedures stating this requirement.

II. Chronology

Date Description

10/27/2015 Applicability determination was received and assigned no. 2727

11/3/2015 Mr. Voelker sent Mr. Voorhees and email requesting additional information to address 2D .1100 and 2D

.0530 applicability

11/24/2015 Information requested on 11/03/2015 was received via email.

12/9/2015

Mr. Voelker sent an email to Mr. Voorhees explaining that one of the projects considered in the applicability

determination no. 2727 had projected actual emissions of CO2e that exceeded the significance threshold. As

such, that project would be subject to the recordkeeping requirements of 15A NCAC 2D .0544(m). The

DAQ's position on this is that these are applicable requirements and involve a case- by case- regulatory

applicability determination. As such, a significant permit modification (one step or two step) will be required

to add the requirements of 2D .0544(m) to the permit. Therefore, these sources will need to be permitted.

12/10/2015

A phone conference occurred with Mr . Voelker, Willets and Cuilla of the DAQ and Mr. Voorhees, plant

contact and Lori Cress consultant. The DAQ explained its position stated in the 12/09/2015 email and what

was needed to process the application in the most expedient manner, which is the two-step process pursuant

to 2Q .0504. It was noted that although the applicability determination was made up of multiple projects,

only the sources in the project triggering 2D .0544 were subject to permitting requirements. The other

sources will simply be added to the insignificant activities list.

12/30/2015 Application was received and assigned application no. 6700011.15B

Page 3 of 16


The following text is from the application cover letter.

Marine Corps Base (MCB) Camp Lejeune [Facility ID 6700011] is in the process of adding 338 natural

gas-fired boilers and hot water heaters as part of a single decentralization project (P1449B). These units

have heat input capacities between 0.199 and 3 million Btu (British Thermal Units) per hour and are all

equipped with low NOx (Oxides of Nitrogen) burners. These external combustion units are being installed

to reduce energy usage intensity aboard the installation.

During the review of our October 2015 permit determination submittal, the North Carolina Division of

Air Quality (NC DAQ) concluded that, as a result of the Greenhouse Gas (GHG) emissions being

potentially added as part of this single project, a PSD (Prevention of Significant Deterioration) Avoidance

condition would need to be added to our Title V permit (Permit No. 06591T37). Per your electronic

correspondence dated 10 December 2015, we are submitting the additional information requested to

process a permit modification for the emission sources being added to our facility as part of

decentralization project P1449B only.

As discussed in the chronology in Section II. this project, like the other projects discussed in the applicability determination, is

made up of sources that each meet the definition of an insignificant activity because of size or production rate pursuant to 15A

NCAC 2AQ .0503.

To ensure continued understanding of all the projects at the facility, a brief explanation of all the projects is as follows:

Project Descriptions & Schedules

MCB CAMLEJ and MCAS New River currently operate six central heating (i.e., steam) plants that provide steam and/or

hot water to various portions of the base. Executive Orders have mandated reductions in the energy usage intensity aboard

the installation. To meet these energy reduction goals, MCB CAMLEJ and MCAS New River are implementing several

projects to replace the steam plants with small natural gas-fired boilers, process heaters, and hot water heaters that will

be located in buildings currently served by the steam plants. Upon formalization of the decentralization efforts, the

installation will decommission the steam plants. In addition to reducing the energy usage intensity aboard the

installation, these decentralization efforts will substantially reduce air pollution emissions generated aboard MCB

CAMLEJ and MCAS New River.

A majority of the emission sources being addressed in this permit determination are associated with steam plant

decentralization projects and other miscellaneous infrastructure improvement projects. Specific projects and their

associated equipment are described below. Each of these projects has been funded separately with an independent

funding mechanism.

Decentralization Project P14498

Under this project, MCB CAMLEJ is making heating-system modifications at various locations within the French Creek

and Hadnot Point areas. Ninety-nine (99) natural gas-fired external combustion sources are being installed in 26

buildings located within the French Creek area. Two hundred fifty-three (253) natural gas-fired external combustion

sources are being installed in 63 buildings located within the Hadnot Point area. This is part of the installation's effort to

replace the Building HP-1700 steam plant.

Decentralization Project P1449

Under this project, MCB CAMLEJ is making heating-system modifications at various locations within the Courthouse

Bay area. Twenty-six (26) natural gas-fired external combustion sources are being installed in 6 buildings located within

the area. This is part of the installation's effort to replace the Building BB-9 steam plant.

Decentralization Project 13-0078

Under this project, MCB CAMLEJ is making heating-system modifications at various locations within the Camp Geiger

area. Nine (9) natural gas-fired external combustion sources are being installed in 9 buildings located within the area.

This is part of the installation's effort to replace the Building CG-650 steam plant.

Project 14-0062

Page 4 of 16

Under this project, MCB CAMLEJ is making heating-system modifications within the Tarawa Terrace residential area.

The existing No.2 fuel oil-fired water heater located at Building TT-2457 is being replaced with a natural gas-fired water

heater.

Project 14-0171

Under this project, MCB CAMLEJ is installing one diesel-fired emergency generator at _Building M-303, located within

the Camp Johnson area. This unit will replace an existing 35 KW unit located at Building M-303.

Project ER-14-116

Under this project, MCB CAMLEJ is installing one diesel-fired emergency generator at Building SSR45, located within

the Greater Sandy Run area.

MLCON Project P1383/ P1384

Under this MLCON project, MCB CAMLEJ is installing two diesel-fired emergency generators at Buildings TT-13

and TT-18, located within the Tarawa Terrace residential area. These emergency generators are in support of the new

Wilson Creek Gatehouse.

Starling Communication Tower Generator Upgrade

MCB CAMLEJ is installing one new diesel-fired emergency generator at the Starling Communication Tower in Training

Area Q.

MCAS Epoxy Curing Bench

MCB CAMLEJ is in the process of installing an epoxy curing bench/fiberglass repair operation aboard the MCAS

New River portion of the installation. The operation is similar to existing sources I-C-AS-265-02 and I-C-AS-3900-04.

Table 1 below shows an emission summary for all the projects discussed above. Note that only the projects P1449 and P1449B,

if each entire project were considered a single emission source, would not meet the definition of an insignificant activity

because of size or production rate pursuant to 15A NCAC 2AQ .0503 ( insignificant activity). A review of the individual

sources in each project shows that each project does consist of insignificant activities. Except for PSD considerations, these

projects would not trigger any permitting requirements.

For PSD considerations, each of the projects are considered independently As indicated in the applicability determination

request letter ( and the subsequent application), each of the projects as indicated above have been funded separately, each with

an independent funding mechanism. Examination of Table 1 shows only project P1449B exceeds the PSD applicability for any

regulated pollutant, in this case CO2e, which has a significance threshold of 75,000 tpy. Note Table 1 suggests that the PSD

significance threshold for NOX has been exceeded; however, it is only exceeded if the independent projects are aggregated

which is not required under PSD.

Table 1.

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The Permittee also supplied the following netting calculation (Table 2) which shows that since the projects are to reduce

demand on the existing coal fired boilers, the net emissions increase will be below PSD thresholds. Note that only project

P1449B is in question. The other projects shown have already demonstrated that PSD review is not triggered.

Table 2

The only way to make this reduction in emissions from the boiler in demand creditable under PSD (41. CFR 51.166(3)(vi) is to

make it enforceable as a “practical matter”, which can be most expediently accomplished via a 2D .0544(m) recordkeeping

permit condition.

In summary only the emission sources associated with project P1449B will be discussed further. All other sources will simply

be added to the insignificant activities list (a total of 374 boilers and water heaters and five emergency engines). Whether a

source is on Section 1 of the permit or the attached insignificant activities list, it is still subject to all applicable air quality rules

and regulations.

The following 338 external combustion sources in Table 3 are associated with project 1449B.

Table 3

Emission Source ID

No. Emission Source Description

Heat Input Capacity

(MMBtu/hr)

I-A-FC-100-1 Natural gas-fired boiler (3 million Btu per hour heat input capacity) [MACT DDDDD] 3.000

I-A-FC-100-2 Natural gas-fired boiler (3 million Btu per hour heat input capacity) [MACT DDDDD] 3.000

I-A-FC-115-1 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) 0.399























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I-A-FC-270-1 Natural gas-fired boiler (1.5 million Btu per hour heat input capacity) [MACT DDDDD] 1.500










I-A-FC-285-1 Natural gas-fired boiler (1.5 million Btu per hour heat input capacity) 1.500

I-A-FC-285-2 Natural gas-fired boiler (1.5 million Btu per hour heat input capacity) 1.500










































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I-A-HP-01-1 Natural gas-fired water heater (0.399 million Btu per hour heat input capacity) 0.399





























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I-A-HP-425-4 Natural gas-fired boiler (1.5 million Btu per hour heat input capacity) [MACT DDDDD] 1.500
















I-A-HP-52-3 Natural gas-fired water heater (2 million Btu per hour heat input capacity) 2.000





























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I-A-HP-56-1 Natural gas-fired boiler (2.5 million Btu per hour heat input capacity) 2.500

I-A-HP-56-2 Natural gas-fired boiler (2.5 million Btu per hour heat input capacity) 2.500
































I-A-HP-H13-1 Natural gas-fired water heater (0.285 million Btu per hour heat input capacity) 0.285














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IV. Regulatory Review Typically a full regulatory review is not presented for insignificant activities. However, given the “unusual middle ground” this

permitting action presents, a regulatory review for the sources that will be subject to the 2D .0544(m) recordkeeping condition

will be provided.

15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES All the water heaters and boilers will combust natural gas and or LPG and are subject to the 2.3 pounds per million Btu heat

input limitation Using AP-42 emission factors, the combustion of natural gas or LPG is expected to result in SO2 emissions

on the order of 5.9E-04 and 1.1 E-04 lb/MMBtu respectively. Compliance is expected by a wide margin.


The combustion of natural gas or LPG usually results (based on experience of other permitted sources at the subject facility

and in general) in visible emissions well below the 20% allowed by this rule. Compliance is expected by a wide margin.


2D .0503 states:

For residential facilities or institutions (such as military and educational) whose primary fuel burning capacity is for

comfort heat, only those fuel burning indirect heat exchangers located in the same power plant or building or otherwise

physically interconnected (such as common flues, steam, or power distribution line) shall be used to determine the total

heat input.


Combustion of natural gas and LPG, based on AP-42 emission factors, is expected to produce PM emissions much less than

those allowed by this rule.

Compliance is expected by a wide margin.


40 CFR Part 60, Subpart Dc, New Source Performance Standards for Small Industrial-Commercial-Institutional Steam

Generating Units is potentially applicable to these sources. However, all of the water heaters and boilers have heat input

capacities of less than 10 million Btu per hour, the applicability threshold pursuant to 40CFR 60.40c(a). Thus, this rule does

not apply to any of the sources in this modification.




The following is excerpted from the regulatory review for the applicability determination request. Note the referenced Table 1

of the application is the same as Table 3 above.

MCB CAMLEJ and MCAS New River are classified as a major source of HAPs and the boilers identified in Table 1 are subject to Subpart DDDDD. These boilers were constructed after 4 June 2010 and are categorized as "new" in accordance with 40 CFR 63.7490(b). The sources will burn natural gas and are categorized as subcategory (1) sources, i.e., sources designed to burn natural gas, refinery gas, or other gas 1 fuels, in accordance with §63.7499(1).

The boilers identified in Table 1 (3 above) are similar to those covered by permit condition number 2.l.F

in that they burn natural gas, have heat input capacities of less than 10.0 million Btu per hour each, and

are categorized as new sources. As a result, they are subject to the same requirements with respect to

Subpart DDDDD as the combustion sources currently covered by permit condition 2.1.F. Specifically,

the units are subject to work practice standards, recordkeeping requirements, and reporting requirements

as described in permit condition number 2.1.F.4. As new sources, they will comply with applicable

requirements upon startup as required by permit condition number 2.1.F.4.d.

The water heaters identified in Table 1 ( 3 above) have heat input capacities of less than 1.6 million Btu

per hour and, as such, are classified as hot water heaters in accordance with 40 CFR 63.7575. These hot

water heaters are not subject to Subpart DDDDD in accordance with 40 CFR 63.7491(d).

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This engineer agrees with the above statements.




The addition of the combustion sources are not expected to affect compliance with this rule. MCBCL already has similar

sources and has such a large facility footprint that it is not expected to create off-site odor problems.

15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION The subject facility is considered a major source for PSD applicability purposes. To date, separate funding of projects at

military bases has been used as justification to not consider all contemporaneous modifications as a single PSD project. As

stated in Section III above, the boilers and water heaters associated with project P1449B have potential CO2e (effectively the

same as CO2 for natural gas combustion sources) emissions greater than 75,000 tpy. The Permittee has shown that through

netting calculations (Table 2 in Section III above) the increase in emissions associated with the operation of the new boilers

and water heaters will be offset by the reduction in emissions associated with the reduced demand of boiler A-HP-1700.

The rule, 15A NCAC 2D .0544 “Prevention of Significant Deterioration Requirements for Greenhouse Gases” at paragraph

(m) provides

the owner or operator shall maintain records of annual emissions in tons per year, on a calendar year basis related to the modifications for 10 years following resumption of regular operations after the change if the project involves increasing the emissions unit's design capacity or its potential to emit the regulated NSR pollutant; otherwise these records shall be maintained for five years following resumption of regular operations after the change. The owner or operator shall submit a report to the Director within 60 days after the end of each year during which these records must be generated. The report shall contain the items listed in 40 CFR 51.166(r)(6)(v)(a) through (c). The owner or operator shall make the information documented and maintained under this Paragraph available to the Director or the general public pursuant to the requirements in 40 CFR 70.4(b)(3)(viii).

In context, the facility is adding heat input capacity but is not increasing any emission unit’s design capacity as mentioned

above. A permit condition will be placed into the permit requiring the Permittee to calculate the actual CO2e emissions as

required at 40 CFR 51.166(r)(6)(v)(a)through(c) associated with this project for 5 years. The permit will also require

recordkeeping and reporting pursuant to 2D .0544(m).

15A NCAC 02D .1100 - CONTROL OF TOXIC AIR POLLUTANTS On 28 June 2012, North Carolina Session Law 2012-91 was enacted. This law requires the DAQ to


existing source or facility, that would result in an increase in the emission of toxic air pollutants,

the Department shall review the application to determine if the emission of toxic air pollutants

from the source or facility would present an unacceptable risk to human health.

Then, if a determination is made that these sources do not pose a risk as described above, the sources are not subject to 15A

NCAC 2Q .0700 or 2D .1100.

This application represents the tenth time the facility has been modified to add and/or remove combustion sources that are

subject to a standard under 40 CFR 63 since the facility had conducted a facility-wide modeling demonstration. During each of

the permitting actions since the last facility-wide modeling demonstration (permit no. T27), a justification was made that each

of the modifications would not pose an unacceptable risk to human health. The Permittee supplied the following analysis

(Table 4 below) with the applicability determination no. 2727 and addresses all the projects under (or soon to be under)

construction, not just project P1449B.

The Permittee has simply shown what percentage the new emissions represent of the existing TAP emission limitations in the

current permit. Note that all increases are well under 0.1%. Given that the purpose of the new combustion sources is to meet

the demands that are currently being met by the current boilers, it is expected that the TAP emissions from the new sources will

be offset by the decreases in emissions from the existing large centralized boilers. Considering that the existing boilers are fired

with coal, which generally have greater TAP emission rates, and keeping all other considerations equal, it would be expected

that a decrease in TAP emissions would be associated with this project. However, given the new combustion sources will be

installed closer to the sources of demand and hence will experience less transmission losses associated with long lengths of

Page 14 of 16

steam piping as they currently exist at the facility, the net combustion efficiency is expected to increase which will also

contribute to the net reduction in TAP emission rates.

Based on the above discussion, the MACT affected sources (and indeed any of the combustion sources considered) included in

the modifications considered here since the last modeling demonstration can be exempted from 2D .1100 because it is highly

unlikely their operation poses an “unacceptable risk to human health”:

Page 15 of 16

Table 4

Page 16 of 16


Existing

Condition

No.

New

Condition

No.

Changes

Cover Letter Same • Used current shell language, updated permit numbers, dates, etc.

Permit page 1 Same • Updated permit numbers, dates, etc.

Insignificant


• Added 5 emergency generators

• Added 374 boilers and water heaters

NA Section

2.2.F Created new section and added 2 condition

NA 2.2.F.1 Added a recordkeeping and reporting requirement pursuant to 15A NCAC 2D .0544(m)

NA 2.2.F.2 Added a permit application submittal requirement pursuant to 15A NCAC 2Q .0504.



Hedrick, of the Wilmington Regional Office, the facility appeared to be in compliance with all applicable requirements. The

facility is out of compliance for the following reason as shown in the compliance inspection report. It has no bearing on the

current permit modification.

2015: NOV/NRE issued 10/2/15 for 2 Violations as follows: In violation of Clean Air Act Section

112(j) via 15A NCAC 2D .1109 – “Case-by-Case MACT” on April 7, 2015 for failing to meet the

particulate standard. In addition, MCIEAST-MCB CAMLEJ was in violation for failing to meet the

required deadline for showing compliance with the MACT emission standard for filterable

particulate matter (FPM) through stack testing, which was 180 days after the MACT compliance

deadline of May 20, 2014, or November 16, 2014. The Enforcement package (Case File No. 2015-

032) was sent to RCO 11/20/15.




NORTH CAROLINA DIVISION OF - NC

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