Department of Energy Richland Operations Office

P.O. Box 550 Richland, Washington 99352

17-ESQ-002 1

Mr. Tim Hamlin, Director Office of Air and Waste, OAW-150 U.S. Environmental Protection Agency Region 10 1200 Sixth A venue, Suite 900 Seattle, Washington 98101

DEC .1 2 2016

Ms. Alexandra K. Smith, Program Manager Nuclear Waste Program Washington State Department of Ecology 3100 Port of Benton Richland, Washington 99354

Addressees:

~-entral Files A,' r r lie Name: I ~ rr Cross Reference: __:

RECEIVED

DEC 1 9 2016

Depar+JT'lent of Ecology NWP • Ricn and

TRANSMITTAL OF NOTIFICATION OF OFF-PERMIT CHANGE, PERMIT NUMBER 00-05-006, RENEW AL 2, FOR ADDITION OF SEASONAL SOURCE RECIPROCATING INTERNAL COMBUSTION ENGINES USED AT THE 400 AREA, CENTRAL WASTE COMPLEX (CWC), AND SOLID WASTE OPERATIONS COMPLEX (SWOC) ADMINISTRATIVE OFFICES

This letter transmits the subject Notification of Off-Permit Change to register seasonally used diesel powered light plants and generator sets at three aggregated use areas at the 400 Area (Attachment 1), CWC (Attachment 2), and SWOC Administrative Offices (Attachment 3) to the Hanford Site Air Operating Permit (AOP). All attachments have been prepared in accordance with the Washington Administrative Code 173-401-724. All attachments are submitted to the Washington State Department of Ecology for its administration of the AOP and to the U.S. Environmental Protection Agency, Region l 0, as part of the notification process for off-permit changes as outlined in the AOP.

If you have any questions, please contact me, or your staff may contact Jeffrey A. Frey, Assistant Manager for Safety and Environment, on (509) 376-7727.

ESQ:ETF

5ly, s.ct~ Doug ~oop Mana;e~~J'

Attachments

cc w/attachs: See page 2

Addressees 17-ESQ-0021

cc w/attachs: Dennis A. Faulk, EPA Phil M. Gent, Ecology Jim McAuley, EPA Administrative Record Environmental Portal, 03-35

cc w/o attachs: Gabriel Bohnee, NPT Frank J. Carleo, CHPRC Gary M. Fritz, MSA Russell Jim, YN Reed A. Kaldor, MSA Paul T. Karschnia, CHPRC Rod Skeen, CTUIR

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ATTACHMENT I

NOTIFICATION OF OFF-PERMIT CHANGE PERMIT NUMBER: 00-05-006, RENEW AL 2

400 AREA WATER SYSTEM

Consisting of 4 pages, including this cover page

NOTIFICATION OF OFF-PERMIT CHANGE Permit Number: 00-05-006, Renewal 2

This notification is provided to the Washington State Department of Ecology, as a notice of an off-permit change described as fo llows.

The following changes are allowed pursuant to the Washington Administrative Code (WAC) 173-401-724(1 ), WAC 173-40 I-724(2), and WAC 173-401 -724(6): 1. Change is not speci fically addressed or prohibited by the Air Operating Permit (AOP) terms and

conditions; 2. Change does not weaken the enforceability of the existing AOP conditions; 3. Change is not a Title I modification or subject to the acid rain requirements under Title IV of the

FCAA; 4 Change meets all applicable requ irements and does not violate an existing permit term or condition; 5 Change has complied with applicable preconstruction review requirements established pursuant to

RCW 70.94.152.

Description of the chane:e Diesel engines as described below are used to power seasonal usage light plants and/or generators at the 400 Area Water System (WS). The area is defined as within the boundary of the chain link fence surrounding the Fast Flux Test Facility and Maintenance and Storage Fac ilities. The aggregate maximum power output of stationary engines in the 400 Area WS will not exceed 142.7 horsepower, as converted from an aggregate heat input of 1,000,000 Btu/hr. Accordingly, this change is exempt from new source review and notice of construction req uirements per WAC 173-400-110(4)(c)(iv).

Aggregated Area identifier: 400 Area Water System (WS)

Light Plant Engines:

• Engine Usage: Non-Emergency Compression Ignition • Model Year: 2008 or later • Maximum Power Output: < 19kW (25 horsepower) • Cylinder displacement: < IO I iters • Regulation: 40 CFR 60, Subpart 1111

Generator Engines:

• Engine Usage: Non-Emergency Compression Ignition • Model Year: 2008 or later • Maximum Power Output: 19 :5 kW < 37 • Cylinder displacement: < IO liters • Regulation: 40 CFR 60, Subpart III!

The addition of an aggregated point source area for seasona lly used compression ignition engine driven light plants and generator sets to Table 1.4 of the Hanford AOP, 00-05-06 Renewal 2, Revision B is needed to support the 400 Area WS maintenance operations. The aggregate horsepower of the emission unit non-emergency use engines will not exceed 142.7 Hp. The engines are factory certified to meet the U.S. Environmental Protection Agency Emissions Requirements (40 CFR 60.4204(b)). The engines will be operated and maintained in accordance with the manufacturer's written emission related instructions to meet the 40 CFR 60 Subpart 1111 Requirements.

Date of change: (To be provided in the agency approval order.)

Effective upon approval

Describe the emissions resultin2 from the chan2e: The engine complies with the 40 CFR 60 New Source Performance Standards (NSPS) as it is certified by the manufacturer as meeting the 40 CFR I 039. 10 I Table I Standards and will be installed, operated and maintained in accordance with the manufacturer's instructions. Low sulfur diesel fuel ( less than 0.001 5%) will be used to power the engine. The emiss ions that result from the operation of this engine comply with the emission limits establ ished in 40 CFR 60.4201 (40 CFR I 039.625) and WAC 173-400-040.

Rated Power Exhaust( 2/kw-hr) Opacity(%)

Class N MHC NO, NMHC+NOx co PM 8S KW< l9 NIA NIA 7.5 6.6 0.40 20

( I I '.SHP<25 19SKW<37 NIA NIA 4.7 5.5 0.03 20 (25S HP<50)

Describe the new applicable requirements that will apply as a result of the change: Note: 40 CFR 63 Subpart ZZZZ applies to the engines deta iled in this change. However, per 40 CFR 63 .6590(e)(7), the applicable requirements of 40 CFR 63 Subpart ZZZZ are met by meeting the applicable requirements of 40 CFR 60 Subpart 1111.

Requirement Citation: NSPS Subpart IIII

Condition: ( I) Non-methane hydrocarbons (NMHC) and nitrogen oxides (NOX) emission limit of 9 .5 g/KW-hr

(2) Particulate matter emission limit of 0.80 g/K W-hr (3) Carbon Monoxide (CO) emission limit of 6.6 g/kW-hr for the light plants

and 5.5 g/kW-hr for the generator sets Compliance Requirement: Compliance will be determined by operating and maintaining the engine in

accordance with the manufacturer's recommendations or instructions. Required Records: (I ) Manufacturer' s maintenance or operation manual

(2) Documentation of maintenance performed State-Only No Calculation Model Not applicable.

Condition: Use of fuel per 40 CFR 60.4207 (b) Periodic Monitoring: Compliance will be demonstrated by use of fuel containing no greater than

0.00 15 weight percent sulfur ( 15 parts per million by weight). Test Method: Not applicable. Test Frequency: Not applicable. Required Records: Vendor certification for diesel fuel sulfur content for a ll purchases. State-Only No. Calculation Model Not applicable .

Condition:

Periodic Monitoring:

Test Method: Test Frequency: Required Records: State-Only Calculation Model

Maintain an engine inventory with no more than an aggregate of 142.7 horsepower Inventory of engines used seasonally to support the 400 Area WS operations. At a minimum; record the current and past engines used with the date the engine was located in the 400 Area and the date it was removed from the 400 Area.

Not applicable. ot applicable.

Engine Inventory. No. Not applicable.

For this emission unit the 40 CFR 60 Subpart 1111 requirements that apply are: a) 40 CFR 60.4204(b) non-emergency engine emission standards- The engines have been certified by the

manufacturer to comply with the emission standards contained in 40 CFR 60.420 I b) 40 CFR 60.4206 li fe time emission standard applicability - The manufacturer 's emission-related written

instructions will be followed and records o f conducted maintenance will be retained for each engine covered by this change. Each engine will be operated and maintained according to the manufacturer's recommendations.

c) 40 CFR 60.4207 (a) & (b) diesel fuel requirements - The current Hanford diesel fuel specification meets the 40 CFR 80.510 requirements.

d) 40 CFR 60.4209(b) monitoring requirements - These engines are not equipped with a diesel particulate filter therefore backpressure monitoring is not required.

e) 40 CFR 60.4211 (a) compliance requfrements - The engines and control devices will be operated and maintained according to the manufacturer's emission-related written instructions and only those changes to emission-related settings that are permitted by the manufacturer will be made.

f) 40 CFR 60.4212 test methods - The engines have been certified by the manufacturer to comply with the emission standards contained in 40 CFR 60.420 I

g) 40 CFR 60.4214 notification, reporting and recordkeeping requirements - These engines are not subject to this section but will follow the reporting requirements outlined in Table 8 to Subpart III of Part 60.

ATTACHMENT 2

NOTIFICATION OF OFF-PERMIT CHANGE PERMIT NUMBER: 00-05-006, RENEW AL 2 CENTRAL WASTE COMPLEX FACILITY

Consisting of 5 pages, including this cover page

NOTIFICATION OF OFF-PERMIT CHANGE Permit Number: 00-05-006, Renewal 2

This notification is provided to the Washington State Department of Ecology, as a notice of an off-permit change described as fo llows.

The following changes are allowed pursuant to WAC 173-401 -724( I), WAC 173-40 I-724(2), and WAC I 73-401-724( 6): I. Change is not specifically addressed or prohibited by the Air Operating Permit (AOP) terms and

conditions; 2. Change does not weaken the enforceability of the existing AOP conditions; 3. Change is not a Title I modification or subject to the acid rain requ irements under Title IV of the

FCAA; 4. Change meets all applicable requirements and does not violate an existing permit term or condition; 5. Change has complied with appl icable preconstruction review requirements established pursuant to

RCW 70.94. 152.

Description of the chan2e: Diesel engines as described below are used to power seasonal usage light plants at the Central Waste Complex (CWC) Facility. The area is defined as with in the boundary of the chain link fence surrounding the CWC Facility. The aggregate maximum power output of stationary engines in the CWC Area will not exceed 142.7 horsepower, as converted from an aggregate heat input of 1,000,000 Btu/hr. Accordingly, this change is exempt from new source review and notice of construction requirements per Washington Admin istrative Code (WAC) 173-400-1 10(4)(c)(iv).

Aggregated Area identifier: CWC Facility

Existing Light Plant Engines:

• Engine Usage: Non-Emergency Compression Ignition • Number: limited to two units not to exceed an aggregate total of 20 horsepower • Model Year: Prior to 7/1 1/2005 • Maximum Power Output: < 9kW ( 12 horsepower) • Cylinder displacement: <IO I iters • Regulation: 40 CFR 63, Subpart ZZZZ

New Light Plant Engines:

• Engine Usage: Non-Emergency Compression Ignition • Model Year: 2005 or later • Maximum Power Output: 8 :S kW < 19 (HP < 25) • Cylinder displacement: <IO liters • Regulation: 40 CFR 60, Subpart III!

The addition of an aggregated point source area for seasonally used compression ignition engine driven light plants to Table 1.4 of the Hanford AOP, 00-05-06 Renewal 2, Revision B is needed to support the CWC Facility operations. The aggregate horsepower of the emission unit non-emergency use engines will not exceed 142.7 Hp. The two existing light plant engines that were purchased in 1994 are required to only meet the Maximum Achievable Control Technology 40 CFR 63 Subpart ZZZZ maintenance requirements. The new engines are factory certified to meet the U.S. Environmental Protection Agency

Emissions Requirements (40 CFR 60.4204(b)). The engines will be operated and maintained in accordance with the manufacturer·s written emission related instructions to meet the 40 CFR 60 Subpart rm Requirements. Date of change: (To be provided in the agency approval order.)

Effective upon approval.

Describe the emissions resulting from the change: The existing engines were installed prior to the July 11, 2005, 40 CFR 60 Subpart IIII applicability date and are not subject to the New Source Performance Standards (NSPS). They will be operated and maintained in accordance with the 40 CFR 63 Subpart ZZZZ requirements. Low sulfur diesel fuel (less than 0.0015%) will be used to power the engines.

The new engines comply with the 40 CFR 60 New Source Performance Standards, as they are certified by the manufacturer as meeting the 40 CFR 60 Subpart IIII Table I standards and will be installed, operated and maintained in accordance with the manufacturer's instructions. Low sulfur diesel fuel (less than 0.00 I 5%) will be used to power the engines. The emissions that result from the operation of these engines comply with the emission limits established in 40 CFR 60.4201 (40 CFR I 039.625) and WAC 173-400-040.

Rated Power Exhaust(g/kw-hr) Opacity(%)

Class NMHC NO, NMHC+NOx co PM 8~KW< l9

NIA NIA 9.5 6.6 0.80 20 ( I J<HP<25

Describe the new applicable requirements that will apply as a result of the change: Note: 40 CFR 63 Subpart ZZZZ applies to the engines detailed in this change. However, per 40 CFR 63.6590(eX7), the applicable requirements of 40 CFR 63 Subpart ZZZZ are met by meeting the app licable requirements of 40 CFR 60 Subpart 1111.

EXISTING LIGHT PLANTS o more than two engines with an aggregate of20 horsepower may power light plants used in the CWC

Area Requirement Citation: NESHAP Subpart ZZZZ

Condition: (I) Operate and maintain the engine in accordance with Manufacturer's recommendations or instructions

(2) Change oi l and filter every 500 hours of operation or annually whichever comes first

(3) Inspect air cleaner every 1,000 hours of operation or annually whichever comes first

( 4) Inspect all hoses and belts every 500 hours of operation or annually whichever comes first. and replace as necessary

Compliance Requirement: Compliance will be determined by operating and maintaining the engine in accordance with the manufacturer's recommendations or instructions.

Required Records: (I) Manufacturer' s maintenance or operation manual (2) Documentation of maintenance performed

State-Only No Calculation Model Not applicable.

Condition: Use of fuel per 40 CFR 60.4207 (b) Periodic Monitoring: Compliance will be demonstrated by use of fuel containing no greater than

Test Method: Test Frequency: Required Records: State-Only Calculation Model Condition:

Periodic Monitoring:

Test Method: Test Frequency: Required Records: State-Only Calculation Model NEW LIGHT PLANTS

0.0015 weight percent sulfur ( 15 parts per million by weight). Not appl icable. Not appl icable. Vendor certification for diesel fue l sulfur content for all purchases. No. Not applicable. Maintain an engine inventory with no more than an aggregate of20 horsepower Inventory of engines used seasonally to support the CWC operations. At a minimum; record the current and past engines used with the date the engine was located in the CWC Area and the date it was removed from the CWC Area.

Not appl icable. Not applicable. Engine Inventory. No. Not applicable.

No more than an aggregate of 122.7 horsepower may be used to power light plants used in the CWC Area Requirement Citation: NSPS Subpart llII

Condition: ( I) Non-methane hydrocarbons (NMHC) and nitrogen oxides (NOX) emission limit of9.5 g/KW-hr

(2) Particulate matter emission limit of 0.80 g/K W-hr (3) Carbon Monoxide (CO) emission limit of 6.6 g/kW-hr for the light plants

Compliance Requirement: Compliance wi ll be determined by operating and maintaining the engine in accordance with the manufacturer' s recommendations or instructions.

Required Records:

State-Only Calculation Model

Condition: Periodic Monitoring:

Test Method: Test Frequency: Required Records: State-Only Calculation Model

(I) Manufacturer' s maintenance or operation manual (2) Documentation of maintenance performed No Not applicable.

Use of fuel per 40 CFR 60.4207 (b) Compliance will be demonstrated by use of fuel containing no greater than 0.001 5 weight percent sulfur ( 15 parts per million by weight). Not applicable. Not applicable. Vendor certification for diesel fuel sulfur content for all purchases. No. Not applicable.

- - - ---------------------------------------------

Condition:

Periodic Monitoring:

Test Method: Test Frequency: Required Records: State-Only Calculation Model

Maintain an engine inventory with no more than an aggregate of 122. 7 horsepower Inventory of engines used seasonally to support the ewe operations. At a minimum; record the current and past engines used with the date the engine was located in the ewe Area and the date it was removed from the ewe Area. Not applicable. Not applicable. Engine lnventory. No. Not aoolicable.

For this new light plants in this emission unit the 40 CFR 60 Subpart 1111 requirements that apply are: a) 40 CFR 60.4204(b) non-emergency engine emission standards- T he engines have been certified by the

manufacturer to comply with the emission standards contained in 40 CFR 60.420 1 b) 40 CFR 60.4206 lifetime emission standard applicability - The manufacturer's emission-related written

instructions will be followed and records of conducted maintenance will be retained for each engine covered by this change. Each engine will be operated and maintained according to the manufacturer's recommendations.

c) 40 CFR 60.4207 (a) & (b) diesel fuel requirements - The current Hanford diesel fuel specification meets the 40 CFR 80.5 10 requirements.

d) 40 CFR 60.4209(b) monitoring requirements - These engines are not equipped with a diesel particulate fil ter therefore backpressure monitoring is not required.

e) 40 CFR 60.4211 (a) compliance requirements - The engines and control devices will be operated and maintained according to the manufacturer's emission-related written instructions and only those changes to emission-related settings that are permitted by the manufacturer wi ll be made.

f) 40 CFR 60.42 12 test methods - The engines have been certified by the manufacturer to comply with the emission standards contained in 40 CFR 60.420 I

g) 40 CFR 60.4214 notification , reporting and recordkeeping requirements - These engines are not subject to this section but will follow the reporting requirements outlined in Table 8 to Subpart lll of Part 60.

ATTACHMENT 3

NOTIFICATION OF OFF-PERMIT CHANGE PERMIT NUMBER: 00-05-006, RENEW AL 2

200 WEST SOLID WASTE OPERATIONS COMPLEX

Consisting of 4 pages, including this cover page

NOTIFICATION OF OFF-PERMIT CHANGE Permit Number: 00-05-006, Renewal 2

This notification is provided to the Washington State Department of Ecology, as a notice of an off-permit change described as follows.

The following changes are allowed pursuant to Washington Administrative Code (WAC) 173-401-724( I), WAC 173-401-724(2), and WAC 173-401-724(6): I. Change is not specifically addressed or prohibited by the Air Operating Permit (AOP) terms and

conditions; 2. Change does not weaken the enforceability of the existing AOP conditions; 3. Change is not a Title I modification or subject to the acid rain requirements under Title IV of the

FCAA; 4. Change meets all applicable requirements and does not violate an existing permit term or condition; 5. Change has complied with applicable preconstruction review requirements established pursuant to

RCW 70.94. 152.

Description of the chanee: Diesel engines as described below are used to power seasonal usage light plants at the 200W Solid Waste Operations Complex (SWOC) Administrative Offices. The area is defined as a rectangular area south of MO438, West of Dayton Avenue, East ofMO743 and North of2405W. The aggregate maximum power output of stationary engines in the 200W SWOC Administrative Office Area will not exceed 142.7 horsepower, as converted from an aggregate heat input of 1,000,000 Btu/hr. Accordingly, this change is exempt from new source review and notice of construction requirements per WAC 173-400-110( 4)( c)(iv).

Aggregated Area identifier: 200W SWOC Administrative Offi~es

Light Plant Engines:

• Engine Usage: Non-Emergency Compression Ignition • Model Year: 2005 or later • Maximum Power Output: 8~ kW < 19 (25 horsepower) • Cylinder displacement: < IO liters • Regulation: 40 CFR 60, Subpart 1111

The addition of an aggregated point source area for seasonally used compression ignition engine driven light plants and generator sets to Table 1.4 of the Hanford AOP, 00-05-06 Renewal 2, Revision Bis needed to ensure adequate lighting during winter months for personnel working in the 200W SWOC Administrative Offices. The aggregate horsepower of the emission unit non-emergency use engines will not exceed 142.7 Hp. The engines are factory certified to meet the U.S. Environmental Protection Agency Emissions Requirements (40 CFR 60.4204(a)). The engines will be operated and maintained in accordance with the manufacturer's written emission related instructions to meet the 40 CFR 60 Subpart IIII requirements.

Date of chanee: (To be provided in the agency approval order.)

Effective upon approval.

Describe the emissions resultine from the change: The engine complies with the 40 CFR 60 New Source Performance Standards (NSPS) as it is certified by the manufacturer, as meet ing the 40 CFR 60 Subpart IIII Table I Standards and will be installed, operated and maintained in accordance with the manufacturer's instructions. Low sulfur diesel fuel (less than 0.00 15%) will be used to power the engine. The emissions that result from the operation of this engine comply with the emission limits established in 40 CFR 60.420 I (40 CFR I 039.625) and WAC 173-400-040.

Rated Power Exhaust(J!/kW-hr) Opacity(%) Class NMHC NO, NMHC+NO, co PM

8:'.SkW< l9 IA IA 9.5 6.6 0.80 20

(I lg{P<25)

Describe the new applicable requirements that w ill apply as a result of the change: ote: 40 CFR 63 Subpart ZZZZ applies to the engines detai led in this change. However, per 40 CFR

63.6590(e)(7), the applicable requirements of 40 CFR 63 Subpart ZZZZ are met by meeting the aoolicable requirements of 40 CFR 60 Subpart 1111. Requirement Citation: NSPS Subpart Illl

Condition: ( I) Non-methane hydrocarbons (NMHC) and nitrogen oxides (NOX) emission limit of9.5 g/KW-hr

(2) Particulate matter emission limit of0.80 g/KW-hr (3) Carbon Monoxide (CO) emission limit of 6.6 g/kW-hr

Compliance Requirement: Compliance will be determined by operating and maintaining the engine in accordance with the manufacturer' s recommendations or instructions.

Required Records: (I) Manufacturer's maintenance or operation manual (2) Documentation of maintenance performed

State-Only No Calculation Model Not applicable.

Condition: Use of fuel per 40 CFR 60.4207 (b) Periodic Monitoring: Compliance will be demonstrated by use of fuel containing no greater than

0.0015 weight percent sulfur ( 15 parts per million by weight). Test Method: Not applicable. Test Frequency: Not applicable. Required Records: Vendor certification for diesel fuel sulfur content for a ll purchases. State-Only No. Calculation Model Not applicable.

I

L

Condition:

Periodic Monitoring:

Test Method: Test Frequency: Required Records: State-Only Calculation Model

Maintain an engine inventory with no more than an aggregate of 142.7 horsepower. Inventory of engines used seasonally to support the 200W SWOC Administrative Offices operations. At a minimum; record the current and past engines used with the date the engine was located in the 200W SWOC Administrative Offices Area and the date it was removed from the 200W SWOC Administrative Offices Area.

Not applicable. Not applicable. Engine Inventory. No. Not applicable.

For this emission un it the 40 CFR 60 Subpart 1111 requirements that apply are: a) 40 CFR 60.4204(b) non-emergency engine emission standards- The engines have been certified by the

manufacturer to comply with the emission standards contained in 40 CFR 60.420 I. b) 40 CFR 60.4206 lifetime emission standard applicability - The manufacturer's emission-related written

instructions will be followed and records of conducted maintenance will be retained for each engine covered by this change. Each engine will be operated and maintained according to the manufacturer's recommendations.

c) 40 CFR 60.4207 (a) & (b) diesel fuel requirements - The current Hanford diesel fuel specification meets the 40 CFR 80.5 10 requirements.

d) 40 CFR 60.4209(b) monitoring requirements - These engines are not equipped with a diesel particulate filter therefore backpressure monitoring is not required.

e) 40 CFR 60.42 11 (a) compliance requirements - The engines and control devices will be operated and maintained according to the manufacturer's emission-related written instructions and only those changes to emission-related settings that are permitted by the manufacturer wi ll be made.

f) 40 CFR 60.4212 test methods - The engines have been certified by the manufacturer to comply with the emission standards contained in 40 CFR 60.420 I.

g) 40 CFR 60.4214 notification, reporting and recordkeeping requirements - These engines are not subject to this section but will follow the reporting requirements outlined in Table 8 to Subpart Ill of Part 60.