Georgia Department of Natural Resources Environmental Protection Division Air Protection Branch 4244 International Parkway Suite 120 Atlanta Georgia 30354 404/363-7000 Fax: 404/363-7100 Judson H. Turner, Director NARRATIVE TO: FROM: Dika Kuoh Steve Allison DATE: August 5, Facility Name: Dept. of Veteran's Affairs - Carl Vinson VA Medical Center AIRS No.: 17500074 Location: Dublin, GA (Laurens County) Application #: 23206 Date of Application: March 31, Background Information The Department of Veterans Affairs (DVA) Medical Center is an existing general medical and surgical hospital located at 1826 Veterans Boulevard in Dublin (Laurens County), in an attainment area for ozone and PM2.5. The existing facility has three natural gas fired boilers that are exempt from permitting (less than 10 ) and nine diesel powered emergency generators. The DVA is currently exempt from permitting but is requesting a minor source permit with this application. Purpose of Application The facility submitted SIP Application No. 23206 dated March 31, for the construction and operation of a Combined Heat and Power (CHP) plant at the DVA. The CHP project includes: (i) the addition of one natural gasfired engine (1,155 KW) and (ii) the replacement of three existing boilers with five new boilers ( each) equipped with Low NOX Burners. The facility is seeking a construction and operating permit for the new CHP and existing DVA Medical Center. The facility-wide emissions will not exceed major source thresholds specified in GA Rule 391-3-1-.03(6)(i)3 and Title V. A public advisory was issued on April 22, and expired on May 22,. No Comments were received.
Updated Equipment List The facility will own and operate the following emission units. Source Code Capacity Description Installation/ Construction Date Applicable Requirements/Standards BL01 BL02 BL03 BL04 BL05 GEN01 1,609 hp 1,155 kw CHP Engine, Natural Gas fired MTU Onsite Energy GB1155N6 40 CFR 60 Subpart A 40 CFR 60 Subpart Dc 391-3-1-.02(2)(d) 40 CFR 60 Subpart A 40 CFR 60 Subpart JJJJ 40 CFR 63 Subpart A 40 CFR 63 Subpart ZZZZ 391-3-1-.02(2)(b) EG-1 201 hp 150 kw Emergency Generator, Boiler Plant Building #27 Distillate Fuel Oil fired; Onan Serial: 6475940802 4/1/1975 EG-2 201 hp 150 kw Emergency Generator, Portable Generator 650 Distillate Fuel Oil fired; Generac Serial: 0812300 6/23/1986 391-3-1-.02(2)(b) EG-3 EG-4 EG-5 EG-6 EG-7 EG-8 536 hp 168 hp 369 hp 603 hp 603 hp 2,762 hp 400 kw Emergency Generator, OPC Building #5 Distillate Fuel Oil fired; Onan Serial: 9910403619 125 kw Emergency Generator, Bldg #82 Water Tower Distillate Fuel Oil fired; Onan Serial: 1010283636 275 kw Emergency Generator, Nursing Home Bldg #8 Distillate Fuel Oil fired; Generac Serial: 2108710 450 kw Emergency Generator, OR Bldg #4 Distillate Fuel Oil fired; Kohler Serial: 0739502 450 kw Emergency Generator, Diet Bldg #2 Distillate Fuel Oil fired; Kohler Serial: 0739500 2,060 kw Emergency Generator, Bldg #71 Chiller Generator Distillate Fuel Oil fired; Kohler Serial: 3057319 10/1/1992 6/10/2010 8/24/2011 12/20/2012 12/20/2012 40 CFR 60 Subpart A 40 CFR 60 Subpart IIII 40 CFR 63 Subpart A 40 CFR 63 Subpart ZZZZ 391-3-1-.02(2)(b) EG-9 268 hp 200 kw Emergency Generator, Bldg #86 Hospice Distillate Fuel Oil fired; Generac Serial: NAV Page 2
Emissions Summary The following is a summary of the emissions before and after the installation of the new CHP system. Since the facility was previously exempt from permitting, pre-modification emissions were not calculated or provided. Similarly, actual emissions from the facility have yet to be determined. Pollutant Before Facility-Wide Emissions (in tons per year) Potential Emissions After Emissions Change Before Actual Emissions After PM NA 2.66 - NA TBD - NOx NA 71.5 - NA TBD - SO 2 NA 7.18 - NA TBD - CO NA 56.9 - NA TBD - VOC NA 13.0 - NA TBD - Max. Individual HAP NA <10 - NA TBD - Total HAP NA <25 - NA TBD - Total GHG (if applicable) NA NA - NA TBD - Emissions Change Regulatory Applicability CHP Engine (GEN01): GA Rule (g) Sulfur Dioxide According to GA Rule 2., fuel burning sources below 100 MMBtu of heat input per hour cannot burn fuel containing more than 2.5% sulfur by weight. The new gas-fired CHP engine only fires pipeline quality natural gas so it is expected to meet the Rule (g) sulfur content limit. [Condition 2.1] GA Rule (b) Visible Emissions According to GA Rule 391-3-1-.02(2)(b)1., the facility cannot emit visible emissions from its engine the opacity of which is equal to or greater than 40%. The new gas-fired CHP engine only fires pipeline quality natural gas so it is expected to meet the Rule (b) standard [Condition 2.5]. 40 CFR 60 Subpart JJJJ (NSPS JJJJ) New Source Performance Standards (NSPS) for Stationary Spark Ignition Internal Combustion Engines (SI ICE)- applies to the new gas-fired CHP engine because it is a lean burn SI ICE with a maximum engine power greater than 1,350 HP manufactured on or after July 1, 2007. As required under 40 CFR 60.4233(e) and Table 1 to Subpart JJJJ, the CHP engine must meet the following emission standards which apply to non-emergency lean burn natural gas SI engines of 1,350 HP or greater after July 1, 2010 [Condition 2.3]. The facility will demonstrate compliance with the NSPS limits in Table 1 below by purchasing an EPA-certified engine and installing, configuring, operating, and maintaining per manufacturers written emission-related instructions, and keeping required records of such. Page 3
Table 1: Emission Standards for non-emergency lean burn natural gas SI engines of 1,350 HP or greater after July 1, 2010 ID No. Emission Standards grams per horsepower-hour (g/hp-hr) ppmvd at 15% O 2 NOx CO VOC NOx CO VOC GEN01 1.0 2.0 0.7 82 270 60 The Permittee may choose to comply with the emission standards in units of either g/hp-hr or ppmvd at 15 percent O 2. ppmvd = parts per million volume, dry; O2 = oxygen; NOx = Nitrogen Oxides; CO = Carbon Monoxide; VOC = Volatile Organic Compounds 40 CFR 63 Subpart ZZZZ (RICE MACT) NESHAP for Stationary Reciprocating Internal Combustion Engines applies to the new gas-fired CHP engine as stationary reciprocating internal combustion engines located at area or major sources of HAP. The engine will comply with the RICE MACT by complying with NSPS JJJJ as allowed in 40 CFR 63.6590(c). Boilers (BL01, BL02, BL03, BL04, and BL05): GA Rule (d) PM/Visible Emissions From Fuel-Burning Equipment - applies to the new boilers as fuel burning equipment constructed after January 1, 1972 with a heat input capacity between 10 and 250. GA Rule (d) sets a PM emission limit and visible emissions limit of 20% opacity (27% opacity for any 6 minute period per hour) [Condition 2.7]. 40 CFR 60 Subpart Dc (NSPS Dc) New Source Performance Standards (NSPS) for Small Industrial- Commercial-Institutional Steam Generating Units - applies to the new boilers because they have a heat input capacity greater than 10 and less than or equal to 100 and will be constructed after June 9, 1989. Because the gas-fired boilers can still fire fuel oil as a backup, NSPS Dc sets a fuel sulfur content limit of 0.5% sulfur by weight [40 CFR 60.42c(d)]. This sulfur content subsumes the limit of 2.5% sulfur by weight found in GA Rule 2. [Condition 2.9] 40 CFR 63 Subpart JJJJJJ (Boiler GACT) National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Industrial, Commercial, and Institutional Boilers in Area Sources - does not apply to the new boilers because they are gas-fired boilers that only burn fuel oil during periods of gas curtailment; which allows them to qualify for an exemption under 40 CFR 63.11195(e). Emergency Engines (EG-1, EG-2, EG-3, EG-4, EG-5, EG-6, EG-7, EG-8, and EG-9): Emergency engines are exempt from permitting under Georgia Rules for Air Quality Control 391-3-1-.03(6)(b)11(i). GA Rule (b) Visible Emissions According to GA Rule 391-3-1-.02(2)(b)1., the facility cannot emit visible emissions from its engines the opacity of which is equal to or greater than 40% [Condition 2.12]. The emergency generators only fire No. 2 distillate fuel oil so they are expected to meet the GA Rule (b) standard. 40 CFR 60 Subpart IIII (NSPS IIII) NSPS for Stationary Compression Ignition Internal Combustion Engines - applies to emergency engines EG-4 through EG-9 because they were manufactured after April 1, 2006 [Condition 2.10]. NSPS IIII limits non-emergency service time to 100 hours per year and requires engines to be certified to meet the standards in 40 CFR 60.4205(b). The performance standards that apply to emergency engines EG-4 through EG-9 are presented in Table 2 below: Page 4
Table 2: NSPS Subpart IIII Emission Standards For Stationary 2007 and later Model Year Diesel Engines With A Displacement Of Less Than 10 Liters Per Cylinder And Maximum Engine Power Of Larger Than 560 kw, with emission limits in terms of g/kw-hr (lb/hp-hr) [40 CFR 89.112(a)]. Pollutant NO x + NMHC CO PM EG-4 4.0 (0.007) 5.0 (0.00821) 0.30 (4.94x10-4 ) EG-5, EG-6, EG-7, 4.0 (0.007) 3.5 (0.00575) 0.20 (3.29x10-4 ) and EG-9 EG-8 4.0 (0.007) 3.5 (0.00575) 0.20 (3.29x10-4 ) Pollutant NO x + NMHC CO PM EG-5 EG-9 6.4 (0.011) 3.5 (0.00575) 0.20 (3.29x10-4 ) According to 40 CFR 60.4207, the emergency generators can only burn distillate fuel oil that has a maximum sulfur content of 15 ppm (subsumes GA Rule (g) limit of 2.5% sulfur by weight) [Condition 2.11]. 40 CFR 63 Subpart ZZZZ (RICE MACT) NESHAP for Stationary Reciprocating Internal Combustion Engines potentially applies to emergency engines EG-1 through EG-9 as stationary reciprocating internal combustion engines located at an area source of HAP. RICE MACT does not apply to the engines EG-1, EG2, and EG-3 because DVA Medical Center meets the definition of an institution located at an area source of HAP and according to 40 CFR 63.6585(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 63.6640(f)(2)(ii) and (iii) and that do not operate for the purpose specified in 63.6640(f)(4)(ii). [A stationary RICE is existing if you commenced construction or reconstruction of the stationary RICE before June 12, 2006. 40 CFR 63.6590(a)(1)(iii)] Engines EG-4 through EG-9 will comply with the RICE MACT by complying with NSPS IIII as required by 40 CFR 63.6990(c). Permit Conditions Conditions 2.1 through 2.5 are in a section dedicated to CHP engine (GEN01). Condition 2.1 limits fuel burning to natural gas in CHP engines Conditions 2.2 and 2.3 establish NSPS JJJJ applicability and standards. Condition 2.4 establishes RICE MACT applicability Condition 2.5 Rule (b) limit of 40% opacity. Conditions 2.6 through 2.9 are in a section dedicated to CHP Boilers (BL01, BL02, BL03, BL04, and BL05). Condition 2.6 ensures that best practices are used to control NOx Condition 2.7 Rule (d) visible emissions and particulate emissions limits Condition 2.8 establishes NSPS Dc applicability. Condition 2.9 sets boiler fuel use restrictions and standards needed to comply with NSPS Dc and Rule (g) while ensuring exemption from 40 CFR 63 Subpart JJJJJJ. Conditions 2.10 through 2.14 are in a section dedicated to emergency generators (EG-1 through EG-9). Conditions 2.10 and 2.11 establish NSPS IIII applicability and standards. Condition 2.12 sets GA Rule (b) limit of 40% opacity. Page 5
Condition 2.13 sets the GA Rule (g) fuel sulfur content limit of 2.5 percent sulfur for the non-nsps emergency generators. Condition 2.14 establishes RICE MACT applicability and indicates that the MACT will be complied with through compliance with NSPS IIII. Condition 5.2 requires monitoring of the sulfur content of fuel through obtaining records from fuel suppliers or from performing analysis of the fuel. Condition 5.3 requires the installation of gas meters on each of the boilers as required in NSPS Dc. Condition 7.3 establishes recordkeeping requirements including fuel oil receipts, emergency generator hours of operation, and fuel usage information. Condition 7.5 gives the facility 15 days to notify the Division of engine and boiler initial start-up. Condition 7.6 requires the permittee to demonstrate compliance with NSPS limits by purchasing certified engines. The permittee indicated this was the course they were going to take (versus testing). Condition 7.7 requires the permittee to submit a semi-annual report as required by the NSPS. Toxic Impact Assessment No toxic impact assessment is needed based on this application. Summary & Recommendations I recommend issuing SIP Permit No. 8062-175-0074-B-01-0 to DVA. A public advisory was issued on April 22, and expired on May 22,. No Comments were received by the Division. Page 6