COMMONWEALTH OF PENNSYLVANIA Department of Environmental Protection Southwest Regional Office ·

TO: Air Quality Case File OP-04-00480

FROM:

THROUGH: Barbara Hatch, P.E.~ Environmental Engin Air Quality

DATE:

RE:

July 24, 2012

SOOP Renewal Application OP-04-00480 Heritage Valley Health System, Inc. Borough of Beaver, Beaver County APS 776486 AUTH 920192 PF 495213

BACKGROUND

~#' Mark A. Wayner, P.E. Regional Manager Air Quality

OFACIAL FilE COP I

MEMO

The Department received a renewal Operating Permit application on February 14, 2012 from the Heritage Valley Health System (HVHS) for their Beaver County Medical Center (BCMC) facility in the borough of Beaver, Beaver County. The hospital is located on Dutch Ridge Rd. just north of downtown Beaver. The SIC and NAICS Codes for Services- General Medical and Surgical Hospitals are 8062 and 622110, respectively.

The main emission sources at the hospital are two (2) 25.5 mmbtu/hr Cleaver Brooks model #WT 200X-BR-1 boilers that were installed in 1980 under Plan Approval #04-302-048 and a 12.075 mmbtu/hr Cleaver Brooks model #CB200-350 unit installed in 2004 under GP1-04-00480 (GP-1 is the General Plan Approval & Operating Permit for Small Gas & No. 2 Oil Fired Combustion Units). The newest unit serves as a summertime boiler and replaced an existing Cleaver Brooks model #D-34-E unit. All three boilers fire mostly on natural gas but have the capability to burn No.2 fuel oil as well under emergency conditions. The identical units are Source #032 and #033 in the operating permit and the newer summer boiler is #034.

There are four (4) diesel-fired emergency generators at the hospital. Two ofthese units, Source #102 and #103, are 620 kW, Caterpillar model# SR4 generators installed in 1980. Source #101 is a 930 kW Caterpillar SRCR unit also installed in 1980. The fourth generator was constructed under an approved Request for Determination (RFD) in November 2010. It is a 1.0 MW

. . Cummins model #QST30-G5 unit which will be designated as Source #104 in the renewal operating permit.

The hospital also has process emission source which was not included in the previous operating permit. Constructed in 2005 , BCMC operates two Steris Ethylene Oxide (ETO) Sterilizers model # 3017 (Source #105) which are subject to the National Emissions Standards for Hazardous Air Pollutants (NESHAPs) Subpart WWWWW for Hospital Ethylene Oxide Sterilizers. The applicable requirements from Subpart WWWWW have been added to the operating permit. The ETO Sterilizers use approximately 35 lbs each of ETO per year in 190 cycles. Each unit has a capacity of 5.6 cubic feet.

There are no other individual sources listed in the permit nor are there any small sources listed in Section G as "Sources of Minor Significance" in the previous version of the operating permit.

The application was deemed administratively complete on June 25, 2012. The previous renewal operating permit expired on November 23, 2010.

SOURCES, CONTROL DEVICES AND EMISSIONS

Potential emission estimates were taken from our application files for prior plan approvals and operating permits. The emissions were calculated based upon rated heat input capacities, AP-42 emission factors, and manufacturer' s data. Potential to emit (PTE) from the sources at this faci lity are based on operation of the boilers for 8,760 hours per year and combustion of natural gas or low sulfur diesel fuel, whichever resulted in the higher PTE. PTE for the emergency generators was based on the use of low sulfur diesel fuel for 500 hours per year. The emissions calculations are presented in Table 1 below:

Table 1 - BCMC Potential To Emit

Source Pollutant in Tons Per Year NOx co S02 PM voc ETO*

Cleaver Brooks Boiler #WT 200X-BR-1 -15.7 3.6 27.8 1.6 0.1

-Source #032 Cleaver Brooks Boiler #WT 200X-BR-1-

15.7 3.6 27.8 1.6 0.1 -Source #033 Cleaver Brooks Boiler #CB200-350 -

8.7 2.2 15.1 0.9 0.2 -

Source #034 Caterpillar Emergency Generator #SRCR -

10.0 0.7 0.7 0.2 -

Source #101 2.2

Caterpillar Emergency Generator #SR4-6.7 0.4 0.5 0.1

-Source #102

1.5

Caterpillar Emergency Generator #SR4 -6.7 0.4 0.5 0.1

-Source #103

1.5

Cummins Emergency Generator #QST30-0.0 0.1 0.0

-G5 Source # 104

3.2 0.5

Ethylene Oxide Sterilizers (2) - Source 70.0 - - - - -

#105 TOTALS 66.7 15.1 72.2 5.9 0.6 70.0 * EO = Ethylene Oxide, in Pounds Per Year

REGULATORY ANALYSIS

There are new federal regulatory requirements which apply to the sources at this facility. 40 CFR Part 63, Subpart ZZZZ, Stationary Reciprocating Internal Combustion Engines (SRICE) applies to both major and area sources of hazardous air pollutants (HAPs). However, 40 CFR 63.6590(b)(3)(vii) exempts existing institutional emergency SRICE located at area sources of HAP emissions from having to meet the requirements of Subpart ZZZZ. Therefore only the newest engine, Source # 104, is subject to the requirements of Subpart ZZZZ.

40 CFR 63.6590(c)(1) states that new compression ignition (CI) SRICE at area sources must comply with Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. 40 CFR 60.4205 requires that this engine complies with the emission standards for new nonroad CI engines in 40 CFR 60.4202, for all pollutants, for the same model year and maximum engine power for the 2007 model year and later emergency CI SRICE. 40 CFR 60.4202(a)(2) states that engines with maximum engine power greater than 50 horsepower (HP) must meet the certification emission standards for new nonroad CI engines for the same model year and maximum engine power in 40 CFR 89.112 and 40 CFR 89.113 for all pollutants beginning in model year 2007. The Tier 2 standards for this engine from Table 1 of 40 CFR 89.112 are as follows:

Table 2- Source #104 Tier 2 Emission Standards

Pollutants Emission Rate in g!bhp-hr NOx + HC (Oxides ofNitrogen as N02 + Non 4.77 Methane Hydrocarbonsl CO (Carbon Monoxide) 2.61 PM (Particulate Matter) 0.15

Compliance requirements for Source #104 are found in 40 CFR 60.4211(c) and (f). 40 CFR 60.4214 lists the reporting and recordkeeping requirements.

40 CFR 60, Subpart De, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units applies to combustion units with maximum design heat input capacities greater than 10.0 mmbtu/hr but only those that commenced construction after June 9, 1989. Therefore, Subpart De does apply to the newest boiler, Source #034. As stated above, the boiler was installed under GP-1. The applicable requirements from Subpart De are listed in GP-1 . To summarize these briefly, included are conditions for the installation and maintenance of meters to monitor daily fuel usage and recordkeeping and reporting requirements including: 1) Monthly fuel firing rates to determine sulfur dioxide emissions and, 2) Any instances of excess emissions.

GP-1 also includes Best Available Technology (BAT) emission limits for units constructed after December 2, 1995 with rated capacity equal to or greater than 10 mmbtu/hr. The limits for Source #034 at the time of installation were:

Table 3- Source #034 GP-1 BAT Emission Limits

Pollutant Emission Rate in ppmv, dry N Ox at 3% 0 2 firing gas 30 NOx at 3% 0 2 firing No.2 oil 90 CO at 3%02 400

The applicability of 40 CFR 63 , Subpart 0 , Ethylene Oxide Emissions Standards for Sterilization Facilities was considered. However, 40 CFR 63.360(e) specifically exempts "ethylene oxide sterilization operations at stationary sources such as hospitals."

40 CFR 63 , Subpart WWWWW, NESHAPs for Hospital Ethylene Oxide Sterilizers does apply to this facility. Owners or operators of ethylene oxide sterilization facilities at hospitals that are area sources of hazardous air pollutants (HAP) emissions are subject whether they are new or existing sources. Existing sources are those that commenced construction before November 6, 2006. The applicable sections of Subpart WWWWW have been incorporated into this renewal permit.

Notable SIP standards which apply include 25 Pa. Code Section 123.11 - 0.4 lb PM/mmbtu, 123.22 - 4 lb S02/mmbtu, the malodor provisions of 123.31 , and the opacity standards of 123.41. The

permittee is required to do weekly monitoring for fugitive, visible, and malodor emissions and to keep records of the observations. Annual fuel usage records are required to be kept. The emergency generators are limited to 500 hours of operation per consecutive 12 month period apiece and records of operation must be maintained.

CONCLUSIONS AND RECOMMENDATIONS

I have completed my review ofHVHS 's Natural Minor renewal application. HVHS has met the regulatory requirements associated with this application submittal. The attached draft permit includes the applicable regulatory requirements for this facility. I recommend that the proposed Operating Permit be issued for this for a five (5) year permit term.