Air Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
B1833 / STAFF REPORT / MI-ROP-B1833-2013a
MARQUETTE BOARD OF LIGHT AND POWER
SHIRAS STEAM PLANT
SRN: B1833
Located At:
400 East Hampton, Marquette, Michigan 49855
Permit Number:MI-ROP-B1833-2013a
Staff Report Date:April 22, 2013
Amended Date:March 7, 2016
This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451). Specifically, Rule 214(1) requires that the Michigan Department of Environmental Quality, Air Quality Division, prepare a report that sets forth the factual basis for the terms and conditions of the Renewable Operating Permit.
TABLE OF CONTENTS
APRIL 22, 2013 - STAFF REPORT
JUNE 17, 2013 - STAFF REPORT ADDENDUM
SEPTEMBER 26, 2013 - STAFF REPORT ADDENDUM
MARCH 7, 2016 - STAFF REPORT FOR RULE 217(2) REOPENING
APRIL 26, 2016 - STAFF REPORT ADDENDUM FOR RULE217(2) REOPENING
JUNE 16, 2016 - STAFF REPORT ADDENDUM FOR RULE217(2) REOPENING
/ Michigan Department of Environmental QualityAir Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
B1833 /
APRIL 22, 2013 - STAFF REPORT
/ MI-ROP-B1833-2013Purpose
Major stationary sources of air pollutants, and some non-major sources, are required to obtain and operate in compliance with a Renewable Operating Permit pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a stationary source’s applicable requirements and compliance with them by consolidating all state and federal air quality requirements into one document.
This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the draft permit terms and conditions including citations of the underlying applicable requirements, an explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the stationary source.
The Air Quality Division issued present ROP #MI-ROP-B1833-2006to the Marquette Board of Light and Power effective July 1, 2006. This ROP has an expiration date of June 30, 2011. This ROP has been modified once. On November 5, 2010, the Air Quality Division received application #201000103 for renewal of the ROP for the Shiras Steam Plant. This application was received within the time frame specified in Rule 210(7), and was considered timely and administratively complete. Therefore, pursuant to Rule 217(1), existing ROP #MI-ROP-B1833-2006 shall not expire until the renewal permit has been issued or denied.
General Information
Stationary Source Mailing Address: / 2200 Wright StreetMarquette, Michigan 49855
Source Registration Number: / B1833
Standard Industrial Classification: / 4911
Number of Stationary Source Sections: / 1
Application for an Initial or Renewal Permit: / Renewal of ROP #MI-ROP-B1833-2006
Application Number: / 201000103
Responsible Official: / Paul Kitti, Executive Director
906-228-0359
AQD Contact: / Thomas Maki, Staff Specialist
906-346-8503
Date Permit Application Received: / November 5, 2010
Date Application Was Administratively Complete: / November 16, 2010
Is Application Shield In Effect? / Yes
Date Public Comment Begins: / April 22, 2013
Deadline for Public Comment: / May 22, 2013
Source Description
The Shiras Steam Plant is located in the City of Marquette at the Lower Harbor. The plant provides electricity to the City of Marquette and surrounding communities. The plant has three coal fired boilers and associated coal, ash, and lime handling and storage equipment. Boiler #1 is a Riley spreader stoker coal fired boiler built in 1956. It is rated at 150,000 pounds of steam per hour and has a heat input capacity of 198 million BTU per hour. It serves a generator with a nameplate capacity of 12.5 megawatts. Boiler #2 is a Riley-Union spreader stoker coal fired boiler built in 1971. It is rated at 200,000 pounds of steam per hour and has a heat input capacity of 264 million BTU per hour. It serves a generator with a nameplate capacity of 21.158 megawatts. Boilers #1 and #2 share a common stack. Boilers #1 and #2 were upgraded in 1979 with the addition of individual baghouse dust collectors under Air Use Permit #345-78. Boiler #3 is a Combustion Engineering pulverized coal fired boiler built in 1981 under Air Use Permit #65-80. It is rated at 415,000 pounds of steam per hour and has a heat input capacity of 517 million BTU per hour. It serves a generator with a nameplate capacity of 44 megawatts. Boiler #3 is controlled by a lime slurry scrubber for fluegas desulfurization followed by a baghouse dust collector.
Source Emissions
The following table lists emission information for the Shiras Steam Plant as reported to the Michigan Air Emissions Reporting System (MAERS) for 2011.
Pollutant / Quantity Emitted Per YearCarbon Monoxide / 65 tons per year
Lead / 84 pounds per year
Nitrogen Oxides / 311 tons per year
Particulate Matter (PM10) / 0.4 tons per year
Sulfur Oxides / 365 tons per year
Volatile Organic Compounds / 4 pounds per year
Total Hazardous Air Pollutants ** / 0 pounds per year
**As listed pursuant to Section 112(b) of the Clean Air Act.
No Hazardous Air Pollutant (HAP) emissions were included in the facility’s 2011 MAERS emission inventory report (and none were required by the Air Quality Division to be reported).
In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of Greenhouse Gases in tons per year of CO2e is greater than 100,000 short tons per year. CO2e is a calculation of the combined global warming potentials of six Greenhouse Gases (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride).
Regulatory Analysis
The following is a general description of the regulatory requirements applicable to the source. Please refer to Part C of the draft Renewable Operating Permit for detailed regulatory citations for the stationary source. Part A contains regulatory citations for the general conditions. Any determinations of regulatory non-applicability for this source are explained below in the Non-Applicable Requirements portion of the Staff Report and Part E of the ROP. The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all applicable requirements and are consistent with the DEQ’s “Procedure for Evaluating Periodic Monitoring Submittals.”
The Shiras Steam Plant is located in Marquette County, which is currently designated by the USEPA as attainment/unclassified for all criteria pollutants. Boiler #3 at the stationary source is subject to theNew Source Performance Standards for Electric Utility Steam Generating Units for Which Construction is Commenced After September 18, 1978as promulgated in 40 CFR 60 Subparts A and Da. The facility is considered a 40 CFR Part 70 major source because potential (and actual) emissions of sulfur dioxide and nitrogen oxides exceed 100 tons per year.
At this time, there are no Greenhouse Gas applicable requirements to include in the ROP. The 40 CFR Part 98 Mandatory Greenhouse Gas Reporting Rule is not an ROP applicable requirement and is not included in the ROP.
Until superseded by the requirements of 40 CFR 63 Subparts DDDDD or UUUUU, emission units EUBOILER#1, EUBOILER#2, and EUBOILER#3 at the stationary source will subject to federal Compliance Assurance Monitoring (CAM) requirements for particulateas provided under 40 CFR Part 64. These emission units have a particulate control device and potential pre-control emissions of particulate greater than the major source threshold. CAM requirements are incorporated inthe draft ROP in theEUBOILER#1, EUBOILER#2, and EUBOILER#3tables. When effective, Subpart DDDDD and UUUUU requirements will supersede the 40 CFR Part 64 (CAM) requirements. As specified in 40 CFR 64.2(b)(i), the requirements of 40 CFR Part 64 shall not apply to any emission limitations or standards proposed by the Administrator after November 15, 1990 pursuant to section 111 or 112 of the Clean Air Act.
40 CFR 63 Subparts UUUUU and DDDDD contain Emission Limitations, Work Practice Standards, Operating Limits, General Compliance Requirements, Initial and Continuous Compliance Requirements, Monitoring, Installation, Operation, Maintenance, Notification, Reporting, and Recordkeeping Requirements, and General Provisions Requirements.
Boiler #3 is subject tothe National Emission Standards for Hazardous Air Pollutants: Coal and Oil Fired Electric Utility Steam Generating Units promulgated in 40 CFR 63 Subparts A and UUUUU. A high-level citation for Subparts A and UUUUU has been included in the EUBOILER#3 Table in the ROP. The facility has requested an extension of compliance with Subpart UUUUU until April 16, 2016. This request was approved via DEQ Air Quality Division letter dated November 29, 2012.
Boilers #1 and #2 are subject to the National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaterspromulgated in 40 CFR 63 Subparts A and DDDDD. A high-level citation for Subparts A and DDDDD has been included in the EUBOILER#1 and EUBOILER#2 Tables in the ROP.
Boiler #2 is subject to Michigan Air Pollution Control Rule 801 for oxides of nitrogen. Boiler #2 has a heat input capacity of 264 million BTU per hour and serves an electrical generator with a nameplate capacity of 21.158 megawatts. Boiler #2 is subject to a nitrogen oxides limitation of 0.40 pounds per million BTU heat input averaged over the ozone control period, as specified in Rule 801(4)(a) and Table 81. These limitations and appropriate monitoring, recordkeeping, testing, and reporting requirements have been included in the EUBOILER#2 table.
Effective January 1, 2015, Boiler #3 will be subject to the requirements of the Michigan Part 15 rules for mercury. At this time, the mercury permit program has been put on hold. Affected facilities have been sent a variance for the Part 15 rules that delays the requirement to submit a mercury permit application for one year.
Phase II Acid Rain Permit and CAIR Permits
Boiler #3 at the stationary source is subject to the federal Acid Rain program promulgated in 40 CFR Part 72.
Boiler #3 at the stationary source is subject to the Clean Air Interstate Rule NOx annual trading program pursuant to rules 802a, 803, 821, and 830 through 834.
Boiler #3 at the stationary source is subject to the Clean Air Interstate Rule NOx ozone season trading program pursuant to Rules 802a, 803, and 821 through 826.
Boiler #3 at the stationary source is subject to the Clean Air Interstate Rule SO2 annual trading program pursuant to Rule 420.
Source-wide Permit to Install (PTI)
Rule 214a requires the issuance of a Source-wide Permit To Install within the ROP for conditions established pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a footnote designation in the integrated ROP/PTI document. Source-Wide PTI No. MI-PTI-B1833-2006 which was issued July 1, 2006 is proposed to be reissued as Source-Wide PTI No. MI-PTI-B1833-2013.
The following table lists all Permits to Install that were incorporated into previous ROPs. Permits to Install that were issued after the effective date of ROP #MI-ROP-B1833-2006 are identified in Appendix 6 of the ROP. The following table lists the individual Permits to Install that were incorporated into original ROP #199600237.
Permit to Install Number / Description of Equipment#345-78 / This permit was issued on August 1, 1978 for Baghouse Fabric Filter Systems on Boilers #1 and #2 at the Shiras Generating Station.
#65-80 / This permit was issued on April 16, 1980 for a 44 MW steam turbine-generator, associated pulverized coal fired boiler, dry flue gas desulfurization system, baghouse filter particulate control system, and ancillary chimney, cooling water intake and discharge at the Shiras Generating Station.
Streamlined or Subsumed Requirements
This draft permit does not include any streamlined or subsumed requirements pursuant to Rules 213(2) and 213(6).
Non-applicable Requirements
Part E of the draft ROP lists requirements that are not applicable to this source as determined by the Air Quality Division, if any were proposed in the application. These determinations are incorporated into the permit shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to Rule 213(6)(a)(ii).
Processes in Application Not Identified in Draft ROP
There were no processes listed in the ROP application listed as exempt devices under Rule 212(4). Exempt devices are not subject to any process-specific emission limits or standards in any applicable requirement.
Draft Permit Terms or Conditions Not Agreed to by Applicant
This permit does not contain any terms or conditions that the Air Quality Division and the applicant did not agree upon pursuant to Rule 214(2).
Facility Compliance Status
The Air Quality Division finds that the stationary source is expected to be in compliance with all applicable requirements as of the effective date of this Renewable Operating Permit.
Proposed Action
The DEQ Air Quality Division proposes to approve this permit. A final decision on the ROP will not be made until the public and affected states have had an opportunity to comment on the AQD’s proposed action and draft permit. In addition, the USEPA is allowed up to 45 days to review the draft permit and related material. The AQD is not required to accept recommendations that are not based on applicable requirements. The delegated decision maker for the Air Quality Division is Mr. Chris Hare, Upper Peninsula District Supervisor. The final determination for ROP approval or disapproval will be based on the contents of the permit application, a judgment that the stationary source will be able to comply with applicable emission limits and other terms and conditions, and resolution of any objections by the USEPA.
/ Michigan Department of Environmental QualityAir Quality Division
State Registration Number / RENEWABLE OPERATING PERMIT / ROP Number
B1833 /
JUNE 17, 2013 - STAFF REPORT ADDENDUM
/ MI-ROP-B1833-2013Purpose
A Staff Report dated April 22, 2013, was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments received on the draft ROP during the 30-day public comment period as described in R 336.1214(3). In addition, this addendum describes any changes to the draft ROP resulting from these pertinent comments.
General Information
Responsible Official: / Paul Kitti, Executive Director906-228-0359
AQD Contact: / Thomas Maki, Staff Specialist
906-346-8503
Summary of Pertinent Comments
A letter dated May 9, 2013 was received from the USEPA noting that the draft permit only included high level citations to 40 CFR Part 63 Subparts DDDDD and UUUUU, and requested that the ROP include detailed applicable requirements including emission limits and operational requirements.
Also, the USEPA commented that the CAM Plan will likely need to be revised to be consistent with monitoring in the MACT Standards. The CAM applicability requirements do not apply to the MACT standards, but CAM does continue to be an applicable requirement of this facility.
Response to Comments and Changes to the April 22, 2013 Draft ROP
On December 16, 2011, the EPA signed the Mercury and Air Toxics Standard (MATS) to reduce emissions of toxic air pollutants from power plants. This final rule was published in the Federal Register on February 16, 2012 and is effective on April 16, 2012. Marquette Board of Light and Power is classified as an existing electric generating unit and must comply with MATS no later than April 16, 2015 unless granted an extension per 40 CFR §63.6(i)(6). On September 28, 2012, Marquette Board of Light and Power requested in writing an extension of compliance of one year to the requirements of MATS. They were granted an extension of compliance to the requirements of MATS until April 16, 2016 by AQD. Any extension of compliance requests to go beyond the April 16, 2016 date will have to be approved by EPA.
With the compliance deadline being a future date, according to § 63.10030, a facility with a unit subject to MATS does not have to inform the regulatory agency how they are going to comply with the requirements of MATS until they submit their initial Notification of Compliance Status. Marquette Board of Light and Power is required to submit this initial Notification of Compliance Status no later than 120 days after the compliance deadline, which is now April 16, 2016 with the approval of their extension of compliance request. They will have until August 15, 2016 to submit the initial Notification of Compliance Status to AQD.
On January 31, 2013, EPA published the final revised major source Boiler MACT rule in the Federal Register. The amendments in this rule to 40 CFR Part 63 Subpart DDDDD are effective as of April 1, 2013. The compliance date for existing sources such as Marquette Board of Light and Power is January 31, 2016. The initial Notification of Compliance Status will need to be submitted by May 31, 2016.
With the prospect of Title V Renewable Operating Permits (ROPs) being issued prior to a MACT compliance date, EPA has already addressed this scenario. In EPA’s May 20, 1999, letter to Mr. Robert Hadanbosi and Mr. Charles Lagges of STAPPA/ALAPCO, in Enclosure B, EPA discussed the issuance of a Title V permit prior to the compliance date of a MACT standard. EPA stated that when a permit is issued prior to the MACT compliance date, there are two options available. The first option is for the permit to describe MACT applicability at the Subpart level, and for all other compliance requirements (including compliance options and parameter ranges) of the MACT that apply below the Subpart level to be added at a later time. Because this more detailed information describes for the first time in the permit specifically how the source will comply with the standard, the source will be required to request a modification of their ROP to add this information as a significant permit modification.
The second option is for the permit to identify the MACT standards or requirements that apply at the section or subsection level, including anticipated compliance options, along with the information identified in the Initial Notification required by the General Provisions, see 40 CFR Part 63, Subpart A, or by the applicable Subpart. Additional compliance information required in the Notice of Compliance Status (e.g., parameter values) would be added to the ROP as a minor permit modification when the initial Notification of Compliance Status is submitted.