Jabari, Vian (DEQ) From: Sent: To: Cc: Subject: Attachments: Fowler, Keith (DEQ) Monday, July 17, 2017 9:00 AM Taylor.L.Engen@dominionenergy.com Diehi, Glenn (DEQ); Fowler, Keith (DEQ) Inspection Report for Dominion - Brernp Power Station, 40199 lnspectionReport.pdf Attached is a copy of the inspection report generated as a result of the compliance evaluation conducted on 6/1/2017, Please maintain a copy of this report for your records; DEQ can also provide a paper copy if it is specifically requested. It is important that you review the report, paying particular attention to the summary and any observations. If you have any comments or concerns regarding the report, or with any of your facility requirements, please contact Glenn Diehl. l j VIRGINIA D m A R T M ( i v r 01ENV]RONMF-NTA1. QUALITY' Valley Regional Office 4411 Early Road, Harrisonburg, VA22801 Phone #: (540) 574-7800 Registration #: 40199 Site Name:Dominion - Bremo Power Station Address: 1038 Bremo Road, Bremo Bluff, VA 23022 Contact:Taylor Engan: (434) 842-4104 Report #.314113 CMS: Title V Major Classification: Major/Potential Major AIR INSPECTION REPORT The purpose of this inspection report is to document DEQ's observations and provide the compliance status for requirements applicable to the facility. Presented below are the following: • • • • Inspection Details describe this inspection report Compliance Summary lists individual requirements addressed in the report Inspection Summary provides an overview of the inspector's observations Inspection Checklist provides additional details and individual observations related to specific requirements Inspection Details Inspection Date: Reason: Type: Inspector: Inspection Results: Jun 1,2017 Complete FCE (Full Compliance Evaluation) FCE With Site Visit Glenn Diehl In Compliance Visit Date Arrival Time Departure Time 6/1/2017 11:28 AM Jul 17,2017 08:59 Weather Program Code Subpart ACIDPRECIP PSD SIP TITLE V Sunny/Clear, 68 F 02:38 PM Inspector: Glenn Diehl Supervisor: B Keith Fowler Signed Date: Jul 14, 2017 Approved Date: Jul 17, 2017 Dominion - Bremo Power Station (40199) Page 1 / 28 Registration #=40199 Site N a m e : D o m i n i o n - Bremo Power Station Report #=314113 (Continued) Compliance Summary fiSGSffiEHfitEfo The a p p l i c a b l e r e q u i r e m e n t s l i s t e d in the table b e l o w were c o n f i r m e d d u r i n g t h e i n s p e c t i o n to be in c o m p l i a n c e . Permit Effective Date or Regulation 5/5/2014 TITLEV Applicable Requirement T51.T5 2, T5 3, T5 4, T5 5, T5 6, T5 7, T5 8, T5 9, T5 10, T5 11, T5 12, T5 13, T5 14, T5 15, T5 16, T5 17, T5 18, T5 19, T5 20, T5 21, T5 22, T5 23, T5 24, T5 25, T5 26, T5 27, T5 28, T5 29, T5 30, T5 31, T5 32, T5 33, T5 34, T5 35, T5 36, T5 37, T5 38, T5 39, T5 40, T5 41, T5 42, T5 43, T5 44, T5 45, T5 46, T5 47, T5 48, T5 49, T5 50, T5 51, T5 52, T5 53, T5 54, T5 55, T5 56, T5 57, T5 58, T5 59, T5 60, T5 61, T5 62, T5 63, T5 64, T5 65, T5 66, T5 67, T5 68, T5 69, T5 70, T5 71, T5 72, T5 73, T5 74, T5 75, T5 76, T5 77, T5 78, T5 79, T5 80, T5 81, T5 82, T5 83, T5 84, T5 85, T5 86, T5 87, T5 88, T5 89, T5 90, T5 91 Inspection Summary Name/Title of contact during inspection: Taylor Engan, Environmental Compliance Coordinator. Purpose: FCE site inspection. Facility & Process Description: The Bremo Power Station is a natural gas-fired electric power generating facility located in Fluvanna County, Virginia. The facility includes two natural gas walhfired Babcoek and Wilcox boilers rated at 920 and 1,684 million Btu per hour (MMBtu/hr) heat input capacity. The facility also includes a diesel fired CAT 200 kW emergency generator and a diesel fire pump. Permitting & Regulatory The facility stopped using coal, distillate oil, and used oil as fuel for the boilers (Ref. 003 and 004) and formally shutdown the coal handling equipment at the facility under a mutual shutdown agreement with the DEQ, on September 19, 2013; after the termination of the use of coal, distillate oil, and used oil, the facility is no longer a major source of Hazardous Air Pollutants (HAPs) (i.e., the facility is considered an area source of HAPs). t h e facility is a title V major source of nitrogen oxides (NOx), and carbon monoxide (CO) with a TV permit dated May 5, 2014. The source is located in an attainment area for all pollutants and is a PSD major source. The facility is also subject to the Title IV Acid Rain regulations (9 VAC 5 Chapter 80, Article 3) and the Clean Air Interstate Rule (CAIR) (9 VAC 5 Chapter 140). Bremo is also subject to the May 2003 USEPA Consent Decree. On April 22, 2003, EPA and others entered into a consent decree for Clean Air Act violations. The Title V renewal permit includes the requirements of the Consent Decree and CAIR by reference. Compliance History: The last full site inspection was conducted October 28, 2014. During that inspection the facility was found to be in compliance. Inspection Notes: Present for the inspection were: Taylor Engan, Environmental Compliance Coordinator; William Reed, Director Power Generation Station II; Steven Call, Control Room Operator; Sam Batemen, Instrument Technician; and Glenn Diehl, DEQ. The facility has been converted to run the primary boilers on natural gas. The Coal handling operation has been dismantled and the coal yard has been graded and seeded with grass. Water treatment storage tanks are now on the old coal pile site. Units 3 and 4 were shutdown due to electrical demand. The Solar generator was removed in 04/15 and a CAT 200 kW diesel generator was installed in 5/15. This unit does not trigger permitting because the size is well below the cutoff for needing a permit according to Mr. Engan. It has a non-resettable hour meter and maintenance records are kept in Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 2 / 2 8 the same manner as the diesel tire pump. The unit was observed Auxiliary boiler uses natural gas but was not running du^ which was reading 6579.Ihpurs.The diesel fire pump was observed in operatioh^1u-15^opac^ Additional observations and the record review are in the attached checklist which covers ail of conditions of theTV permit and tne referenced permits. Recommendations: None Attachments: A-Onits3and4operatingscreen,B-Exampjet^ record,E-^erosene consumption spreadsheet,F-Natural Gas consumption spreadsheet,G-Monthly emissions calculations,Fi-ROIIing 12 Month emissions calculations,l-Oiesel Fire Pump Maintenance Records, J-2016OEO PollutantEmissionsReport,^-Unit4operatinghours exampl^^ Notes w/Permit Condition Checklist. Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 3 / 2 8 Inspection Checklist Effective Date: May 5, 2014 ' Applicable Requirement #: T5 1 Compliance Status: fflt33fiffP!S> A p p l i c a b l e Requirement Fuel Burning Equipment Requirements - (Ref. 002, 003, 004, and 005) Limitations - Oxides of nitrogen (NOx) emissions from Boilers 003 and 004 shall be controlled by low NOx burners with enhanced overfire air, good combustion practices, operator training and proper emissions unit design, construction and maintenance. The low NOx burners shall be installed and operated in accordance with manufacturer's specifications. (9 VAC 5-80-490 B & C and Condition 2 of the 5/24/13 Permit) Observation Low NOx burners in use Effective Date: May 5, 2014 A p p l i c a b l e Requirement #: T5 2 Compliance Status: flEEBBBSH^ Applicable Requirement Limitations - Carbon monoxide (CO) and volatile organic compound (VOC) emissions from Boilers 003 and 004 shall be controlled by enhanced overfire air, good combustion practices, operator training and proper emissions unit design, construction and maintenance. (9 VAC 5-80-490 B & C and Condition 3 of the 5/24/13 Permit) Observation Overfire air in use as well as training. Computer controlled combustion in use. Effective Date: May 5, 2014 A p p l i c a b l e Requirement #: T5 3 Compliance Status: (H5SBH1BHB A p p l i c a b l e Requirement Limitations - The approved fuels for the Solar Combustion Turbine (Ref. 002) are distillate oil and kerosene. Distillate oil is defined as fuel oil that meets the specifications for fuel oil numbers 1 or 2 under the American Society for Testing and Materials ?Standard Specification for Fuel Oils.? A change in the fuels may require a permit to modify and operate. (9 VAC 5-80-490 B & C ) Observation Removed in April, 2015. Effective Date: May 5, 2014 A p p l i c a b l e Requirement #: T5 4 Compliance Status: #IRppQ!p%QB Applicable Requirement Limitations - The approved fuel for Boilers 003, 004 and 005 is natural gas. A change in the fuel may require a permit to modify and operate. (9 VAC 5-80-490 B & C and Condition 5 of the 5/24/13 Permit) Observation Natural gas in use, see attachment F Effective Date: May 5, 2014 A p p l i c a b l e Requirement #: T5 5 Compliance Status: iTBSEBWrEfiffil Applicable Requirement Limitations - Boilers 003 and 004 combined shall consume no more than 6,330 x 10 6 cubic feet of natural gas, per year, calculated monthly as the sum of each consecutive 12-month period. Compliance for the consecutive 12-month period shall be demonstrated monthly by adding the total for the most recently completed calendar month to the individual monthly totals for the preceding 11 months. (9 VAC 5-80-490 B & C and Condition 6 of the 5/24/13 Permit) Observation Not exceeded, through May 2017 2,523.2 x 10*6 scf used, see F. A Effective Date: May 5, 2014 A p p l i c a b l e Requirement #: T5 6 Compliance Status: «fflftffOfflEW& A p p l i c a b l e Requirement Limitations - Emissions from the operation of the Solar Combustion Turbine (Ref. 002) shall not exceed the limits specified below: Particulate Matter 3.14 Ibs/hr Jul 17,2017 08:59 Dominion - Bremo Power Station (40199) Page 4 / 28 Sulfur Dioxide 13.83 Ibs/hr Compliance with these emission limits may be determined as stated in Conditions 3 and 25. (9 VAC 5-40-900, 9 VAC 5-40-930, and 9 VAC 5-80-490 B & C ) Observation Unit removed in April, 2015. Effective Date; May 5, 2014 Applicable Requirement #: T5 7 Compliance Status: ® ^ S l j l E © Applicable Requirement Limitations - Emissions from the operation of Boiler 003 shall not exceed the limits specified below: Particulate Matter (PM) 6.81 Ib/hr PM-10 6.81 Ib/hr PM-2.5 6.81 Ib/hr Sulfur Dioxide (S02) 0.76 Ib/hr Nitrogen Oxides (as N02) 147.20 Ib/hr 0.16 Ib/MMBtu Carbon Monoxide (CO) 55.20 Ib/hr 0.06 Ib/MMBtu Volatile Organic Compounds (VOC) 3.68 Ib/hr 0.004 Ib/MMBtu Unless otherwise specified, NOx and CO limits apply at all times except during startup, shutdown, and malfunction. Periods considered startup and shutdown are defined in Condition 10 of this permit. Compliance with these emission limits may be determined as stated in Conditions 19 and 27. (9 VAC 5-80-490 B & C and Condition 7 of the 5//24/13 Permit) Observation Not exceeded based oh stack testing and CEMS (Conditions 19 and 27). Effective Date: May 5, 2014 Applicable Requirement #: T5 8 Compliance Status: Applicable Requirement Limitations - Emissions from the operation of Boiler 004 shall not exceed the limits specified below: Particulate Matter (PM) 12.46 Ib/hr PM-10 12.46 Ib/hr PM-2.5 12.46 Ib/hr Sulfur Dioxide (S02) Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 5 / 28 1.40 Ib/hr Nitrogen Oxides (as N02) 252.60 Ib/hr 0.15 Ib/MMBtu Carbon Monoxide (CO) 101.04 Ib/hr 0.06 Ib/MMBtu Volatile Organic Compounds (VOC) 6.74 Ib/hr 0.004 Ib/MMBtu Unless otherwise specified, NOx and CO limits apply at all times except during startup, shutdown, and malfunction. Periods considered startup and shutdown are defined in Condition 10 of this permit. Compliance with these emission limits may be determined as stated in Conditions 19 and 27. (9 VAC 5-80-490 B & C and Condition 8 of the 5/24/13 Permit) Observation Not exceeded based on stack testing and CEMS (Conditions 19 and 27). Effective Date: May 5, 2014 A p p l i c a b l e Requirement #: T5 9 Compliance Status: Applicable Requirement Limitations - Combined emissions from the operation of Boilers 003 and 004 shall not exceed the limits specified below: Particulate Matter (PM) 24.2 tons/yr PM-10 24.2 tons/yr PM-2.5 24.2 tons/yr Sulfur Dioxide (S02) 2.7 tons/yr Nitrogen Oxides (as N02) 522.9 tons/yr Carbon Monoxide (CO) 196.1 tons/yr Volatile Organic Compounds (VOC) 13.1 tons/yr Annual emission limits are derived from the estimated overall emission contribution from operating limits, including periods of startup and shutdown. Annual emissions shall be calculated monthly as the sum of each consecutive 12-month period. These emissions are derived from the estimated overall emission contribution from operating limits. Exceedance of the operating limits may be considered credible evidence of the exceedance of emission limits. Compliance with these emission limits may be determined as stated in Conditions 1, 2, 4, and 5, (9 VAC 5-80-490 B & C and Condition 9 of the 5/24/13 Permit) Observation Not exceeded based on natural gas use, throughput, test results and OEMS (Conditions 1,2,4, and 5) see also attachments G, H, K and L. Jul 17,2017 08:59 Dominion - Bremo Power Station (40199) Page 6 / 28 Effective Oafe: May 5, 2014 AppllcableRequiremenf#:T610 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Limitations-The NOx and CO short-term emission limits contained in Conditions7and3apply at all times except during periods of startups a. Startup and shutdown periods are defined as follows: (1) Startup-Astartup begins when the unit begins combusting fuel afterashutdown and ends when the uhitis operating above 40 percent of rated load.Exclusion from the short-term emission limits for startup periods shall not exceed 16hours per occurrence. Emissions from the operation ofthe boilers (Ref. 003 and 004)shall not exceed the limits specified below for each startup: Pollutant Onit003 Unit004 NOx 2.355.2 Ibs/startup 4,041.6 Ibs/startup OO 333.2 Ibs/startup 1,616.6 Ibs/startup (2) Shutdown-Refers to the period between the time the boiler load drops below 40 percent of rated load and the fuel supply to the boiler is cut. Exclusion from the short-term emissions limits for shutdown shall not exceed3hours per occurrence. Emissions from the operation of the boilers (Ref. 003 and 004)shall not exceed the limits specified belowfor each shutdown: Pollutant Unit3 Unit4 NOx 1,177.6 Ibs/shutdown 2.020.3 Ibs/shutdown OO 441.0 Ibs/shutdown 303.3 Ibs/shutdown b. The permittee shall operate the Continuous Emission Monitoring Systems(CEMS)duringperiods of startup and shutdown. c. The permittee shall record thetime, date, and duration of each startup and shutdown period. d. The permittee shall operate the facility so as to minimize the frequency and duration of startup and shutdown events. (gVAC5-30-490S&Cand Condition 10ofthe5/24/13 Permit) Observation a. Reviewed with facility representative. b. Verified as correct. c. Verified as correct. d. Verified as correct. Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 77 28 Effective Oate: May 5, 2014 Applicable Requirement #:T511 Compliance Status: ^ ^ ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Limitations-The annual emissions limit on the boilers (Ref. 003 and 004)inCondition9isacompliance cap,imposed for thepurposeoflimitingthepotentialtoem 30 Article3(9VAC 5-30-1505 etseq.)related to the conversion of the boilers from coal to natural gas.The limit does not providerelieffromobtainingaplanapprovalforanyfuturephysicalchangeorchangeinthemethodofoper^^^^ boiler or the addition or modification of any steam-consuming process(es)at the facility.The latter is true even ifthe permittee does not requestachange in the compliance cap. Furthermore, by accepting this cap and agreeing to consider the two boilers as one emissions unitforNSR/FSO purposes, anyfuture applicability d e t e ^ boilers, e.g. should major NSR/PSO be thggered for any one boiler or process change, BACT/LAER is required for both boilers. If the emissions limit is relaxed at some future date, the source obligation require 40CFR52.21(r)(4)apply. (gVAC5-30-4g08&C,9VAC5-30-1505,andCondition11ofthe5/24/13Permit) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement #:T5 12 Compliance Status: ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Limitations-Visible Emissions from the boiler stack (Ref. 005) shall not exceed 20 percent opacity except during one six-minute period in any one hour in which visible emissions shall not exceed 30 percent opacity as determined by the EPA Method9(reference40CFR50,AppendixA). (gVAC5-50-30and9VAC5-30-4908&C) Observation None on record Effective Oate: May 5, 2014 Applicable Requirement #:T513 Compliance Status: ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Limitations-Visible Emissions from theSolarCombustionTurbine stack (Ref. 002) shall not exceed 20 percent opacity exceptduringonesix-minuteperiodinahyonehourinwhichvisibleemissionsshallnotexceed determined by the EPAMethod9(reference40 CFR 50,AppendixA). (9VAC540 5 0 , 9 V A C 5 4 0 9 4 0 , a n d 9 V A C 5 8 0 4 9 0 8 & C ) Observation None on record Effective Oate: May 5, 2014 Applicable Requirement s: T5 14 Compliance Status: ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Limitations-Visible emissions from each boiler (Ref. 003 and 004)stack shall not exceed lOpercent opacity as determined by the EPAMethod9(reference 40 CFR 50,Appendix A). (gVAC5-30-4g0r3&CandCondition12ofthe5/24/13Permit) Observation None on record since change to natural gas.Llnits3&4not in operation during inspection. Effective Oate: May 5, 2014 Applicable Requirement s: T515 Compliance Status: ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Limitations-Atalltimes,includingperiodsofstart-up, shutdown, andmalfunction,thepermitteeshall,totheex practicable, maintainandoperatetheaffectedsource,includingassociatedairpollutioncontrolequipment^ consistentwithgoodairpollution control practicesforminimizingemissions.Thepermitteeshalltakethe following measures in order to minimize the duration and frequency of excess emissions, with respect to air pollution control equipment, monitoringdevices, and processequipmentwhichaffectsuchemissions: a. Oevelopamaintenance schedule and maintain records of all scheduled and non-scheduled maintenance. b. Maintain an inventory of spare parts. c. Fiaveavailablewrittenoperatingproceduresforequipment.Theseproceduresshallbebasedonthemanufacture^s recommendations, ataminimum. Jul 17,2017 08:59 Dominion - Bremo Power Station (40199) Page 8 / 28 d. Train operators in the proper operation of all such equipment and familiarize the operators with the written operating procedures.Thepermitteeshall maintain records of the training provided,including the namesof trainees, the date of training and the nature of the training. (gVAC5-80^90S&CandCondition28ofthe5/24/13Permit) Observation a. On computer b. On computer c. On computer and paper reports d. available, seeSandCexamples. Effective Date: May 5, 2014 A p p l i c a b l e Requirement # : T 5 1 6 Compliance S t a t u s : ^ ^ ^ ^ ^ ^ ^ A p p l i c a b l e Requirement Limitations-The permittee shall obtainacertification,or alternatives^^ shipment of distillate oil. Each fuel supplier certification or alternative statement shall include the following: a. The nameofthe fuel supplier, b. The date on which the oil was received, c. The volume of distillate oil delivered in the shipment, and d. Astatement that the oil complies with the American Society forTesting and Materials specifications forfuel oil numbers l a n d 2. (9VAC5-80-490P) Observation Records on file, see example D. Effective Oate:May 5, 2014 A p p l i c a b l e Requirement # : T 5 1 7 Compliance S t a t u s : ^ ^ ^ ^ ^ A p p l i c a b l e Requirement Limitations-Except where this permit is more restrictive, the natural-gas auxiliary boiler (Ref. 005) shall be operated in compliance with the requirements of 40 CPR 50, Subpart Dc. (gVAC5-50-4908&Cand40CPR50SubpartDc) Observation Reviewed with facility representative. Effective Date: May 5, 2014 A p p l i c a b l e Requirement #: T5 15 Compliance Status: ^ r ^ ^ ^ ^ A p p l i c a b l e Requirement Consent Decree Requirements-The permittee is subject to the Consent Decree entered by the United States District Court forthe Eastern District ofVirginia, Civil Action N o s . 0 3 - C V - 5 1 7 - A a n d 0 3 - C V - 5 0 3 - A , ^ VirginiaElectric&PowerCompanyandtheUnitedStates,etal(the^ConsentDecree^).TheConsentDecree,^ mightbe amended ormodified in accordance with its terms, is incorporated in itsehtirety into this permitb^ as Attachment CBThe permittee shall comply with the terms and conditions of the Consent Decree that relate to the operation of Sremo Power Station exclusively and such compliance shall be determined exclusively by reference to the terms and conditions of the Decree, whenever any conflict or ambiguity arises between the Consent Decree and this permit, the terms and conditions of the Consent Decree will control. The limitations, monitoring, recordkeeping, and reportingrequirementsincludeapplicablerequirementsfromtheConsentDecree. (0VAC5-50-440land the Consent Decree) Observation Complyingwiththeaveraging,seetabl^ account. Recent stack testing was in compliance for all pollutants ^ Effective Date: May 5, 2014 A p p l i c a b l e Requirement # : T 5 19 Compliance Status: ^ ^ ^ ^ ^ ^ A p p l i c a b l e Requirement Monitoring-Continuous Emission Monitoring Systems(CEMS)shall be installed to measure and record the emissionsof NOx(measuredasNO2)andCO,inlb/MMStufromeachboiler(Ref003and004).CEMSforNOxshallmeetthedesig^ specifications of 40 CPR 75 whereas OEMS for CO shall be installed, evaluated, and operated according to DEO-approved procedures which are equivalent to the requirements o f 4 0 C P R 5 0 . 1 3 a n d A p p e n d i c e s S a n d P f o r compliance with the Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 9 / 28 emission limits containedinConditions7and 3. NOx data and CO data shall each be reduced to 1-hour block averages. The relative accuracy test audit (RATA) of the NOx CEMS shall be performed onalb/MMBtu basis. (gVAC5-30-4g08&C,9VAC5-30-420,and40CFR75,andCondition13ofthe5/24/13Permit) Observation In use, seeattachmentAexample output. ^ Effective Oate: May 5, 2014 Applicable Requirement #:T5 20 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Monitoring-PerformanceevaluationsoftheNOxandCQcontinuousmonitoringsystemsshallbeconductedin accordancewith40CFR50,Appendix8,andshalltakeplaceduringtheperformancete^^^ within 30 days thereafter. Qne copy of the performance evaluation report shall be submitted to the OEQ, within 45 days of the evaluation. The continuous monitoring systems shall he installed and operational prior tests.Verification of operational status shall,asaminimum,include completion ofthe manufacturers whtten require or recommendations forinstallation,operation and calibration ofthe device.A30-day notification,priorto the demonstrationofthecontinuousmonitoringsystem^sperformance.andsubsequentnotificatio OEQ. (gVAC5-30-490S&CandCondition14ofthe5/24/13Permit) Observation Completed showing compliance EffectiveOate:May5,2014 Applicable Requirement s: T5 21 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Monitoring-ACEMS quality control program which is equivalenttothe requirements of 40 CFR 50.13and 40 CFR50, AppehdixForRad 75 shall be implemented for all continuous monitoring systems. (gVAC5-30-4g0B&CandCondition15ofthe5/24/13Permit) Observation Quality program for the monitors in use. Effective Oate:May5, 2014 Applicable Requirements: T522 ApplicableRequirement Monitoring Thepermitteeshallconductvisibleemissionsobservations^ accordancewiththefollowingproceduresandfrequencies: Compliance S t a t u s : ^ ^ ^ ^ a. Ataminimumofonceperoperatingmonth.thepermitteeshallobservethepresenceofvisibleemissions.EachVEO shall be performed forasufficient period of time to identify the presence of visible emissions. If no visible emissions are observed,anote to that effect should be recorded.l^owever,if visible emissions are observed,avisible emissions evaluation(VEE)shallbeconductedusing40CFRFart50,AppendixA,Method9foraperiodofnotlessthansixminute^^ If any of the observations exceed the applicable opacity limit, the observation period shall continue until 50 minutes of observations have been completed. b. All visible emissions inspections shall be performed when the equipment is operating under representative conditions for the day. o.lfvisibleemissionsinspectionsconductedduringfourconsecutiveoperatingmonthsshownovisibleemissions,the permittee may reduce the monitoring frequency from monthly to quarterly for that emission unit. Anytime the quarterly visible emissions inspections show visible emissions, or when requested by OEQ, the monitoring frequency shall be increased to once per operating month for that emission unit (9VAC5-30-4908&C) Observation Quarterly observation now conducted, no visibles observed. U3 and U4 are on quarterly schedule as no visibles have been observed Effective Oate: May 5, 2014 Applicable Requirement #:T5 23 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Monitoring vVhenVEEs, performed inaccordancewithCondition22,indicatethevis^ shown in Condition 14for boiler 003 or 004,then the permittee shall verify that the boiler(s)is operating in accordance with manufacturers specifications or other predetermined site-specific acceptable operating conditions. Ifaboiler is not Jul 17,2017 08:59 Dominion - Bremo Power Station (40199) Page 10/28 operating properly,the permittee shall take corrective action in an effort to reduce emissions to or below the limitation shown in Condon 22. (gVAC5-30-490B&C) Observation None observed. ^ ^ Effective Oate: May 5, 2014 Applicable Requirement #:T5 24 Compliance Status: Applicable Requirement Monitoring-Thepen^ittee shall perform visible emissions observations (VEC)on the exhaust sta^^ 002) according to the following schedule: ^ ^ ^ ^ a. At least one VEO shall be conductedon each unit thatoperatesforacumulative total of 20 hours or moreduring the calendar year. b. At least one VECshall be performed during each 200 hours of unit operation during the calendaryear. c. At least one VEO shall be pedormed during any unit operabilityvehfication testing conducted during t^^ Each VEC shall be performed forasufficient period of time to identify the presence of visible emissions. If no visible emissions are observed,anote to that effect should be recorded.l^lowever,if visible emissions are observed,avisible emissions evaluation (VEE) shall be conducted using 40 CFR Pad 50,AppendixA,Method9foraperiod of hot less than six minutes. If the average opacity exceeds 10 percent, modifications and/or repairs shall be performed to correct the problem and the corrective measures shall be recorded. If such corrective action fails to remedy the opacity problem, a VEEin accordance with 40 CFR Pad 50,Appendix A, Method 9, shall be pedormedforaperiod of atleast13minutes to determine compliance with the opacity limitsspecified in Conditions12and 13. (9VAC5-30-4gOE) Observation Unit removed in April, 2015. ^ Effective Oate: May 5, 2014 Applicable Requirement #:T5 25 Compliance Status: ^ ^ ^ ^ ^ ^ AppllcableReoulrement Recordkeeping-The permittee shall maintain records of all emission data and operating parameters necessary to demonstrate compliance with this permit The content and format of such records shall be arranged with the O records shall include, but are not limited to: a. The annual throughput of distillate oil (in gallons), kerosene (in gallons), and liquefy turbine (Ref. 002).The annual throughput shall be calculated monthly as the sum of each consecutive12-month period. b. Monthly and annual throughputs of natural gas (in cubic feet) forthe boilers (Ref. 003,004, and 005). Annual throughputs shall be calculated monthly as the sum of each consecutive 12 month period. c. All fuel supplier certifications d. The OEO-approved, pollutant-specific emission factors and the equations used to demonstrate compliance with the pounds per hour emissions limitations specified in Condition 5. e. Emissions calculations sufficient to vehfy compliance with the annual emission limitations in Condition 9. f. flours of operation for turbine (Ref. 002) g. Visible emission observation results of the boilers (Ref. 003 and 004)and turbine (Ref. 002)stacks, to include: (1) The date, time and name ofthe person performing each evaluation; (2) vVhether or not visible emissions are observed; (3) Modificationsand/or repairs performed,if applicable; and Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 11/28 (4) VEE results, if applicable. h. All CEM records. i. Maintenance and operatortraining records including the names oftrainees, the date oftraining and the nature of the training. j . Results of all stack tests and visible emissions evaluations. k.CEMScalibrationsandcalibrationchecks,percentoperatingtime,andexcessemissions. I.Scheduledandunscheduledmaintenanceandoperatortraining. m.yVrittenoperatingprocedures,scheduledandunscheduledmaintenanceandoperatortraining,asrequiredbyCondition 15 These records shall be available on site for inspection by the OEO and shall be currentforthe most recent five years. (9VAC5-50-30,9VAC5-30-4g0F,40CFR50 5ub^ 5/24/13Permit) Observation a. Unit removed in April, 2015. b. Fuel through put records on computer,seeattachmentF. c. AvailableseeO d. In computer program and stack tests.Verified emission factor used. e. On computer. f. Unit removed in April, 2015. glnlogbook.Frocedureverified. h. Available on computer and reports. i. Available, see B,Cand I.All records verified. j.Oh file and computer.Stack test and VEEs kept as required. kOn computer and repods. Records verified as kept. I. 5cheduled&unscheduledmaintenenaceand operatortraining keptoncomputer.SeeCand I. M.Available see example B.Cand I. All records kept fora5year period as required. effective Oa^e: May 5, 2014 Appiicabie Requirement #:T5 25 Compliance Status: ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Testing-The permitted facility shall be constructed so as to allow for emissions testing upon reasonable notice at any time using appropnatemethods. This includes constructing the facility/equipment such that volumetric flow rates and pollutant emission rates can be accurately determined by applicable test methods and providingastack or duct that is free from cyclonicflow. Sampling podsshallbeprovidedwhen requested attheappropriatelocationsand safe sampling platforms and access shall be provided. (9VAC5-40-30,9VAC5-30-4g0E&F,gVAC5-30-4g0B&CandCondition4ofthe5/24/13Permit) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement #:T5 27 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement TestingThepermitteeshallconduc^ and VOCfor each boiler (Ref. 003 and 004).The tests shall be performed on each boiler (Ref. 003 and 004)to determine compliance with the emission limits contained in Conditions7and 3.The tests shall be performed within 50 days after achieving the maximum production rate at which the boiler will be operated but in no event later than 130 days after stadup ofthe permitted boiler.Tests shall be conducted and reported and data reduced as set forth in^VAC 5-50 30. The details ofthe tests are to be arranged with the OEO.The permittee shall submitatest protocol at least 30 days phorto testing. One copy of the test results shall be submitted to the OEO within 50 days after test completion and shall conform Jul17,201703:59 Dominion - Bremo Power Station (40199) Page 12/28 to the test report format enclosedwitb this permit. (9VAC5-30-4908&Cand Condition 13ofthe5/24/13Permit) Observation Unit#3 tested on 04/15/14; and Unit#4 tested on 06/12/14. ^ ^ Effective Oate: May 5, 2014 Applicable Requirement #:T5 23 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Testing-Concurrentlywith the initial pertormancetests,Visible Emission Evaluations (VEE) in accordance w ^ Part 60,Appendix A, Method 9,shall also be conducted bythe permittee on each boiler (Ref.003 and 004). Each test shall consist of30 sets of 24 consecutive observations(at15secondintervals)toyieldasix minute average.The observation period may be reduced from 30 sets to lOsets if all 5-minute averages are less than lOpercent and all individual 15-secdnd observations are less than dr equal to 20 percent during the initial 60 minutes tests are to be arranged with the OEO.The permittee shall submitatest protocol at least 30 days prior to testing.The evaluation shall be performed within 130 days after startup. Should conditions prevent concurrent opacity observations, the OEO shall be notified in writing, within seven days, and visible emissions testing shall be rescheduled within 30 days Rescheduled testing shall be conducted under these copy of the test result shall be submitted to the OEO within 60 days after test completion and shall conform to the test repod format enclosed with this permit. (9VAC5-30-4908&CandCondition19of.the5/24/13Permit) Observation Onit#3 tested on 04/15/14; and 0nit#4 tested on 06/12/14. ^ ^ Effective Oate: May 5, 2014 Applicable Requirement #: T5 29 Compliance Status: ^ ^ ^ ^ ^ ^ ApplicableRequirement Testing-Upon request by the OEO, the permittee shall conduct additional stack tests to demonstrate compliance with the emission limits contained in this permit.Thedeta (9VAC5-30-4908&CandCondition20ofthe5/24/13Permit) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirements:T530 Compliance Status: ^ ^ ^ ^ ^ ^ ^ Applicable Requirement testing-Upon request bythe OEO,the permittee shall conduct additional VEEs in accordance with40CPR Part 60, AppendixA,Method9to demonstrate compliance with the visible emission limits contained in the permlt.The details ofthe tests shall be arrangedwith the OEO. (9VAC5-30-490S&CandCondition21ofthe5/24/13 Permit) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirements: T531 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Testing-lf testing is conducted in addition to the monitonng specified in this permit, the permittee shall use the appropriate method(s)inaccordancewithproceduresapproved bythe OEO. (9VAC5-30-490 E) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement #:T532 Compliance Status: ^ ^ ^ ^ ^ Applicable Requirement Reporting The permittee shall furnish written repods to the OEO of excess emissions from any process m o n i t o r OEMS onaquarterly basis,postmarked no laterthan the 30th day following the end ofthe calendar quarter.These reports shall include, but are hot limited to the following information: a. The magnitude of excess emissions, any conversion factors used in the calculation of excess emissions, and the date and time of commencement and completion of each period of excess emissions; b. Specific identification of each period of excess emissions that occurs during startups, shutdowns, and malfunctions of Jul 17,2017 08:59 Dominion - Bremo Power Station (40199) Page 13/28 the process, the nature and cause of the malfunction (if known), the corrective action taken or preventative m adopted; c. Thedate and timeidentifyingeach period d zero and span checks and the nature of the system repairs or adjustments; and d. yVhennoexcessemissionshaveoccurredorthecontinuousmonitoringsystemshavenotbeen inoperative, r e p a ^ adjusted, such information shall be stated in that report. (9VAC5-30-490B&CahdCondition15ofthe5/24/13Permit) Observation EERs submitted to OEO quaderly as required. Effective Oate: May 5, 2014 Applicable Requirement #:T5 33 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Reporting-Thepermitteeshallfurnishwritten notification to the OEO, ofmalfunctionsoftheaffecte^ pollution control equipment that may cause excess emissions for more than one hour.Such notification shall be made as soon as practicable hut not later than tour daytime business hours after the malfunction is disc provideawritten statement givingallpertinentfactsBincludingtheestimated duration ofthebreakdown,within t^^ of discovery of the malfunction.Permittees subject to the requirements of9VAC5-40-50Cand9V^ requiredto provide thewrittenstatementprescribed in thisparagraphforfacilitiessubjecttothemonitoring requirements of9VAC5-40-40and9VAC5-50-40.yVhentheconditioncausingthefailureormalfunctionhasbeenco^^ equipment is again in operation, the pehmit^eeshall notify the OEO in writing. (gVAC5-30^0S&CandCondition25ofthe5/24/13 Permit) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement #:T5 34 Applicable Requirement Reciprocating Internal Combustion Engines-(Ref. 007) Compliance S t a t u s : ^ ^ ^ ^ ^ ^ Limitations-Except where this permit is more restrictive, the stationary recipr^^ (Ref. 007) shall be operated in compliance with the requirements of 40 CPR 53, Subpart 2^2^. (9VAC5-30-4g0S&Cand40CPR53Subpart^^) Observation ComplyingwithRICEMACT,007isthePirepumpdieselfiredandtheCatemiller200kyVgenerator,seeEand records. Effective Oate: May 5, 2014 Applicable Requirement #:T5 35 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Limitations-The stationary RICE(Ref. 007) shall comply with the maintenance requirements specified in sectionsl(a) through (c)ofTable 2c to S u b p a r t ^ ^ : a. Changeoilandfilterevery500hoursofoperationorannually,whichevercomesfirst,oratanextendedfrequencyif utilizing an oil analysis program as described in ?53.6625(i) or (j^ b. Inspect air cleaner everyl,000 hours of operation or annually,whichever comesfirst and replace as necessary; and c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. (gVAC5-30-4908&C,9VAC5-50-90,9VAC 5-50-100, 40CPR53.5502,and40CPR 53, Subpart2^2^) Observation Maintenace that is required is completed by Oominion and contract employees.SeeEandlfor example records. Effective Oate: May 5, 2014 Applicable Requirement#:T535 Compliance S t a t u s : ^ ^ ^ ^ ^ ^ ApplicableRequirement Limitations-Ouringperiodsofstadupthepermitteemustminimi^ethetimespentatidlefortheemergencygenerator(Ref. 007)andminimizetheengine^sstartuptimetoaperiodneededforappropriateandsafeloadingoftheengine,notto exceed 30 minutes, afterwhich time the non-startup emission limitations apply. Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 14/28 (9VAC5-30-490 8 & C , 40 CPR 53.5525(h), and40CPR 53 S u b p a d 2 ^ ) Observation Complying with RICE MACT,007 is the Pire pump di records. ^ ^ Effective Oate: May 5, 2014 Applicable Requirement #: T5 37 Compliance Status: Applicable Requirement Limitations-The stationary RICE (Ref. 007) must be operated in accordance with the following: ^ ^ ^ ^ ^ a. Any operation other than emergency operation, maintenance and testing, and operation in non-emergency situa^ 50 hours peryear,as permitted in this condition,is prohibited. b. ThepermitteemayoperatetheemergencystationaryRICEforthepurposeofmaintenancechecksand readiness testing,provided that the tests are recommended by Federal,State or local government, the manufacturer,the vendor, or the insurance company associated with the engine. Maintenance checks and readiness testing of such units is limited to 100 hours per year.The owner or operator may petition the Administratorfor approval of additional hours to be used for maintenance checks and readiness testing,butapetition is not required if the owner or operate indicatingthatPederal, State, orlocalstandardsrequiremaintenanceandtestingofemergencyRICE beyond lOOhours peryear. (9VAC5-30-490S&Cand40CFR 53.5540(f)) Observation Fire pump and emergency generator are only used for emergencies or periodic maintenances seeEand I. Effective Oate:May 5, 2014 Applicable Requirement #:T533 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Monitoring-The permittee shall install non-resettable hour meter on the stationary RICE provided with adequate access for inspection. (gVAC5-30-490S&Cand40 CFR 53.5525(f)) Observation Non-resettable meter in use reading 5579.Ihours on 05/01/17. Effective Oate: May 5, 2014 Applicable Requirement#:T539 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Monitoring-The permittee must operate and maintain the stationary RICE (Ref. 007) and after-treatment control dev^ any)according to the manufacturers emission related written instructions or developa provide to the extent practicable for the maintenance and operation of the engine inamanner consistent with good air pollution control practice for minimizing emissions. (9VAC5-30-490S&C,40CFR53.5525(e),and40CFR53.5540) Observation Procedures and PM in place, see attachmentsEahdl Effective Oate: May 5, 2014 Applicable Requirement #:T540 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Monitoring-The permittee must bein compliance with the emission limitations, operating limitations, and other requirements in 40 CFR 53 Subpad2^2^ that applyto the stationary RICE (Ref. 007), at all times. At all times the permittee mu and maintain the stationary RICE (Ref. 007), including associated air pollution control equipment and monitoring equipment, inamanner consistent with safety and good air pollution control practices for minimizing emissions.The general duty to minimize emissions does not require the permittee to make any further efforts t^ standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administratorwhich may include,but is n operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (9VAC5-30-490S&Cand40CFR53.5505) Observation Units are in compliance with 40 CFR 53 Subpad2^2: as required. Effective Oate: May 5, 2014 Applicable Requirement Jul 17, 2017 08:59 Applicable Requirement #:T541 Dominion - Bremo Power Station (40199) Compliance Status: ^ ^ ^ ^ ^ ^ Page 15/28 Recordkeeping-Tbepermitteesball maintain recordsofall emission dataandoperatingparametersnecessaryto demonstrate compliance witbtbispermit.Tbe content and format of sucb records shall be arranged witb tbe OEO.These records shall include, but are not limited to: a. Maintenance conducted on the stationary RICE (Ref. 007) in orderto demonstrate that each engine is operated and maintained according to the maintenance plan required by Condition 39. b. Annual hours of operation ofthe stationary RICE(Ref. 007) that is recorded through the non-resettabl^ owner or operator must document bow many hours are spent for emergency operation, including what classified the operation asemergency,andhowmanyhoursarespentfornon-emergencyoperation. These records shall be available for inspection by the OEO and shall be current for the most recent five years. (9VAC5-30-490S&Cand40CFR 53.5555) Observation Recordsavailable,seeattachmentsEandl. ^ Effective Oate:May 5, 2014 Applicable Requirement #:T542 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Testing-lftestingisconductedinadditiontothemonitoringspecifiedinthispermit,thepermitteeshallu method(s) in accordance with procedures approved by the OEO. (9VAC5-30-490S&C) Observation Reviewed witb facility representative. Effective Oate: May 5, 2014 Applicable Requirement #:T5 43 Compliance Status: ^ ^ ^ ! ^ ^ Applicable Requirement Reporting-Thepermitteemustreportanyfailuretopertormthemanagementpracticesin Condition 35form RICE (Ref 007), on tbe schedule required and tbe federal,state or local law underwbicb tbe risk was deemed unacceptable. (9VAC5-30-490S&Cand40CFR53.5502) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement InsignificantEmission Units Applicable Requirement #:T5 44 Compliance Status: ^ ^ ^ ^ ^ ^ ^ Insignificant Emission Units-The following emission units at the facility are identified in the application as insignificant emission units under9VAC 5-30-720: Emission Unit No. Emission Unit Oescription Citation Pollutant(s)Emitted(9VAC5-30-720S) Rated Capacity (9VAC 5^30-720C) 151 Lube Oil Systems/vVaste Oil Systems/hydraulic Oil Systems 9VAC5-30-720S VOC IS-3 275 Gallon Gasoline Dispensing Station & Tank 9 VAC 5-80-720B OC Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 16/28 IS-4 500 Gallon Kerosene Tank 9 VAC 5-80-720B VOC IS-8 Gravel Roads 9 VAC 5-80-720B PM-10 IS-9 Sand Blasters (1) 9 VAC 5-80-720B PM-10 IS-10 Sewage Treatment 9 VAC 5-80-720B VOC IS-12 Ash Storage Ponds 9 VAC 5-80-720 B PM-10 IS-14 Lime Slurry Tank 9 VAC 5-80-720B PM-10 IS-15 275 Gallon Fire Pump Diesel Tank 9 VAC-5-80-720B VOC 006 Natural gas-fired pipeline heater 9 VAC 5-80-720C 4.277 MMBtu/hr / These emission units are presumed to be in compliance with all requirements of the federal Clean Air Act as may apply. Based on this presumption, no monitoring, recordkeeping, or repoding shall be required for these emission units in accordance with 9 VAC 5-80-490 C, E and F. Observation Reviewed with facility representative. Units verified as correct. Effective Date: May 5, 2014 Applicable Requirement Jul 17, 2017 08:59 Applicable Requirement #: T5 45 Compliance Status: ' Dominion - Bremo Power Station (40199) Page 17/28 PemnitShield&lnapplicabie Requirements Permit Shield and Inapplicable Requirements-Compliance wit^ compliance with all applicable requirements in effect as of the permit issuance date as identified in this permit.This permit shield covers only those applicable requirements covered by terms and conditions in this permit and the following requirements which have been specifically identified as being not applicable to this permitted facility; Citation Title of Citation Description of Applicability 40CPR50SubpadsO Standards of Pedormance for Possil-Puel-Pired Steam Generators for vVhich Construction is Commenced After August 17, 1971 Not applicable for Units 003 and 004; Units constructed priortoAugust17,1971 40CPR50SubpadDa Standards ofPeddrmance for Electric Utility Steam Generating Units for vVhichConstruct^^^^ September 13, 1973 Not applicable for Units 003 and 004; Units constructed priorto Septembers,1973 40CPR50SubpadOb Standards of Pedormance for Industrial-Commercial-lnstitutional Steam Generating Units Not applicable Units 003 and 004; Units constructed priortoJune19,1934 40CPR50SubpadKb Standards of Pedormance for Volatile Organic Liquid Storage Vessels Not applicable to storage tanks at facility due to low vapor pressure of stored liquids 40CPR50SubpadV Standards of Pedormance for Coai Preparation and Processing Piants Not applicable to facility; facility no longer handles or combusts coal 40CPR50SubpadGG Standards of Pedormance for Stationary GasTurbines Not applicable to Unit 002; Unit less than lOmillionSTU per hour 40CPR50SubpadKKKK Standards ofPedormance for Stationary CombustionTurbines Not applicable to Unit 002; unit constructed priorto first applicability date in NSPS 40CPR53Subpad^r^^ National Emission Standards for hazardous Air Pollutants for Stationary CombustionTurbines Not applicable to Unit 002; the unit is considered an existing stationary combustion turbine. 40CPR53SubpadUUUUU National Emission Standards for hazardous Air Pollutants for Coal-and Oil-Pired Electric Utility Steam Generating Units Not applicable for Units 003 and 004;the units burn only natural gas 40CPR53SubpadJ^J National Emission Standards for ^azardous Air Pollutants for Industrial, Commercial, and Institutional Sellers Area Sources Not applicable for Units 003, 004, 005, or005, in accordance with 753.11195(e) 40CPR54 Compliance Assurance Monitoring Not applicable for Units 003 and 004; units do not meet the general applicability in 754.2(a). Not applicable for Units 002 or 005 since each unit does not useacontrol device to meet the emission standards. Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 18/28 Nothing in this permit shield shall alterthe provisions of Section 303 ofthe federal Clean Air Act, including the authority of the administrator underthat section,the liability ofthe ownerfor any violation of applicable requirements priori^ time of permit issuance, or tbe ability to obtain information by (i) the administrator pursuant to Section114of the federal Clean Air Act, (ii) the Board pursuant to Section10.1-1314orSectipon 10.1-1315ofthe Virginia Air Pollution Control Law or (ill) the Oepadment pursuant to Section 10.1-1307.3 of the Virginia Air Pollution Control Law. (9VAC5-30-500C) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement General Conditions Applicable Requirement s: T5 45 Compliance Status: ^ ^ ^ ^ ^ Federal Enforceability-AII terms and conditions in this permit are enforceable bythe administrator and citizens underthe federal Clean Air Act, except those that have been designated as only state-enforceable. (9VAC5-30-490N) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement #:T547 ComplianceStatus:^l^4^ll^l^ Aoolicable Requirement Permit Expiration-This permit hasafixed term offiveyears.The expiration date of issuance. Unless the owner submitsatimely and complete application for renewal to the Oepadment consistent with the requirements of^VAC 5-30-430,the right of the facility to operate shall be terminated upon permit expiration. (gVAC5-30-430B,CandP,9VAC5^30-4g0Oand9VAC5-30-530 B) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement#:T543 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Permit Expiration-The owner shall submit an application for renewal at least six months but no earlierthan13months priorto the date of permit expiration. (gVAC5-30-430B,CandP,9VAC5-30-4g0Oand9VAC5-30-530B) Observation Reviewed with facility representative Effective Oate:May 5, 2014 Applicable Requirement#:T549 Compliance Status: ^ ^ ^ ^ ^ ^ ApplicableRequiremeht Penult Expiration-lf an applicant submitsatimely and complete application for an initial permit or renewal underthis section,the failure of the source to haveapermitortbe operation ofthe source withoutapermit shall not beaviolation of Adicle 3, Pad II of9VAC5Chapter30, until the Board takesfinal action on theapplicati^ (0VAC5-30-430B,CandP,9VAC5-30-4g0Oand9VAC5-30-530B) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement #: T5 50 Comoiiance Status: ^ ^ 4 1 1 ^ 4 ^ Applicable Requirement Permit Expiration-No source shall operate afterthe time that it is required to submitatimely and complete application under subsectionsCandOof^VAC 5-30-430 forarenewal permit, except in compliance withapermit issued under Adicle3,Padllof9VAC5Chapter30. (gVAC5-30-430B,CandP,9VAC5-30-490Oand9VAC5-30-530B) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement #:T551 Compliance Status: ^ ^ ^ ^ ^ ApplicableRequiremeht Permit Expiration-lf an applicant submitsatimely and complete application under section^VAC 5-30-430 forapermit Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 19/28 renewal but the Board fails to issue or deny the renewal permit before the end of the term of the previous permit, (i) the previous permit shall not expire until the renewal permit has been issued or denied and (ii) all the terms and conditions of thepreviouspermit,includinganypermitshieldgrantedpursuantto9VAC5-30^500,shal^ the application is determined to be complete until the renewal permit is issued or denied. (9VAC5-30-430B,CandP,9VAC5-30-4g0Oand9VAC5-30-530B) Observation Reviewed with facility representative. Effective Oate: May 5. 2014 Applicable Requirement #:T5 52 Compliance Status: ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Permit Expiration-The protection under subsectionsE.1andP.5(ii) of sectiongVAC5-30-430Pshall cease to apply if, subsequent to the completeness determination made pursuant section9VAC5-30-430O,the applicant fails to submit by thedeadlinespecifiedinwntingbytheBoardanyadditionalinformationidentifiedas application. (gVAC5-30-430B,CandP,9VAC5-30-490Oand9VAC5-30-530B) Observation Reviewed with facility representative Effective Oate: May 5, 2014 Applicable Requirement #:T5 53 Compliance Status: ^ ^ ^ ^ ^ ^ ^ ApplicableRequiremeht RecordkeepingandRepoding-Allrecordsofmonitoringinformationmaintainedtodemonstratecompliancewiththeterms and conditions of this permit shall contain, where applicable, the following: a. The date, place as defined in the permit, and time of sampling ormeasurements. b. The date(s)analyses were pedormed. c. The company or entity that pedormedtheanalyses. d. The analytical techniques or methods used. e. The results of such analyses. f. Theoperatingconditionsexistingatthetimeofsamplingormeasurement. (9VAC5-30-490P) Observation Monitoring ihformationa-fin compliance at this facility. Effective Oate: May 5, 2014 Applicable Requirement #:T5 54 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Recordkeeping and Repoding-Records of all monitoring data and supped information shall be retained for at least five years from the date Of the monitoring sample, measurement, repod, or application. Suppod information includes all calibration and maintenancerecordsand all original strip-chadrecordingsforcontinuous monitoring i n s t r u m e n t a l copies of all repods required by the permit. (gVAC5 50 490E) Observation Records retained for5year period as required. Effective Oate: May 5, 2014 Applicable Requirement #:T5 55 Compliance Status: ^ ^ ^ ^ ^ ^ ^ Applicable Requirement RecordkeepingandRepoding Thepermit^eeshallsubmittheresultsofmonitoringconta^ to OEO no laterthanMarchlandSeptemberlof each calendaryear.Thisrepod must be signed byaresponsible official, consistentwith^VAC 5-30-430 O,and shall include: a.The time period included in the repod.The time periods to be addressed are Januarylto June 30 and Julylto Oecember31 Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 20 / 28 b. All deviations from permit requirements. For purposes of this permit, deviations include, but are not limited to: (1) Exceedance of emissions limitations or operational restrictions: (2) Excursions from control device operating parameter requirements, as documented by continuous emission monitoring, periodic monitoring,or Compliance Assurance Monitoring(OAM) which indicates an exceedance of emission limited operational restrictions: or, ^ (3) Pailure to meetmonitoring,recordkeeping,or repoding requirements contained in this permit. c. lfthere were no deviations from permit conditions during the time period,the permittee shall includeastat^ report that ?no deviations from permit requirements occurred during this semi-annual repoding period?. (9VAC5-50-490P) Observation 5emi-annualMonitoring&OeviatipnRepods submitted as required. Effective Oate: May 5,2014 Applicable Requirement ^:T5 55 ComplianceStatus:^^^^^^ AoolicableReouirement Annual Compliance Certification-Exclusive of any reporting required to assure compliance with the terms and conditions ofthis permit or as pad ofaschedule of compliance contained in this permit, the penmittee shall submit to EPAand OEO no later than Marchleachcalendaryearacertificationofcompliance with all terms and c o n d i t ^ emission limitation standards orworkpractices.The compliance certification shall comply with such additional requirements that may be specified pursuant to 5ection114(a^)and5ection 504(b) of the ^ certification shall be signed byaresponsible official,consistent withgVAC 5-50-430 0,and shall include: a. The time period included in the cedification.The time period to be addressed is January1toOecember31. b. The identification of each tenm or condition of the permit that is the basis of the cedification. c. The compliance status. d. vVhether compliance was continuous or intermittent, and if not continuous, documentation of each incident of noncompliance. e. ConsistentwithsubsectiongVAC 5-50-490 E,the method or methods used for determining the compliance status of the source atthe time of certification and over the reporting period f^uchotherfacts as the permit may require to determine the compliance status ofthe source. g.One copy ofthe annual compliancecertification shall be sent to EPAinelectronicformat only. The c e r t ^ should be sent to the following electronic mailing address: R3^APO^Permits^epa.gov (9VAC 5-50-490 K.5) Observation ACC with informationa-gsubmitted as required. Effective Oate: May 5, 2014 Applicable Requirement ^:T5 57 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Permit Deviation Repoding-The permittee shall notify the OEO, within four daytime business hours after d deviations from permit requirements which may cause excess emissions for more than one hour,including those attributable to upset conditions as may be defined in this permit. In addition,within 14days of the discovery, the p e r m i t shall provideawritten statement explaining the problem,any corrective actions or preventative measures taken,and the estimated duration ofthe permit deviation.The occurtehce should also be reported in the next semi-annual compliance monitoringrepodpursuanttoOeneralCondition55ofthispermit. (9VAC5-50-490P.2) Observation Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 21 /28 Pacilityisawareofrepodingdeadlinesforpermitdeviation. ^ ^ Effective Oate: May 5,2014 Applicable Requirement ^:T5 55 Compliance Status: ^ ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Pailure/MalfunctionRepoding-lnthe malfunctions in suchamanner that may cause excess emissions for more than one hour,the owner shall,as soon as practicable but no later than four daytime business hours after the malfunction is discovered, notify the OEO, by facsimile transmission, telephoneortelegraphofsuchfailureormalfunctionandshallwithin14daysofdiscoveryp^^ statement giving all pedinent facts, including the estimated duration of the breakdown. Owners subject to the requirements of9VAC5-40-50Cand9VAC5-50-50Care not required to provide the written statement p r ^ paragraph forfacilities subject to the monitoring requirements of9VAC 5-40-40 and9VAC 5-50-40.vVhen the condition causing the failure or malfunction has been corrected and the equipment is again in operation, the owner shaii no OEO (9VAC5-20-150C) Observation Facility is aware of reporting deadlines for failure/malfunction. Effective Oate: May 5, 2014 Applicable Requirement ^:T5 59 Compliance Status: ^ ^ ^ ^ ^ ^ ^ ^ Applicable Requirement 5everability-The terms of this permitareseverable.lt any condition,requirement or portion of the permit is held invalid or inapplicable under any circumstance, such invalidity or inapplicability shall not affect or impair the remaining conditions, requirements, or portions of the permit (9VAC5-50-490O.1) Observation Reviewed with facility representative Effective Oate: May 5, 2014 Applicable Requirement ^:T5 50 Compliance Status: ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Outy to Comply-The permittee shall comply with all terms and conditions of this permit. Any permit noncompliance constitutesaviolation of the federal Clean Air Act orthe Virginia Air Pollution Control Law or both and is grounds for enforcement action; for permit termination,revocation and reissuance,or modification; or,for denial o f a p e ^ application. (9VAC5-50^490O.2) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement ^:T551 Compliance Status: ^ ^ ^ 1 ^ ^ Applicable Requirement Need to Fialt or Reduce Activity notaOefense-lt shall not beadefenseforapermittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. (9VAC5-50-490O.3) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement ^:T5 52 Compliance Status: ^ ^ ^ ^ ^ Applicable Requirement Permit Modification-Apbysical change in, or change in the method of operation of, this stationa topermit^ingunderStateRegulations9VAC5-50-50,9VAC5-50-1100,9VAC5-50-1505,or9VAC5-50^^ requireapermit modification and/or revisions except as may be authorized in any approved alternative operating scenarios (9VAC5-50-490OandL,9VAC5-50-550and9VAC 5-50-550) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement ^:T5 53 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Property Rights Thepermit does not conveyanypropertyrightsofanysort, or any exclusive privilege Jul 17, 2017 08:59 Dominion - Bremo Power Station (40199) Page 22/28 (9VAC5-50-4g0O.5) Observation Reviewed with facility representative. Effective Oate: May 5, 2014 Applicable Requirement ^:T5 54 Compliance Status: ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Outy to Submit Information-The permittee shall furnish to the Board,withinareasonable time, any information that the Board may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Board copies of records required to be kept by the permit and, for information claimed to be confidential, the permittee shall furnish such records to the Board alongwithaclaim of confidentiality. (9VAC5-50-4g0O.5) Observation AU&ES submitted annually as required. Effective Oate: May 5, 2014 Applicable Requirement ^:T5 55 Compliance Status: Applicable Requirement Out^ to Submit information Any docum shall containacedificationbyaresponsible official that meets the requirements of^VAC 5-50-430 0. (9VAC5-50-490K.1) Observation All repods submitted contain document certification as required. ^ ^ ^ ^ ^ Effective Oate: May 5, 2014 Applicable Requirement ^:T5 55 Compliance Status: ^ ^ ^ ^ ^ Applicable Requirement Outy to Pay Permit Pees-The owner of any source forwhichapermitunder^VAC 5-50-350 throughgVAC 5-50-700 was issued shall pay permit fees consistent with the requirements of9VAC5^30-310etseq.The actual emissions covered by the permit program fees for the preceding year shaii be calculated by tbe owner and submitted to the Oepadment by April 15of each year.The calculations and final amount of emissions are subject to verification and fin determination byme Department. (gVAC5-30-490ri) Observation Permittees paid as required ^ Effective Oate: May 5, 2014 Applicable Requirement ^: T5 57 Compliance Status: ^ ^ ^ ^ ^ ^ Applicable Requirement Fugitive Oust Emission Standards-Ouring the operation ofastationary source or any other building,structure, facility,or installation, no owner or other person shall cause or permit any materials or property to be handled, transported, stored, used, constructed, altered, repaired, or demolished without taking reasonable precautions to prevent padiculate matter from becoming airborne. Such reasonable precautions may include, but are not limited to, the following: a. Use, where possible, of water or chemicals for control of dust in the demolition of existing buildings or structures, construction operations, the grading of roads, or the clearing of land: b Application of asphalt, water,or suitable chemicals on dirt roads, materials stockpiles, and other sudaces which may createairbornedust:thepavingofroadwaysandthemaintainingoftheminacleancondition: c. Installation and use ofhoods,fans, and fabric filters to enclose and vent the handling of dusty material.Adequate containment methods shall be employed during sandblasting or other similar operations: d. Open equipment for conveying ortransporting material likely to create objectionableair pollution when airbon^ covered ortreated in an equally effective manner at all times when in motion; and, e The prompt removal of spilled ortracked dirt or otber materials from paved streets and of dried sediments resulting from soil erosion (gVAC5-40-20E,9VAC5-50-90and9VAC 5-50-50) Observation Jul17,201703:59 Dominion - Bremo Power Station (40199) Page 23/ 28 Reasonable precautions Elective Oate: May 5, 2014 Applicable Requirement ^:T5 68 Compliance Status: ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Startup. Shutdown.and Malfunction-Atall times, including periodsofstadup. shutdown, and malfunction.ownerssball. totheextentpracticable.maintainandoperateanyaffe^^^ mannerconsistentwithairpollution control practicesforminimi^ing emissions. Oeterminationofwhetheracceptable operating and maintenance proceduresarebeingusedwill be based on information available to theSoard.which may include, butisnotlimitedto. m o n i t o r s and inspection ot tbe source. (9VAC5-50-20Eand9VAC5-40-20E) Observation Oood ARC practices used at this facility. Elective Oate: May 5. 2014 Applicable Requirement^:T669 Compliance Status: ^ ^ ^ ^ ^ Applicable Requirement AlternativeOperatingScenarios-Contemporaneouslywithmakingachangebetweenreasonablyan^ scenarios identified in this permit, the permitteeshall record inalog at tbe permitted facilityarecord of the scenario under which itisoperating.Thepermitshielddescribedin9VAC5-80-600shallextendtoalltermsandconditionsundereach such operating scenano.The terms and conditions of each such alternative scenario shall meet al^^ requirements including the requirements of9VAC5Chapter 80. Adicle 5. (9VAC5-80-490J) Observation No alternative scenarios used at this facility. Effective Oate: May 5. 2014 ApplicableRequirement^:T570 Compliance Status: ^ ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Inspection and Entry Requirements-The permittee shall allow OEO. upon presentation of credentials and other documents asmayberequired bylaw, topedormthefollowing: a. Enter upon the premises where the sourceis located or emissions-related activity is conducted.orwhere records must be kept undertbe terms and conditions of tbe permit b. l^ave access to and copy.at reasonable times, any records that must be kept under the terms and conditions of tbe permit c. Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under tbe permit. d. Sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the permit or applicable requirements (9VAC5-80-490K.2) Observation Source allowed inspection. Effective Oate:May 5. 2014 Applicable Requirement^:T571 Compliance S t a t u s : ^ ^ ^ ^ ^ ^ ^ Applicable Requirement Reopening ForCause-Thepermitshallbereopenedbythe8oardifadditionalfederalrequirementsbecomeapplicablet^ amajorsourcewitharemainingpermittermofthreeyearsormore. Such reopening shall becompletednolaterthan months after promulgation ofthe applicable requirement. No such reopening is required ifthe effective date ofthe requirementislatertbantbedateonwbicbtbepermitisduetoexpire.unlesstbeoriginalpermitor conditions has been extended pursuant to9VAC6-80-430F. a. The permit shall be reopened if the Soardorthe administrator determines that the permit containsamaterial mistake or that inaccurate statements were made in establishing the emissions standards or otherterms or conditions of the permit. b. The permit shall be reopened ifthe administrator ortheSoard determines that the permit must be revised or revoked to Jul 17,2017 08:59 Dominion - Bremo Power Station (40199) Page 24 / 28 assure compliance with the applicable requirements. c. The permit shall not be reopened by the Board if additional applicable state requirements become applicable to a major source prior to the expiration date established under 9 VAC 5-80-490 D. (9 VAC 5-80-490 L Observation Reviewed with facility representative. ' Effective Date: May 5, 2014 Applicable Requirement #: T5 72 Compliance Status: ffltSUBflBBIlWk Applicable Requirement Permit Availability - Within five days after receipt of the issued permit, the permittee shall maintain the permit on the premises for which the permit has been issued and shall make the permit immediately available to DEQ upon request. (9 VAC 5-80-510 G) Observation Permit copy kept on premises as required. ' Effective Date: May 5, 2014 Applicable Requirement #: T5 73 Compliance Status: Applicable Requirement Transfer of Permits - No person shall transfer a permit from one location to another, unless authorized under 9 VAC 5-80-130, or from one piece of equipment to another. (9 VAC 5-80-520) Observation Reviewed with facility representative. Effective Date: May 5, 2014 Applicable Requirement #: T5 74 Compliance Status: IfilgffjPfEflEEl Applicable Requirement Transfer of Permits - In the case of a transfer of ownership of a stationary source, the new owner shall comply with any current permit issued to the previous owner. The new owner shall notify the Board of the change in ownership within 30 days of the transfer and shall comply with the requirements of 9 VAC 5-80-560. (9 VAC 5-80-520) Observation Reviewed with facility representative. Effective Date: May 5, 2014 Applicable Requirement #: T5 75 Compliance Status: Clean Air Interstate Rule (CAIR) Permit - The permittee shall comply with all applicable CAIR requirements (9 VAC 5-140-1010 et seq., 9 VAC 5-140-2010 et seq., 9 VAC 5-140-3010 et seq., 9 VAC 5-140-5010 et seq., and 40 CFR Part 96) by the compliance date in the respective Pad of 9 VAC 5 Chapter 140, as contained in the CAIR Permit. The CAIR Permit is attached to this document and expires upon expiration of this Article 3 permit. (9 VAC 5-50-490, 40 CFR Pad 96, and 9 VAC 5 Chapter 140) Observation Complying based on EPA reports. Jul 17,2017 08:59 Dominion - Bremo Power Station (40199) Page 28 / 28 Unit 4 operating Screen UNIT! PC01 PPM (1 min', 1 • 3 f . ooo QC01E LB'MM (1 m!r . o ol QC31M LB'HR (1 n rl QNOX PPM (1 min)1 QNOXE LB MM(1 nm\ QNOXM LB'HR 1 mini Q02D % (1 min) -.11 CAL o c ol MNT OOC QC01M LB'HR (I min) . o ol OOC CAL QNOX PPM (1 min) . o o o MNT QNOXE ISMM limit!) "1 OOC QNOXM LE.HR (1 min) Q6MW m (1 min) o MNT QGiSVHSC'HRllmml 'I °l OOC 1 STARTUP Q02D % (1 min) 0 0 01 20 . I I maa 3 ) SHUTDOWN . oooj QC01M LBJHR (IS mini . oo CNOX£LciNIM 1Srnln) QN0XVlBi'HR 15min .oo*] . o K O t £ U M I 1 hour) . 0 0 •] QCOlMLBiHR 1 hcur) . oo QNOKE LB/MM (1 hour) QNOXV LB.'HR 11 hcur) 14 100.00 X- MNT 80.00*- 3 OOC 60.00 X- 1.2 40.00 X 0.8 20.00 X- ij.4 CAL o.oo X' OOC M9 9 9 9 W * * * * * * * KjuiiijL&uiuioo^^M OIOUIOUOUIOUIOUIO Comm. Status Lastpolh UNITCmjNE 3 3 STARTUP .ooo] •1 — BRPS.BR03.QCO1E.001M — BRPS.BR03.QNOXE.001M SHUTDOWN tnrnn its OCQ1E LBJWM (IS m.n CEMS HOUR CAL MNT QGMWMW(1 min) 24 3HIFM mr-BTU HR 1 mm) ) ) 3 UNIT ONLINE CAL QC01E LB'MH (1 mini CAL Comm Status Last pod: 6nC01714:2 3 MNT 21.1 OH W mrrBTJ.'HS 11 irmi PC01 PPM <1 min) CEMS MINUTE 100.00 X. 0 0 01 80.00 X- QC31M LBiHR (15 min) . oo 60.00 X- QN0XE'.B.TO 1Smin) . o o oJ QCaiELBtMMftSnin) 40.00 X 20.00 X- BRPS.BR04.QNOXE.001M ,-2 Irj Example of Training Record (Training) BURNER CONTROL Purpose the burner subsystem control shall define the start, stop, and trip operations of the burner and Igniter. Control Philosophy The following control philosophy is typical for each burner (Burner A1 shown, all other burners are identical except tag numbers). BurnerA1 Igniter Control Start-up of the Burner A1 Igniter is initiated by the operator from the HMI only. Shutdown of the Burner A1 Igniter is initiated from the control room. The Burner A1 Igniter start permissives are satisfied and the igniter is ready to start when all of the following conditions occur • • • » • • « « • Furnace Firing Permissives Satisfied Igniter Gas Header Safety SSV Not Tripped Igniter Gas Header Pressure Not Low-Low Igniter Gas Header Pressure Not High-High Burner A1 Skotch Valve Inlet and Outlet Closed Burner A1 Main Flame Not On Burner A1 Air Registers at Light-Off Position Burner A1 No Igniter Trip Condition Detected Scanner Cooling Air Blower Outlet Pressure Adequate (Initially set at >TBD) After all permissives have been met, the operator may start the Burner A1 Igniter from the HMI. The following sequence will proceed automatically: 1. 2. 3 4. Burner A1 Igniter HEI is Energized (3-IG-EE-1A1) Burner A1 Igniter Skotch Valve Commanded to Open (3-IG-SOV-XCV1A1) Begin 10 Second trial for ignition Period when Burner A1 Igniter Gas Skotch Valve is Not Closed De-energize Igniter Ignition Transformer at End of 10 Second Trial for Ignition Period The Burner A1 Igniter is in service when all of the following conditions occur • • Burner A1 Igniter Flame On (3-BMS-BS-2A1) Burner A1 Igniter Gas Skotch Valve Inlet and Outlet Not Closed (3-IG-ZSC-XCV1A1A; 3-IG-ZSCXCV1A1B) DQ56873-4 -__± 6/28/13 -32013 THE BABCOCK & WILCOX COMPANY. ALL RIGHTS RESERVED. This document Is the property ol Tho Bebcock & Wilcox Company (B&W) and is 'CONFIDENTIAL AND PROPRIETARY' to B&W. Recipient and/or lis representatives have, by receiving same, agreed lo maintain ill confidentiality and shall not reproduce, copy, disclose or disseminate the contents. In whole or In part, to any person or entity other than the Recipient and/or Recipient's representatives without the prior written consent of B&W." Engineering Report DQ56874-4 BURNER CONTROL Under normal operation, once the Burner A1 Main Flame has been proven, the igniter will be removed from service and the following actions will occur simultaneously: » « Burner At Igniter Gas Skotch Valve Commanded to Close (3-IG-SOV-XCV1A1) De-energize Burner A1 Igniter HEI (3-IG-EE-1A1) The operator may stop the Burner At Igniter at any time during the start sequence or when the Igniter is in operation by activating the Burner At Igniter Stop Pushbutton on the HMI. The following actions will occur simultaneously: • • Burner A1 Igniter Gas Skotch Valve Commanded lo Close (3-IG-SOV-XCV1A1) De-energize Burner A1 Igniter HEI (3-IG-EE-1 At) The Burner A1 Igniter is shutdown successfully when all of the following conditions occur . • • Burner A1 Igniter Gas Skotch Valve Inlet and Outlet Closed (3-IG-ZSC-XCV1A1A; 3-IG-ZSC-XCV1A1B) Burner A1 Igniter Not Tripped Burner A1 Igniter Start Not Initiated A Burner A1 Igniter trip is generated if any of the following conditions occur during start-up, shutdown, or when the igniter is in service: • • • « M R Activated Burner A1 Igniter Gas Vent Valve Failed to Close [delayed 5 seconds] Burner A1 Flame Failure Igniter Gas Header Trip When a Burner A1 Igniter trip condition occurs, all of the following actions will occur simultaneously: • • Burner At Igniter Gas Skotch Valve Commanded to Close (3-IG-SOV-XCV1A1) De-energize Burner A1 Igniter HEI (3-IG-EE-1A1) A Burner A1 Igniter Flame Failure occurs when all of the following conditions occur; • » « Burner At Igniter Gas Skotch Valve Commanded to Open (delayed 10 seconds) Burner A1 Igniter Not in Service Burner At Igniter Flame Rod Signal Loss DQS6873-4 ^ "02013 THE BABCOCK & WILCOX COMPANY. ALL RIGHTS RESERVED. 8/28/13 This document Is the property of The Babcock & Wilcox Company (B&W) and is "CONFIDENTIAL AND PROPRIETARY" to B&W. Recipient and/or its representatives have, by receiving same, agreed to maintain Its confidentiality and shall not reproduce, copy, disclose or disseminate the contents. In whole or in part, to any person or entity other than the Recipient and/or Recipient's representatives without the prior written consent of B&W." Engineering Report DQ56874-4 BURNER CONTROL Burner A1 Control Start-up of Burner A1 is initiated by the operator from the HMI only. Shutdown of Burner At is initiated from the control room. The Burner At start permissives are satisfied and the burner Is ready to start when all of the following conditions occur: » , • • • • • • • . Furnace Firing Permissives Satisfied Burner Gas Header Pressure Not High-High (3-FG-PT-1) Burner Gas Header Valve Open (3-FG-ZSO-TV1) Burner At Main Gas Skotch Valve Inlet and Outlet Closed (3-FG-ZSC-XCV1A1A; 3-FG-ZSC-XCV1A1B) BurnerAI Main Gas Skotch Valve Manual Vent Valve Open (3-FG-ZSO-20A1) BurnerAI Igniter In Service Igniter Gas Header Pressure Not Low (3-IG-PT-1) BurnerAI No Trip Condition Detected Scanner Cooling Air Blower Outlet Pressure Adequate (Initially set at > TBD) Burner Gas Header Flow Control Valve Closed (0% Open) (3-FG-ZT-FCV1) Note: permissive is only for the first burner to be started. The subsequent burner does not need the control valve proven closed as part of its start permissive. After all permissives have been met, the operator may start Burner At from the HMI. The following will proceed automatically: 1. Burner At Main Gas Skotch Valve Commanded to Open (3 FG-SOV XCV1A1) Burner A1 is in service when all of the following conditions occur: • • BurnerAI Main Flame On (3-BMS-BS-1A1) Burner At Skotch Valve Inlet and Outlet Not Closed (3-FG-ZSC-XCV1A1A; 3-FG-ZSC-XCV1A1B) The operator may slop Burner At at any time during the start sequence or when the burner is In operation by activating the Burner At Stop Pushbutton on the HMI. The following action will occur. . Burner A1 Main Gas Skotch Valve Commanded to Close (3-FG-SOV-XCV1 At) Burner At is shutdown successfully when all of the following conditions occur: . • • Burner At Main Gas Skolch Valve Inlet and Outlet Closed (3-FG-ZSC-XCV1A1 A; 3-FG-ZSC-XCV1A1B) BurnerAI Not Tripped BurnerAI Start Not Initiated DQ56B73-4 -16•©2013 THE BABCOCK & WILCOX COMPANY. ALL RIGHTS RESERVED. 8/26713 This document Is the property ofthe Bsbcock 6 Wilcox Company (B&W) and Is "CONFIDENTIAL AND PROPRIETARY" to B&W. Recipient and/or its representatives have, by receiving same, agreed to maintain its confidentiality and shall not reproduce, copy, disclose or disseminate the contents. In whole or In part, to any person or entity other than the Recipient and/or Recipient's representatives without the prior written consent of B&W.' Engineering Report DQ56874-4 BURNER CONTROL A Burner A1 trip is generated if any of the following conditions occur during startup, shutdown or when the burner is in service: • • • • • MFT Activated Burner A1 Emergency Stop Pushbutton Activated Burner A1 Gas Vent Valve Failed to Close (delayed 5 seconds) Burner At Skotch Valve Manual Gas Vent Valve Closed (3-FG-ZSC-20A1) Burner At Flame Not On (3-BMS-BS-1A1) • Burner Gas Header Trip When a Burner At trip condition occurs, all of the following actions will occur: • Burner At Main Gas Skotch Valve Commanded to Close (3-FG430V-XCV1A1) BurnerAI Gas & Vent Valves Leak Test Leak testing of the Skotch Trifecta valve will be completed through the valve manufacturer's standard procedure. DQ56873-4 -17- "P2013 THE BABCOCK & WILCOX COMPANY. ALL RIGHTS RESERVED. . 8/28/13 : This document Is the property of The Babcock & Wilcox Company (B&W) and Is "CONFIDENTIAL AND PROPRIETARY" lo B&W. Recipient and/or Us representatives have, by receiving same, agreed lo maintain Its contidenliality and shall not reproduce, copy, disclose or disseminate the contents, in whole or In part, to any person or entity other than the Recipient and/or Recipient's representatives without the prior written consent ol B&W." Engineering Report DQ56874-4 BURNER CONTROL Interface Interfaces described below are required. Inputs to Operator • . BurnerAI Stop/Reset Pushbutton MFT Pushbutton (from BCS DCS) (By Others) Outputs to Operator • INDICATION - See Burner At Igniter Start Permissives - Reference Item 2 in General Requirements Section INDICATION -r Burner A1 Igniter In Service INDICATION - Burner At Igniter Shutdown INDICATION - Burner A1 Igniter Start Initiated INDICATION - Burner At Igniter Flame On INDICATION ^ BurnerAI Igniter Gas Skotch Valve Open INDICATION - Burner At Igniter Gas Skotch Valve Closed INDICATION - Burner At Igniter Trial for Ignition Timer Time Remaining INDICATION - See Burner At Start Permissives - Reference Item 2 in General Requirements Section INDICATION - Burner At In Service INDICATION - Burner At Shutdown INDICATION - Burner A I Start Initiated INDICATION Burner A1 Main Gas Skotch Valve Open INDICATION - BurnerAI Main Gas Skotch Valve Closed INDICATION - BurnerAI Manual Gas Vent Valve Open INDICATION - Burner At Manual Gas Vent Valve Closed INDICATION - Burner At Leak Test Started INDICATION - Burner A1 Leak Test Complete / DQ56873-4 -18"©2013 THE BABCOCK & WILCOX COMPANY. ALL RIGHTS RESERVED. 8/28/13 This document is Ihe property of The Babcock & Wilcox Company (B&W) and is "CONFIDENTIAL AND PROPRIETARY" lo B&W. Recipient and/or itsrepresentativeshave, by receiving same, agreed lo maintain lis confidentiality and shall not reproduce, copy, disclose or disseminate ihe contents. In whole or In part, to any person or entity other than Ihe Recipient and/or Recipient's representatives without the prior written consent of B&W." Engineering Report DQ56874-4 BURNER CONTROL • » • • • . • ALARM ALARM ALARM ALARM ALARM ALARM ALARM - See Burner Igniter Trip - Reference Hem 4 in General Requirements Section Burner At Igniter Gas Skotch Valve - Reference Item 11 in General Requirements Section Burner At Igniter - Reference Item 111n General Requirements Section See Burner Trip - Reference Item 4 in General Requirements Section Burner At Main Gas Skotch Valve - Reference Item 11 in General Requirements Section Burner At - Reference Item 11 in General Requirements Section Burner At Flame Scanner Fault Inputs from Process • • • • • . • . • • . o . • • . . • o Igniter Gas Header Pressure Not High-High (3-IG-PT-1) Igniter Gas Header Pressure Not Low-Low (3-IG-PT-1) Igniter Gas Header Pressure Not Low (3-IG-PT-1) Burner Gas Header Pressure Not High-High (3-FG-PT-1) Burner Gas Header Pressure Not Low-Low (3-FG-PT-1) Burner A1 Igniter Flame On (3-BMS-BS-2A1) Burner At Igniter Gas Skotch Automatic Vent Valve Open (3-IG-ZSO-XCV1A1) Burner At Igniter Gas Skotch Valve Inlet and Outlet Closed (3-IG-ZSC-XCV1A1A; 3-IG-ZSC-XCV1A1B) Burner At Main Flame On (3-BMS-BS-1A1) BurnerAI Main Flame Intensity (3-BMS-BT-1A1} Burner At Main Gas Skotch Valve Inlet and Outlet Closed (3-FG-ZSC-XCV1A1A; 3-FG-ZSC-XCV1A1B) Burner A1 Main Gas Skotch Valve Automatic Vent Valve Open (3-FG-ZSO-XCV1A1) Burner At Main Gas Skotch Valve Manual Vent Valve Open (3-FG-ZSO-20A1) Burner At Main Gas Skotch Valve Manual Vent Valve Closed (3-FG-ZSC-20A1) Flame Scanner Cabinet Source A No Power Fault (3-PS1 -FLT) Flame Scanner Cabinet Source B No Power Fault (3-PS2-FLT) Flame Scanner Rack 0 No Alarm (3-RCKO-FLT) Burner At Stop/Reset Pushbutton Not Activated (By Others) MFT Pushbutton Not Activated (from BCS DCS) (By Others) Outputs to Process • • o Burner At Igniter Skotch Valve Open Command (3-IG-SOV-XCV1A1) Burner At Energize Igniter HEI Command (3-IG-EE-1A1) Burner A1 Main Gas Skotch Valve Open Command (3-FG-SOV-XCV1A1) Inputs from BCS • • Burner Gas Header Flow Control Valve Closed (3-FG-ZT-FCV1) MFT HMI Pushbutton Not Activated (from BCS DCS) (By Others) DQ56873-4 -V£ "©2013 THE BABCOCK & WILCOX COMPANY. ALL RIGHTS RESERVED. 8/28/13 ^ This document Is Ihe properly of The Babcock & Wilcox Company (B&W, and is "CONFIDENTIAL AND PROPRIETARY" lo B&W. Recipient and/or itsrepresentativeshave, byreceivingsame, agreed to maintain its confidentiality and shall not reproduce, copy, disclose or disseminata Ihe contents, in whole or In part, to any person or entity other than the Recipient and/or Recipient's representatives without the prior written consent of B&W." Engineering Report DQ56874-4 \remo Class Title Operations Gas Training Class Date: 2-25-14 Class Location: Bremo Class Instructor: Ashley Anderson, Greg Searcy, Chris Bamberg Sign Name Print Name CL^\ ^•cU'^^^^ /•^phrtrtt^ t * l * f?j/d&'£A fc%a—J/tmf S7t%?2/ii L&4 Jortbjciry Aidcfrlw /f.J^J> J^'C-Jc nAZ.Ajf&fi.JA LJ;U\^ Hc^i ^ t T)e.<>n{ m cwh £ OJJL U/M&~IM**Mfc,4 JEFFRIES OIL CO. . 2966M..N. James Madison Hwy. #H4i9TMra 1 V 2 # i ^ # a r g e d after 30 days This is a 4 # # e r c e n t a g e _ j W e o f 18% U.-« Start ol Q*Hv*fy DYED DIESEL FUEL \k X Shfrf of Delivery aDATE E ,y• - — - CHARGE • I M I I i / ? " SALESMAN Your Sole Number ^ '.' i. 7 59 7 58 P Previous Sol* Number Lai: TIME GALLON. READING FINISH. r r W' &&% KM m*% r*-""^" —.... TANK TRUCK bbvW-W % 2-jL7-*S-ty TJ — — # §.;< sou, TO .%H't^Jtfi: . - Sale NO Taxable Highway Use Tenths'. 434-581 iS& fef 11: # 1 mmmi Igjfj Not Intended for 0 W tnd Mlvoi»;j>.'-. Gallon: CASH «2sr .TeAiuV: CuHooer CoW Hifcn .' y, t t - • 'o i W ^ l t t .;>...:P u Off p i GALLON READING START. GALLONS DELIVERED ion* s A l":; JUMUHISASS cmE^^zf^wy^ Example of Kerosene Fuel Record j* V Date 2/20/2015 Driver WllliawB Tractor. 154 Tankfl 133 U N MOTOR LINES, BN£ 2401 COMMERCE ROAD RICHMOND, VIRGIN A 23234 . 03115 80»-23a-43« - RICHMOND -S404474321-Monwilt (H)74BJ58S -ThomjiP. lenMnl (H) 74B-5121-lurry R. Gr«en FAX(804)Z3Z-«Z2S BILL OF LADING / A 7 & % CONSIGNEE DESTINATION JEFFERIBS O I L CO. 2 9 6 6 1 N 0 R T TERMINAL PARKER H MBDISON HWY NEW CANTON, VA ® FIRST ENERGY TERMINAL TERMINAL ORIGIN RICHMOND CONSIGNOR WXQr INC 2000 5500 Before PRODUCT raUaS.KeiorJaM.S.M.XXX C l e a r Kerosene 0K1J23, Koroeone, 3, PO. I l l Dyed Karosena 10053 ODOMETER STICK READINGS GALLONS ( I N) Before Rale After After Collect CLKEBO a 1 1 DYKDRBRO / & '^ />""» / • %J f Amount Total Gals. Product Qty Loaded Reformulated Gas O Convenllonal Gas T~l SPECIAL INSTRUCTIONS PO N u m b e r - - - > Pump Track Tbna Used 562859 sruRT: - Two Drop [ Two Terminal r~] SptS Reck r~j Spin Drop FINISH: Pump Truck Used Sinned c.o.0. Y«« Freight for product received :ub ect lo price eheeb In effect on Ihe d»l« of BUI ol ledln@. CUSTOMER PRODUCT RECEIVED BY: Gloned \ . U- /3t\**J& J L COPY Q r j EMERGENCY RESPONSE i COMM. ] 804-674-2400 j i ! LOADING ORDER - TRUCK BILL OF LADING AND MANIFEST EMERGENCY NUMBER CHEMTREX 1-800-424-9300 THIS IS TO CERTIFY THAT THE NAMED. MATERIALS ARE PROPERLY CLASSIFIED, DESCRIBED. PACKAGED, MARKED AND LABELED. AND ARE IN PROPER CONDITION OR TRANSPORTATION, ACCORDING TO THE APPLICABLE REGULATIONS OF THE DEPARTMENT OF TRANSPORTATION. THIS IS TO ALSO CERTIFY THAT THE NAMED MATERIALS ARE PROPERLY; CLASSIFIED, DESCRIBED, PACKAGED, MARKED AND LABELED ACCORDING TO THE APPLICABLE REGULATIONS OF THE FEDERAL TRADE COMMISSION AND THE ENVIORNMENTAL PROTECTION AGENCY. Load: Load Start Load bale: Loadspot: Period: Loaded at the following location: First Energy Terminal First Energy Terminal Richmond. VA 167268 Bill of Lading 2/20/15 6:36 am 2/20/15 8:02 am 5 167286 3.648 Page I o i l CARRIER CERTIFIES THAT THE CARGO TANK SUPPLIED FOR THIS SHIPMENT IS A PROPER CONTAINER FOR THE TRANSPORTATION OF THIS COMMODITY SSALNOS. GOODS RECEIVED BY: RECHVEO BY TRUCK DRIVER: Supplier: DATE PARKER OIL COMPANY, INC. Bill-To: Bill-To # : PAPCOOU. COMPANY 250286 ACCOUNT # : 14975Z Ship-To: VIRGINIA VARIOUS DATE Carrier: GREEN MOTOR LINES. INC. (310) Driver: WILLIAMS. MICHAEL (3243) SCAC: OREL 133 Trailer: Card: 0 P.O.*: Ship-To # : 1 Consignee: = = HAZARD INFORMATION« Gross Gallons UN1223.KEROSENE, 3.PGII11 CARGO TANK 7,500 = = = FINISHED PRODUCT SUMMARY ============= Prod 05 Description KEROSENE. LOW SULFUR (K-1) 07 Gross 101 NettQl 2000 2029 5500 5581 DYED KEROSENE, LOW SULFUR (K-1) === Temp (Fl 31.7 31.7 Gray. 46.0 46.0 Additive (ol 0.0000 0.2759 PRODUCT NOTES ' DYED DIESEL HON TAXABLE USE ONLY. PENALTY FOR TAXABLE USE. ==== PRODUCT COMPONENTS = = = = = No. Product 1 07 2 05 Total Gross Gross IG) Component 1,000 DYED KEROSENE. LOW SULFUR 2400 DYED KEROSENE. LOW SULFUR DYED KEROSENE. LOW SULFUR 2.000 KEROSENE. LOW SULFUR IK-fl 2.000 Mel 10) 1,015 2,637 2,029 2,029 Tamp I R Gray. 46.0 31.7 48.0 31.7 31:7 Tank 3 3 46.0 3 31.7 Plaase address correspondence lo: PARKER OIL COMPANY. INC. P O BOX 120 EPA FACILITY REGISTRATION # 83244/20011 TCN # T-59.FL.2678 SOUTH HILL. VA 23970 Kerosene Consumption Spreadsheet Enter data only in the blue cells Removed, and a new diesel EG in service on 5/19/2015 - RNM i CT Emergency Generator Kerosene Cumul. total for calendar year Gallons Burned 2014 Year 5 34.0 No 23 , 57.0 57:0 No March 28 85.0 85.0 No April 23 108.0 108.0 No May 23 131.0 131.0 No June 56 187.0 187.0 No 34 ; 221.0 221.0 No August 17 238.0 238.0 No September 68 306.0 306.0 No 45 , 351.0 351.0 No November 45 396.0 396.0 No December 34 430.0 430.0 NO January 34 34.0 430.0 No February 23 , 57,0 430.0 No March 0 • 57.0 402.0 No April 23 80.0 402.0 No 80:0 — Unit disabled)! RNM 34 February ! October (estim) May Year 6 12-Month Exceeds Rolling Sum Permit limit? 34.0 January July 2015 Is there a > 90% Alarm? No • June 80.0 July 80.0 August 80:0 September 80.0 ! -.. -• . ..... ,. . •• ' , Per f Natural Gas Consumption Spreadsheet Average Data Plant: BREMO Interval: 12 Month Type: Roll Report Period: 01/01/2016 00:00 Through 12/31/2016 23:59 Time Online Criteria: 1 minute(s) Source STATION Parameter Unit QGASVT (MSCF) 01/16 1.693 7 02/16 1,121.7 03/16 1.625 5 04/16 2,591.5 05/16 2.779.9 06/16 3,165.5 07/16 3,467.2 08/16 3.964.0 09/16 4,300.7 10/16 4,161.7 11/16 4,201.9 12/16 4,123.9 F = Unit Offline M = Maintenance Report Generated: 06/01/1715:21 E = Exceedance T = Out Of Control Report Version 4.0 C = Calibration * = Suspect S = Substituted U = Startup MBULOGINUaylo15 I = In D= £ Monthly Emissions Calculations Average Data Plant: BREMO Interval: 1 Month Type: Block Report Period: 05/01/2017 00:00 Through 05/31/2017 23:59 Source BR04 BROS Parameter Unit 05717 QG01MT (TONS) QGASVT (MSCF) QNOXMT (TONS) 0.1 38.9 2.6 QPM10MT (TONS) QPM25MT (TONS) QPMMT (TONS) QS02MT (TONS) QVOGMT (TONS) QCOlMT (TONS) 0.0 0.0 0.01 0.0 0:7 0.0 0.0 o:o 0.0 0.01 0.01 0.01 0:01 0.0 0.0 oo 0.0 0.7 0.7 0.7 0.7 Average 0.1 38.9 2.6 0.0 Minimum Maximum Summation 0.1 0.1 0.1 38.9 38.9 38.9 2.6 2.6 2.6 0.0 0.0 0.0 00 0.0 o:o 0.0 Included Data Points Total number or Data Points 1 1 1 1 1 1 1 1 F = Unit Offline M = Maintenance Report Generated: 06701/1715:33 1 1 E = Exceedance T = Out Of Control Report Version 4.0 C = Calibration * = Suspect 1 1 S = Substituted U = Startup MBULOGIN\taylo15 1 1 1 1 1 1 I = Invalid D = Shutdown 1 of 3 Average Data Plant BREMO Interval: 1 Month Type: Block Report Period: 05/01/2017 00:00 Through 05/31/2017 23:59 Time Online Criteria: 1 minute(s) Source STATION BR04 Parameter Unit 05717 QGASVT (MSCF) QN0XMT (TONS) QPM10MT (TONS) QPM25MT (TONS) QPMMT (TONS) QS02MT (TONS) QVOCMT (TONS) QC01MT „ f p A . 0 % Issue Page 3 Date !>«>t\K«_ .. 58, Standard Personal Protective Equipment (Doeethe task involve:) Face or eye protection (other than safety glasses). Hand protection - type of glove. Hre retardant clothing (all natural). a n n u J S^fiA C Initial Mid-Shift Siefing Briefing Yes No Yes No ' P P or D 6A. Special Precautions (Does the task involve) Asbestos or lead-paint removal or exposure. R Adverse ambient conditions (i.e. vervhof oricy). Sack work. Scaffolding work. P Warning signs or barricades. p Special equipment or rigging required. p Obtaining a DtiC.f Drilling. Digging or Cutting j fernit; P Confined Space Entry Ftermlt required. p Diving Ftermit. p EtjuiDment operator certifications Rescue contingency plan required. p^ Competent person identified. . Radiation Boundaries. 6B. Special Precautions to be Noted (Does the task involve:) Access to non-routine working surfaces (IOP). p Welding and Flame ftrmlt. p Scaffolding Inspection. p Crew change or shift change p Coordinating with others. Who? 7. Environmental - Is There a Potential to Cause an Unpermitted Discharge to the Environment (Ground/Air/Water) w P P P ET • U*V<* C\louO O —,—•• _ • p p p p p p p p w a The Human Performance (HP) Items in 5Bdo not normally require a detailed discussbn. • n n % p p p cr p vt ET p p tit .Ll 0* p ET u n -uT p P p .n". W p Waste water, service water, fire water, process water. Excess stack emissions or fugitive dust emissions FBtroleum products, chemicals, waste products Comments A "Yes" requires a detailed and documented discussbn. n n w H-PWV p m> 0- p ^ p ET Li b p & u p ET p ET" u U p • p p p p a u n p p p p p p p Kerns in 6B do not automaticallyrequirea detailed dsoissien. Is a fire watch needed? Must be Inspected each shift or prior to use. General or detailed prejob required. Ckr> J BxiyvVvr^ A "Yes" requires a detailed and documented discussbn. p p • p p (Mandatory for All Jobs) Identify / Discuss the "Error Precursors" Impacting this task: (Time pressure, unfamtllarfty with task, Complacency, etc) Documented Discussion: ftum No. T2am%Sity 2014) ® 2014 Doirinfon Resources Scrrricas inc. 04/25/2016 Order 67998238 Page 4 Identify / Discuss the "Error -Likely Situations" possible (example: 2 switches side by side that look alike) Documented Discussion: Identify / Discuss the "Critical Steps" (Tactical Work Zone should be considered) Documented Discussion: Identify / Discuss the "Defenses" mat will be used: (&way corhmunication. Peer Check, Job-Site Review, etc.) Documented Discussion: Miscellaneous Items for Discussion I Post Work Briefing Comments flUny &ietV'Pt'\No^rTBM^:'9uwffSaanMl Contaminant Time f t ports Completed for Arsenic, Lead, Asbestos, Or Other 01 Yes ONo Initial Briefing Completed By Mid-Shift Briefing Completed By •Refer to the Pwr. Gen. Human Performance Field Guide for additional Information Rwn I * . KOBSIUuly 2014) @ 2014 Dpm'nkn Resources Services Inc. £ 04/25/2016 Order 67998238 Page 5 Maintenance Order Summary of Work Performed: ^ As Found: W+fi l/lXjc^l /A y^J ins^cfcyN « f u j pr\i\- \T\ kenf^. onyhW «W p r c ^ W ^ . jVu.VvrV 6. ( n / ) A ^ A ofoUu. U * k > , a j i '^ j J U of & •fop- Work P e r f o r m e d : -A&W—ISU-Urt „( U c k . fepkr JS iZ^I&uCfP ct.r A e L & f t : UPA U oru.rtAi^oX By: r&J <«t I y , ( j j J < j ZQ^fr .nj Wll'p ( t w j >•'! £ l W s \ \ w skvk. ; j ^MjlLf t^/'^\ r\u ^ / ^ l «W pr»^ «J ^ j L u ^ c ».V ^ f t f ^ i g j < 1 U , . ; \ ? M A - ftj^/ fy^ , F u J Performed r c f k ^ g y t „^*h^ ,j Date; HJ^JI\* 4 Dominion - Bremo Power Station - CEDS I Air Page 1 of2 CEDSAir Home / Air Facility Search / Dominion - Bremo Power Station Site: Dominion - Bremo Power Station (40199) 1038 Bremo Road, Bremo Bluff, VA 23022 General Permits Emissions Inspections Events Enforcement Requirements Contacts Targeting Data Financials Site Emissions Site Information Emission Year Status Release Points Units Processes Emissions Drill Down Pollutant 2016 2015 2014 2013 CO 26.29 13.97 22.15 53.92 285.19 150.41 284.63 911.76 0.00 0.00 0.00 0.03 PM 10 11.35 6.84 15.79 202.90 PM2.5 11.35 6.84 11.84 13.89 S02 1.30 0.66 2.71 3627.02 VOC 0.19 5.10 11.39 6.40 NOX PB 127.40 HCL Road Map 15.92 HF Emission Limits Report Criteria Emissions (Pie) http://ecmiis/ui NHS 6.62 3.64 6.64 0.07 PM 11.35 6.84 15.78 202.83 > II = ^ L I 6/20/2017 Unit 4 Operating Hours Example 2016 Cumulative Emissions Plant: BRPS Cumulative Emissions for: 2016 BR04 RUHR OpHrs RUHR OpTime January 93.61 96 February 132.38 135 March 510.52 512 April 529.10 530 May 165.29 168 June 484.36 487 July 421.99 431 August 443.42 445 September 339.07 340 October 0.52 1 November 51.28 52 December 88.25 90 Quarter 1 736.51 743 Quarter 2 1,178.75 1,185 Quarter 3 1,204.48 1,216 Quarter 4 140.05 143 YTD 3,259.79 3,287 Ozone Quarter 2 649.65 655 Ozone Quarter 3 1,204.48 1,216 Ozone YTD 1,854.13 1,871 Report Generated: 06/01/17 14:21 Report Version 52 MBULOGIN\taylo15 Unit 3 Operating Hours Example 2016 Cumulative Emissions Plant: BRPS Cumulative Emissions for: 2016 BR03 PUHR OpTime PUHR OpHrs January 000 0 February 0.00 0 March 136.02 137 April 457,60 459 May 132.80 139 June 240.24 243 July 176.50 180 August 120,07 121 September 95.05 96 October 0.35 2 November 28.54 30 December 49.10 50 Quarter 1 136.02 137 Quarter 2 830.64 841 Quarter 3 391.62 397 Quarter 4 77.99 82 YTD 1,436.27 1,457 Ozone Quarter 2 373.04 382 Ozone Quarter 3 391,62 397 Ozone YTD 764.66 779 Report Generated: 06/01/17 14:19 Report Version 5.2 MBULOGINVtaylo15 ••*>• -r Compliance Summary (A R e p o r t * : 314113 (Continued) Registration #=40199 Site N a m e : D o m i n i o n - B r e m o Power Station o$/o\/n IA: UJur..w out! t . M - f - ^ ^ W . Inspection Summary N a m ^ , a o f contact W n q , n , p ^ n = % ^ pfuAjL^f^ Purpose: FCE site inspection. rJW:?^ * —- Facility & Process Description: The Bremo Power Station is a natural gas-fired electric power generating facility located in Fluvanna County, Virginia. The facility includes two natural gas wail-fired Babcock and Wilcox boilers rated at 920 and 1,684 million Btu per hour (MMBtu/hr) heat input capacity, The facility also includes a kerosene fired Solar Combustion Turbine and a diesel fire pump. Permitting & Regulatory The facility stopped using coal, distillate oil, and used oil as fuel for the boilers (Ref. 003 and 004) and formally shutdown the coal handling equipment at the facility under a mutual shutdown agreement with the DEQ, on September 19, 2013; after the termination of the use of coal, distillate oil, and used oil, the facility is no longer a major source of Hazardous Air Pollutants (HAPs) (i.e., the facility is considered an area source of HAPs). The facility is a Title V major source of nitrogen oxides (NOx), and carbon monoxide (CO) with a TV permit dated May 5, 2014. The source is located in an attainment area for all pollutants and is a PSD major source. The facility is also subject to the Title IV Acid Rain regulations (9 VAC 5 Chapter 80, Article 3) and the Clean Air Interstate Rule (CAIR) (9 VAC 5 Chapter 140). Bremo is also subject to the May 2003 USEPA Consent Decree. On April 22, 2003, EPA and others entered into a consent decree for Clean Air Act violations. The Title V renewal permit includes the requirements ofthe Consent Decree and CAIR by reference. Compliance History: The last full site inspection was conducted October 28, 2014. During that mspeuuun inspection,the, i n t i facNity l a u i i i y was was found to in compliance. / ^.'tfjsnpst. Inspection Notes: The facility has been converted to run the primary b^ilej^pn natural gas. The Goal handling ^p^r^tjon has been dismantled and the coal yard h a s _ ^ ^ grass. Unit 3 was i n ^ ^ shutdown due to electrical demand. Unit 4»was o g ^ a t t g o n iidluidl'gcjs Willi luw NOX DUIheT CBbX-b-/UU-bUU-3UUS I and— .nuar-firft nir r j p n p r f l l L a i j 1 1 1 M\A/ i j i m i M ,'l,,,,li'irity > P H -gtt-arhmnnt l\ J f b e r e WBTO n o v i o i b l o CmiOOiOfiyuUbWI Ved tt'Otit. Vrhe Solar generator w3l-ai p o r a t o i i p n I m r p r n n n vuith n n y i o i h l r n m i r r i n n n J h n n n n r n n n t t n h l n rlmrk' imari 010. hwure. T h e e o » U-) Cleaver Brooks Auxiliary boilerjjses natura' as but* was not running during the inspection. The diesel fire pump has a non-resettable clock which was reading hours. Additional observations and the record review are in the attached . checklist which covers all of conditions ofthe TV permit and the reference permits. o ^m^W^W^^r' .. - - ... Recom has been completed. ^v-C^-n^vvc i s-+~JL ^ fW". Av4 Uhlt- r f) to PM ... testing since the natural gas conversion ,- .....ifres-vwih"re%rd a u Qy 0 - l < \ a ^ X ) [y.vo - * r f £ j £ y s ^ ^ ^ z t ^ Attachments: A - Unit 4 operating screen, B - Example training record, C - Example training record, D - Example kereseTiefuel record, E Kerosene consumption spreadsheet, F - Natural Gas consumption spreadsheet, G - Monthly emissions calculations, H Rolling 12 Month emissions calculations, I - Diesel Fire Pump records i r r nt Prnrnn MQY rlnrl S^P-N-t—K ',/n#-1 operating hours example, example, L L -- Unit Unit 3 3 operating operating hours hours example example V^.AV-HI^ (•JCWJU )j n ^ - ' } M M j perating hours V^INL.A-^-HI-^ \y>v^**x* , 0 i ^L^\ f i \ - f.4A <5W KAIV* May 31, 2017 03:51 "f *WJ*^ ' L - W * 5 U ! t ( ; (Wv;^- Dominion - Bremo Power Station (40199) u»/o Page 2 / 2 6 Inspection Checklist Effective Date: May 5, 2014 Applicable Requirement #: T5 1 Applicable Requirement Fuel Burning Equipment Requirements - (Ref. 002, 003, 004, and 005) Compliance Status: Limitations - Oxides of nitrogen (NOx) emissions from Boilers 003 and 004 shall be controlled by low NOx burners with enhanced overfire air, good combustion practices, operator training and proper emissions unit design, construction and maintenance. The low NOx burners shall be installed and operated in accordance with manufacturer's specifications. (9 VAC 5-80-490 B & C and Condition 2 of the 5/24/13 Permit) Observation Low NOx burners in use Effective Date: May 5, 2014 Applicable Requirement #: T5 2 Compliance Status: Applicable Requirement Limitations - Carbon monoxide (CO) and volatile organic compound (VOC) emissions from Boilers 003 and 004 shall be controlled by enhanced overfire air, good combustion practices, operator training and proper emissions unit design, construction and maintenance. (9 VAC 5-80-490 B & C and Condition 3 ofthe 5/24/13 Permit) Observation ^S' ^ Overfire air in use as well as training. Computer controlled combustion in use. Effective Date: May 5, 2014 Applicable Requirement #: T5 3 Compliance Status: flSfflflfr Applicable Requirement Limitations - The approved fuels for the Solar Combustion Turbine (Ref. 002) are distillate oil and kerosene. Distillate oil is defined as fuel oil that meets the specifications for fuel oil numbers 1 or 2 under the American Society for Testing and Materials ?Standard Specification for Fuel Oils ? A change in the fuels may require ajpermit to modify and operate. (9 VAC 5-80-490 B&C) Observation . , u i ^ k^prngpnp in, mm rnn nttnrhmrnt- R nnrl f ^ J ^ - w * ^ A— Effective Date: May 5, 2014 Applicable Requirement #: T5 4 Compliance Status: Applicable Requirement Limitations - The approved fuel for Boilers 003, 004 and 005 is natural gas. A change in the fuel may require a permit to modify and operate. (9 VAC 5-80-490 B & C and Condition 5 of the 5/24/13 Permit) Observation Natural gas in use, see attachment F Effective Date: May 5, 2014 Applicable Requirement #: T5 5 Compliance Status: Applicable Requirement Limitations - Boilers 003 and 004 combined shall consume no more than 6,330 x 10 6 cubic feet of natural gas, per year, calculated monthly as the sum of each consecutive 12-month period. Compliance for the consecutive 12-month period shall be demonstrated monthly by adding the total for the most recently completed calendar month to the individual monthly totals for the preceding 11 months. (9 VAC 5-80-490 B & C and Condition 6 ofthe 5/24/13 Permit) Observation Not exceeded, throughgQUuubi 2014 3,411.6 x 10 6 scf used, see F. A A Effective Date: May 5, 2014 Applicable Requirement #: T5 6 Compliance Status: Applicable Requirement Limitations - Emissions from the operation of the Solar Combustion Turbine (Ref. 002) shall not exceed the limits specified below: Particulate Matter 3.14lbs/hr Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 3 / 26 Sulfur Dioxide 13.83 Ibs/hr Compliance with these emission limits may be determined as stated in Conditions 3 and 25 (9 VAC 5-40-900, 9 VAC 5-40-930, and 9 VAC 5-80-490 B & C ) Observation V^fc NoLsaceeded-UdbWU Oil throughput dllU fuel spwunudliuii., ulludiinonto D and-E- QLA^K^ ^lif- Effective Date: May 5, 2014 Applicable Requirement #: T5 7 Compliance Status: Applicable Requirement Limitations - Emissions from the operation of Boiler 003 shall not exceed the limits specified below: Particulate Matter (PM) 6.81 Ib/hr PM-10 6.81 Ib/hr PM-2.5 6.81 Ib/hr Sulfur Dioxide (S02) 0.76 Ib/hr Nitrogen Oxides (as N02) 147.20 Ib/hr 0.16 Ib/MMBtu Carbon Monoxide (CO) 55.20 Ib/hr 0.06 Ib/MMBtu Volatile Organic Compounds (VOC) 3.68 Ib/hr 0.004 Ib/MMBtu Unless otherwise specified, NOx and CO limits apply at all times except during startup, shutdown, and malfunction. Periods considered startup and shutdown are defined in Condition 10 of this permit. Compliance with these emission limits may be determined as stated in Conditions 19 and 27. (9 VAC 5-80-490 B&C and Condition 7 of the 5//24/13 Permit) / Observation C ^ L ^ " lyL^-U ^ c w L \ \ \ V~>, Effective Date: May 5, 2014 Applicable Requirement #: T5 8 Compliance Status: ^BBffif) Applicable Requirement Limitations - Emissions from the operation of Boiler 004 shall not exceed the limits specified below: Particutete Matter (PM) 12.46 Ib/hr PM-10 12.46 Ib/hr PM-2.5 12.46 Ib/hr Sulfur Dioxide (S02) 1.40 Ib/hr Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 4 / 26 Nitrogen Oxides (as N02) 252.60 Ib/hr 0.15 Ib/MMBtu Carbon Monoxide (CO) 101.04 Ib/hr 0.06 Ib/MMBtu Volatile Organic Compounds (VOC) 6.74 Ib/hr 0.004 Ib/MMBtu Unless otherwise specified, NOx and GO limits apply at all times except during startup, shutdown, and malfunction. Periods considered startup and shutdown are defined in Condition 10 of this permit. Compliance with these emission limits may be determined as stated in Conditions 19 and 27. / (9 VAC 5-80-490 B & C and Condition 8 of the 5/24^ Permit) , Observation ^/ ^ Not exceeded based on stack testing and CEMS Mvft^-v^ V*^ Ci-Jf^ • \A ^ Effective Date: May 5, 2014 Applicable Requirement #: T5 9 Compliance Status: IfSffiffiBl Applicable Requirement Limitations - Combined emissions from the operation of Boilers 003 and 004 shall not exceed the limits specified below: Particulate Matter (PM) 24.2 tons/yr PM-10 24.2 tons/yr PM-2.5 24.2 tons/yr Sulfur Dioxide (S02) 2.7 tons/yr Nitrogen Oxides (as N02) 522.9 tons/yr Carbon Monoxide (CO) 196.1 tons/yr Volatile Organic Compounds (VOC) 13.1 tons/yr Annual emission limits are derived from the estimated overall emission contribution from operating limits, including periods of startup and shutdown. Annual emissions shall be calculated monthly as the sum of each consecutive 12-month period. These emissions are derived from the estimated overall emission contribution from operating limits. Exceedance of the operating limits may be considered credible evidence of the exceedance of emission limits. Compliance with these emission limits may be determined as stated in Conditions 1, 2, 4, and 5. , (9 VAC 5-80-490 B&C and Condition 9 of the 5/24/13 Permit) / Observation C-Jl U * i ^ » * f «T . ' Not exceeded based on natural gas use, throughput, test results and CEMS see also attachments G, H, K and L. Effective Date: May 5, 2014 Applicable Requirement #: T5 10 Compliance Status: fJjHffffltt Applicable Requirement Limitations - The NOx and CO short-term emission limits contained in Conditions 7 and 8 apply at all times except during Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 5 / 26 periods, of startup and shutdown: a. Startup and shutdown periods are defined as follows: £A*AW-^ ^ ( ^""^ (1) Startup - A startup begins when the unit begins combusting fuel after a shutdown and ends when the unit is operating above 40 percent of rated load. Exclusion from the short-term emission limits for startup periods shall not exceed 16 hours per occurrence. Emissions from the operation of the boilers (Ref. 003 and 004) shall not exceed the limits specified below for each startup: Pollutant Unit 003 Unit 004 NOx 2.855.2 los/startup 4.041.8 IPs/startup OO 888.2 IPs/startup 1.818.8 IPs/startup (2) Shutdown-Refers to the period between the time the boiler load drops Pelow 40 percent of rated load and the fuel supply to the boiler is cut. Exclusion from the short-term emissions limits for shutdown shall not exceed8hours per occurrence. Emissions from the operation of the boilers (Ref. 008 and 004) shall not exceed the limits specified below for each shutdown: Pollutant Onit8 0nit4 NOx 1.177.8 Ibs/shutdown 2.020.8 Ibs/shutdown OO 441.0 Ibs/shutdown 808.8 Ibs/shutdown b. The permittee shall operate the Continuous Emission Monitoring Systems (CEMS) during periods of startup and shutdown. via^-A i*o_ Cr^A . c. The permittee shall record the time, date, and duration of each startup and shutdown period. \ j t % ^ ( c y v ~'^" d. The permittee shall operate the facility so as to minimize the frequency and duration of startup and shutdown events. (9 VAC 5-80-490 B&C and Condition 10 of the 5/24/13 Permit) VuCJ^U ofw-k • Observation Effective Date: May 5, 2014 Applicable Requirement #: T511 Compliance Status: flSiffflift Applicable Requirement Limitations - The annual emissions limit on the boilers (Ref. 003 and 004) in Condition 9 is a compliance cap, imposed for the purpose of limiting the potential to emit carPon monoxide so as to avoid permitting applicability under 9 VAC 5 Chapter 80 Article 8 (9 VAC 5-80-1605 et seq.) related to the conversion of the boilers from coal to natural gas. The limit does not provide relief from obtaining a plan approval for any future physical change or change in the method of operation of either boiler or the addition or modification of any steam-consuming process(es) at the facility. The latter is true even if the permittee does not request a change in the compliance cap. Furthermore, by accepting this cap and agreeing to consider the two boilers as one emissions unit for NSR/PSD purposes, any future applicability determinations must involve both boilers, e.g. should major NSR/PSD be triggered for any one boiler or process change, BACT/LAER is required for both Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 6 / 26 boilers.,If the emissions limit is relaxed at some future date, the source obligation requirements of 9 VAC5-80-1605.C and 40 CFR 52.21 (r)(4) apply. (9 VAC 5-80-490 B & C, 9 VAC 5-80-1605, andpondition 11 of the 5/24/13 Permit) Observation £jur. yj j^y-«-- M^. r Effective Date: May 5, 2014 Applicable Requirement #: T5 12 Compliance Status: Applicable Requirement Limitations - Visible Emissions from the boiler stack (Ref. 005) shall not exceed 20 percent opacity except during one six-minute period in any one hour in which visiPle emissions shall not exceed 30 percent opacity as determined Py the EPA Method 9 (reference 40 CFR 60, Appendix A). (9 VAC 5-50-80 and 9 VAC 5-80-490 B&C) Observation ^ None record Effective Date: May 5, 2014 Applicable Requirement #: T5 13 Compliance Status: Applicable Requirement Limitations - Visible Emissions from the Solar Combustion Turbine stack (Ref, 002) shall not exceed 20 percent opacity except during one six-minute period in any one hour in which visible emissions shall not exceed 60 percent opacity as determined by the EPA Method 9 (reference 40 CFR 60, Appendix A). (9 VAC 5-40-80, 9 VAC 5-40-940, and 9 VAC 5-80-490 B&C) Observation , . to.1 * WoAe-ewecaFd A B ^ ^ L ^ 9 [ '> Effective Date: May 5, 2014 Applicable Requirement #: T5 14 Compliance Status: Applicable Requirement Limitations - Visible emissions from each boiler (Ref. 003 and 004) stack shall not exceed 10 percent opacity as determined by the EPA Method 9 (reference 40 CFR 60, Appendix A). (9 VAC 5-80-490 B & C and Condition 12 of the 5/24/13 Permit) ^ . Observation \*^St \*\ A^T o ^ - g >—«(J None on record since change to natural ga&Nonc oboorvod during tho incpoction. • Effective Date: May 5, 2014 Applicable Requirement #: T5 15 Compliance Status: fljflHHS) Applicable Requirement Limitations - At all times, including periods of start-up, shutdown, and malfunction, the permittee shall, to the extent practicable, maintain and operate the affected source, including associated air pollution control equipment, in a manner consistent with good air pollution control practices for minimizing emissions. The permittee shall take the following measures in order to minimize the duration and frequency of excess emissions, with respect to air pollution control equipment, monitoring devices, and process equipment which affect such emissions: a. Develop a maintenance schedule and maintain records of all scheduled and non-scheduled maintenance. b. Maintain an inventory of spare parts. c. Have available written operating procedures for equipment. These procedures shall be based on the manufacturer's recommendations, at a minimum. d. Train operators in the proper operation of all such equipment and familiarize the operators with the written operating procedures. The permittee shall maintain records of the training provided, including the names of trainees, the date of training and the nature of the training. (9 VAC 5-80-490 B & C and Condition 28 of the 5/24/13 Permit) Observation a. On computer P. On computer ^ / c. On computer and paper reports d. available, see B and C examples.^ X Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 7 / 26 Effective Date: May 5, 2014 Applicable Requirement #: T5 16 Compliance Status: Applicable Requirement Limitations - The permittee shall obtain a certification, or alternative statement, from the fuel supplier covering each shipment of distillate oil. Each fuel supplier certification or alternative statement shall include the following: a. The name of the fuel supplier, b. The date on which the oil was received, c. The volume of distillate oil delivered in the shipment, and d. A statement that the oil complies with the American Society for Testing and Materials specifications for fuel oil numbers 1 and 2. (9 VAC 5-80-490 F) Observation / Records on file, see example D. Effective Date: May 5, 2014 Applicable Requirement #: T5 17 Compliance Status: Applicable Requirement Limitations - Except where this permit is more restrictive, the natural-gas auxiliary boiler (Ref. 005) shall be operated in compliance with the requirements of 40 CFR 60, Subpart Dc. (9 VAC 5-80-490 B & C and 40 CFR 60 Subpart Dc) Observation Not less restrictive Effective Date: May 5, 2014 Applicable Requirement #: T5 18 Compliance Status: Applicable Requirement Consent Decree Requirements - The permittee is subject to the Consent Decree entered Py the United States District Court for the Eastern District of Virginia, Civil Action Nos. 03-CV-517-A and 03-CV-603-A, filed on October 10, 2003 between Virginia Electric & Power Company and the United States, et al (the "Consent Decree"). The Consent Decree, as such might be amended or modified in accordance with its terms, is incorporated in its entirety into this permit by reference and as Attachment C. The permittee shall comply with the terms and conditions of the Consent Decree that relate to the operation of Bremo Power Station exclusively and such compliance shall Pe determined exclusively Py reference to the terms and conditions of the Decree. Whenever any conflict or ambiguity arises between the Consent Decree and this permit, the terms and conditions of the Consent Decree will control. The limitations, monitoring, recordkeeping, and reporting requirements include applicable requirements from the Consent Decree. (9 VAC 5-80-440 I and the Consent Decree) Observation Complying with t h e j r v e n ™ , see taPle example J. Currently negotiating with the Department of Justice (DOJ) on having 4ne consent decree^TiooTfied to take natural gas firing into account. Recent stack testing was in compliance for all pollutants. Effective Date: May 5, 2014 Applicable Requirement #: T5 19 Compliance Status: Applicable Requirement Monitoring - Continuous Emission Monitoring Systems (CEMS) shall be installed to measure and record the emissions of NOx (measured as N02) and CO, in Ib/MMBtu from each boiler (Ref. 003 and 004). CEMS for NOx shall meet the design specifications of 40 CFR 75 whereas CEMS for CO shall be installed, evaluated, and operated according to DEQ-approved procedures which are equivalent to the requirements of 40 CFR 60.13 and Appendices B and F for compliance with the emission limits contained in Conditions 7 and 8. NOx data and CO data shall each be reduced to 1-hour block averages. The relative accuracy test audit (RATA) of the NOx CEMS shall be performed on a Ib/MMBtu Pasis. (9 VAC 5-80-490 B&C, 9 VAC 5-80-420, and 40 CFR 75, and Condition 13 of the 5/24/13 Permit) Observation In use, see attachment A example output. Effective Date: May 5, 2014 Applicable Requirement #: T5 20 Compliance Status: Applicable Requirement Monitoring - Performance evaluations of the NOx and CO continuous monitoring systems shall be conducted in Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) flffffif) Page 8 / 26 accordance with 40 OFR 60, Appendix B,and shall take place during the performance tests under^VAO 5-50-30 or within 30 days thereafter.One copy of the performance evaluation report shall PesuPmitted to the OEO,within 45 days of the evaluation. The continuous monitoring systems shall Pe installed and operational prior to conducting init^ tests.Verification of operational status shall,asaminimum,include completion of the manufacturer's written req or recommendations for installation,operation and caliPration ofthe device.A30-day notification,priorto the demonstration otthecontinuousm^ OEO ^VAO5-30-490r3&OandOondition14ofthe5^4^3Permit) OPservafion Completed showing compliance Effective Date: May 5, 2014 Applicable Requirement #: T5 21 Compliance Status: Applicable Requirement Monitoring - A CEMS quality control program which is equivalent to the requirements of 40 CFR 60.13 and 40 CFR 60, Appendix F or Part 75 shall Pe implemented for all continuous monitoring systems. (9 VAC 5-80-490 B & C and Condition 15 of the 5/24/13 Permit) Observation Quality program for the monitors in use. y Effective Date: May 5, 2014 Applicable Requirement #: T5 22 Compliance Status: Applicable Requirement Monitoring - The permittee shall conduct visible emissions oPservatipns (VEO) on each stack (Ref. 003 and 004) in accordance with the following procedures and frequencies: a. At a minimum of once per operating month, the permittee shall observe the presence of visiPle emissions. Each VEO shall Pe performed for a sufficient period of time to identify the presence of visible emissions. If no visiPle emissions are observed, a note to that effect should Pe recorded. However, if visiPle emissions are observed, a visible emissions evaluation (VEE) shall be conducted using 40 CFR Part 60, Appendix A, Method 9 for a period of not less than six minutes. If any of the observations exceed the applicable opacity limit, the oPservation period shall continue until 60 minutes of observations have been completed. b. All visible emissions inspections shall Pe performed when the equipment is operating under representative conditions for the day. c. If visible emissions inspections conducted during four consecutive operating months show no visiPle emissions, the permittee may reduce the monitoring frequency from monthly to quarterly for that emission unit. Anytime the quarterly visible emissions inspections show visible emissions, or when requested by DEQ, the monitoring frequenc/shall be increased to once per operating month for that emission unit. (9 VAC 5-80-490 B & C) Observation, w - ^ ^ ^ O b s e r v a t i o na ^ MaQlbJ^bDservation completed, no visibles observed. U3 and U4 are on •monthly-schedule uvuu lliuugh no visibles have been observed. Effective Date: May 5, 2014 Applicable Requirement #: T5 23 Compliance Status: Applicable Requirement Monitoring - When VEEs, performed in accordance with Condition 22, indicate the visible emissions exceed the limitation shown in Condition 14 for boiler 003 or 004, then the permittee shall verify that the boiler(s) is operating in accordance With manufacturer's specifications or other predetermined site-specific acceptable operating conditions. If a boiler is not operating properly, the permittee shall take corrective action in an effort to reduce emissions to or Pelow the limitation shown in Condition 22. (9 VAC 5-80-490 B&C) Observation None observed / Effective Date: May 5, 2014 Applicable Requirement #: T5 24 Compliance Status: (ffHBWSfr Applicable Requirement Monitoring - The permittee shall perform visible emissions observations (VEO) on the exhaust stack ofthe turbine (Ref. Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 9/26 002) according to the following schedule: a. At least one VEO shall be conducted on each unit that operates for a cumulative total of 20 hours or more during the calendar year. b. At least one VEO shall be performed during each 200 hours of unit operation during the calendar year. c. At least one VEO shall Pe performed during any unit operability verification testing conducted during the calendar year. Each VEO shall be performed for a sufficient period of time to identify the presence of visiPle emissions. If no visible emissions are observed, a note to that effect should Pe recorded. However, if visible emissions are observed, a visible emissions evaluation (VEE) shall be conducted using 40 CFR Part 60, Appendix A, Method 9 for a period of not less than six minutes. If the average opacity exceeds 10 percent, modifications and/or repairs shall be performed to correct the problem and the corrective measures shall Pe recorded. If such corrective action fails to remedy the opacity proPlem, a VEE in accordance with 40 CFR Part 60, Appendix A, Method 9, shall Pe performed for a period of at least 18 minutes to determine compliance with the opacity limits specified in Conditions 12 and 13. (9 VAC 5-80-490 E) Observation • i v . ' VFO'ci conaplptod no oxooodanoop obocfved. yvX~-wu-^- < / Effective Date: May 5, 2014 Applicable Requirement #: T5 31 Compliance Status: Applicable Requirement Testing - If testing is conducted in addition to the monitoring specified in this permit, the permittee shall use the appropriate method(s) in accordance with procedures approved Py the DEQ. (9 VAC 5-80-490 E) Observation jjur ^ -fV- q^tf Effective Date: May 5, 2014 Applicable Requirement #: T5 32 Compliance Status: Applicable Requirement Reporting - The permittee shall furnish written reports to the DEQ of excess emissions from any process monitored Py a CEMS on a quarterly basis, postmarked no later than the 30th day following the end of the calendar quarter. These reports shall include, Put are not limited to the following information: a. The magnitude of excess emissions, any conversion factors used in the calculation of excess emissions, and the date and time of commencement and completion of each period of excess emissions; P. Specific identification of each period of excess emissions that occurs during startups, shutdowns, and malfunctions of the process, the nature and cause of the malfunction (if known), the corrective action taken or preventative measures adopted; c. The date and time identifying each period during which the continuous monitoring system was inoperative except for zero and span checks and the nature of the system repairs or adjustments; and d. When no excess emissions have occurred or the continuous monitoring systems have not Peen inoperative, repaired or adjusted, such information shall be stated in that report. (9 VAC 5-80-490 B & C and Condition 16 of the 5/24/13 Permit) ' _ Observation 5 5 ( JrW / - ^ Effective Date: May 5, 2014 Applicable Requirement #: T5 34 Applicable Requirement Reciprocating Internal Combustion Engines - (Ref. 007) Compliance Status: @ E H B ) Limitations - Except where this permit is more restrictive, the stationary reciprocating internal combustion engine (RICE) (Ref. 007) shall be operated in compliance with the requirements of 40 CFR 63, Subpart 7777. (9 VAC 5-80-490 B & C and 40 CFR 63 Subpart ZZZZ) Observation Complying with RICE MACT, 007 is the Fire pump diesel fired, see I for example records. Effective Date: May 5, 2014 Applicable Requirement #: T5 35 Compliance Status: Applicable Requirement Limitations - The stationary RICE (Ref. 007) shall comply with the maintenance requirements specified in sections 1 (a) through (c) of Taple 2c to Subpart ZZZZ: a. Change oil and filter every 500 hours of operation or annually, whichever comes first, or at an extended frequency if utilizing an oil analysis program as described in ?63.6625(i) or (j); b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first and replace as necessary; and c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. (9 VAC 5-80-490 B & C , 9 VAC 5-60-90, 9 VAC 5-60-100, 40 CFR 63.6602, and 40 CPPT63, SuPpart 7777) Observation Maintenace that is required is completed Py Dominion and contract employees. See I for example records. Effective Date: May 5, 2014 Applicable Requirement #: T5 36 Compliance Status: f Applicable Requirement Limitations - During periods of startup the permittee must minimize the time spent at idle for the emergency generator (Ref. 007) and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the non-startup emission limitations apply. (9 VAC 5-80-490 B & C, 40 CFR 63.6625 (h), and 40 CFR F ^63 S Subpart u b p a7777) r t Z Z Z Z ^ ^ ^ ^ Observation 0 0 7 is the only RICE engine on site and is the diesel fire pump, T-he generaiui is tl iw solar lui uine, 002r t Effective Date: May 5, 2014 Applicable Requirement #: T5 37 Compliance Status: QBRSB Applicable Requirement Limitations - The stationary RICE (Ref. 007) must be operated in accordance with the following: a. Any operation other than emergency operation, maintenance and testing, and operation in non-emergency situations for 50 hours per year, as permitted in this condition, is prohibited. b. The permittee may operate the emergency stationary RICE for the purpose of maintenance checks and readiness testing, provided that the tests are recommended by Federal, State or local government, the manufacturer, the vendor, or the insurance company associated with the engine. Maintenance checks and readiness testing of such units is limited to 100 hours per year. The owner or operator may petition the Administrator for approval of additional hours to Pe used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency RICE beyond 100 hours per year. (9 VAC 5-80-490 B & C and 40 CFR 63.6640 (f)) Observation Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 13/26 Fire pump is only used for emergencies or periodic maintenance, see I. Effective Date: May 5, 2014 Applicable Requirement #: T5 38 Compliance Status: Applicable Requirement Monitoring - The permittee shall install non-resettaPle hour meter on the stationary RICE (Ref. 007). The hour meter shall be provided with adequate access for inspection. (9 VAC 5-80-490 B & C and 40 CFR 63,6625 (f)) Observation tyj'V' , Non-resettable meter in use reading.G&13.hours rv ' / ol / i i , 0 Effective Date: May 5, 2014 Applicable Requirement #: T5 39 Compliance Status: Applicable Requirement Monitoring - The permittee must operate and maintain the stationary RICE (Ref. 007) and after-treatment control device (if any) according to the manufacturers emission related written instructions or develop a maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions. (9 VAC 5-80-490 B & C, 40 C F ^ 63.6625 (e), and 40 CFR 63,6640) Observation Procedures and PM in place, see attachment I Effective Date: May 5, 2014 Applicable Requirement #: T5 40 Compliance Status: Applicable Requirement Monitoring - The permittee must Pe in compliance with the emission limitations, operating limitations, and Other requirements in 40 CFR 63 Subpart ZZZZ that apply to the stationary RICE (Ref. 007), at all times. At all times the permittee must operate and maintain the stationary RICE (Ref. 007), including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the permittee to make any further efforts to reduce emissions if levels required by this standard have Peen achieved. Determination of whether such operation and' maintenance procedures are being used Will be based on information available to the Administrator which may include, Jaut is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. (9 VAC 5-80-490 B&C and 40 CFR 63.660£) Observation H^o-^k^-^ ^ I ^j't- i^a A^-yAt T" Effective Date: May 5, 2014 Applicable Requirement #: T5 41 Compliance Status: Applicable Requirement Recordkeeping - The permittee shall maintain records of all emission data and operating parameters necessary to demonstrate compliance with this permit. The content and format of such records shall be arranged with the DEQ. These records shall include, but are not limited to: a. Maintenance conducted on the stationary RICE (Ref. 007) in order to demonstrate that each engine is operated and maintained according to the maintenance plan required by Condition 39. b. Annual hours of operation of the stationary RICE (Ref. 007) that is recorded through the non-resettable hour meter. The owner or operator must document how many hours are spent for emergency operation, including what classified the operation as emergency, and how many hours are spent for non-emergency operation. These records shall be available for inspection Py the DEQ and shall be current for the most recent five years. (9 VAC 5-80-490 B & C and 40 CFR 63,6655)^ Observation Records available, see attachment I. Effective Date: May 5, 2014 Applicable Requirement #: T5 42 Compliance Status: Applicable Requirement Testing - If testing is conducted in addition to the monitoring specified in this permit, the permittee shall use the appropriate method(s) in accordance with procedures approve^ by the DEQ. (9 VAC 5-80-490 B&C) Observation ^ J^. ^ Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 14/26 Effective Date: May 5, 2014 Applicable Requirement #: T5 43 Compliance Status: (^Bfr Applicable Requirement Reporting - The permittee must report any failure to perform the management practices in Condition 35 for the stationary RICE (Ref. 007), on the schedule required and the federal, state or local law under which the risk was deemed unacceptable. (9 VAC 5-80-490 B & C and 40 CFR 63.6602^ Observation ^\ ^ _ Effective Date: May 5, 2014 Applicable Requirement Insignificant Emission Units Applicable Requirement #: T5 44 Compliance Status: flSBffift Insignificant Emission Units - The following emission units at the facility are identified in the application as insignificant emission units under 9 VAC 5-80-720: Emission Unit No. Emission Unit Description Citation Pollutant(s) Emitted (9 VAC 5-80-720 B) Rated Capacity (9 VAC 5-80-720 C) IS-1 Lube Oil Systems/ Waste Oil Systems/ Hydraulic Oil Systems 9 VAC 5-80-720B VOC IS-3 275 Gallon Gasoline Dispensing Station & Tank 9 VAC 5-80-720B OC IS-4 500 Gallon Kerosene Tank 9 VAC 5-80-720B VOC IS-8 Gravel Roads 9 VAC 5-80-720B PM-10 IS-9 Sand Blasters (1) 9 VAC 5-80-720B PM-10 IS-10 Sewage Treatment 9 VAC 5-80-720B VOC Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 15/26 IS-12 Ash Storage Ponds 9 VAC 5-80-720B PM-10 IS-14 Lime Slurry Tank 9 VAC 5-80-720B PM-10 1S-15 275 Gallon Fire Pump Diesel Tank 9 VAC-5-80-720B VOC 006 Natural gas-fired pipeline heater 9 VAC 5-80-720C 4.277 MMBtu/hr These emission units are presumed to Pe in compliance with all requirements of the federal Clean Air Act as may apply. Based on this presumption, no monitoring, recordkeeping, or reporting sryfll Pe required for these emission units in accordance with 9 VAC 5-80-490 C, E and F.i> . Observation (jw - ^jl / ^ # ^ - ^ - \Nh8r^ Effective Date: May 5, 2014 Applicable Requirement #: T5 45 Applicable Requirement Permit Shield & Inapplicable Requirements Compliance Status: Permit Shield and Inapplicable Requirements - Compliance with the provisions of this permit shall Pe deemed to be in compliance with all applicable requirements in effect as ofthe permit issuance date as identified in this permit. This permit shield covers only those applicable requirements covered by terms and conditions in this permit and the following requirements which have Peen specifically identified as being not applicable to this permitted facility: Citation Title of Citation Description of Applicability 40 CFR 60 Subparts D Standards of Performance for Fossil-Fuel-Fired Steam Generators for Which Construction is Commenced After August 17,1971 y Not applicaPle for Units 003 and 004; Units constructed prior to August 17, 1971 40 CFR 60 SuPpart Da Standards of Performance for Electric Utility Steam Generating Units for Which Construction is Commenced After SeptemPer 18, 1978 Not applicable for Units 003 and 004; Units constructed prior to September 18, 1978 40 CFR 60 Subpart Db / Standards of Performance for Industrial-Commereial-lnstitutiohal Steam Generating Units Not applicable Units 003 and 004; Units constructed prior to June 19, 1984 • Mar 14, 201703:17 Dominion - Bremo Power Station (40199) Page 16/26 40CPP00SuPpartKP Standards of Perform Notapplioable to storage tanksatfaoility due tolowvaporpressureofstored liquids 40CPP60 Subparts Standards of Performance for Coal Preparation and Processing Plants Not applicaPle to facility; facility no longer handles or combusts coal 40CPP60SuPpartGG Standards of Performance for Stationary GasTurbines Not applicaPle to Unit 002; Unit less than lOmillionBTU per hour 40CPR60SuPpartKKKK Standards of Performance for Stationary CombustionTurbines NotapplicaPle to Unit 002; unit constructedpriortofirst applicaPility date in NSPS 40CPP03SuPpart^^B National Emission Standards for Hazardous Air Pollutants for Stationary Not applicable to Unit 002; the unit is considered an existing stationary combustion turbine. . ^—^ . ^ ^ 40 CFR 63 Subpart UUUUU / National Emission Standards for Hazardous Air Pollutants for Coal- ancMZfil-Fired Electric Utility Steam Generating Units Not applicable for Units 003 and 004; the units bum only natural gas v 40 CFR 63 Subpart JJJJJJ National Emission Standards for Hazardous Air Pollutants for Industrial, CommerciaLand Institutional Boilers Area Sources Not applicable for Units 003, 004, 005, or 006, in accordance with 763.11195(e) ^ 40 CFR 64 1 Compliance Assurance Monitoring pyNot.applicable for Units 003 and 004; units do not meet the general applicability in 764.2(a). Not applicaPle for Units 002 or 005 smce each unit doorj not use a control device to meet the emission standards. ^ f^Jy iso v«r, Nothing in this permit shield shall alter the provisions of Section 303 of the federal Clean Air Act, including the authority of the administrator under that section, the liaPility of the owner for any violation of applicaPle requirements prior to or at the time of permit issuance, or the aPility to oPtain information Py (i) the administrator pursuant to Section 114 of the federal Clean Air Act, (ii) the Board pursuant to Section 10.1-1314 or Sectipon 10.1-1315 of the Virginia Air Pollution Control Law or (iii) the Department pursuant to Section 10.1-1307.3^ the Virginia Air Pollution Control Law. (9 VAC 5-80-500 C) Observation tur- U j . Effective Date: May 5, 2014 Applicable Requirement General Conditions Applicable Requirement #: T5 46 Compliance Status: Q Federal Enforceability - All terms and conditions in this permit are eriforceaPle Py the administrator and citizens under the federal Clean Air Act, except those that have Peen designated as only state-enforceaPle. (9 VAC 5-80-490 N) > Observation . S*^. L wvw C Effective Date: May 5, 2014 ApplicaPle Requirement #: T5 56 Compliance Status: Applicable Requirement Annual Compliance Certification - Exclusive of any reporting required to assure compliance with the terms and conditions of this permit or as part of a schedule of compliance contained in this permit, the permittee shall submit to EPA and DEQ no later than March 1 each calendar year a certification of compliance with all terms and conditions of this permit including emission limitation standards or work practices. The compliance certification shall comply with such additional requirements that may Pe specified pursuant to Section 114(a)(3) and Section 504(P) of the federal Clean Air Act. This certification shall Pe signed Py a responsiPle official, consistent with 9 VAC 5-80-430 G, and shall include: a. The time period included in the certification. The time period to Pe addressed is January 1 to DecemPer 31. b. The identification of each term or condition of the permit that is the hasis of the certification. c. The compliance status. d. Whether compliance was continuous or intermittent, and if not continuous, documentation of each incident of non-compliance. e. Consistent with suPsection 9 VAC 5-80-490 E, the method or methods used for determining the compliance status of the source at the time of certification and over the reporting period. Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 19/26 f. Such other facts as the permit may require to determine the compliance status of the source. g. One copy of the annual compliance certification shall be sent to EPA in electronic format only. The certification document should Pe sent to the following electronic mailing address: R3_APD_Permits@epa.gov (9 VAC 5-80-490 K.5) , Observation ^rCC- J . V*\r*~~ n i . t ^ °) . ^ y ^ - ' Effective Date: May 5, 2014 Applicable Requirement #: T5 57 Compliance Status: Applicable Requirement Permit Deviation Reporting - The permittee shall notify the DEQ, within four daytime business hours after discovery of any deviations from permit requirements which may cause excess emissions for more than one hour, including those attributable to upset conditions as may Pe defined in this permit. In addition, within 14 days ofthe discovery, the permittee shall provide a written statement explaining the proPlem, any corrective actions or preventative measures taken, and the estimated duration ofthe permit deviation. The occurrence should also Pe reported in the next semi-annual compliance monitoring report rt pursuant to General Condition 55 of this permit. ^ (9 VAC 5-80-490, OPservation . i p * " , Zo Lw-^yu A^pfe^ L J L ^ ^ r v (uArS^W^t— / Effective Date: May 5, 2014 Applicable Requirement #: T5 58 Compliance Status: ApplicaPle Requirement Failure/Malfunction Reporting - In the event that any affected facility or related air pollution control equipment fails or malfunctions in such a manner that may cause excess emissions for more than one hour, the owner shall, as soon as practicable Put no later than four daytime business hours after the malfunction is discovered, notify the DEQ, by facsimile transmission, telephone or telegraph of such failure or malfunction and shall within 14 days of discovery provide a written statement giving all pertinent facts, including the estimated duration of the Preakdown. Owners suPject to the requirements of 9 VAC 5-40-50 C and 9 VAC 5-50-50 C are not required to provide the written statement prescribed in this paragraph for facilities suPject to the monitoring requirements of 9 VAC 5-40-40 and 9 VAC 5-50-40. When the condition causing the failure or malfunction has been corrected and the equipment is again in operation, the owner shall notify the DEQ. (9 VAC 5-20-180 C) . i t JL Observation ^ Cu^v~*- « / v ^ < ^ MWuLCs*. >^v ^jS***- j /iQlhdfc-. Effective Date: May 5, 2014 Applicable Requirement #: T5 59 Compliance Status: Applicable Requirement Severability - The terms of this permit are severable. If any condition, requirement or portion of the permit is held invalid or inapplicaPle under any circumstance, such invalidity or inapplicability shall not affect or impair the remaining conditions, requirements, or portions of the permit. (9 VAC 5-80-490 G.1) ^ Observation <(Lw. o j j 4%_ y u ^ / .... Effective Date: May 5, 2014 ApplicaPle Requirement #: T5 60 Compliance Status: Applicable Requirement Duty to Comply - The permittee shall comply with all terms and conditions of this permit. Any permit noncompliance constitutes a violation of the federal Clean Air Act or the Virginia Air Pollution Control Law or Poth and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or, for denial of a permit renewal application. (9 VAC 5-80-490 % Observation ^ f n y y/ ^ Effective Date: May 5, 2014 Applicable Requirement #: T5 61 Compliance Status: ApplicaPle Requirement Need to Halt or Reduce Activity not a Defense - It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit. Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 20/26 (9 VAC 5-80-490 G.3) Observation K**^ dr** Effective Date: May 5, 2014 Applicable Requirement #: T5 62 Compliance Status: Q Applicable Requirement Permit Modification - A physical change in, or change in the method of operation of, this stationary source may Pe suPject to permitting under State Regulations 9 VAC 5-80-50, 9 VAC 5-80-1100, 9 VAC 5-80-1605, or 9 VAC 5-80-2000 and may require a permit modification and/or revisions except as may be authorized in any approved alternative operating scenarios. / (9 VAC 5-80-490 G and L, 9 VAC 5-80-550 and 9 VAC5-80-660) Observation ^ u r ^ ^ y^y-i Effective Date: May 5, 2014 Applicable Requirement #: T5 67 Compliance Status: Applicable Requirement Fugitive Dust Emission Standards - During the operation of a stationary source or any other Puilding, structure, facility, or installation, ho owner or other person shall cause or permit any materials or property to be handled, transported, stored, used, constructed, altered, repaired, or demolished without taking reasonahle precautions to prevent particulate matter from becoming airPorne. Such reasonaPle precautions may include, Put are hot limited to, the following: a. Use, where possiPle, of water or chemicals for control of dust in the demolition of existing Puildings or structures, construction operations, the grading of roads, or the clearing'of land; b. Application of asphalt, water, or suitaPle chemicals on dirt roads, materials stockpiles, and other surfaces which may create airborne dust; the paving of roadways and the maintaining of them in a clean condition; Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 21 / 26 c. Installation and use of hoods, fans, and fabric filters to enclose and vent the handling of dusty material. Adequate containment methods shall be employed during sandblasting or other similar operations; d. Open equipment for conveying or transporting material likely to create objectionable air pollution when airborne shall be covered or treated in an equally effective manner at alj times when in motion; and, e. The prompt removal of spilled or tracked dirt or other materials from paved streets and of dried sediments resulting from soil erosion. (9 VAC 5-40-20 E^9 VAC 5-50-90 and 9 VAC 5-50-50) OPservation Effective Date: May 5, 2014 Applicable Requirement #: T5 76 Compliance Status: Applicable Requirement Malfunction as an Affirmative Defense - A malfunction constitutes an affirmative defense to an action brought for noncompliance with technology-based emission limitations if the requirements stated in Condition 77 are met. (9 VAC 5-80-250) /> Observation ff-Cyr u/^ Effective Date: May 5, 2014 Applicable Requirement #: T5 77 Compliance Status: ApplicaPle Requirement Malfunction as an Affirmative Defense - The affirmative defense of malfunction shall Pe demonstrated Py the permittee through properly signed, contemporaneous operating logs, or other relevant evidence that show the following: a. A malfunction occurred and the permittee can identify the cause or causes of the malfunction. P. The permitted facility was at the time being properly operated. Mar 14, 201703:17 Dominion - Bremo Power Station (40199) Page 23/26 c. During the period of the malfunction the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit. d. The permittee notified the Board of the malfunction within two working days following the time when the emission limitations were exceeded due to the malfunction. This notification shall include a description ofthe malfunction, any steps taken to mitigate emissions, and corrective actions taken. The notification may Pe delivered either orally or in writing. The notification may Pe delivered by electronic mail, facsimile transmission, telephone, or any other method that allows the permittee to comply with the deadline. This notification fulfills the requirements of 9 VAC 5-80-490 F.2.P to report promptly deviations from permit requirements. This notification does not release the permittee from the malfunction reporting requirement under 9 VAC 5-20-180 C. (9 VAC 5-80-250) y/ Observation - f ^ . IL*-*-^ ^ jUL$yJz-« &• - J L / ^ W ^ , / u ^ Effective Date: May 5, 2014 Applicable Requirement #: T5 78 Compliance Status: Applicable Requirement Malfunction as an Affirmative Defense - In any enforcement proceeding, the permittee seeking to estaPlish the occurrence of a malfunction shall have the Purden of proof. (9 VAC 5-80-250) Observation £ ^ y j £ 4?*vEffective Date: May 5, 2014 Applicable Requirement #: T5 79 Compliance Status: isSSEim Applicable Requirement Malfunction as an Affirmative Defense - The provisions of this section are in addition to any malfunction, emergency or upset provision contained in any applicable requirement. (9 VAC 5-80-250) Observation (£u/~ oJ^ -fc-c . A^f Effective Date: May 5, 2014 Applicable Requirement #: T5 80 Compliance Status: (_____[) Applicable Requirement Permit Revocation or Termination for Cause - A permit may Pe revoked or terminated prior to its expiration date if the owner knowingly makes material misstatements in the permit application or any amendments thereto or if the permittee violates, fails, neglects or refuses to comply with the terms or conditions of the permit, any applicaPle requirements, or the applicable provisions of 9 VAC 5 Chapter 80, Article 3. The Board may suspend, under such conditions and for such period of time as the Board may prescriPe, any permit for any of the grounds for revocation or termination or for any other violations of these regulations. / (9 VAC 5-80-490 G and L, 9 VAC 5-80-640 and 9 / A C 5-80-660) Observation J U ^ *M W\ • < L ^ ^ ^ ykfi — ^ c C Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Jfo i/ v Page 24 / 26 • Effective Date: May 5, 2014 Applicable Requirement #:T5 83 Compliance Status: Applicable Requirement Asbestos Requirements - The permittee shall comply with the requirements of National Emissions Standards for Hazardous Air Pollutants (40 CFR 61) SuPpart M, National Emission Standards for Asbestos as it applies to the following: Standards for Demolition and Renovation (40 CFR 61.145), Standards for Insulating Materials (40 CFR-61.148), and Standards for Waste Disposal (40 CFR 61.150). (9 VAC 5-60-70 and 9 VAC 5-80-490 A. 1) » Observation f^ya. jlrVa r~\ %~ c^JL—< 2 r X y h rA < Effective Date: May 5, 2014 Applicable Requirement #: T5 84 Compliance Status: Applicable Requirement Accidental Release Prevention - If the permittee has more, or will have more than a threshold quantity of a regulated suPstance in a process, as determined Py 40 CFR 68.115, the permittee shall comply with the requirements of 40 CFR Part 68. (40 CFR Part 68) , . U_i , Observation yvO^A^ J ^ J r ^ ^ ^ Effective Date: May 5, 2014 Applicable Requirement #: T5 85 Compliance Status: Applicable Requirement Changes to Permits for Emissions Trading - No permit revision shall be required under any federally approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are provided for in this permit. (9 VAC 5-80-4901) • . Observation (frp i ^ J L ^ ^rT j^^.. Effective Date: May 5, 2014 Applicable Requirement #: T5 86 Compliance Status: (___]__> ApplicaPle Requirement Emissions Trading - Where the trading of emissions increases and decreases within the permitted facility is to occur within the context of this permit and to the extent that the regulations provide for trading such increases and decreases without a case-Py-case approval of each emissions trade: a. All terms and conditions required under 9 VAC 5-80-490, except suPsection N, shall Pe included to determine compliance. P. The permit shield descriPed in 9 VAC 5-80-500 shall extend to all terms and conditions that allow such increases and decreases in emissions. c. The owner shall meet all applicaPle requirements including the requirements of 9 VAC 5-80-360 through 9 VAC 5-80-700. (9 VAC VAC 5-80-490 (9 5-80-490 I)I) , Q I d Q Observation ^ ^ w y " j Z ^ r ^ ^ cT d,^* Effective Date: May 5, 2014 Applicable Requirement #: T5 87 Applicable Requirement i Title IV (Phase II Acid Rain) Permit Allowances and Requirements Compliance Status: Q The Phase II Acid Rain permit is incorporated into this permit Py reference. The owners and operators of the source shall comply with the standard requirements and special provisions set forth in the application. (9 VAC 5-80-440 and 9 VAC 5-80-490 A.4.a and c, B, C, E, F, M, O and P) Statutory and Regulatory Authorities - In accordance with the Air Pollution Control Law of Virginia Section 10.1-1308 and Section 10.1-1322, the Environmental Protection Agency (EPA) Final Full Approval of the Operating Permits Program (Titles IV and V) puPlished in the Federal Register DecemPer 4, 2001, Volume 66, Mumper 233, Rules and Regulations, Pages 62961-62967 and effective November 30, 2001, and Title 40, the Code of Federal Regulations Sections 72.1 through 76.16, the Commonwealth of Virginia Department of Environmental Quality issues this Phase II Acid Rain permit pursuant to 9 VAC 5 Chapter 80, Article 3 of the Virginia Regulations for the Control and APatement of Air Pollution (Federal Operating Permit Article 3) Mar 14, 2017 03:17 Dominion - Bremo Power Station (40199) Page 25 / 26 (9 VAC, 5-80-490 B2) Observation %J^r - 4**^ Effective Date: May 5, 2014 Applicable Requirement #: T5 88 Applicable Requirement S02 Allowance Allocations and NOx Requirements for Affected Units Compliance Status: PLEASE REFERENCE THE PERMIT FOR THE TABLE. (9 VAC 5-80-490 A.4) Observation %uur -