Statement of Basis Vigor Shipyards Inc. - Puget Sound Clean Air ...

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Statement of Basis forVigor Shipyards, Inc.Administrative Amendment: June 13, 2011 Page 12 of 31Sound Clean Air Agency reserves the right to evaluate the maintenance of each piece ofequipment to determine if it has been maintained in good working order.5. 2.7 Requirement I.A.9In accordance with Puget Sound Clean Air Agency Regulation I, Section 7.09(b), ToddPacific Shipyards is required to develop and implement an Operation and MaintenancePlan (O&M Plan) to assure continuous compliance with Puget Sound Clean Air AgencyRegulations I, II, and III. The requirement specifies that the plan shall reflect goodindustrial practice, but does not define how to determine good industrial practice. Toclarify the requirement, the Puget Sound Clean Air Agency added that, in most instances,following the manufacturer’s operations manual or equipment operational schedule,minimizing emissions until the repairs can be completed and taking measures to preventrecurrence of the problem may be considered good industrial practice. This language isconsistent with a Washington Department of Ecology requirement in WAC 173-400-101(4). The Puget Sound Clean Air Agency also added language establishing criteria fordetermining if good industrial practice is being used. These include monitoring results,opacity observations, review of operations and maintenance procedures, and inspectionsof the emission unit or equipment. The Puget Sound Clean Air Agency added thiswording in response to Washington State court decision, Longview Fibre Co. v. DOE, 89Wn. App. 627 (1998), which held that similar wording was not vague and gave sufficientnotice of the prohibited conduct.Puget Sound Clean Air Agency Regulation I, Section 7.09(b) also requires Todd PacificShipyards to promptly correct any defective equipment. However, the underlyingrequirement in most instances does not define “promptly”; hence for significant emissionunits and applicable requirements that Todd Pacific Shipyards has a reasonablepossibility of violating or that a violation would cause an air quality problem, the PugetSound Clean Air Agency added clarification that “promptly” usually means within 24hours. For many insignificant emission units and equipment not listed in the permit,“promptly” cannot be defined because the emission sources and suitable pollution controltechniques vary widely, depending on the contaminant sources and the pollution controltechnology employed. However, the permit identifies a means by which to identify ifTodd Pacific Shipyards is following good industrial practice.As described in Section V.Q, Todd Pacific Shipyards must report to the Puget SoundClean Air Agency any instances where it failed to promptly repair any defectiveequipment, both equipment that received approval from the Agency and that which didnot. In addition, Todd Pacific Shipyards has the right to claim certain problems were aresult of an emergency (Section V.S) or unavoidable (Section V.T).Following these requirements demonstrates that Todd Pacific Shipyards has properlyimplemented the O&M Plan, but it does not prohibit the Puget Sound Clean Air Agencyor EPA from taking any necessary enforcement action to address violations of theunderlying applicable requirements after proper investigation. However, not followingits own O&M Plan is an indication that Todd Pacific Shipyards was not using goodindustrial practice.
Statement of Basis forVigor Shipyards, Inc.Administrative Amendment: June 13, 2011 Page 13 of 315. 2.8 Requirement I.A.10Puget Sound Clean Air Agency Regulation I, Section 9.10 specifies that HCl emissionsshall not exceed 100 ppm (dry) corrected to 7% O 2 for combustion sources. Since ToddPacific Shipyards burns only pipeline grade natural gas and distillate fuel oil and theother processes do not use chlorine in a form likely to emit HCl, it is incapable ofviolating this standard while complying with the other requirements in the permit.Refer to the “Conversion Factors for Concentration” table in Section 2 of ReferenceMethod 19 to compute value for C d . Note that this factor is equal to molecular weight ofthe pollutant divided by 10 6 , and then divided by 385.3 ft 3 per mole. The conversionfactor for HCl is 36.4610 -6 /385.3 ft 3 = 9.46310 -8 lb/dscf-ppmdv. One part per millionof HCl is equivalent to 9.46310 -8 lb HCL per dry standard cubic foot of stack gas.Residual oil:EquationEquation 1According to AP-42, Section 1.3:• Burning 1,000 gallons of No. 6 “residual” oil produces 0.347 pound ofchloride. Assume all of the chloride is emitted in the form of hydrogenchloride.• There are 150 MMBtu/10 3 gallons of No. 6 oil.Equation converts the emission factor for chloride in Table 1.3-11 frompounds of HCl per 1,000 gallons of oil burned to pounds per million Btu.3lb10 gallbE 0.347 0.3470.00231310 gal 150 MMBtu MMBtuAccording to Table 19.1 of EPA Reference Method 19:• Burning a million Btu of oil produces 9,190 dry standard cubic feet ofstack gas.• One part per million HCl is equivalent to 9.46310 -8 pound of HydrogenChloride per dry standard cubic foot.Equation 1 is derived from Equation 19-1 from EPA Reference Method 19,which may be used to calculate parts per million HCl, corrected to 7% O 2 ,from HCL emissions in lb/MMBtu.Cd E20 .9%O2( dry)20.9 7 20.9Fd 0.00231lbMMBtu8MMBtudscf ppmdv20.9dscf lb9,1909.4610Therefore, based on the AP-42 emission factor for HCl (expressed aschloride) from new residual oil, the concentration of HCl in the boilerexhaust will be less than 2% of the regulatory limit of 100 ppmdv,corrected to 7% O 2 , 1.77ppmdv
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