1 

### Maurin, Lawrence

From: BECKHAM, LISA

Sent: Monday, November 16, 2015 12:27 PM

To: Maurin, Lawrence

Subject: FW: Re: NGS Addendum to Title V Renewal Application

From: BECKHAM, LISA

Sent: Friday, April 10, 2015 10:32 AM

To: Raju Bisht <rbisht@navajo

‐ nsn.gov>

Cc: Tennille B. Begay <tbbegay@navajo

‐ nsn.gov>; Gutierrez, Roberto <Gutierrez.Roberto@epa.gov>

Subject: RE: Re: NGS Addendum to Title V Renewal Application

I took a closer look.  You are right, these are different. But, NGS needs to submit a Tribal Minor NSR application for this

project.

It is not clear to me whether the application they already submitted to us is related to the PAC system. I’m inclined to

think that they are (without information from NGS explaining why there are not.) I would prefer that they simply add

this as an addendum to the existing application.

I don’t see it being any trouble to get a tribal minor NSR permit revision for the PAC system before their October 1, 2015

deadline.

From: Raju Bisht [ mailto:rbisht@navajo

‐ nsn.gov ]

Sent: Thursday, April 09, 2015 3:50 PM

To: BECKHAM, LISA

Cc: Tennille B. Begay

Subject: RE: Re: NGS Addendum to Title V Renewal Application

Lisa,

These are two different applications for different projects.

Thanks. Raju

From: BECKHAM, LISA [ mailto:BECKHAM.LISA@EPA.GOV ]

Sent: Thursday, April 9, 2015 4:36 PM

To: Raju Bisht

Cc: Tennille B. Begay

Subject: RE: Re: NGS Addendum to Title V Renewal Application

Hi Raju

‐

We received an application from NGS for a tribal minor NSR permit revision. As such, a PSD modification is not needed.

Attached is a copy

– I don’t think they officially said it was a tribal minor NSR application, but that is how we are treating

it.2 Lisa Beckham

Environmental Engineer

Air Permits Office

EPA Region 9

(415) 972

‐ 3811

From: Raju Bisht [ mailto:rbisht@navajo

‐ nsn.gov ]

Sent: Thursday, April 09, 2015 3:10 PM

To: BECKHAM, LISA

Cc: Tennille B. Begay

Subject: FW: Re: NGS Addendum to Title V Renewal Application

Hi Lisa,

Could you please take a quick look at the application, a copy of which was also sent to Region 9, and help us figure out if

this would require a PSD or Minor NSR. If you look at the string of emails below, our contractor seems to think that it

might trigger PSD since the baghouse is a control device. NGS is making an argument that the baghouses are an integral

part of the silo and used for retention with no outlets and not control devices. If this indeed requires a construction

permit, we would have to refer them to you and they are in a tight timeline to comply with MATS.

Thank you for your help. Raju

From: Heckel Kyle C [ mailto:Kyle.Heckel@srpnet.com ]

Sent: Tuesday, April 7, 2015 11:51 AM

To: Raju Bisht

Cc: Cenalmor Bruquetas Maria B (Barbara)

Subject: RE: Re: NGS Addendum to Title V Renewal Application

Hi Raju,

Thank you for your time on the call earlier this morning. I wanted to summarize what we had discussed regarding the

potential emissions from the storage silo baghouses which are part of the Hg control strategy equipment included in the

Title V renewal addendum application.

The proposed silos which will be storing powder activated carbon (PAC) are equipped with baghouses. While the

baghouses do reduce the amount of emissions generated from the silos, their purpose is not as an emission control

device. Having baghouses on storage silos is very conventional in the industry for purposes of preventing product from

being lost during the unloading process. The baghouses are considered integral to the storage silo equipment as the

silos would not be operated without them. As a result, uncontrolled potential to emit emissions should be based

on grain loading rate of the baghouses, as was included in the Title V renewal addendum application submitted.

It should be noted that this approach is consistent with how other storage silos at NGS are handled. For example, the

soda ash and lime handling operations at NGS include storage silos with baghouses equipped. The potential to emit

calculations for the operations are based on emissions from the silos taking into account the control resulting from the

baghouses. Further, there has been no need for operation and monitoring requirements to be included in the permit for

these operations.

As a reminder, timing is becoming more critical. As part of the 1

‐ year extension granted to NGS for complying with the

Hg provisions of the MATS Rule, NGS must commence construction of the Hg control strategy by no later than October

1, 2015. Because commencing construction of the Hg control strategy equipment, including the PAC storage silos, is3 contingent on the issued Title V permit renewal, the Title V permit must be issued by October 1, 2015 for NGS to be able

to comply with this deadline.

If you have any questions or need additional details, please let me know.

Thanks,

Kyle

Kyle Heckel

Salt River Project

Environmental Engineer

602

‐ 236

‐ 5493

Mail Station PAB352

‐ PO Box 52025

‐ Phoenix, AZ 85072

-------- Original Message --------

Subject: Re: NGS Addendum to Title V Renewal Application

From: Yu-Lien Chu < Yu-Lien.Chu@erg.com >

Date: Apr 3, 2015, 12:20 PM

To: "Raju Bisht ( rbisht@navajo-nsn.gov )" < rbisht@navajo-nsn.gov >



### ***SRP WARNING: THIS IS AN EXTERNAL EMAIL. THINK BEFO RE YOU CLICK ON LINKS OR

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Hi Tennille and Raju,

Have you discussed with EPA about the new Hg control system installation project (a calcium bromide

application system and a PAC injection system) at NGS? I don't think we can incorporate this Hg control

system to the Title V permit directly unless both NNEPA and EPA are certain that this project does not need a

construction permit.

I think some sort of construction permit evaluation should be done before the project can be moved forward.

The uncontrolled PM10 emissions from PAC injection system is 20 tons/yr [0.02 tons/yr / (1

‐ 99.9%)

= 20

tons/yr] which is greater than the PSD significant threshold. The operation and monitoring requirements

associated with the control devices are necessary to be established in a permit. In addition, PM emissions

increases from truck traffic increases were not discussed in this permit application. Therefore, please forward

this application to EPA for evaluation if you haven't.

Please let me know if you have any questions about this message or would like to discuss this issue further.

Thank you.

Yu-Lien Chu

Eastern Research Group (ERG), Inc.

TEL: (608) 695-2534

E-Mail: yu-lien.chu@erg.com

From: Cenalmor Bruquetas Maria B (Barbara) < Barbara.CenalmorBruquetas@srpnet.com >

Sent: Tuesday, March 31, 2015 12:06 PM

To: Raju Bisht ( rbisht@navajo

‐ nsn.gov )

Cc: Yu

‐ Lien Chu

Subject: FW: NGS Addendum to Title V Renewal Application

Hello Raju,4 Attached is a pdf copy of the final MATS addendum for the Navajo Generating Station Title V permit renewal. The hard

copy is in the mail.

Please let me know if you need anything else,

Barbara Cenalmor | Sr. Environmental Engineer | Air Quality

SALT RIVER PROJECT

PO Box 52025 | Phoenix, AZ 85072

‐ 2025

Office: (602) 236

‐ 2322 | Mobile: (602) 323

‐ 6455