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 18 of 315. 3.4 EU-3 Small Gas-Fired Boilers and One Boiler withdiesel Standby(a) Visible EmissionsBoth WAC 173-400-040(1) and Puget Sound Clean Air Agency Regulation I,Section 9.03 standards are 20% opacity and apply to the fuel burning equipment at ToddPacific Shipyards. Although the permit lists all these requirements together, Todd PacificShipyards must comply with each.The fuel burning equipment at Todd Pacific Shipyards can only burn natural gas exceptone boiler that has diesel fuel as a standby. The monitoring method requires checking forvisible emissions once per quarter, and the frequency was determined based on thefollowing.1) Compliance. None of the fuel burning equipment at Todd Pacific Shipyards normallyhas visible emissions. The Puget Sound Clean Air Agency has inspected this facilityat least annually since 1997 and has not identified opacity issues at the fuel burningequipment, nor has Todd Pacific Shipyards. Therefore, we conclude that it isgenerally in compliance with the opacity requirement and the margin of compliance islarge. In addition, the monitoring method is designed so that Todd Pacific Shipyardswill take corrective action before a violation occurs, further enhancing the compliancemargin.2) Variability of process and emissions. The equipment burns natural gas. The steamand heat demand at Todd Pacific Shipyards fluctuates throughout the day and fromseason-to-season, causing variations in load on the equipment. These boilers are onlyshut down completely for annual maintenance or if a problem occurs where morefrequent maintenance is required. Typically, one boiler is in operation while the othertwo are in "hot stand-by" mode, meaning the unit is still under pressure and theburner modulates to maintain a set pressure level. Once per year, the boilers aretaken down to undergo pressure vessel testing. However, the demand is verypredictable and seldom changes quickly.3) Environmental impacts of problems. Observed opacity is generally related toemissions of particulate matter or finely divided liquid droplets. The fuel burningactivities at Todd Pacific Shipyards typically do not generate significant quantities ofparticulate matter, typically less than one ton per year. Hence, the environmentalimpacts of the emissions are small especially considering the amount of land onwhich the facility is located. A maintenance problem is unlikely to result inemissions that would have a significant environmental impact.4) Technical considerations. Although the opacity standard is 20%, the monitoringmethod requires corrective action, or Reference Method testing, upon detection ofvisible emissions. This will provide an added margin of compliance.
Statement of Basis forVigor Shipyards, Inc.Administrative Amendment: June 13, 2011 Page 19 of 31(b) Fuel Burning ParticulatePuget Sound Clean Air Agency Regulation I, Section 9.09 also limits particulateemissions to 0.05 gr/dscf corrected to 7% oxygen from fuel burning equipment (i.e.,equipment that produces hot air, hot water, steam, or other heated fluids by externalcombustion of fuel) combusting natural gas. WAC 173-400-050(1) limits particulateemissions to 0.1 gr/dscf corrected to 7% O 2 from all combustion units (i.e., units usingcombustion for steam production or other process requirements, excluding open burning).Todd Pacific Shipyards burns only pipeline grade natural gas. It can be shown for SO 2 ,that if fuels are properly burned, Todd Pacific Shipyards is incapable of violating thisstandard while complying with the other requirements such as the fuel content andopacity requirements. Improper fuel burning that would result in high particulateemissions would also cause opacity problems and would be detected by the Fuel BurningOpacity monitoring requirement.(c) Fuel StandardsThe permit does not contain Puget Sound Clean Air Agency Regulation I, Section 9.08(a)and RCW, 70.94.610 “Burning used fuel oil in land-based facilities” because ToddPacific Shipyards does not and cannot burn such oil.(d) Federal StandardsPuget Sound Clean Air Agency Regulation I, Section 6.11 and WAC 173 400-115 bothadopt by reference the federal new source performance standards in 40 CFR Part 60.5. 3.5 EU-4 Gasoline Underground Storage TankTodd Pacific Shipyards has one underground gasoline storage tank used for fuelequipment used on site. Because, the motor vehicles are used on site and not on publicroads, the tank is not subject to Regulation II Section 2.07. However, the undergroundgasoline storage tank is subject to the registration (Regulation I Article 5) and new sourcereview (Regulation I Article 6). The notice of construction approval required the sourceto inspect the stage 1 vapor recovery equipment after each fuel delivery. Theunderground gasoline storage tank at Todd Pacific Shipyards can only be used for yardequipment that is not licensed to travel on public roadways.5. 3.6 EU-5 Ground Water Remediation EquipmentOver the years, Todd Pacific Shipyards’ soil has been contaminated with solvents. Thegroundwater remediation system draws water from all areas at the facility. Water isextracted and a solvent such as benzene is separated from the water. Air from thestripper is passed through an afterburner where the benzene and other solvents aredestroyed (turned into water and carbon dioxide). Less than 25,000 gallons of waterpassed through the system. The after burner operates at greater than 1,400 degrees F.Currently the system is shut down because the afterburner has failed and cannot be
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Statement of Basis Vigor Shipyards Inc. - Puget Sound Clean Air ...

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