NARRATIVE. Dika Kuoh Alaa-Eldin A. Afifi DATE: December 14, 2015

Transcription

1 Georgia Department of Natural Resources Environmental Protection Division Air Protection Branch 4244 International Parkway Suite 120 Atlanta Georgia / Fax: 404/ Judson H. Turner, Director NARRATIVE TO: FROM: Dika Kuoh Alaa-Eldin A. Afifi DATE: December 14, 2015 Facility Name: Emory University Hospital Midtown AIRS No.: Location: Atlanta, Georgia (Fulton County) Application #: of Application: August 27, 2015 Background Information Emory University Hospital Midtown is an existing general medical and surgical hospital facility located at 550 Peachtree Street NE, Atlanta, Georgia (Fulton County) an ozone and PM 2.5 non-attainment area. The facility currently has a NOx synthetic minor limit of 25 tons per year (tpy) for Title V, Georgia Rule (yy), and NAA-NSR avoidance. The facility is classified as a PSD minor source because potential emissions are below 250 tpy and it is not one of the 28 named source categories under PSD. The facility was issued Air Quality Permit No S-02-0 on June 12, 2007 (Application No ) and Air Quality Permit Amendment No S-02-1 on September 23, 2008 (Application No ). Purpose of Application Application No was received on September 1, This application notified us of a change in ownership/name for the general medical and surgical hospital facility in Atlanta, Georgia. The previous facility ownership/name was Emory Crawford Long Hospital. The new facility ownership/name is Emory University Hospital Midtown. A public advisory is not needed for this modification.

2 Updated Equipment List Facility emission units include boilers, emergency generators, and storage tanks. The boilers are listed in the table below. Boilers (Source Codes B03 through B05) burn natural gas and use distillate fuel oil as a backup. The facility has ten existing generators, all of which are for emergency purposes only (emergency backup of electrical power). The existing generators (Source Codes EG1 through EG6, EG8, and EG9) are powered by combustion of distillate fuel oil and the existing generators (Source Codes EG7 and EG10) are powered by combustion of natural gas. The underground storage tanks hold distillate fuel oil. Low-sulfur (no more than 0.5 percent) fuel oil is used for the boilers and the generators. Source Code Input Heat Capacity (MMBtu/hr) Boilers Description Installation Construction B Cleaver-Brooks Boilers CBLE natural gas/distillate oil fired B Cleaver-Brooks Boilers CBLE natural gas/distillate oil fired B Cleaver-Brooks Boilers CBLE natural gas/distillate oil fired Generators Source Code Description Installation Construction EG1 750-KW distillate fuel oil fired Emergency Generator EG kW distillate fuel oil fired Emergency Generator EG kW distillate fuel oil fired Emergency Generator EG4 750-KW distillate fuel oil fired Emergency Generator EG5 750-KW distillate fuel oil fired Emergency Generator EG6 175-KW distillate fuel oil fired Emergency Generator EG7 80-KW Natural Gas fired Emergency Generator EG KW distillate fuel oil fired Emergency Generator EG9 150-KW distillate fuel oil fired Emergency Generator EG KW Natural Gas fired Emergency Generator Page 2

3 Emissions Summary There will be no emissions increase due to this modification. Pollutant Facility-Wide Emissions (in tons per year) Potential Emissions (at 200 hrs/yr for each generator) NOx < 25* CO 26.1 SO VOC 2.0 PM/PM 10 /PM Single HAP 0.5 Total HAP 0.5 Total GHG * Synthetic minor limit. Regulatory Applicability The facility is located in Fulton County, which is a part of the Atlanta ozone non-attainment area and is considered non-attainment area for PM 2.5 under the National Ambient Air Quality Standards (NAAQS). The facility is considered a synthetic minor (SM) source under Title V of the Clean Air Act. Boilers B03, B04, and B05: Boilers are rated at MMBtu/hr each and subject to Georgia Rule (d)2.(ii), which specifies the allowable particulate emissions from fuel-burning equipment built after January 1, 1972, and with heat input capacity between 10 and 250 MMBtu/hr. they are also subject to the opacity limit of Georgia Rule (d)3. Because this boiler will burn only natural gas, compliance with particulate and opacity limits is expected without emissions controls. Therefore no controls and no monitoring are proposed. Because the boilers (Source Codes B03, B04, and B05) are fuel-burning equipment that installed after May 1, 1999, having a heat input capacity between 10 and 250 MMBtu/hr and because they are located in Fulton County, they are subject to rule (lll). Rule (lll) restricts NO x emissions from such sources to no more than 30 ppm during the ozone season (May 1 September 30). 40 CFR 60 Subpart Dc New Source Performance Standards (NSPS) for Small Industrial-Commercial- Institutional Steam Generating Units Because Boilers B03, B04, and B05 were constructed after June 9, 1989 and are rated at 10 MMBtu/hr or more, they are subject to the requirements of NSPS Subpart Dc. Subpart Dc includes a limit on sulfur emissions from steam-generating units that burn fuel oil. However, the regulation allows the Permittee to use fuel oil with not more than 0.5 percent sulfur in lieu of demonstrating compliance with the emission limit. The facility has elected to use low-sulfur fuel oil to ensure compliance with the fuel sulfur content requirement in Subpart Dc and by extension the fuel sulfur content requirement in GA Rule (g), which is less stringent (2.5 percent sulfur by weight). Subpart Dc also requires that the facility monitor the daily Page 3

4 amount of each type of fuel burned in each boiler, to certify the sulfur content of the fuel, to keep records, and to report compliance and dates of boiler construction and startup. However, the owner or operator of an affected facility that combusts only natural gas may elect to record and maintain records of the amount of natural gas combusted during each calendar month. 40 CFR 63 Subpart JJJJJJ National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources Subpart JJJJJJ (Boiler GACT) regulates emissions from boilers located at an area source of HAP emissions. The Boiler GACT lists specific classes of boilers that are not subject to this subpart in 40 CFR including gas-fired boilers in paragraph (e). The facility has indicated that the existing boilers (Source Codes: B03, B04, and B05) will only burn distillate fuel oil during times of gas curtailment. Therefore, they are not subject to the Area Source MACT 40 CFR 63 Subpart JJJJJJ for Industrial, Commercial, and Institutional Boilers, as specified in 40 CFR (e). Emergency Generators EG1 through EG10: The allowable visible emissions from the emergency generators (EG1 through EG10) are 40% in accordance with Georgia Rule (2)(b)1 [Cond. 2.7]. To be considered an emergency engine under GA Rule (6)(b)11.(v)(I), each engine is limited to less than 200 hours [Cond. 2.6]. The engines are considered Emergency standby stationary engines exempt from Georgia Rule (mmm) limits under (2)(mmm)7. The allowable fuel sulfur content is 2.5 weight percent in accordance with Georgia Rule (2)(g)2, however the facility has elected to burn distillate fuel oil with a maximum sulfur content of 0.05 percent by weight for the emergency generators (Source Codes: EG1 through EG6, EG8, and EG9) and to burn natural gas in the emergency generators (Source Codes: EG7 and EG10) [Cond. 2.8]. Because the emergency generators (EG1 through EG10) are constructed before July 11, 2005 and were manufactured before April 1, 2006, they are not subject to the requirements of 40 CFR 60 Subpart IIII. However, since the emergency generators (EG1 through EG10) commenced construction prior to June 12, 2006, they are considered existing stationary RICE located at an area source of HAP subject to 40 CFR 63, Subpart ZZZZ. 40 CFR 63 Subpart ZZZZ (RICE MACT) NESHAP for Stationary Reciprocating Internal Combustion Engines does not apply to emergency engines EG1 through EG10 as existing stationary reciprocating internal combustion engines located at an area source of HAP. Emory hospital meets the definition of an institution located at an area source of HAP and according to 40 CFR (f)(3), the following engines are not subject to RICE MACT: Existing institutional emergency stationary RICE located at an area source of HAP emissions that do not operate or are not contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in (f)(2)(ii) and (iii) and that do not operate for the purpose specified in (f)(4)(ii). Permit Conditions Permit Condition 2.1 limits the NOx emissions from the entire facility to less than 25 tons during any consecutive twelve-month period. Page 4

5 Permit Condition 2.2 incorporates the applicable provisions of 40 CFR 60 Subparts A and Dc for operation of the boilers (Source Codes: B03, B04, and B05). Permit Condition 2.3 ensures that the boilers (Source Codes: B03, B04, and B05) only fire natural gas for Boiler GACT avoidance. Permit Condition 2.4 defines particulate matter emissions limits the opacity limits for the boilers (Source Code: B03, B04, and B05). Permit Condition 2.5 states the requirements of Georgia Rule (2)(lll) as they apply to the boilers (Source Codes: B03, B04, and B05). During the period May 1 through September 30 of each year, the concentration of NOx emitted by the boilers (Source Codes: B03, B04, and B05) may not exceed 30 ppm. For Title V avoidance 30 ppm applies all year round. Permit Condition 2.6 limits the total hours of operation of each emergency generator at the facility to less than 200 hours per year to avoid the Georgia Rule (mmm) limit. Permit Condition 2.7 defines the opacity limits from the generators (Source Codes: EG1 through EG10). Permit Condition 2.8 states that the emergency generators (Source Codes: EG1 through EG6, EG8, and EG9) are only allowed to burn distillate fuel oil that contains no more than 0.5% of sulfur by weight and the emergency generators (Source Codes: EG7 and EG10) are only allowed to burn natural gas. Permit Condition 3.1 incorporates Georgia Rule (n) to minimize fugitive dust for the entire facility. Permit Conditions 4.1 requires the facility to conduct routine maintenance. Permit Condition 5.1 explains general requirements for the operation of a continuous monitoring system. Permit Condition 5.2 requires natural gas meters or alternate protocol for monitoring natural gas usage in the boilers (Source Codes: B03, B04, and B05) as required by NSPS Subpart Dc. Permit Condition 5.3 requires verification that fuel oil usage for the boilers (Source Codes: B03, B04, and B05) and the emergency generators (Source Codes: EG1 through EG10) complies with conditions 2.3 and 2.8. Permit Condition 5.4 provides the monitoring method to determine compliance with the NO X emissions limit per Rule (2)(lll) from the boilers (Source Codes: B03, B04, and B05). Permit Condition 5.5 requires installation of equipment to monitor the hours of operation for the emergency generators (Source Codes: EG1 through EG10). Permit Condition 6.1 contains standard requirements for performance testing. Permit Condition 7.1 requires the facility to maintain monthly records of natural gas and distillate fuel oil consumption, fuel supplier certification, and monthly hours of operation for all emergency generators. Permit Condition 7.2 defines semiannual reporting requirements. Page 5

6 Permit Conditions 7.3 and 7.4 require record keeping and reporting of total operating hours of the emergency generators (Source Codes: EG1 through EG10). Permit Condition 7.5 provide the equation to calculate the monthly NOx emissions for the facility. Permit Condition 7.6 requires the facility to use the total monthly NOx emissions records to calculate the twelve-month rolling total of NOx emissions. Permit Condition 8.1 explains the Division s authority to determine additional control of emissions. Permit Condition 8.2 requires the Permittee to pay an annual permit fee to the Division. Permit Condition 8.3 revokes previous permits. Toxic Impact Assessment No toxic impact assessment was performed, since toxic emissions are not being increased. Summary & Recommendations I recommend issuing Air Quality Permit No S-03-0 to Emory University Hospital Midtown. This permit was prepared to document the new ownership/name for the general medical and surgical hospital facility located at 550 Peachtree Street NE, Atlanta, Georgia. The previous ownership/name was Crawford Long Hospital and the new ownership/name is Emory University Hospital Midtown. This administrative action does not require a public advisory. Page 6