Permit 206-10.pdf

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B502--Air Emissions Survey Inventory Aleda E. Lutz VA Medical Center
Solicitation number
36C25025Q0410
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This document is a Permit to Install (PTI) issued by the Michigan Department of Natural Resources and Environment for a 500-kw diesel-fueled emergency backup generator located at the Aleda E. Lutz VA Medical Center. The permit (No. 206-10) was issued on November 29, 2010, and specifies detailed emissions requirements for the generator, including a nitrogen oxide (NOx) limit of 2.0 tons per year based on an emission factor of 7.92 lbs NOx per hour and a maximum operating time of 500 hours annually.

The permit includes stringent operational restrictions, such as limiting maintenance checks and readiness testing to 100 hours per 12-month period, requiring the use of diesel fuel with a maximum sulfur content of 15 ppm, and mandating the installation of a non-resettable hours meter to track operation. The generator must be operated in accordance with manufacturer specifications and comply with federal New Source Performance Standards. Detailed monitoring and recordkeeping requirements are specified, including monthly tracking of fuel usage, emissions calculations, and operational hours, with all records to be maintained for five years and made available to the Department upon request.

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Aleda E. Lutz VA Medical Center November 29, 2010 Permit No. 206-10 Page 1 of 7

PERMIT TO INSTALL

Table of Contents

Section Page

Alphabetical Listing of Common Abbreviations / Acronyms

General Conditions

Special Conditions

Emission Unit Summary Table

Special Conditions for EU-ENGINE BLDG21

Permit No. 206-10 Page 2 of 7

Common Abbreviations / Acronyms

Common Acronyms Pollutant/Measurement Abbreviations AQD Air Quality Division BTU British Thermal Unit

BACT Best Available Control Technology °C Degrees Celsius

CAA Clean Air Act CO Carbon Monoxide

CEM Continuous Emission Monitoring dscf Dry standard cubic foot

CFR Code of Federal Regulations dscm Dry standard cubic meter

COM Continuous Opacity Monitoring °F Degrees Fahrenheit

EPA Environmental Protection Agency gr Grains

EU Emission Unit Hg Mercury

FG Flexible Group hr Hour

GACS Gallon of Applied Coating Solids H2S Hydrogen Sulfide

GC General Condition hp Horsepower

HAP Hazardous Air Pollutant lb Pound

HVLP High Volume Low Pressure * m Meter

ID Identification mg Milligram

LAER Lowest Achievable Emission Rate mm Millimeter

MACT Maximum Achievable Control Technology MM Million

MAERS Michigan Air Emissions Reporting System MW Megawatts

MAP Malfunction Abatement Plan ng Nanogram

MDNRE

Michigan Department of Natural Resources and Environment (Department)

NOx Oxides of Nitrogen

MSDS Material Safety Data Sheet PM Particulate Matter

NESHAP

National Emission Standard for Hazardous Air Pollutants

PM10 PM less than 10 microns diameter

NSPS New Source Performance Standards PM2.5 PM less than 2.5 microns diameter

NSR New Source Review pph Pound per hour

PS Performance Specification ppm Parts per million

PSD Prevention of Significant Deterioration ppmv Parts per million by volume

PTE Permanent Total Enclosure ppmw Parts per million by weight

PTI Permit to Install psia Pounds per square inch absolute

RACT Reasonably Available Control Technology psig Pounds per square inch gauge

ROP Renewable Operating Permit scf Standard cubic feet

SC Special Condition sec Seconds

SCR Selective Catalytic Reduction SO2 Sulfur Dioxide

SRN State Registration Number THC Total Hydrocarbons

TAC Toxic Air Contaminant tpy Tons per year

TEQ Toxicity Equivalence Quotient µg Microgram

VE Visible Emissions VOC Volatile Organic Compounds yr Year

* For High Volume Low Pressure (HVLP) applicators, the pressure measured at the HVLP gun air cap shall not exceed ten (10) pounds per square inch gauge (psig).

Permit No. 206-10 Page 3 of 7

GENERAL CONDITIONS

1. The process or process equipment covered by this permit shall not be reconstructed, relocated, or modified, unless a Permit to Install authorizing such action is issued by the Department, except to the extent such action is exempt from the Permit to Install requirements by any applicable rule.

(R 336.1201(1))

2. If the installation, construction, reconstruction, relocation, or modification of the equipment for which this permit has been approved has not commenced within 18 months, or has been interrupted for 18 months, this permit shall become void unless otherwise authorized by the Department. Furthermore, the permittee or the designated authorized agent shall notify the Department via the Supervisor, Permit Section, Air Quality Division, Michigan Department of Natural Resources and Environment, P.O. Box 30260, Lansing, Michigan 48909, if it is decided not to pursue the installation, construction, reconstruction, relocation, or modification of the equipment allowed by this Permit to Install. (R 336.1201(4))

3. If this Permit to Install is issued for a process or process equipment located at a stationary source that is not subject to the Renewable Operating Permit program requirements pursuant to R 336.1210, operation of the process or process equipment is allowed by this permit if the equipment performs in accordance with the terms and conditions of this Permit to Install. (R 336.1201(6)(b))

4. The Department may, after notice and opportunity for a hearing, revoke this Permit to Install if evidence indicates the process or process equipment is not performing in accordance with the terms and conditions of this permit or is violating the Department’s rules or the Clean Air Act. (R 336.1201(8), Section 5510 of Act 451, PA 1994)

5. The terms and conditions of this Permit to Install shall apply to any person or legal entity that now or hereafter owns or operates the process or process equipment at the location authorized by this Permit to Install. If the new owner or operator submits a written request to the Department pursuant to R 336.1219 and the Department approves the request, this permit will be amended to reflect the change of ownership or operational control. The request must include all of the information required by subrules (1)(a), (b), and

(c) of R 336.1219 and shall be sent to the District Supervisor, Air Quality Division, Michigan Department of Natural Resources and Environment. (R 336.1219)

6. Operation of this equipment shall not result in the emission of an air contaminant which causes injurious effects to human health or safety, animal life, plant life of significant economic value, or property, or which causes unreasonable interference with the comfortable enjoyment of life and property. (R 336.1901)

7. The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that results in emissions of a hazardous or toxic air pollutant which continue for more than one hour in excess of any applicable standard or limitation, or emissions of any air contaminant continuing for more than two hours in excess of an applicable standard or limitation, as required in Rule 912, to the Department. The notice shall be provided not later than two business days after start-up, shutdown, or discovery of the abnormal condition or malfunction. Written reports, if required, must be filed with the Department within 10 days after the start-up or shutdown occurred, within 10 days after the abnormal conditions or malfunction has been corrected, or within 30 days of discovery of the abnormal condition or malfunction, whichever is first. The written reports shall include all of the information required in Rule 912(5).

(R 336.1912)

8. Approval of this permit does not exempt the permittee from complying with any future applicable requirements which may be promulgated under Part 55 of 1994 PA 451, as amended or the Federal Clean Air Act.

9. Approval of this permit does not obviate the necessity of obtaining such permits or approvals from other units of government as required by law.

10. Operation of this equipment may be subject to other requirements of Part 55 of 1994 PA 451, as amended and the rules promulgated thereunder.

Permit No. 206-10 Page 4 of 7

11. Except as provided in subrules (2) and (3) or unless the special conditions of the Permit to Install include an alternate opacity limit established pursuant to subrule (4) of R 336.1301, the permittee shall not cause or permit to be discharged into the outer air from a process or process equipment a visible emission of density greater than the most stringent of the following. The grading of visible emissions shall be determined in accordance with R 336.1303. (R 336.1301)

a) A six-minute average of 20 percent opacity, except for one six-minute average per hour of not more than 27 percent opacity.

b) A visible emission limit specified by an applicable federal new source performance standard.

c) A visible emission limit specified as a condition of this Permit to Install.

12. Collected air contaminants shall be removed as necessary to maintain the equipment at the required operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so as to minimize the introduction of contaminants to the outer air. Transport of collected air contaminants in Priority I and II areas requires the use of material handling methods specified in R 336.1370(2).

(R 336.1370)

13. The Department may require the permittee to conduct acceptable performance tests, at the permittee’s expense, in accordance with R 336.2001 and R 336.2003, under any of the conditions listed in R 336.2001. (R 336.2001)

Permit No. 206-10 Page 5 of 7

SPECIAL CONDITIONS

EMISSION UNIT SUMMARY TABLE

The descriptions provided below are for informational purposes and do not constitute enforceable conditions.

Emission Unit ID Emission Unit Description (Process Equipment & Control Devices) Flexible Group ID

EU-ENGINE BLDG21 A 500-kw diesel-fueled emergency backup generator, model year 2010. Emissions from EU-ENGINE BLDG21 exhaust via stack SV-ENGINE BLDG21

NA

Changes to the equipment described in this table are subject to the requirements of R 336.1201, except as allowed by R 336.1278 to R 336.1290.

The following conditions apply to: EU-ENGINE BLDG21

DESCRIPTION: A 500-kw diesel-fueled emergency backup generator

Flexible Group ID: NA

POLLUTION CONTROL EQUIPMENT: None

I. EMISSION LIMITS

Pollutant Limit Time Period / Operating Scenario Equipment

Testing / Monitoring

Method

Underlying Applicable Requirements

1. NOx 2.0 tpy 12-month rolling time period as determined at the end of each calendar month

EU-ENGINE

BLDG21

SC VI.3 R 336.1205,

R 336.2803, R 336.2804, 40 CFR 52.21 (c) & (d)

The NOx limit is based on an emission factor of 7.92 lbs NOx per hour and a maximum of 500 hours of operation a year.

II. MATERIAL LIMITS

1. The diesel fuel used in EU-ENGINE BLDG21 shall meet the requirements of 40 CFR 80.510 (b) with the maximum sulfur content of the fuel oil not to exceed 15 ppm (0.0015 per cent) by weight. (R 336.1205, 40 CFR 60.4207 (b), 40 CFR 80.510(b))

III. PROCESS/OPERATIONAL RESTRICTIONS

1. The permittee shall install and operate EU-ENGINE BLDG21 in accordance with the manufacture’s specifications. (40 CFR Part 60 Subpart IIII)

2. The permittee shall comply with all provisions of the federal Standards of Performance for New Stationary Sources as specified in 40 CFR Part 60 Subparts A and IIII, as they apply to EU-ENGINE BLDG21. (40 CFR Part 60 Subparts A & IIII)

Permit No. 206-10 Page 6 of 7

3. The permittee shall not operate EU-ENGINE BLDG21 for more than 500 hours per 12-month rolling time period as determined at the end of each calendar month. Of these 500 hours, the permittee shall not exceed 100 hours for maintenance checks and readiness testing. (R 336.1205, R 336.1225, R 336.1702(a), 40 CFR 52.21 (c) & (d), Subpart IIII, § 60.4211 (e))

IV. DESIGN/EQUIPMENT PARAMETERS

1. The permittee shall equip and maintain EU-ENGINE BLDG21 with non-resettable hours meter to track its operating hours. (R 336.1205, R 336.1224, R 336.1225, 40 CFR 60.4209(a))

V. TESTING/SAMPLING

N/A

VI. MONITORING/RECORDKEEPING

Records shall be maintained on file for a period of five years, unless otherwise indicated. (R 336.1201(3))

1. The permittee shall complete all required calculations in a format acceptable to the AQD District Supervisor by the 15th day of the calendar month, for the previous calendar month, unless otherwise specified in any monitoring/recordkeeping special condition. (R 336.1205, R 336.2803, R 336.2804, 40 CFR 52.21 (c) & (d))

2. The permittee shall monitor and record in a satisfactory manner the diesel fuel usage rate for the generator on a monthly and 12-month rolling time period basis. The permittee shall also monitor and record in a satisfactory manner the diesel fuel usage rate for EU-ENGINE BLDG21 on a monthly and 12-month rolling time period basis. The permittee shall keep all records on file and make them available to the Department upon request. (R 336.1205, R 336.1225, R 336.1702(a), R 336.2803, R 336.2804, 40 CFR 52.21 (c) & (d))

3. The permittee shall keep, in a satisfactory manner, monthly and 12-month rolling time period NOx emission calculation records for EU-ENGINE BLDG21. The permittee shall keep all records on file and make them available to the Department upon request. (R 336.1205, R 336.2803, R 336.2804, 40 CFR 52.21 (c) & (d))

4. The permittee shall keep separate records of the sulfur content calculations for EU-ENGINE BLDG21, in percent by weight, on an annual average. Alternately, the permittee shall keep, for EACH fuel shipment delivery, a statement from the fuel supplier indicating that the diesel fuel sulfur content is 15 ppm or less, by weight. The permittee shall keep all records on file and make them available to the Department upon request. (R 336.1205, 40 CFR Part 72.7, 40 CFR 80.510(a), 40 CFR 80.510(b))

5. The permittee shall keep, for the life of the engine, the manufacture certification documentation indicating that EU-ENGINE BLDG21 meets the applicable emission limitations contained in the federal Standards of Performance for New Stationary Sources 40 CFR Part 60 Subpart IIII. The permittee shall keep all records on file and make them available to the Department upon request. (40 CFR 60.4211(b) (3))

6. The permittee shall monitor the hours of operation of EU-ENGINE BLDG21 and the reason it was in operation during that time on a monthly basis in a manner that is acceptable to the District Supervisor, Air Quality Division. (R 336.1205(1)(a) and (3), 40 CFR Part 60, Subpart IIII, § 60.4214)

VII. REPORTING

N/A

VIII. STACK/VENT RESTRICTIONS

Permit No. 206-10 Page 7 of 7

The exhaust gases from the stack listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted:

Stack & Vent ID Maximum Exhaust

Diameter/ Dimensions (inches)

Minimum Height Above Ground

(feet)

Underlying Applicable Requirements

1. SV-ENGINE BLDG21 12.0 21.0 R 336.1225,

R 336.2803, R 336.2804, 40 CFR 52.21 (c) & (d)

File details come from the government source that posted it. Updated .