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Statement of Legal and Factual Basis


COMMONWEALTH OF VIRGINIA
Department of Environmental Quality
South Central Regional Office

STATEMENT OF LEGAL AND FACTUAL BASIS

Dominion Resources, Inc.
Hurt, Virginia
Permit No. SCRO-30871

Title V of the 1990 Clean Air Act Amendments required each state to develop a permit program
to ensure that certain facilities have federal Air Pollution Operating Permits, called Title V
Operating Permits. As required by 40 CFR Part 70 and 9 VAC 5 Chapter 80, Dominion
Resources, Inc. has applied for a Title V Operating Permit for its Hurt, Virginia facility. The
Department has reviewed the application and has prepared a draft Title V Operating Permit.


Engineer/Permit Contact:
Date:
Keith
Sandifer
(434) 582-6232


Air Permit Manager:

Date:


David J. Brown


Regional Director:

Date:


T. L. Henderson

Dominion Resources, Inc - Pittsylvania Power Station
SCRO-30871
Statement of Basis
Page 2
FACILITY INFORMATION

Permittee
Dominion Resources, Inc.
5000 Dominion Boulevard
Glen Allen, Virginia 23060

Facility
Pittsylvania Power Station
821 Grit Road
Hurt, Virginia 24563

State-County-Plant Identification Number: 51- 143-0123


SOURCE DESCRIPTION

NAICS Code: 221119 Electric power generation

Pittsylvania Power Station is authorized to operate an electric power production facility located
in Hurt, Virginia. The plant uses three identically sized wood-fired spreader stoker boilers, each
having a maximum rated capacity of 373.3 MMBtu/hr (heat input) to generate steam. The steam
from the three boilers is directed to two turbine-driven electric generators, each with a rated
maximum generating capacity of 45 megawatts (MW) of electrical power. The facility also
contains one auxiliary diesel IC-powered electric generator and associated fuel storage tanks,
wood storage, and handling equipment and ash handling and storage.

The facility is a Title V major source of nitrogen oxides, volatile organic compounds, and carbon
monoxide. This source is located in an attainment area for all pollutants, and is a PSD major
source. The facility was previously permitted under a PSD Permit issued on April 8, 1991,
which was amended on February 21, 1992, January 19, 1993, June 7, 1994, September 28, 1995,
November 6, 1996, April 9, 1997, March 24, 1999, and December 9, 1999.

COMPLIANCE STATUS

A full compliance evaluation of this facility, including a site visit on August 22, 2007, was
conducted on August 28, 2007. In addition, all reports and other data required by permit
conditions or regulations, which are submitted to DEQ, are evaluated for compliance. Based on
these compliance evaluations, the facility has not been found to be in violation of any state or
federal applicable requirements at this time.
Dominion Resources, Inc - Pittsylvania Power Station
SCRO-30871
Statement of Basis
Page 3

EMISSION UNIT AND CONTROL DEVICE IDENTIFICATION

The emissions units at this facility consist of the following:

See Title V Permit Condition II.

EMISSIONS INVENTORY

A copy of the 2006 annual emission update is attached. Emissions are summarized in the
following tables.

2006 Actual Emissions


2006 Criteria Pollutant Emission in Tons/Year

Emission
Unit
VOC CO SO
2
PM
10
NO
x

Boilers 30.5
1165.5
12.96
12.5
300.8
Auxiliary
Generator
Just
tested

Total 30.5
1165.5
12.96
12.5
300.8


2006 Facility Hazardous Air Pollutant Emissions


Pollutant
2006 Hazardous Air Pollutant Emission in Tons/Yr
Benzene 14.7
Chlorine 2.8
Formaldehyde 1.8
Hydrogen chloride
66.6




EMISSION UNIT APPLICABLE REQUIREMENTS Boilers (Units 101, 102, and 103)

Limitations

All three boilers are permitted and are NSPS Subpart Db affected facilities. SNCR is used to
control the nitrogen oxides, and multiclones in series with electrostatic precipitators (ESPs) are
used to control particulate emissions from the three boilers. The facility has continuous
emissions monitors (CEMS) for NOx and either CO
2
or O
2
monitors for each of the three boilers.
There is a continuous opacity monitor (COMS) located in the common stack. Dominion Resources, Inc - Pittsylvania Power Station
SCRO-30871
Statement of Basis
Page 4

Condition III.A.1 contains the particulate control equipment for each boiler. This condition is
taken from the permit issued December 9, 1999

Condition IIIA.2 contains the nitrogen oxide control equipment for each boiler. This condition is
taken from the permit issued December 9, 1999.

Condition III.A.3 contains the wood consumption limitation for the three boilers. This condition
is taken from the permit issued December 9, 1999.

Condition III.A.4 contains the approved fuel (wood) and the definition of wood. This
condition is taken from the permit issued December 9, 1999.

Condition III.A.5 contains the analysis requirements of the wood. This condition is taken from
the permit issued December 9, 1999.

Condition III.A.6 contains the emissions limitations for each boiler. This condition is taken from
the permit issued December 9, 1999.

Condition III.A.7 contains the sulfur dioxide and sulfuric acid mist emission limits for the three
boilers. This condition is taken from the permit issued December 9, 1999.

Condition III.A.8 contains annual emissions limits for the combined operation of the boilers.
This condition is taken from the permit issued December 9, 1999.

Condition III.A.9 contains the opacity limitation for the boilers. This condition is taken from the
permit issued December 9, 1999 which was determined to be BACT for the permit.

Condition III.A.10 requires a maintenance schedule and maintaining records of scheduled and
non-schedule maintenance. This condition is taken from the permit issued December 9, 1999.

Condition III.A.11 contains the requirement to comply with 40 CFR 60 Subparts Db and A.

Monitoring

Periodic monitoring is not required for the boilers, since they already have CEMS and COMS.
An increase in CO or VOC emissions would be the result of a boiler upset. The boiler operator
has sufficient monitoring to be alerted to such an event.

Condition III.B.1 requires the facility to install, maintain, and operate continuous emissions
monitors for opacity, nitrogen oxide, and carbon dioxide or oxygen. This condition is taken Dominion Resources, Inc - Pittsylvania Power Station
SCRO-30871
Statement of Basis
Page 5
from the permit issued December 9, 1999.

Condition III.B.2 specifies the data capture, quality assurance, and reporting requirements. This
condition is taken from the permit issued December 9, 1999.

Condition III.B.3 states that the continuous emission monitoring data may be used as evidence of
violation of the emissions standards. This condition is taken from the permit issued December 9,
1999.

COMPLIANCE ASSURANCE MONITORING (CAM)

Generally, the requirements of 40 CFR 64, CAM, apply to each emissions unit meeting all three
of the following criteria at a major source required to obtain a Title V permit:



The unit emits or has the potential to emit (in the absence of add-on control devices)
quantities of one or more regulated air pollutants that exceed major source thresholds,
The unit is subject to one or more emission limitations for the regulated air pollutants
for which it is major before control, and
The unit uses a control device to achieve compliance with one or more of these
emission limitations.

VOCs
Each of the three boilers (Units 101, 102, and 103) has the potential to emit greater than 100 tons
per year of VOCs, but there are no controls for VOC at the facility. Therefore the boilers are not
subject to CAM for VOCs.

NOx
Each of the three boilers (Units 101, 102, and 103) is potentially subject to CAM for emissions
of nitrogen oxides (NOx), The units each have the potential to emit more than 100 tons per year
of each of this pollutant for which emissions limits apply and use control devices to comply with
the limit.

Emissions of NOx from the three boilers are controlled by selective non-catalytic reduction
(SNCR). Each boiler is subject to the same emission limitation of 0.10 pounds of NOx per
million Btu (heat input) on a 30-day rolling average basis and each has uncontrolled potential to
emit more than 100 tons