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Commonwealth of VirginiaVIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY

TIDEWATER REGIONAL OFFICE5636 Southern Boulevard, Virginia Beach, Virginia 23462

(757) 518-2000 FAX (757) 518-2009www.deq.virginia.gov

Matthew J. Strickler David K. PaylorSecretary of Natural Resources Director

(804) 698-4000

Craig R. NicolRegional Director

STATEMENT OF LEGAL AND FACTUAL BASIS

Hampton Roads Sanitation District - Boat Harbor WWTP300 Terminal Avenue, Newport News, Virginia

Permit No. TRO-60351

Title V of the 1990 Clean Air Act Amendments required each state to develop a permit program to ensure that certain facilities have federal Air Pollution Operating Permits, called Title V Operating Permits. As required by 40 CFR Part 70 and 9VAC5 Chapter 80, Hampton Roads Sanitation District – Boat Harbor WWTP has applied for a Title V Operating Permit for its Newport News, Virginia facility. The Department has reviewed the application and has prepared a draft Title V Operating Permit.

Permit Writer: Date: March XX, 2020 Laura D. Corl(757) 518-2178

Air Permit Manager: Date: DRAFT

Regional Director: Date: DRAFT

HRSD – Boat Harbor WWTP60351

Statement of BasisDRAFT 12/18

FACILITY INFORMATION

PermitteeHampton Roads Sanitation DistrictP.O. Box 5911Virginia Beach, Virginia 23471-0911

FacilityBoat Harbor WWTP300 Terminal AvenueNewport News, Virginia 23607

County-Plant Identification Number: 51-700-00068

FACILITY DESCRIPTION

NAICS Code: 221320 - Sewage Treatment FacilitiesNAICS Code: 562219 - Non-Hazardous Waste Treatment and DisposalNAICS Code: 562213 - Solid Waste Combustors or Incinerators, Non-Hazardous

The Hampton Roads Sanitation District (HRSD) is a political subdivision of the Commonwealth of Virginia and was established as a governmental instrument to provide for the public health and welfare by abating water pollution in the Hampton Roads area through the interception of wastewater outfalls and providing wastewater treatment plants. Each of the HRSD plant facilities meets the definition of a non-industrial Publicly Owned Treatment Works (POTW) as defined in 40 CFR 63, Subpart VVV. All of the HRSD treatment plants are interconnected for diverting wastewater flow to alternate treatment locations as the area’s daily amount of generated wastewater flow varies along with the operational capabilities of each plant. Each HRSD facility has been evaluated based on its individual maximum design capacity, whereby no flows can be re-directed to any of the facilities in excess of their individual design capacities. The Boat Harbor Plant provides both primary and secondary municipal wastewater treatment for the Hampton Roads area, serving mainly Newport News and Hampton clients in the Hampton Roads area. The Boat Harbor Plant is rated to treat a design maximum average dry weather flowrate of 25 million gallons per day (mgd) and sized to accommodate an instantaneous wet weather peak hour flowrate of 50 mgd. The facility process units are grouped into four main functions: liquids management, solids handling, sludge incineration, and other combustion units.

Liquids Management - Liquids management consists of all of the unit processes that treat the received wastewater prior to discharge to the Elizabeth River. These unit processes include the septic tank truck unloading station, headworks (influent screening and pumping)/grit removal chamber, aerobic reactors, primary and secondary clarification, and disinfection contact basin.



Solids Handling - Solids handling consists of unit processes that treat liquid treatment by-product streams before disposal. These unit processes include grit handling, raw and primary scum holding tank/concentrator, gravity belt thickener, primary and waste biosolids holding tank, biosolids day tank, dewatering centrifuges, biosolids screw conveyors, foreign biosolids storage and handling, biosolids belt conveyors (converting to screw conveyor), and ash storage/disposal.

Sludge Incineration - Sludge incinerator units are comprised of two identical multi-hearth incinerators used to dispose of dewatered solids from the solids handling sections. Each incinerator has eight hearths, a dedicated induced-draft fan, and air pollution control equipment for particulate matter consisting of a multiple venturi and packed bed wet scrubbing system. The incinerators can fire either natural gas or distillate oil as supplemental fuel in the combustion process.

Electrical generators - The Boat Harbor Plant uses two diesel engine-generator sets that fire diesel fuel oil. The two diesel engine-generator sets have been retrofitted with Diesel Oxidation Catalysts (DOC) to meet MACT standards. HRSD is now enrolled in the Emergency Load Response Program (ELRP) and will participate in ISO-declared emergencies.

The facility is a Title V major source of NOx, VOC, SO2, and CO and an area source for HAPs. This source is located in an attainment area for pollutants. The facility is currently permitted under two minor NSR Permits issued on February 13, 1973 and April 24, 2000.

SIGNIFICANT MODIFICATION SUMMARY

This significant modification is based on an application received on April 5, 2019. The Title V permit for Hampton Roads Sanitation District - Boat Harbor Waste Water Treatment Plant currently has an effective date of July 28, 2016 and an expiration date of July 27, 2021. The significant permit modification is to convert two engine-generator sets from emergency operations to non-emergency operations as defined in the 40 CFR 63 Subpart ZZZZ (MACT). The facility anticipates that the non-emergency designation will allow the engines to participate in PJM’s Emergency Load Response Program (ELRP). The two engine-generator sets affected are permitted in a minor NSR permit dated April 24, 2000.

In 9VAC5-80-230, “Significant modification procedures shall be used for those permit modifications that:

Involve significant changes to existing monitoring, reporting, or recordkeeping requirements in the permit, such as a change to the method of monitoring to be used, a change to the method of demonstrating compliance or a relaxation of reporting or recordkeeping requirements…”

For the engines to operate in compliance with MACT ZZZZ requirements for non-emergency generators sets, emission standards, monitoring requirements and recordkeeping requirements will significantly change making this permit a significant amendment.



Virginia’s definition of “emergency” continues to allow participation in the Emergency Load Response Program, so there are no NSR implications from the two generators’ participation in this program.

COMPLIANCE STATUS

A full compliance evaluation of this facility, including a site visit, was conducted on October 23, 2018. All reports and other data required by permit conditions or regulations, which are submitted to DEQ, have been evaluated for compliance. Based on these compliance evaluations, the facility has not been found to be in violation of any state or federal applicable requirements at this time.

EMISSIONS INVENTORY

Emissions from the facility in 2018 are summarized in the following tables.

2018 Criteria Pollutant in Tons/YearEmissions VOC CO SO2 PM10 PM2.5 NOX

Total 10.67 117.01 2.92 1.51 N/A 27.01

2018 Hazardous Air Pollutant (HAP) EmissionsPollutant Tons/YearTetrachloroethylene (Perchloroethylene) 0.11Methyl chloroform (1, 1, 1-Triechloroethane) 0.25Trichloroethylene 0.17Chloroform 0.91



EMISSION UNITS

Emission Unit ID Emission Unit Description Size/Rated Capacity

I-1I-2

Multi hearth SSI units (natural gas or distillate oil as backup fuel), 1973

13 burners per each unit -6 burners at 2.7 MMBtu/hr and7 at 1.8 MMBtu/hr.43 dry tons/day (sludge) per SSI

L-1 Liquids Management, 1940 25 mgd (dry)(wastewater)

G-3G-4

Diesel-fired Non-Emergency Electrical Generators, 2000 MACT Subpart ZZZZ

15.5 MMBtu/hr (combined)(1,500 kW) each

S-1 Solids Handling, 1973 25 mgd (dry)(wastewater)

T-28 Gasoline UST, 2007MACT Subpart CCCCCC 1,000 gallons



EMISSION UNIT APPLICABLE REQUIREMENTS – NON-EMERGENCY GENERATORS - (G-3 & G-4)

The equipment to be modified are two Caterpillar diesel-fired engines (EU ID G-3 and G-4), both model year 2000. They are equipped with dual Rachor CCV6000 closed crankcase ventilation systems. The engines’ exhaust systems are being retrofitted with diesel oxidation catalysts (DOC) to ensure the engines, when operating in non-emergency mode, can meet the applicable requirements of 40 CFR 63 MACT ZZZZ.

In addition, the facility has formally shutdown another engine generator set (ISU-CB-24) that is being removed from the permit at the same time. The mutual agreement to shut down the unit was signed on October 24, 2019.

CHANGES TO THE PERMIT

Table of Contents The Table of Contents was revised to reflect changes in the name of Section IV.

Changes to Sections I through IXThe page header throughout the permit was updated to reflect the new permit date and new page numbers.

Section IIn Section I the Electrical Generators description was updated to reflect the changes to these generators.

Section IIThe Emission Unit table was updated to remove the generator that has been shut down and change the description of the modified engine-generators to non-emergency, remove the term electrical from the description, include the new controls for the non-emergency engine-generators and add the pollutants they control.

Section IVThis section is for the engine-generators so all references to the units have been changed throughout the section to reflect that the units are now non-emergency engine-generators removing the term electrical from the description. References to the generator that has been shut down have been removed from all conditions.

Condition 41 has been updated to the current boilerplate language.



Condition 43 changed the wording in the condition from “Emissions from the operation of each engine for the emergency electrical generators (G-3 and G-4) shall..” to Emissions from the operation of the engines used to power the non-emergency generators (G-3 and G-4) shall..” to better explain the limits listed in the condition. Added condition 6 of minor NSR permit as a reference.

Removed the condition defining emergency power operation because there are no units that are emergency units

Removed condition requiring non-resettable hour meters because the units are no longer emergency engine-generators.

Condition 45 - corrected the citation to remove the reference to Condition 8 in the minor NSR permit.

Condition 47 - corrected the citation by removing the reference to Condition 11 of the minor NSR permit.

Condition 48 – (a) Changed the word ‘amount’ to ‘consumption’ to match the wording used in Condition 42. Changed ‘electrical generators’ to ‘engine-generators’.

Removed the recordkeeping condition to record the cause of operation for each engine-generator.

(g) Added a recordkeeping requirement for scheduled and unscheduled maintenance and operator training.

Condition 49 – Added the reference to condition 3 of the minor NSR permit.

Conditions 50 – changed the reference of the Department to DEQ to be consistent with other conditions.

Conditions 51-59 have been added for the MACT ZZZZ requirements that apply to the non-emergency engine-generator sets (G3 and G4). Note that the initial performance test was conducted in October 2019, so this requirement was not included in the modified TV permit.

Sections V through IX – All condition numbers have been updated.

STREAMLINED REQUIREMENTS

There were no stream lined requirement in the application and there have been no new streamlined requirements since the July 28, 2016 TV renewal permit.



INSIGNIFICANT EMISSIONS UNITS

None identified in the application to modify the July 28, 2016 TV renewal permit.

COMPLIANCE PLAN

N/A

INAPPLICABLE REQUIREMENTS

None identified in the application to modify the July 28, 2016 TV renewal permit.

GENERAL CONDITIONSThe permit contains general conditions required by 40 CFR Part 70 and 9VAC5-80-110 that apply to all Federal-operating permitted sources. These include requirements for submitting semi-annual monitoring reports and an annual compliance certification report. The permit also requires notification of deviations from permit requirements or any excess emissions. Comments for Condition 66 through 96 with respect to changes from the July 28, 2016 TV renewal permit are provided below.

The General Condition numbers have all been updated and the new boilerplate has combined several conditions with what used to be multiple conditions into one condition with subparts. Most of the citations listed below each condition have been changed to remove specific subsections of the sections listed to reflect the new boilerplate. The headers for each condition now include the section name in addition to the subject. Other changes are listed below:

Condition 66 is now a combination of six conditions in the Renewal permit with the same heading. Condition (c) also now cites a regulation rather than a reference to ‘this section’.

Condition 70(b) now includes excursions from CAM requirements.

Condition 72 has been changed to note that owners that are subject to 9VAC5-40-50 C and 9VAC5-50-50 C are not subject to the written statement requirement. The boilerplate language has also been updated.

Condition 73 has been updated to include the new boilerplate language.

Condition 74 has been added.

Condition 82 has been updated to the new boilerplate language.


Condition 88 no longer specifies calendar days.



Condition 89 is now a combination of three conditions in the renewal permit with the same heading.


STATE-ONLY ENFORCEABLE REQUIREMENTS

No new SOE requirements were identified in the application to modify the July 28, 2016 TV renewal permit.

CONFIDENTIAL INFORMATION

The permittee did not submit a request for confidentiality. All portions of the Title V application are suitable for public review.

PUBLIC PARTICIPATION

The proposed permit will be placed on public notice from [ January 29, 2020 ] to [ February 28, 2020 ] . The notice will be published in Daily Press newspaper on [Wednesday, January 29, 2020].

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