Title V Program on Navajo Nation An Overview

Title V Program on Navajo Nation An Overview

Route 112 North/Bldg. 2837Fort Defiance, AZ 86504

FAX: (928) 729-4313Phone: (928) 729-4096

http://www.navajonationepa.org/airq/index.html

Navajo Nation Operating Permit Program

Navajo Nation EPA

NNEPA was established in 1995 to protect human health, welfare, and the environment of the Navajo NationThe mission is to develop, implement, and enforce environmental laws and regulations with a commitment to public participation, sustainability, partnership, and restoration

NAVAJO EPA Executive Director

AIR & TOXICS Department Manager

AIR QUALITY CONTROL Program Supervisor

Section 105 Grant Program

Senior Environmental Specialist

( Air Monitoring)

Senior Environmental Specialist

( Outreach, Open Burn, New Regulations)

Environmental Specialist

( Air Monitoring, assist OPP, Outreach)

Environmental Technician

Office Specialist

Operating Permit Program

Environmental Engineer

(Title V Permit Writer/Reviewer)

Environmental Specialist

(Compliance Evaluation Inspector)

Sr. Information Systems Technician Office Specialist

Environmental Engineer, (Permit Writer, Reviewer)

NNOPP- Overview

• October 2004 and March 2006, USEPA approved a Clean Air Act (CAA) program for NNEPA to administer a Title V operating permit program (Part 71 permit program)

• Under this approval, NNOPP issues air permits to 12 facilities operating on Navajo Nation

• EPA issues PSD permits and approves final Title V permits• NNOPP performs applicability determination such as NSPS,

NESHAP’s requirements etc.,• NNOPP incorporates PSD , FIP requirements to the Title V

permit• Emission fees from the Title V facilities paid to the Navajo

Nation is used to cover the cost of operating the permit program

Navajo Nation Permit Procedure

Title V Permit

Navajo Uniform Regs NNOPR, NCAA 40 C.F.R Part 71

PSD, FIP, Acid Rain Req, NSPS,

NESHAP

Title V Permit

• A Title V permit grants a source permission to operate and includes all air pollution requirements that apply to the source, emissions limits, monitoring, record keeping, and reporting requirements in a single document.

• Major Source Threshold in Attainment Areas

• State and local permitting authority : Part 70 Permit (40 CFR part 70). • EPA issues permit to the sources on Indian land or delegates tribal

nation to issue permit : Part 71 permit ( 40 CFR part 71)

Pollutant Annual Emissions ( tons/yr)VOC, NOx, SOx, CO, PM10 100

Single HAP 10

Combination of HAPs 25

Major Source :VOC, NOx, CO, PM10, SOx > 100 tpy Single HAP > 10 tpy and Combination HAP > 25 tpy

Source submits part 71 operating permit application package to permitting authority

60days

Permitting authority determines completeness of application and request for supplement or correct application

Permitting authority develops draft permit and statement of basis

30 Day Public Notice (NNEPA Website, Newspapers, Radio, Etc) and Affected State Letter45 Day EPA Review Process

Public comments and requests for public hearing

Incorporate applicable comment(s) and issuance of permit (valid for 5 years)

Permit Revisions, Permit Renewal

Title V Permit Process

Title V Sources on the Navajo Nation

• El Paso Natural Gas Compressor stations at:1. Leupp2. Dilkon3. Navajo (Cornfields, AZ)4. Window Rock5. Gallup 6. White Rock

• Transwestern Pipeline Leupp Compressor Station• Peabody Western Coal Company• ConocoPhillips Wingate Fractionating Plant• Resolute Aneth Unit • APS Four Corners Steam Electric Station• SRP Navajo Generating Station

Part 71 Permit Application

Currently NNOPP is processing permit renewal applications for Resolute Aneth Unit, Four Corners Power Plant, Navajo Generating Station, EPNG Leupp, and EPNG Window Rock and EPNG Gallup permit renewal application is due in the near future. Facilities submit application for permit renewal not less than 6 but not more than 18 months prior to permit expiration date:

• General Information• List of Storage Tanks• Fuel Usage and Fuel data• Air Pollution Units and Control equipment data• Emission Unit Description• Insignificant Emissions• Actual Emission • Potential to Emit Calculation • Applicability Determination , Regulatory Analysis• Compliance Plan and Certification• Certification of Truth and Accuracy• Modification to Existing Permit

Application Checklist

NNOPP reviews for completeness of application using its checklist:– Timely Application [40 CFR 71.5(a)(1)(iii)]– Certification by responsible official– Standard Application Form and Identifying Information [40 CFR 71.5(c)]– Description of Source’s Processes [40 CFR 71.5(c)(2)]– Emissions-Related Information (PTE) [40 CFR 71.5(c)(3)]– Air Pollution Control Requirements [40 CFR 71.5(c)(4)]– Other Information and Exemptions [40 CFR 71.5(c)(5,6,7)]– Compliance Plan and Certification [40 CFR 71.5(c)(8,9)]– Acid Rain Forms if applicable [40 CFR 71.5(c)(10)]

NNOPP requests for additional information if required

PSD Permit

• PSD permit is required for construction of a "major" new source and for modifications at an existing "major" sources that have significant increases in emissions

• Navajo Generating Station for installation of Low NOx Burners/Over Fire Air – Increase in “CO”

• EL Paso Natural Gas Compressor Stations for facility modernization with installation of Turbines, emission limits, operational limits

Listed 28 Source Categories 100 tpy

Not Listed 250 tpy

Significant threshold 40 tpy NOx, 15 tpy PM etc.,

NGS PSD Permit Amendment

Potential To Emit

• PTE assumes 8,760 hours/year at max rated capacity except for operating hour restriction

• Criteria air pollutants, HAPs• AP 42, manufactures data, stack testing data, engineering

judgment, material balance etc.,• Permit streamlining for emission limits• PSD , FIP emission limits• Major Source Determination • PTE calculation should be included in the final permit and

summary of emissions in Statement of Basis (SOB)

Sample PTE Calculation

Emission Calculation MethodologyEl Paso Natural GasNavajo Compressor StationPotential to Emit

Emission Rate (lb/hr) Annual Emissions (tpy)hp MMBtu/hr NOx CO VOC SO2 PM10

C01C02D01D02

AUX-C01AUX-D01

4,58510,6817,3207,3201,1601,160

45.395.778.978.916.016.0

8,7608,7608,7608,7608,7608,760

6.3 lb/hr0.32 lb/MMBtu0.32 lb/MMBtu0.32 lb/MMBtu0.32 lb/MMBtu0.32 lb/MMBtu

5.084 lb/hr0.082 lb/MMBtu0.082 lb/MMBtu0.082 lb/MMBtu0.082 lb/MMBtu0.082 lb/MMBtu

0.0021 lb/MMBtu0.0021 lb/MMBtu0.0021 lb/MMBtu0.0021 lb/MMBtu0.0021 lb/MMBtu0.0021 lb/MMBtu

0.0034 lb/MMBtu0.0034 lb/MMBtu0.0034 lb/MMBtu0.0034 lb/MMBtu0.0034 lb/MMBtu0.0034 lb/MMBtu

0.0066 lb/MMBtu0.0066 lb/MMBtu0.0066 lb/MMBtu0.0066 lb/MMBtu0.0066 lb/MMBtu0.0066 lb/MMBtu

6.26 5.08 0.10 0.15 0.3030.6 7.8 0.20 0.33 0.6325.2 6.5 0.17 0.27 0.5225.2 6.5 0.17 0.27 0.525.1 1.3 0.03 0.05 0.115.1 1.3 0.03 0.05 0.11

27.4 22.3 0.4 0.7 1.3134.1 34.4 0.9 1.4 2.8110.6 28.3 0.7 1.2 2.3110.6 28.3 0.7 1.2 2.322.5 5.8 0.1 0.2 0.522.5 5.8 0.1 0.2 0.5

Emission Factor Basis: 427.7 124.9 2.9 4.9 9.7Unit C01 (natural gas turbine)NOx: PSD Permit Condition IX.D CO: PSD Permit Condition IX.DVOC: AP-42, Section 3.1 (4/00 version) SO2: AP-42, Section 3.1 (4/00 version)PM10: AP-42, Section 3.1 (4/00 version)

NOx: 1999 test data average

CO: AP-42, Section 3.1 (4/00 version) VOC: AP-42, Section 3.1 (4/00 version) SO2: AP-42, Section 3.1 (4/00 version)

Units C02, D01, C02, AUX-C01 and AUX-D01 (natural gas turbines)

PM10: AP-42, Section 3.1 (4/00 version)

EmissionUnit ID

Site Rating Hours ofOper.

Emission FactorsNOx CO VOC SO2 PM10 NOx CO VOC SO2 PM10

Applicable Requirements• New Source Performance Standards (NSPS)

– 40 CFR Part 60 – Identify by Source Category– Applicability & Designation of Affected Facility– NSPS General Provisions Subpart A– Emission limits, monitoring, testing and recordkeeping (MRR)

• National Emission Standards for Hazardous Air Pollutant (NESHAP)– 40 CFR Part 61 & Part 63– Maximum Achievable Control Technology (MACT)– Work Practice Standards– Emission limits, MRR

New rules that become applicable or might become applicable in future, like NESHAP Subpart HH for Oil and Gas Production Facilities, Subpart ZZZZ for engines, NSPS Subpart GG for turbines, MATS and BART for power plants need to be incorporated into the new permit

TCEQ FlowchartNNOPP - TCEQ Flowcharts to Determine Applicability of Rules

Title V- 40 CFR Part 71 Permit Content

I. Source IdentificationA. Company name, address, and location, etcB. Owner/ OperatorC. Process and Operation of FacilityD. SIC Code and AFS Plant Identification Number.

II. Requirements of Specific Units A. New Source Performance Standards ( NSPS General Provisions)B. Federal Implementation Plan Requirements ( FIP e.g. NGS, FCPP)C. Acid Rain RequirementsD. Operation Flexibility

III. Facility Wide or Generic Permit ConditionA. Testing RequirementsB. Recordkeeping RequirementsC. Reporting RequirementsD. Protection of Stratospheric OzoneE. Asbestos from Demolition and RenovationF. Compliance Schedule

Title V- 40 CFR Part 71 Permit Content cont’d

IV. Title V Administrative RequirementsA. Part 71 Fee PaymentB. Compliance CertificationsC. Minor Permit and Significant ModificationsD. Administrative AmendmentsE. Inspection and Entry

Statement of Basis (S.O.B): Is an Engineering DocumentF. Discussion of the Monitoring and Operational RequirementsG. Discussion of Applicability and ExemptionsH. Insignificant ActivitiesI. New Emission Units and Control EquipmentJ. Emission CalculationK. PSD Applicability

Public Outreach

Four Corners Power Plant Title V Minor Permit Modification

to install a limited use auxiliary boiler

NNEPA Air Quality Operating Permit ProgramAugust 31, 2012

Nenahnezad Chapter

Draft Permit Public Notice

• Public Notice– Location of the source, permit action, applicable

requirements– Deadline for submittal of comments– Permitting authority contact information– Opportunity to be included in NNOPP mailing list

• 30 day public notice of draft permit– Newspapers, radio announcement, NNOPP website– Mailing a copy of the notice to affected state /local/tribe– Public can view the draft permit at NNOPP office

• Administrative record of the draft permit

Public Notice on NNOPP Website Cancelling TWP Klagetoh Permit

Public Notice

TERMINATION OF PART 71 PERMIT

TRANSWESTERN PIPELINE COMPANY

LOCATED NEAR KLAGETOH, ARIZONA

Notice is hereby given that the Navajo Nation Environmental Protection Agency (NNEPA), Navajo Air Quality Control Program (NAQCP), Operating Permit Program (OPP) Section is terminating the Part 71 permit for the Transwestern Pipeline Company – Klagetoh Compressor Station. The Klagetoh Compressor Station is located at Section 18, Township 25-N, Range 28-E, 10 miles Northeast of Klagetoh, AZ on the Navajo Nation. The compressor station performs natural gas inlet separation and natural gas compression, and consists of three 5,000 horsepower electric centrifugal compressors, two emergency natural gas fired generators, and one 500-barrel storage tank. Only the generators produce air emissions, and because they are emergency generators that will not be operating more than 200 hours per year their emissions will be below the major source threshold. The facility is therefore not required to have a Part 71 permit. Instead, it is required to register with the U.S. EPA as a minor source pursuant to 40 C.F.R. ' 49.160, which it has already done. The letter terminating the Part 71 permit and all other relevant documents are available for review at NNEPA, NAQCP, OPP Section, Rt.112 North, Bldg # 2837, Fort Defiance, AZ 86504. Viewing hours are from 8:00 a.m. to 4:30 p.m., Monday through Friday (except holidays). Copies of the letter and all relevant documents can also be obtained from NNEPA’s website at: http://www.navajonationepa.org/opp/Permits.html

Factsheet for Outreach

FACT SHEET REOPENING OF A PART 71 PERMIT

NAVAJO GENERATING STATION A COAL FIRED POWER PLANT

AIR PERMIT ACTIONS NNEPA UNIFORM REGULATIONS § 206

Permit Reopen: The Navajo Nation Environmental Protection Agency (“NNEPA”) is seeking comment on the reopening of the Navajo Generating Station Part 71 Air Permit. The permit reopen incorporates the USEPA Federal Implementation Plan (FIP) and the Compliance Assurance Monitoring (CAM) plan into the existing Title V Permit. The Compliance Certification provision of the Title V Permit has also been modified in this action. Navajo Generating Station is located on the Navajo Reservation near Page, Arizona. The FIP establishes federally enforceable emissions limits for Sulfur Dioxide (“SO2”) and Particulate Matter (“PM”), as well as opacity limits for the boiler stacks, coal storage and handling, and other dust generating activities. The FIP also establishes related requirements for testing, monitoring, recordkeeping, and reporting. The PM emission limit triggered CAM, codified in 40 CFR § 64, which requires continuous monitoring of the electrostatic precipitators and wet limestone scrubbers, the PM control devices for each boiler. The FIP was promulgated March 5, 2010 in the Federal Register and became effective April 5, 2010. The Final FIP for NGS is codified in 40 CFR § 49.24.

What is the Role of the Public in Permits?

• Become knowledgeable about the operation of facilities• Ask questions, provide comments, and submit concerns• Participate during outreach and public hearing• Notify permitting authority about any issues with facility

operation• Request for:

– Navajo Air Quality Regulations– Copies of Permits– General Information– Public Workshop

• Submit comments during public comment period that relate to the permit conditions

Request for Public Hearing

• Any interested person may submit written comments and request for public hearing– Request should be in writing and state the nature of issue

• If there is significant degree of interest on the permit, NNOPP will hold a public hearing in accordance with Navajo Uniform Regulation– Issue public notice of the hearing – Develop factsheet– Hearing Moderator, Diné interpreter – Certified court reporter or recorder– Presentation of the permit action– Public comment extends until conclusion of the hearing

Response to Comments & Appeal of Permit

• Prepare responses to all comments • Justify the changes made to permit• Legal review of the responsesFinal Permit Package

Final Permit signed by NNEPA Executive Director Statement of Basis, Emission Calculation, Public Notice

and Response to CommentsAppeal of Permit

– 30 days after the final permit – Any person who filed comments on the draft permit or at

public hearing– Environmental Appeals Board Review

Response to Public Comments

Navajo Nation Environmental Protection Agency – Air Quality Control/Operating Permit Program Post Office Box 529, Fort Defiance, AZ 86504 Rt.112 North, Bldg # 2837

Telephone (928) 729-4096, Fax (928) 729-4313

Detailed Information Permitting Authority: NNEPA County: Navajo State: Arizona AFS Plant ID: 04-017-N0613

Facility: El Paso Natural Gas Company - Dilkon Compressor Station Document Type: PERMIT RENEWAL-RESPONSE TO COMMENTS

NAVAJO NATION ENVIRONMENTAL PROTECTION AGENCY

Response to Comments on the Draft Part 71 Permit Renewal to Operate

El Paso Natural Gas Company-Dilkon Compressor Station Permit # NN OP 10-004

May 7, 2012

Beginning March 16, 2012, the Navajo Nation Environmental Protection Agency (“NNEPA”) had notice published in the Arizona Daily Sun, Arizona; the Navajo Times, Arizona; the Holbrook Tribune News, Arizona and the Gallup Independent, New Mexico and broadcast over the radio through KTNN and KWRK in Window Rock, Arizona.

Comments from Citizens at the Dilkon Chapter Meeting (Comments 1 through 6) Comments made in Navajo have been translated into English

Comment 1: Manuel Shirley

Regarding the compressor station, the buildings [have] been there how long? Some are deteriorating [and] need replacing as they were built in 1960’s. Maybe these buildings can be moved away from the community? Regarding the pipeline, there are communities along the pipeline like Dilkon wanting to do economic development such as a hospital and more stores like Bashas.

Response to Comment 1:

EPNG Dilkon Compressor Station was initially constructed in 1964 and comprised a single gas turbine (Unit A-01). In 1992, EPA issued PSD permit AZP 90-3 to EPNG for the installation of one GE Frame 3 regenerative cycle turbine (Unit B-01) and one reciprocating combustion engine for auxiliary power generation (Unit Aux A-01). The draft Part 71 Permit contains emission limits, applicable requirements, and appropriate monitoring, recordkeeping, and reporting requirements.

NNOPP Permitting Experience

• Peabody Western Coal Company V/S NNEPA • NGS Permit Reopen Public Hearing• Request for waiver from annual emission testing due to

market condition from EPNG• Cancellation of Klagetoh Compressor Station Title V permit

due to transition to electrically powered turbines• New microturbines replacing older auxiliary engines to avoid

major HAP source NESHAP requirements and better reliability• Administrative amendments, permit reopening, minor permit

modification• New regulations, compliance deadline, applicability

determination• Outreach to local chapters

Thank You !

Questions ?