Here’s one you don’t see every day: 1) a state university needing an RMP for its power generation plant’s SCR, 2) the SCR uses 29% aqua ammonia rather than anhydrous ammonia, and 3) they exceeded the doubled TQ for Aqua Ammonia > 20% of 20,000 pounds.
Respondent is part of a State University system and owns and operates a Combined Power and Heat Plant. Respondent uses aqueous ammonia as the reduction reagent in the selective catalytic reduction (SCR) system used to control nitrogen oxide emissions from the 9.6-megawatt diesel-fired generator located adjacent to the facility. The aqueous ammonia is stored in vessels that are connected by piping to the SCR system. The vessels storing aqueous ammonia, the SCR system, and the related piping constitute a single process under 40 C.F.R. ยง 68.3 (hereinafter “Aqueous Ammonia Process”). More than 20.000 pounds of 29% aqueous ammonia solution was present in Respondent’s Aqueous Ammonia Process from at least December 16, 2014, through October 7, 2016. Here are the facts as stated in the CAFO: