STATEMENT OF BASIS SPIRE ALABAMA, INC. - COOSADA LNG ...

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STATEMENT OF BASIS SPIRE ALABAMA, INC. - COOSADA LNG FACILITY COOSADA, ELMORE COUNTY, ALABAMA FACILITY/PERMIT NO. 205-0008 Page 1 of 9 The proposed Title V Major Source Operating Permit (MSOP), third renewal, is issued under the provisions of ADEM Admin. Code r. 335-3-16. Spire Alabama, Inc. (Spire) has requested authorization to operate the facility, as indicated in the application and drawings, plans and other documents attached hereto or on file with the Air Division of the Alabama Department of Environmental Management, in accordance with the terms and conditions of this permit. The current MSOP was issued on July 15, 2016, modified on May 31, 2018, and is scheduled to expire on July 14, 2021. The May 31, 2018, modification incorporated the requirements of Air Permit No. X014 issued on June 2, 2017, reflecting the change of the operational status of the existing generator (EU002) to emergency only. The owner of the facility was also changed from Alabama Gas Corporation (Alagasco) to Spire Alabama, Inc. The reporting period and submittal dates of the Title V Semiannual Compliance Report (SCR) required under 40 CFR Part 63, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants (NESHAP) for Stationary Reciprocating Internal Combustion Engines (RICE MACT) Subpart ZZZZ for EU001 was also updated to align these reporting dates with the Semiannual Monitoring Report (SMR) in accordance with 40 CFR §63.6650(b)(5). With Spire’s timely and complete application submittal, the terms of the previous permit remain in effect until this renewal has been issued or denied, in accordance with ADEM Admin. Code r. 335-3-16-.12(2)(c). The applicant has requested authorization to perform the work or operate the facility shown on the application and drawings, plans, and other documents attached hereto or on file with the Air Division of the Alabama Department of Environmental Management, in accordance with the terms and conditions of this permit. The initial MSOP was issued on June 19, 2000, and a renewal was issued on June 9, 2005. However, Alagasco (now Spire) requested limits to become a synthetic minor source under Title V regulations on April 12, 2010. The current MSOP was issued on July 15, 2016, after control devices were installed on the Ingersoll Rand and Caterpillar engines to comply with RICE MACT, and test results indicated an increase in NOx emissions above Title V major source thresholds. The MSOP was modified on May 31, 2018, as previously described above. Facility Operations Spire operates an existing liquefied natural gas (LNG) production and distribution operation (SIC 4925) located in Coosada, Elmore County. The significant sources of air pollutants at this facility include: one 1500 hp Ingersoll Rand natural gas-fired reciprocating engine (EU001), one 930 hp Caterpillar natural gas-fired emergency generator (EU002), three LNG product vaporizers (1 30.5 MMBtu/hr and 2 27.6 MMBtu/hr) (EU003-EU005, respectively), and one 3.34 MMBtu/hr GasTech H-100 regeneration heater (EU006). Insignificant emission sources at this station include a waste oil tank, a hexane tank, loading/unloading of LNG trucks, solvent metal cleaning, and fugitive emissions from ethylene glycol, ethylene, propane, liquefaction, and the vaporization process. Proposed Changes The MSOP renewal includes the following changes to the current permit:

Transcript of STATEMENT OF BASIS SPIRE ALABAMA, INC. - COOSADA LNG ...

STATEMENT OF BASIS

SPIRE ALABAMA, INC. - COOSADA LNG FACILITY

COOSADA, ELMORE COUNTY, ALABAMA

FACILITY/PERMIT NO. 205-0008

Page 1 of 9

The proposed Title V Major Source Operating Permit (MSOP), third renewal, is issued under the

provisions of ADEM Admin. Code r. 335-3-16. Spire Alabama, Inc. (Spire) has requested authorization

to operate the facility, as indicated in the application and drawings, plans and other documents attached

hereto or on file with the Air Division of the Alabama Department of Environmental Management, in

accordance with the terms and conditions of this permit. The current MSOP was issued on July 15,

2016, modified on May 31, 2018, and is scheduled to expire on July 14, 2021. The May 31, 2018,

modification incorporated the requirements of Air Permit No. X014 issued on June 2, 2017, reflecting

the change of the operational status of the existing generator (EU002) to emergency only. The owner of

the facility was also changed from Alabama Gas Corporation (Alagasco) to Spire Alabama, Inc. The

reporting period and submittal dates of the Title V Semiannual Compliance Report (SCR) required under

40 CFR Part 63, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants (NESHAP)

for Stationary Reciprocating Internal Combustion Engines (RICE MACT) Subpart ZZZZ for EU001

was also updated to align these reporting dates with the Semiannual Monitoring Report (SMR) in

accordance with 40 CFR §63.6650(b)(5). With Spire’s timely and complete application submittal, the

terms of the previous permit remain in effect until this renewal has been issued or denied, in accordance

with ADEM Admin. Code r. 335-3-16-.12(2)(c). The applicant has requested authorization to perform

the work or operate the facility shown on the application and drawings, plans, and other documents

attached hereto or on file with the Air Division of the Alabama Department of Environmental

Management, in accordance with the terms and conditions of this permit.

The initial MSOP was issued on June 19, 2000, and a renewal was issued on June 9, 2005. However,

Alagasco (now Spire) requested limits to become a synthetic minor source under Title V regulations on

April 12, 2010. The current MSOP was issued on July 15, 2016, after control devices were installed on

the Ingersoll Rand and Caterpillar engines to comply with RICE MACT, and test results indicated an

increase in NOx emissions above Title V major source thresholds. The MSOP was modified on May 31,

2018, as previously described above.

Facility Operations

Spire operates an existing liquefied natural gas (LNG) production and distribution operation (SIC 4925)

located in Coosada, Elmore County. The significant sources of air pollutants at this facility include: one

1500 hp Ingersoll Rand natural gas-fired reciprocating engine (EU001), one 930 hp Caterpillar natural

gas-fired emergency generator (EU002), three LNG product vaporizers (1 – 30.5 MMBtu/hr and 2 –

27.6 MMBtu/hr) (EU003-EU005, respectively), and one 3.34 MMBtu/hr GasTech H-100 regeneration

heater (EU006). Insignificant emission sources at this station include a waste oil tank, a hexane tank,

loading/unloading of LNG trucks, solvent metal cleaning, and fugitive emissions from ethylene glycol,

ethylene, propane, liquefaction, and the vaporization process.

Proposed Changes

The MSOP renewal includes the following changes to the current permit:

205-0008 October 1, 2021

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During the review of the current application, it was noted that Spire was requesting an increase in the

NOx limit for the 1500 hp Ingersoll Rand engine. It was determined that this increase would have to be

reviewed under the air permitting process prior to being included in the operating permit. A complete

Air Permit application was submitted on June 9, 2021, and Air Permit No. X015 was issued to Spire on

July 1, 2021, to increase the NOx limit from 61.80 lb/hr to 66.00 lbs/hr for the 1500 hp Ingersoll Rand

engine. A revised application was submitted on July 29, 2021 which included a request to incorporate

the requirements of Air Permit No. X015.

Applicability: Federal Regulations

Title V

The facility is a major source under Title V regulations because the potential NOx emissions exceed the

100 TPY major source threshold. Based on the category of this facility, fugitive emissions are not

considered for Title V applicability per ADEM Admin. Code r. 335-3-16-.01(1)(q)2. The facility is a

minor source of Hazardous Air Pollutants (HAP) because emissions do not exceed the major source

threshold of 10 TPY of an individual HAP and 25 TPY for total HAP.

Prevention of Significant Deterioration (PSD)

According to an EPA Memorandum from July 31, 2003, the change of state of natural gas from a liquid

to a gas (or vice-versa) takes place “without the need for chemical or process change that generally

occurs at other sources that EPA considers as ‘fuel conversion plants’ (e.g., coal gasification, oil shale

processing, conversion of municipal waste to fuel gas, processing of sawdust into pellets) under the PSD

rules”. This facility is not considered a fuel conversion plant since there is no chemical process change

and would not be subject to the 100 TPY threshold for fuel a conversion plant. Therefore, the facility is

subject to the 250 TPY criteria pollutant major source threshold for PSD regulations. This facility is

located in an attainment area for all criteria pollutants and is considered a synthetic minor source under

PSD regulations because limits were taken to reduce the facility-wide potential NOx emissions below

the major source threshold of 250 TPY. As a result of emission testing which indicated emissions of

NOx greater than levels indicated by AP-42 values, Spire was required to indicate a lb/hr limit to be used

in calculating potential to emit. To achieve the reduction of NOx emissions, the previous owner,

Alagasco, requested limitations to the hours of operation for EU001, EU002, EU003, EU004, EU005,

and EU006, and NOx emission limits of 61.80 lb/hr and 9.84 lb/hr for the Ingersoll Rand engine (EU001)

and the Caterpillar generator (EU002), respectively. To ensure the NOx synthetic minor limits were met,

annual testing of NOx was required for the Ingersoll Rand engine (EU001) and the Caterpillar generator

(EU002). The May 31, 2018, permit modification included an update to emergency status for the

Caterpillar generator (EU002) which removed the operational and emission limits, and annual test

requirements. Air Permit No. X015 was issued to Spire on July 1, 2021, increasing the NOx emission

limit to 66.00 lbs/hr for the 1500 hp Ingersoll Rand engine. The increased NOx synthetic minor limit for

EU001 of 66.00 lb/hr will be updated in this renewal, and the hourly operation limit of 7,000 hours

during any consecutive 12 month period will be retained in this renewal. Based on the category of this

facility, fugitive emissions are not considered for PSD applicability per ADEM Admin. Code r. 335-3-

14-.05(1)(k). After the proposed action, the facility would remain a synthetic minor source under PSD

regulations.

205-0008 October 1, 2021

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NSPS

40 CFR Part 60, Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal

Combustion Engines [Adopted by reference in ADEM Admin. Code r. 335-3-10-.02(88)]

Engines with a horsepower rating greater than or equal to 500 hp are subject to 40 CFR Part 60, Subpart

JJJJ if construction commences (i.e. engine is ordered from the manufacturer) after June 12, 2006, and

the engine is manufactured on or after July 1, 2007. The Ingersoll Rand engine (EU001) and Caterpillar

natural gas-fired emergency generator (EU002) were manufactured in 1972 and 1971, respectively,

therefore, they are not subject to Subpart JJJJ. The application indicated the engines have not been

reconstructed or modified as defined in Subpart JJJJ since June 12, 2006.

40 CFR Part 60, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional

Steam Generating Units [Adopted by reference in ADEM Admin. Code r. 335-3-10-.02(2)(c)]

Based on their size (30.5 MMBtu/hr and 27.6 MMBtu/hr) and date of manufacture (1992, 2005, and

2005), the vaporizers (EU003-EU005) are subject to 40 CFR Part 60, Subpart Dc for which construction,

modification, or reconstruction is commenced after June 9, 1989 and that has a maximum design heat

input capacity of 100 MMBtu/hr or less, but greater than or equal to 10 MMBtu/h. Because the

vaporizers burn natural gas exclusively, they are only subject to the fuel usage recordkeeping

requirements of Subpart Dc. The regeneration heater (EU006) is not subject to Subpart Dc because of

its size (3.34 MMBtu/hr).

40 CFR Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production,

Transmission, and Distributions [Adopted by reference in ADEM Admin. Code r. 335-3-10-.02(91)]

The site is not an affected source for 40 CFR Part 60, Subpart OOOO because the facility is classified

as a liquefied natural gas production and distribution operation (SIC 4925) which is located past the

point of custody transfer to a local distribution company.

40 CFR Part 60, Subpart OOOOa, Standards of Performance for Crude Oil and Natural Gas Facilities

for which Construction, Modification, or Reconstruction Commenced After September 18, 2015

[Adopted by reference in ADEM Admin. Code r. 335-3-10-.02(91)(a)]

The site is not an affected source for 40 CFR Part 60, Subpart OOOOa because the facility is classified

as a liquefied natural gas production and distribution operation (SIC 4925) which is located past the

point of custody transfer to a local distribution company.

NESHAP

Per 40 CFR §63.2 a facility is considered an area source for hazardous air pollutants (HAP) when

potential emissions do not exceed 10 tons per year or more of any single HAP or 25 tons per year or

more of combined HAP.

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40 CFR Part 63, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for Stationary

Reciprocating Internal Combustion Engines (RICE MACT) [Adopted by reference in ADEM Admin.

Code r. 335-3-11-.06(103) major source provisions only]

The RICE MACT applies to existing, reconstructed, and new engines at both major and area sources of

HAPs. The Ingersoll Rand engine (EU001) and Caterpillar emergency generator engine (EU002) are

each greater than 500 hp and were constructed in 1972 and 1971, respectively, therefore, they would

each be considered existing engines based on the construction date [prior to June 12, 2006, per 40 CFR

§63.6590(a)(1)(iii)]. The Ingersoll Rand engine (EU001) is considered an existing, non-remote, non-

emergency, 4SLB RICE, greater than 500 hp, located at an area source. After the status change (non-

emergency to emergency) in the May 31, 2018, permit modification, the 930 hp Caterpillar generator

(EU002) is considered an existing, emergency, 4-stroke rich burn RICE, greater than 500 hp, located at

an area source. The engines are subject to the applicable requirements of this Subpart as follows:

Ingersoll Rand Engine (EU001)

Equipment Standards

In accordance with 40 CFR §63.6603(a) and Item 9 of Table 2d to Subpart ZZZZ, Spire must install an

oxidation catalyst to reduce HAP emissions from the stationary RICE.

Emission/Operation Limitations

In accordance with 40 CFR §63.6630(a) and Item 13 of Table 5 to Subpart ZZZZ, Spire must (i) install

an oxidation catalyst to reduce of emissions of CO is 93 percent or more, or the average CO concentration

is less than or equal to 47 ppmvd at 15 percent O2, and (ii) install a CPMS to continuously monitor

catalyst inlet temperature according to the requirements in §63.6625(b), or install equipment to

automatically shut down the engine if the catalyst inlet temperature exceeds 1350 °F. The equipment to

automatically shut down the engine has been installed and is in operation.

In accordance with 40 CFR §63.6625(h), Spire is required to minimize the engine’s time spent at idle

and minimize the engine’s startup time to a period needed for appropriate and safe loading of the engine

not to exceed 30 minutes.

Testing Requirements

In accordance with 40 CFR §63.6630(a) and Item 13 of Table 5 Section 13 to Subpart ZZZZ, Spire is

required to install an oxidation catalyst and conduct an initial compliance demonstration as specified in

§63.6630(e) to show that the average reduction of emissions of CO is 93 percent or more, or the average

CO concentration is less than or equal to 47 ppmvd at 15 percent O2.

In accordance with 40 CFR §63.6640(c)(7), a performance test must be performed after each replacement

of the oxidation catalyst for the engine.

Fuel Requirements

There are no fuel requirements under this Subpart.

205-0008 October 1, 2021

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Continuous Compliance Monitoring

Spire is required to perform annual compliance demonstrations as specified in 40 CFR §63.6640(c) and

Item 14 of Table 6 to Subpart ZZZZ to show (i) that the average reduction of emissions of CO has been

maintained for the engine and, (ii) collect catalyst inlet temperature data according to 40 CFR

§63.6625(b), reduce this data to 4-hour rolling averages, and ensure the 4-hour rolling average remains

within the limitation of greater than 450 °F and less than or equal to 1350 °F for the catalyst inlet

temperature of the engine or immediately shut down the engine if the catalyst inlet temperature exceeds

1350 °F. As previously stated, the equipment to automatically shut down the engine has been installed

and is operational. If Spire decides to utilize a CPMS for catalyst temperature, requirements of 40 CFR

§§63.6625 and 63.6635 would be applicable.

In accordance with 40 CFR §63.6640(c)(7) and Item 14 of Table 6 to Subpart ZZZZ if the results of the

annual compliance demonstration show that the emissions exceed the applicable average

reduction/concentration for CO, Spire would be required to shut down the stationary RICE as soon as

safely possible, and the appropriate corrective action would be taken (e.g., repairs, catalyst cleaning,

catalyst replacement). Spire would be required to retest the stationary RICE within 7 days of being

restarted.

Notifications

In accordance with 40 CFR §63.6645, Spire is required to submit a Notification of Intent at least 60 days

prior to conducting each performance test. Following the initial performance test of the engines, Spire

is required to submit a Notification of Compliance Status, including the performance test results, within

60 days of completing the performance test. These notifications must be sent to the EPA and the Air

Division.

Per ADEM Admin. Code r. 335-3-16-.05, ADEM requires that the permittee shall submit a written

notification of the intent to replace the catalyst associated with Ingersoll Rand engine (EU001) to the Air

Division at least 30 days prior to taking any action. The permittee shall submit a written notification to

the Air Division that the replacement has been completed within 15 days of completing the action.

Reports

The reporting requirements are outlined in 40 CFR §63.6650 and Table 7 of Subpart ZZZZ. Spire is

required to submit a semiannual compliance report to the EPA Administrator and the Air Division, based

on the calendar semiannual periods of January – June and July – December. Each report must be

submitted by July 31st and January 31st, respectively. Per 40 CFR §63.6650(b)(5) Spire may elect to

submit the compliance reports according to the dates established in the MSOP for semiannual reporting

periods which are July 15th – January 14th and January 15th - July 14th.

Recordkeeping

In accordance with 40 CFR §§63.6660 and 63.6655 all notifications and reports (and supporting

documentation) including records pertaining to initial and continuous compliance, and all maintenance

conducted must be maintained for a period of 5 years from the date of each record or report. They must

205-0008 October 1, 2021

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be maintained in a form suitable and readily accessible for expeditious review in hard copy or electronic

form.

Caterpillar Emergency Generator Engine (EU002)

Equipment Standards

In accordance with 40 CFR §63.6625(f), the unit must be equipped with a non-resettable hour meter.

Emission/Operation Limitations

There are no emission limitations under this Subpart.

In accordance with 40 CFR §63.6603(a) and Item 5 of Table 2d to Subpart ZZZZ, Spire is required to

change the oil and filter every 500 hours of operation or annually, whichever comes first; inspect spark

plugs every 1,000 hours of operation or annually, whichever comes first, and replace as necessary; and

inspect all hoses and belts every 500 hours of operation or annually, whichever comes first and replace

as necessary.

Per Footnote 2 of Table 2d to Subpart ZZZZ, if a unit is operating during an emergency and it is not

possible to shut down the engine in order to perform the work practice requirements on the schedule, the

work practice can be delayed.

In accordance with 40 CFR 63.6625(h), Spire is required to minimize the engine’s time spent at idle

during startup and minimize the engine’s startup time to a period needed for appropriate and safe loading

of the engine not to exceed 30 minutes.

As indicated by 40 CFR §63.6640(f), the generator is limited to operating during:

Emergency situations;

Maintenance checks and readiness testing, not to exceed 100 hours per year; and

Non-emergency situations, not to exceed 50 hours per year (those 50 hours are counted towards

the 100 hours per year provided for maintenance and testing).

Testing Requirements

There are no emissions testing requirements under this Subpart.

Fuel Requirements

There are no fuel requirements under this Subpart.

Continuous Compliance Monitoring

Spire is required to operate and maintain the unit in a manner consistent with good air pollution control

practices for minimizing emissions and demonstrate continuous compliance with Item 5 of Table 2d to

Subpart ZZZZ.

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Notifications

There are no notification requirements under this Subpart.

Reports

Spire shall report to the Air Division any failure to perform a work practice on the schedule required,

including instances when the work practice standard was not performed due to emergency operation or

unacceptable risk under a federal, state, or local law. Spire is required to submit the report within two

working days of the deviation and shall provide an explanation as to why the work practice requirement

was not performed with the information required by 40 CFR §63.6650(d).

Recordkeeping

To show continuous compliance, Spire is required to develop a maintenance plan and to keep records of

the maintenance conducted on the emergency generator as indicated in 40 CFR §63.6655(e). In addition,

per 40 CFR §63.6655(f), Spire is required to record the hours of operation for the unit on a monthly and

annual total basis and shall maintain records of the date, time, duration, and purpose each time the

generator is operated to ensure it is being operated as an emergency stationary RICE as indicated by 40

CFR §63.6640(f).

In accordance with 40 CFR §§63.6660 and 63.6655 all notifications and reports (and supporting

documentation) including records pertaining to initial and continuous compliance, and all maintenance

conducted must be maintained for a period of 5 years from the date of each record or report. They must

be maintained in a form suitable and readily accessible for expeditious review in hard copy or electronic

form.

Applicability: State Regulations

ADEM Admin. Code r. 335-3-4-.01, “Control of Particulate Emissions: Visible Emissions”

The Ingersoll Rand engine (EU001), Caterpillar generator (EU002), vaporizers (EU003-EU005) and

regeneration heater (EU006) are subject to the State visible emission standards for stationary sources

which states that no air emission source may emit particulate of an opacity greater than 20% (as measured

by a six-minute average) more than once during any 60 minute period and at no time shall emit

particulate of an opacity greater than 40% (as measured by a six-minute average).

ADEM Admin. Code r. 335-3-4-.03, “Control of Particulate Emissions: Fuel Burning Equipment”

Although the Ingersoll Rand engine (EU001) and Caterpillar generator (EU002) are each a fuel

combustion source, they are not subject to any particulate matter (PM) emission limitation of ADEM

Admin. Code r. 335-3-4 because they do not meet the definition of fuel burning equipment and are not

considered one of the process industries, general or specific. The vaporizers (EU003-EU005) and

regeneration heater (EU006) are subject to particulate matter (PM) emission limitation of ADEM Admin.

Code r. 335-3-4.

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ADEM Admin. Code r. 335-3-5-.01, “Control of Sulfur Compound Emissions: Fuel Combustion”

Although Ingersoll Rand engine (EU001) and Caterpillar generator (EU002) are a fuel combustion

source, they are not subject to any SO2 emission limitation of ADEM Admin. Code r. 335-3-5 since they

do not meet the definition of fuel burning equipment. The vaporizers (EU003-EU005) and regeneration

heater (EU006) are subject to SO2 emission limitation of ADEM Admin. Code r. 335-3-5.

Emission Testing and Monitoring

Spire is required to certify on a semiannual basis that only natural gas was burned in all emission units

as a method for monitoring compliance with the visible emission requirements of ADEM Admin. Code

r. 335-3-4-.01(1) because opacity would be negligible while combusting natural gas.

Spire is required to conduct annual NOx testing for the Ingersoll Rand engine (EU001). Compliance

with the applicable synthetic minor NOx emission limit of 66.00 lb/hr for EU001 will be demonstrated

while simultaneously conducting the emission testing required by 40 CFR Part 63, Subpart ZZZZ. As

required by Air Permit No. X015 which is being incorporated into this renewal, the first emission testing

conducted must be conducted using an approved US EPA Reference Method. After the first performance

test is conducted, no periodic monitoring will be required if the unit does not operate for production

purposes during the respective annual testing period.

Recordkeeping and Reporting

In addition to the recordkeeping and reporting required to comply with 40 CFR Part 63, Subpart ZZZZ,

for Ingersoll Rand engine (EU001) and Caterpillar generator (EU002), Spire is required calculate the

hours of operation for the Ingersoll Rand engine (EU001), the three vaporizers (EU003-EU005), and the

regeneration heater (EU006) for the previous month and previous 12-month period to determine

compliance with the PSD operational limitations. Should the units exceed the hourly limit at any time,

Spire would be required notify the Air Division in writing within 2 working days of determining that the

exceedance occurred. Spire is also required to submit a certification semiannually that only natural gas

was fired in EU001-EU006 as a method for demonstrating compliance with the visible emission

requirements of ADEM Admin. Code r. 335-3-4-.01(1).

Compliance Assurance Monitoring (CAM)

The Ingersoll Rand engine (EU001) is the only emissions unit at the facility that has the potential to emit

greater than 100 TPY of a criteria pollutant (NOx and CO). However, the active control device for EU001

is not utilized to meet the synthetic minor NOx emission limitation. As such, EU001 is not subject to

CAM requirements.

The change in operational status to “emergency only” in the May 31, 2018, permit modification removed

any requirements under CAM for the Caterpillar generator (EU002).

205-0008 October 1, 2021

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Environmental Justice

ADEM utilized the EJSCREEN screening tool to perform an analysis of the area. Please refer to

Appendix A.

Public Notice

The renewal of this Title V MSOP would require a 30-day public comment period and a 45-day EPA

review period.

Recommendation

Based on the above analysis, I recommend that Spire Alabama, Inc.’s MSOP (205-0008) be renewed to

Spire, with the requirements noted above, pending the resolution of any comments received during the

30-day public comment period and the EPA 45-day review.

16208 205-0008 051 10-01-2021 T5SOB JRM 3REN MSOP

Supervisory Review:

Chris Ailor

Lisa B. Cole

State

Percentile

EPA Region

Percentile

USA

Percentile

1/3

Selected Variables

EJ Index for PM2.5

EJ Index for Ozone

EJ Index for NATA* Diesel PM

EJ Index for Wastewater Discharge Indicator

EJ Indexes

This report shows the values for environmental and demographic indicators and EJSCREEN indexes. It shows environmental and demographic raw data (e.g., the estimated concentration of ozone in the air), and also shows what percentile each raw data value represents. These percentiles provide perspective on how the selected block group or buffer area compares to the entire state, EPA region, or nation. For example, if a given location is at the 95th percentile nationwide, this means that only 5 percent of the US population has a higher block group value than the average person in the location being analyzed. The years for which the data are available, and the methods used, vary across these indicators. Important caveats and uncertainties apply to this screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of these issues before using reports.

EJ Index for NATA* Air Toxics Cancer Risk

EJ Index for NATA* Respiratory Hazard Index

EJ Index for Traffic Proximity and Volume

EJ Index for Lead Paint Indicator

EJ Index for Superfund Proximity

EJ Index for RMP Proximity

EJ Index for Hazardous Waste Proximity

EJSCREEN Report (Version )

71

71

70

71

72

72

69

91

68

71

82

68

64

65

66

69

65

70

96

63

63

75

72

66

67

69

73

64

69

93

63

64

72

1 mile Ring Centered at 32.496372,-86.307317, ALABAMA, EPA Region 4

Approximate Population: 160

Spire 205-0008 1mile

August 09, 2021

Input Area (sq. miles): 3.14

2020

2/3

EJSCREEN Report (Version )

Superfund NPLHazardous Waste Treatment, Storage, and Disposal Facilities (TSDF)

Sites reporting to EPA

1 mile Ring Centered at 32.496372,-86.307317, ALABAMA, EPA Region 4

Approximate Population: 160

Spire 205-0008 1mile

August 09, 2021

Input Area (sq. miles): 3.14

2020

00

zhuangv
Highlight

EJSCREEN Report (Version )

Value State

Avg.

%ile in

State

EPA

Region

Avg.

%ile in

EPA

Region

USA

Avg.

%ile in

USA

3/3

RMP Proximity (facility count/km distance)Hazardous Waste Proximity (facility count/km distance)Wastewater Discharge Indicator (toxicity-weighted concentration/m distance)

Demographic Index

Population over 64 years of age

People of Color PopulationLow Income PopulationLinguistically Isolated PopulationPopulation With Less Than High School EducationPopulation Under 5 years of age

Demographic Indicators

EJSCREEN is a screening tool for pre-decisional use only. It can help identify areas that may warrant additional consideration, analysis, or outreach. It does not provide a basis for decision-making, but it may help identify potential areas of EJ concern. Users should keep in mind that screening tools are subject to substantial uncertainty in their demographic and environmental data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of these issues before using reports. This screening tool does not provide data on every environmental impact and demographic factor that may be relevant to a particular location. EJSCREEN outputs should be supplemented with additional information and local knowledge before taking any action to address potential EJ concerns.

For additional information, see: www.epa.gov/environmentaljustice

Selected Variables

Environmental Indicators

Particulate Matter (PM 2.5 in µg/m3)Ozone (ppb)NATA* Diesel PM (µg/m3)NATA* Cancer Risk (lifetime risk per million)NATA* Respiratory Hazard IndexTraffic Proximity and Volume (daily traffic count/distance to road)Lead Paint Indicator (% Pre-1960 Housing)Superfund Proximity (site count/km distance)

* The National-Scale Air Toxics Assessment (NATA) is EPA's ongoing, comprehensive evaluation of air toxics in the United States. EPA developed the NATA to prioritize air toxics, emission sources, and locations of interest for further study. It is important to remember that NATA provides broad estimates of health risks over geographic areas of the country, not definitive risks to specific individuals or locations. More information on the NATA analysis can be found at: https://www.epa.gov/national-air-toxics-assessment.

Demographic Indicators

1 mile Ring Centered at 32.496372,-86.307317, ALABAMA, EPA Region 4

Approximate Population: 160

Spire 205-0008 1mile

August 09, 2021

Input Area (sq. miles): 3.14

2020

37.2

9.84

0.285

0.09

0.17

0.16

0.077

0.073

63

0.79

49

54%

67%

18%

6%

17%

7%

40%

38

9.31

0.346

1.2

0.82

0.41

0.054

0.18

220

0.65

43

36%

34%

38%

1%

14%

6%

16%

37%

39%

36%

3%

13%

6%

17%

36%

39%

33%

4%

13%

6%

15%

38

8.57

0.417

0.65

0.91

0.6

0.083

0.15

350

0.52

36

42.9

8.55

0.478

9.4

5

0.74

0.13

0.28

750

0.44

32

32

75

49

89

33

49

81

37

48

89

79

78

83

55

95

64

55

61

76

79

58

84

69

56

64

77

77

67

78

73

54

67

42

94

<50th

93

31

37

72

49

39

95-100th

95-100th

17

88

<50th

88

22

30

57

33

28

95-100th

95-100th

State

Percentile

EPA Region

Percentile

USA

Percentile

1/3

Selected Variables

EJ Index for PM2.5

EJ Index for Ozone

EJ Index for NATA* Diesel PM

EJ Index for Wastewater Discharge Indicator

EJ Indexes

This report shows the values for environmental and demographic indicators and EJSCREEN indexes. It shows environmental and demographic raw data (e.g., the estimated concentration of ozone in the air), and also shows what percentile each raw data value represents. These percentiles provide perspective on how the selected block group or buffer area compares to the entire state, EPA region, or nation. For example, if a given location is at the 95th percentile nationwide, this means that only 5 percent of the US population has a higher block group value than the average person in the location being analyzed. The years for which the data are available, and the methods used, vary across these indicators. Important caveats and uncertainties apply to this screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of these issues before using reports.

EJ Index for NATA* Air Toxics Cancer Risk

EJ Index for NATA* Respiratory Hazard Index

EJ Index for Traffic Proximity and Volume

EJ Index for Lead Paint Indicator

EJ Index for Superfund Proximity

EJ Index for RMP Proximity

EJ Index for Hazardous Waste Proximity

EJSCREEN Report (Version )

56

54

56

56

56

36

63

84

38

59

55

52

51

53

52

51

38

63

90

36

55

51

55

54

57

56

55

45

64

87

44

58

56

3 miles Ring Centered at 32.496443,-86.307392, ALABAMA, EPA Region 4

Approximate Population: 3,819

Spire 205-0008 3mile

August 09, 2021

Input Area (sq. miles): 28.27

2020

2/3

EJSCREEN Report (Version )

Superfund NPLHazardous Waste Treatment, Storage, and Disposal Facilities (TSDF)

Sites reporting to EPA

3 miles Ring Centered at 32.496443,-86.307392, ALABAMA, EPA Region 4

Approximate Population: 3,819

Spire 205-0008 3mile

August 09, 2021

Input Area (sq. miles): 28.27

2020

00

zhuangv
Highlight

EJSCREEN Report (Version )

Value State

Avg.

%ile in

State

EPA

Region

Avg.

%ile in

EPA

Region

USA

Avg.

%ile in

USA

3/3

RMP Proximity (facility count/km distance)Hazardous Waste Proximity (facility count/km distance)Wastewater Discharge Indicator (toxicity-weighted concentration/m distance)

Demographic Index

Population over 64 years of age

People of Color PopulationLow Income PopulationLinguistically Isolated PopulationPopulation With Less Than High School EducationPopulation Under 5 years of age

Demographic Indicators

EJSCREEN is a screening tool for pre-decisional use only. It can help identify areas that may warrant additional consideration, analysis, or outreach. It does not provide a basis for decision-making, but it may help identify potential areas of EJ concern. Users should keep in mind that screening tools are subject to substantial uncertainty in their demographic and environmental data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of these issues before using reports. This screening tool does not provide data on every environmental impact and demographic factor that may be relevant to a particular location. EJSCREEN outputs should be supplemented with additional information and local knowledge before taking any action to address potential EJ concerns.

For additional information, see: www.epa.gov/environmentaljustice

Selected Variables

Environmental Indicators

Particulate Matter (PM 2.5 in µg/m3)Ozone (ppb)NATA* Diesel PM (µg/m3)NATA* Cancer Risk (lifetime risk per million)NATA* Respiratory Hazard IndexTraffic Proximity and Volume (daily traffic count/distance to road)Lead Paint Indicator (% Pre-1960 Housing)Superfund Proximity (site count/km distance)

* The National-Scale Air Toxics Assessment (NATA) is EPA's ongoing, comprehensive evaluation of air toxics in the United States. EPA developed the NATA to prioritize air toxics, emission sources, and locations of interest for further study. It is important to remember that NATA provides broad estimates of health risks over geographic areas of the country, not definitive risks to specific individuals or locations. More information on the NATA analysis can be found at: https://www.epa.gov/national-air-toxics-assessment.

Demographic Indicators

3 miles Ring Centered at 32.496443,-86.307392, ALABAMA, EPA Region 4

Approximate Population: 3,819

Spire 205-0008 3mile

August 09, 2021

Input Area (sq. miles): 28.27

2020

37.1

9.82

0.319

0.028

0.33

0.13

0.075

0.091

57

0.8

49

39%

41%

15%

6%

15%

1%

36%

38

9.31

0.346

1.2

0.82

0.41

0.054

0.18

220

0.65

43

36%

34%

38%

1%

14%

6%

16%

37%

39%

36%

3%

13%

6%

17%

36%

39%

33%

4%

13%

6%

15%

38

8.57

0.417

0.65

0.91

0.6

0.083

0.15

350

0.52

36

42.9

8.55

0.478

9.4

5

0.74

0.13

0.28

750

0.44

32

31

74

57

83

47

39

80

43

45

91

82

63

68

48

76

57

49

47

59

60

52

56

63

51

52

62

60

62

50

68

48

56

42

94

<50th

90

48

27

71

54

37

95-100th

95-100th

16

88

<50th

84

32

21

56

37

26

95-100th

95-100th

State

Percentile

EPA Region

Percentile

USA

Percentile

1/3

Selected Variables

EJ Index for PM2.5

EJ Index for Ozone

EJ Index for NATA* Diesel PM

EJ Index for Wastewater Discharge Indicator

EJ Indexes

This report shows the values for environmental and demographic indicators and EJSCREEN indexes. It shows environmental and demographic raw data (e.g., the estimated concentration of ozone in the air), and also shows what percentile each raw data value represents. These percentiles provide perspective on how the selected block group or buffer area compares to the entire state, EPA region, or nation. For example, if a given location is at the 95th percentile nationwide, this means that only 5 percent of the US population has a higher block group value than the average person in the location being analyzed. The years for which the data are available, and the methods used, vary across these indicators. Important caveats and uncertainties apply to this screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of these issues before using reports.

EJ Index for NATA* Air Toxics Cancer Risk

EJ Index for NATA* Respiratory Hazard Index

EJ Index for Traffic Proximity and Volume

EJ Index for Lead Paint Indicator

EJ Index for Superfund Proximity

EJ Index for RMP Proximity

EJ Index for Hazardous Waste Proximity

EJSCREEN Report (Version )

61

63

61

61

61

74

71

85

61

70

77

57

58

56

57

58

67

71

91

56

63

70

61

61

60

60

62

65

70

88

59

64

68

5 miles Ring Centered at 32.496443,-86.307392, ALABAMA, EPA Region 4

Approximate Population: 21,192

Spire 205-0008 5mile

August 09, 2021

Input Area (sq. miles): 78.53

2020

2/3

EJSCREEN Report (Version )

Superfund NPLHazardous Waste Treatment, Storage, and Disposal Facilities (TSDF)

Sites reporting to EPA

5 miles Ring Centered at 32.496443,-86.307392, ALABAMA, EPA Region 4

Approximate Population: 21,192

Spire 205-0008 5mile

August 09, 2021

Input Area (sq. miles): 78.53

2020

01

zhuangv
Highlight

EJSCREEN Report (Version )

Value State

Avg.

%ile in

State

EPA

Region

Avg.

%ile in

EPA

Region

USA

Avg.

%ile in

USA

3/3

RMP Proximity (facility count/km distance)Hazardous Waste Proximity (facility count/km distance)Wastewater Discharge Indicator (toxicity-weighted concentration/m distance)

Demographic Index

Population over 64 years of age

People of Color PopulationLow Income PopulationLinguistically Isolated PopulationPopulation With Less Than High School EducationPopulation Under 5 years of age

Demographic Indicators

EJSCREEN is a screening tool for pre-decisional use only. It can help identify areas that may warrant additional consideration, analysis, or outreach. It does not provide a basis for decision-making, but it may help identify potential areas of EJ concern. Users should keep in mind that screening tools are subject to substantial uncertainty in their demographic and environmental data, particularly when looking at small geographic areas. Important caveats and uncertainties apply to this screening-level information, so it is essential to understand the limitations on appropriate interpretations and applications of these indicators. Please see EJSCREEN documentation for discussion of these issues before using reports. This screening tool does not provide data on every environmental impact and demographic factor that may be relevant to a particular location. EJSCREEN outputs should be supplemented with additional information and local knowledge before taking any action to address potential EJ concerns.

For additional information, see: www.epa.gov/environmentaljustice

Selected Variables

Environmental Indicators

Particulate Matter (PM 2.5 in µg/m3)Ozone (ppb)NATA* Diesel PM (µg/m3)NATA* Cancer Risk (lifetime risk per million)NATA* Respiratory Hazard IndexTraffic Proximity and Volume (daily traffic count/distance to road)Lead Paint Indicator (% Pre-1960 Housing)Superfund Proximity (site count/km distance)

* The National-Scale Air Toxics Assessment (NATA) is EPA's ongoing, comprehensive evaluation of air toxics in the United States. EPA developed the NATA to prioritize air toxics, emission sources, and locations of interest for further study. It is important to remember that NATA provides broad estimates of health risks over geographic areas of the country, not definitive risks to specific individuals or locations. More information on the NATA analysis can be found at: https://www.epa.gov/national-air-toxics-assessment.

Demographic Indicators

5 miles Ring Centered at 32.496443,-86.307392, ALABAMA, EPA Region 4

Approximate Population: 21,192

Spire 205-0008 5mile

August 09, 2021

Input Area (sq. miles): 78.53

2020

37

9.8

0.35

0.019

0.41

0.17

0.08

0.083

130

0.8

50

37%

39%

13%

7%

14%

1%

36%

38

9.31

0.346

1.2

0.82

0.41

0.054

0.18

220

0.65

43

36%

34%

38%

1%

14%

6%

16%

37%

39%

36%

3%

13%

6%

17%

36%

39%

33%

4%

13%

6%

15%

38

8.57

0.417

0.65

0.91

0.6

0.083

0.15

350

0.52

36

42.9

8.55

0.478

9.4

5

0.74

0.13

0.28

750

0.44

32

29

73

63

81

51

51

82

40

63

91

86

61

65

48

74

54

66

32

57

57

52

54

60

67

39

60

57

61

47

65

64

43

42

94

<50th

88

52

39

73

52

52

95-100th

95-100th

16

87

<50th

82

35

32

59

35

39

95-100th

95-100th