STATEMENT OF BASIS. University of Arkansas for Medical Sciences (UAMS) 4301 West Markham St. Little Rock, Arkansas 72205

Transcription

1 STATEMENT OF BASIS For the issuance of Draft Air Permit # 2125-AOP-R3 1. PERMITTING AUTHORITY: Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, Arkansas APPLICANT: University of Arkansas for Medical Sciences (UAMS) 4301 West Markham St. Little Rock, Arkansas PERMIT WRITER: Christopher Riley 4. NAICS DESCRIPTION AND CODE: NAICS Description: General Medical and Surgical Hospitals NAICS Code: SUBMITTALS: Date of Application Type of Application (New, Renewal, Modification, Deminimis/Minor Mod, or Administrative Amendment) Short Description of Any Changes That Would Be Considered New or Modified Emissions 11/7/2014 Minor Mod Replacing SN-03, removing SN REVIEWER S NOTES: The University of Arkansas for Medical Sciences (UAMS) operates a General Medical and Surgical Hospital (NAICS and ) in Little Rock, Arkansas. The purpose of this modification is to: Replace SN-03 with a 700 bhp boiler (down from 750 bhp currently) Remove SN-26, a 2C, from the permit The emissions will change as follows: PM -0.4 tpy, PM tpy, NO X -0.4 tpy, SO tpy, CO -0.1 tpy, VOC -0.1 tpy, benzene tpy, formaldehyde tpy POM tpy, and hexane tpy

2 Page 2 of COMPLIANCE STATUS: The following summarizes the current compliance of the facility including active/pending enforcement actions and recent compliance activities and issues. No enforcement actions as of most recent inspection 8. PSD APPLICABILITY: a) Did the facility undergo PSD review in this permit (i.e., BACT, Modeling, etc.)? N b) Is the facility categorized as a major source for PSD? N Single pollutant 100 tpy and on the list of 28 or single pollutant 250 tpy and not on list If yes, explain why this permit modification is not PSD. 9. SOURCE AND POLLUTANT SPECIFIC REGULATORY APPLICABILITY: Pollutant Regulation (NSPS, NESHAP or PSD) SO X NSPS, 40 CFR Part 60, Subpart Dc, Standards of Performance for Small Industrial - Commercial - Institutional Steam Generating Units VOC, NO X, CO, PM NSPS, 40 CFR Part 60, Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines VOC, NO X, CO, PM 40 CFR Part 89 Control of Emissions From New and In- Use Nonroad Compression- Ignition Engines NESHAP, 40 CFR Part 60, Subpart ZZZZ National VOC, NO X, CO, PM Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Subpart JJJJ Standards of 57 VOC, NO X and CO Performance for Stationary Spark Ignition Internal Combustion Engines SN-02 through SN-05, SN- 10A, SN-10B, and SN-10C SN-34 through SN-39, SN-54 and SN-55 SN-34 through SN-39, SN-54 and SN-55 SN-34 through SN-39, SN-54, SN-55 and 57

3 Page 3 of EMISSION CHANGES AND FEE CALCULATION: See emission change and fee calculation spreadsheet in Appendix A. 11. AMBIENT AIR EVALUATIONS: a) Reserved. b) Non-Criteria Pollutants: The non-criteria pollutants listed below were evaluated. Based on Department procedures for review of non-criteria pollutants, emissions of all other non-criteria pollutants are below thresholds of concern. 1 st Tier Screening (PAER) Estimated hourly emissions from the following sources were compared to the Presumptively Acceptable Emission Rate (PAER) for each compound. The Department has deemed the PAER to be the product, in lb/hr, of 0.11 and the Threshold Limit Value (mg/m 3 ), as listed by the American Conference of Governmental Industrial Hygienists (ACGIH). Pollutant TLV (mg/m 3 ) PAER (lb/hr) = 0.11 TLV Proposed lb/hr Pass? Hexane Yes Cadmium No Chromium (hex) No Formaldehyde No POM No Acrolein No Benzene No Ethylene oxide No 2 nd Tier Screening (PAIL) AERMOD air dispersion modeling was performed on the estimated hourly emissions from the following sources, in order to predict ambient concentrations beyond the

4 Page 4 of 15 property boundary. The Presumptively Acceptable Impact Level (PAIL) for each compound has been deemed by the Department to be one one-hundredth of the Threshold Limit Value as listed by the ACGIH. Pollutant PAIL (μg/m 3 ) = 1/100 of Threshold Limit Value Modeled Concentration (μg/m 3 ) Pass? Cadmium Yes Chromium (hex) Yes Formaldehyde Yes POMS Yes Acrolein Yes Benzene Yes Ethylene oxide Yes c) H 2 S Modeling: The facility does not emit H 2 S 12. CALCULATIONS: SN 01 through 05 Emission Factor (AP-42, testing, etc.) AP-42 Ch. 1.4 natural gas combustion And Ch. 1.3 fuel oil combustion Emission Factor (lb/ton, lb/hr, etc.) Natural Gas (lb/mmscf) 7.6 = PM/PM = CO = NO X 0.6 = SO X 5.5 = VOC No. 2 Fuel Oil (lb/gal) 3.3 = PM 1.3 = PM 10 Control Equipment Control Equipment Efficiency Comments None uncontrolled

5 Page 5 of 15 SN SN-06 through SN- 09 SN-10A, SN-10B, and SN-10C SN-20 through SN- 25, SN-29, SN-30, SN- 32 and SN- 33 SN-12 through SN- 19, SN-28 and SN-31 SN-34 through SN- 39 SN-40 through SN- 52 Emission Factor (AP-42, testing, etc.) AP-42 Ch. 1.4 natural gas combustion only AP-42 Section 3.3, Table AP-42 Section 3.4, Table Vendor performance data, with the exception of SO X. No vendor performance data available for SO X, so used AP-42, Table Ch. 13.4, Table (no drift limitation applied) Emission Factor (lb/ton, lb/hr, etc.) 5 = CO 20 = NO X = SO X, with a maximum sulfur content of wt% = VOC Natural Gas (lb/mmscf) 7.6 = PM/PM = CO = NO X 0.6 = SO X 5.5 = VOC (lb/mmbtu) 0.31 = PM/PM = CO 4.41 = NO X 0.29 = SO X 0.36 = VOC (lb/mmbtu) 0.10 = PM/PM = CO 3.20 = NO X = SO X 0.09 = VOC (gal/hp-hr) 0.09 = PM/PM = CO 7.52 = NO X = SO X 0.03 = VOC 1.7 = lb H 2 O/1000 gal H 2 O 700 lb PM/1 E6 lb H 2 O Control Equipment Control Equipment Efficiency Comments None Uncontrolled None Uncontrolled None Uncontrolled None Uncontrolled None Uncontrolled

6 Page 6 of 15 SN Emission Factor (AP-42, testing, etc.) Emission Factor (lb/ton, lb/hr, etc.) SN-53 Material balance 2-pound cylinder per hour SN-54 and Vendor Unit = g/hp-hr SN-55 performance data PM/PM 10 = CO = 0.76 NO X = 7.52 SO X = Vendor Supplied Drift Loss Factor VOC = % Control Equipment Control Equipment Efficiency Comments None Uncontrolled None Uncontrolled None Uncontrolled Ch. 13.4, Table AP-42 Ch. 1.4 natural gas combustion only lb PM/1000 Gal H 2 O Natural Gas (lb/mmscf) 7.6 = PM/PM = CO = NO X 0.6 = SO X 5.5 = VOC None Uncontrolled 13. TESTING REQUIREMENTS: The permit requires testing of the following sources. SN Pollutants Test Method Test Interval Justification 34 through 39, 54 and 55 VOC, NO X, CO, and PM See Table 7 of Subpart Initial performance test Required by 40 CFR 60, Subpart Part IIII 57 VOC, NO X and CO See Table 2 of subpart Initial performance test Required by 40 CFR 60, Subpart Part JJJJ 14. MONITORING OR CEMS: The permittee must monitor the following parameters with CEMS or other monitoring equipment (temperature, pressure differential, etc.)

7 Page 7 of 15 SN Parameter or Pollutant to be Monitored Method (CEM, Pressure Gauge, etc.) Frequency Report (Y/N) N/A 15. RECORDKEEPING REQUIREMENTS: The following are items (such as throughput, fuel usage, VOC content, etc.) that must be tracked and recorded. SN Recorded Item Permit Limit Frequency Report (Y/N) SN-01 through SN-05 Fuel usage MMscf of pipeline quality natural gas per year 47,800 gallons of distillate oil per year 200 hours per consecutive 12 month period Reason for using fuel oil Monthly Yes SN-10A, SN- 10B, and SN- 10C Fuel Usage MMscf of pipeline quality natural gas per year Monthly Yes SN-12 through SN-33 Hours of operation 100 hours per year Daily Yes Fuel Oil Sulfur Content % by weight SN-34 through SN-39, SN-27, SN-54 and SN- 55 Hours of operation Fuel Oil Sulfur Content 580 hrs/yr for SN-34 through SN-39, 100 hrs/yr for SN-54, and 200 hrs/yr for SN % by Daily Yes

8 Page 8 of 15 SN Recorded Item Permit Limit Frequency Report (Y/N) 57 Hours of operation weight 100 hrs/yr Daily Yes 16. OPACITY: SN Opacity Justification for limit SN-01 through SN-05 5% - natural gas 20% - fuel oil Regulation 18 ( and A.C.A ) Regulation 19 ( and 40 CFR Part 52) Compliance Mechanism weekly SN10-A, SN-10B and SN-10C SN-12 through SN- 39, SN-54 and SN-55 5% Regulation 18 ( and A.C.A ) 20% - fuel oil Regulation 19 ( and 40 CFR Part 52) weekly Yearly 57 5% Regulation 18 ( and A.C.A ) weekly 17. DELETED CONDITIONS: Former SC Justification for removal N/A

9 Page 9 of GROUP A INSIGNIFICANT ACTIVITIES**: Name Two (2) Natural Gas Boilers 100 Hp (4.2 MMBtu/hr) Two (2) Natural Gas (0.2 MMBtu/hr) boilers Bench-scale laboratory equipment solvent storage Two (2) diesel powered fire pumps at MCEP #1 (1,600 gallons) at MCEP #2 (1,600 gallons) at MCEP #3 Group A Category A-1 A-1 A-2 A-1 Emissions (tpy) PM/PM 10 SO 2 VOC CO NO x <0.1 HAPs Single Total

10 Page 10 of 15 Name (1,600 gallons) at Biomedical (1,400 gallons) at CI #1 (1,290 gallons) at CI #2 (1,290 gallons) at JEI (75 gallons) at OPC/Carti (40 gallons) at COPH (600 gallons) Group A Category Emissions (tpy) PM/PM 10 SO 2 VOC CO NO x HAPs Single Total

11 Page 11 of 15 Name Group A Category at EDIII (2,700 gallons) at 7A (220 gallons) at EDII #1 (180 gallons) at EDII #2 (180 gallons) at OPC (375 gallons) at 2C (50 gallons) at IAO Computer Room (25 gallons) Emissions (tpy) PM/PM 10 SO 2 VOC CO NO x HAPs Single Total

12 Page 12 of 15 Name at Bioventures (1,350 gallons) at Distribution (220 gallons) at IOA/RIOA (720 gallons) at JTS (1,600 gallons) at MRI (200 gallons) at FMC (100 gallons) Group A Category Emissions (tpy) PM/PM 10 SO 2 VOC CO NO x HAPs Single Total

13 Page 13 of 15 Name at WCEP #1 (500 gallons) at WCEP #2 (500 gallons) at WCEP #3 (500 gallons) at WCEP #4 (500 gallons) at WCEP #5 (500 gallons) at WCEP #6 (500 gallons) Underground Storage Tank #1 (20,000 gal) Underground Group A Category A-13 A-13 Emissions (tpy) PM/PM 10 SO 2 VOC CO NO x HAPs Single Total

14 Page 14 of 15 Name Storage Tank #2 (20,000 gal) Underground Storage Tank #3 (20,000 gal) Storage Tank at IAO Computer Room (500-gallon) Storage Tank at WPRCI #3 (1500 gallon) Storage Tank at Data Center (1500 gallon) Storage Tank at WCEP #6 (500 gallons) Bench Scale Sterilizer Group A Category A-13 A-5 Emissions (tpy) PM/PM 10 SO 2 VOC CO NO x HAPs Single Total <0.01 <0.01

15 Page 15 of 15 *Note: TANKS software was run to determine emissions from these tanks. The facility s entire annual usage was assumed to run through one tank and the resulting emissions were 0.53 lbs diesel/year. ** Note: Emissions (from currently listed sources) not listed in previous SOB s will not be tracked down. 19. VOIDED, SUPERSEDED, OR SUBSUMED PERMITS: List all active permits voided/superseded/subsumed by the issuance of this permit. Permit # 2125-AOP-R2

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17 APPENDIX A EMISSION CHANGES AND FEE CALCULATION

18 Fee Calculation for Major Facility Name: UAMS Permit Number: 2125-AOP-R3 Revised $/ton factor Annual Chargeable Emissions (tpy) Permit Type Minor Mod Permit Fee $ 500 Minor Modification Fee $ 500 Minimum Modification Fee $ 1000 Renewal with Minor Modification $ 500 Check if Facility Holds an Active Minor or Minor General Permit If Hold Active Permit, Amt of Last Annual Air Permit Invoice $ 0 Total Permit Fee Chargeable Emissions (tpy) -1 Initial Title V Permit Fee Chargeable Emissions (tpy) HAPs not included in VOC or PM: Air Contaminants: Chlorine, Hydrazine, HCl, HF, Methyl Chloroform, Methylene Chloride, Phosphine, Tetrachloroethylene, Titanium Tetrachloride All air contaminants are chargeable unless they are included in other totals (e.g., H2SO4 in condensible PM, H2S in TRS, etc.) Pollutant (tpy) Check if Chargeable Emission Old Permit New Permit Change in Emissions Permit Fee Chargeable Emissions Annual Chargeable Emissions PM PM SO VOC CO NO X Hexane Cadmium

19 Pollutant (tpy) Check if Chargeable Emission Old Permit New Permit Change in Emissions Permit Fee Chargeable Emissions Annual Chargeable Emissions Chromium (hex) Formaldehyde POM Acrolein Benzene Beryllium 4.74E E E-10