WDEQ Permit P0020542 B3 and Engine testing req.pdf

Matthew H. Mead, Governor

Department of Environmental Quality To protect, conserve and enhance the qua/tty of Wyoming's environment for the benefit of current and future generations.

March 4, 2016

Todd Parfitt, Director

Mr. Sean Saltzman Chief, Facil ities Management Service Department of Veterans Affairs

RECEIVED

1898 Fort Road MAR 16 2016 Sheridan, WY 8280 I

Permit No. P0020542

Dear Mr. Saltzman:

The D ivision of Air Q ua lity of the Wyoming Depa11ment of Environmenta l Q ual ity has completed final review of the Department of Veterans Affairs' application to modify Air Quality Permit MD-13 164 for the Sheridan VA Medical Center to al low the operation of two (2) constructed but not started-up coal-fired boilers w ith a reduced maximum heat input of 9.44 MM Btu/hr each, and o ne (1) 29.3 MM Btu/hr natural gas fired steam generator. The Sheridan VA Medical Center is located at 1898 Fort Road, in Sheridan, Sheridan County, Wyoming.

Following this agency's proposed approval o f the request as published January 29, 20 16, and in accordance with Chapter 6, Section 2(m) of the Wyom ing Air Qual ity Standards and Regulations, the publ ic was afforded a th irty (30) day period in which to submit comments concerning the proposed mod ification , and an oppo11unity for a public hearing. No comments have been received. Therefore, o n the basis of the information provided to us, approval to mod ify the Sheridan VA Medical Center as described in the application is hereby granted pursuant to Chapter 6, Section 2 of the regulatio ns with the following conditions:

I . That authorized representatives of the Division of A ir Quality be given permission to enter and inspect any property, premise or place on o r at which an a ir pollution source is located or is being constructed or installed for the purpose of investigating actual or potential sources of air pollution and for determining compliance or non-compliance with any rules, standards, pem1its or orders.

2. That all substantive commitments and descriptions set forth in the application for this permit, unless superseded by a specific condition of th is permit, are incorporated herein by this reference and are enforceable as condit ions of thi s permit.

3. That a permit to operate, in accordance with Chapter 6, Section 2(a)(i ii) of the WAQSR, is required after a 120 day sta11-up period in order to operate th is facil ity.

4. That all notifications, repo11s and correspondences associated ,v ith this permit shall be submitted to the Stationary Source Compl iance Program Manager. Submissions may be done electronically through https://airimpact.wyo.gov to satisfy requ irements of th is permit.

5. The owner or o perator shal l furnish the Administrator written notification of: (i) the anticipated date of initial s tartup not more than sixty (60) days or less than thi1ty (30) days prior to such date, and ; (ii) the actual date of initial start-up within fifteen ( 15) days after such date in accordance with Chapter 6, Section 2(i) or the WAQSR. For the generator eng ine such not ification sha ll be submitted on a complete Engine installation/Removal form. The form can be down loaded from the Air Quality website http://deg.wyoming.gov/agd/ o r obtained from the Air Quality Divis ion.

200 West 17th Street · Cheyenne, WY 82002 · http://deq.wyoming.gov · Fax (307)635-1784

ADMIN/OUTREACH ABANDONED MINES AIR QUALITY INDUSTRIAL SITING LAND QUALITY SOLID & HAZ. WASTE WATER QUALITY

(307) 777-7937 (307) 777-6145 (307) 777-7391 (307) 777-7369 (307) 777-7756 (307) 777-7752 (307) 777-7781

Department of Veterans Affairs Air Quality Permit P0020542

6. That the date of commencement of construction shall be reported to the Administrator within thirty

(30) days of commencement. in accordance with Chapter 6, Section 2(h) of the WAQSR, approval to construct or modify shall become invalid if construction is not commenced within twenty-four

(24) months after receipt of such approval or if constniction is discontinued for a period of twenty four (24) months or more. The Administrator may extend the period based on satisfactory justification of the requested extension.

7. That performance tests be conducted, in accordance with Chapter 6, Section 2(i) of the WAQSR, within thirty (30) days of achieving a maximum design rate but not later than ninety (90) days following initial start-up, and a written report ofthe results be submitted. The operator shall provide fifteen ( 15) days prior notice of the test date. If a maximum design rate is not achieved within ninety (90) days of start-up, the Administrator may require testing be done at the rate achieved and again when a maximum rate is achieved.

8. Initial performance tests, as required by Condition 7 of this permit, sha!l be conducted on the following sources:

1. Boiler# I and #2 Aaghouse:

NOx and CO Emissions:

S02 Emissions:

PM/PM1_o/PM~s Emissions:

Opacitv:

Compliance testing shall consist of three (3) 1 -hour tests following EPA Reference Methods 1-4, 7E and 10.

Compliance tests shall consist of three (3) 1-hour tests following EPA Rcrerence Methods 1-4 and 6C.

Compliance tests shall consist of EPA Reference Test Methods !-4. 5, 20 I A and 202 or a Division approved test method.

Opacity testing shall consist of three (3) 6-rninute averages of the opacity as detennined by of 40 CFR part

60. appendix A, Method 9.

11. Backup steam generator (Boiler #3)

NOx and CO Emissions: Testing shall consist or three (3) I-hour tests following EPA Reference Methods 1-4, 7E and 10.

111. Cummins QSX 15-G9 NR2 Emergency Diesel Generator Engine

NO, and CO Emissions: To veril)' NO, and CO emissions, testing shall be conducted in accordance \Vith EPA reference methods or the State of Wyoming's P011able Analyzer Protocol.

A test protocol shall be submitted for rcvie\\ and approval prior to testing. Engine horsepower.

and other operating conditions shall be recorded during each test run and submitted with the test report. Results shall be submitted to lhis Division within forty-five (45) days of completion.

Ai1· Quality Permit P0020542 Page3

9. That emissions from the fl1llowing boilers shall be limited as follows;

10.

11.

12.

13.

• . --Boiler #1 nnd -Boiler #2 1 Backup steam generator (Boiler #3) Boiler lb/ton coal Ib/MMBtu 1b/hr .. tpy tpy

NO~ 8.8 44.0 0.031 0.9 4.0

co 5.0 25.0 0.082 2.4 10.6

so. l 7.5 87.5 - - - 1 Emissions m lpy arc based 011 n tot.ii throughput of I 0.()0() tons per )car lor llo1lcr It I nnd Boiler 112 cornb111cd.

That emissions from the Boiler fl I and Boiler #1 baghouse shall be limited as follows:

P.1.\-110 PMz.s source gr/dscf lb/hr lpy Jb/br tpy Boiler ti! and Boiler #2

0.01 0.3 1.4 0.14 0.61 Baghouse

That the Boiler #1 and Boiler #2 baghouse shall be operated and maintained during all Boiler #1 and #2 operations. Visible emissions from the Boiler #I and #2 baghouse shall be limited to no greater than ten percent ( 10%) opacity. The VA shall, 011 a daily basis, check for the presence of any visual emissions at the boiler baghousc on any day that the baghousc is operating. The visual observation shall be conducted al each baghouse by personnel who are educated on the general procedures for determining the presence of visible emissions but not necessarily ce11ified to perform Method 9 observations. Observation of any visible emissions from any or these units shall prompt immediate inspection amL if necessary, corrective action.

The Sheridan VA Medical Center shall be limited to a sub-bituminous coal throughput of I 0,000 tons per year. The Sheridan VA Medical Center shall keep records of the delivered coal.

The sulfur content of the received coal shall be limited to a sulfur content of0.6% and a 11-month rolling average of 0.5%. ·1·1ic VA shall demonstrate the compliance ,vith the sulfur content limits by providing the monthly coal analysis to demonstrate compliance with a sulfur content of 0.6% sulfi.ir (as received) and a permitted l 2-month rolling average or 0.5% sulfur content (as received).

The monthly coal analyses and records of delivered coal as required by Condition 12 of this permit shall be submitted every six (6) months ,vith a year-to date total for the delivered coal and the rolling average of the sulfur content of the delivered coal.

! 4. That the Sheridan VA Medical Center shall l'ol!O\v the testing requirements as follows for the three

(3) boilers and emergcnc)- generator:

1. That every one ( 1) year follov,ing completion of the initial performance test or the last periodic test. the Boiler #1 and Boiler #2 bag.house shall be tested for NO,. CO, SO".

PM/PM 10/PMc, emissions. nnd opacity as outlined in Condition 8 or this permit. A test protocol shall be submitted for review and approval prior to testing, and notification of the test date shall be provided to the Di\"ision al least fiHeen ( 15) days prior to the test date.

Test results shnll be submitted to the Division within fo1iy-five ( 45) days after completion of the periodic lest.

Department of Vetcrnus Affairs

11. That every five (5) years or 5,000 hours of operation, whichever comes first, following completion of the initial performance test or the last periodic test. the backup steam generator {Boiler #3) shall be tested for NC\ and CO emissions as outlined in Condition 8 of this permit. A test prolocol shall be submitted for review and approval prior to testing, and notification of the test date shall be provided to the Division at least fifleen ( ! 5) days prior to the test date. Test results shall be submitted to the Division within forty-live (45) days after completion of the periodic test.

15. That the stack height for Boiler# l and Boiler #2 shall be a minimum of thirty {30) meters.

16. The Cummins QSXl5-Ci9 NR.2 diesel generator engine shall be limited to 100 hours of non emergency annual operation. The VA shall install and maintain a non-resettable hour meter to demonstrate compliance with the hours limit in this condition. Documentation of the hours of operation shall be maintained for at least five (5) years and made available to the Division upon request.

l 7. The Cummins QSX I 5-G9 NR.2 diesel generator engine shall be EPA Tier 2 certified. The VA shall maintain documentation of the diesel generator engine ·s tier certification.

18.

19.

20.

21.

22.

24.

The natural gas fired boiler shall be flred only with pipeline quality natural gas.

The Sheridan VA Medical Center shall comply v. ith a!I applicable requiremenls of-1.0 CFR part 60.

subpart lllL

The Sheridan VA Medical Center shall comply\\ ith al! applicable requirements or 40 CFR part 60, subpart De for Boiler 113.

The Sheridan VA Medical Center shall comply\\ ith all applicable requirements of 40 CFR part 63, subpmi ZZZZ.

The Sheridan VA Medical Center shall comply with all applicable requirements of40 CFR part 63, subpmi JJJJJJ.

The Sheridan V /\ Medical Center shall keep records of the hourly heat input rates for Boiler If. I and Boiler #2. For the first year or operation, the V /\ shall submit quarterly reports to the Division. If the V /\ can represent that after one ( l) year, the heat input rates are below IO MMBtu/hr for each of the boilers, then the reports shall be provided to the Division upon request.

All records required under this permit shall be kept for a period ofat least live (5) years and shall be made available to the Division upon requesl.

25. Effective upon permit issuance. this permit shall supersede al! previous air quality permits and waivers for the Sheridan V /\ Medical Center.

It must be noted that th is approval does not rel ieve you of your obligat ion to comply w ith all applicable county, state, and federal standards, regulations or ord inances. Special a ttention must be g iven to Chapter 6, Section 2 of the Wyoming Air Quality Standards and Regulations, which details the requirements for compl iance with Conditions 3, 5, 6 and 7. Any appeal of this permit as a final action of the Depai1ment must be made to the Environmental Quality Council within s ixty (60) days of permit issuance per Section 16, Chapter I, General Rules of Practice and Procedure, Depa11ment of Environmental Qual ity.

If we may be of further assistance to you, please fee l free to contact this office.

S incerely, fa111a ef, YiUI Nancy E. Z ehr Administrator A ir Quality Division

Todd Parfitt Director Dept. of Environmental Quality

Dep:1rtment of Veterans Affairs

T3.blc-1: Coal Fired Boilet NO.-., CO,·and S02 Emissions 1·

NO, co Source MM Btu/hr lb/ton lb/ton coal tpy coal tpy

Boiler #1 9.44

8.8 44.0 5.0 25.0

Boiler #2 9A4

S02 2 lb/ton coal tpy

17.5 87.5

. . - -1 l·,rn1ss10n laclors Jor NO,. CO. nnd SO" 111 term~ of pounds per ton o! coal Iced taken lrom i\P-42. C haptcr 1.1. J able 1.1-3 lor sub-bituminous coal. ant.I Ip)' emissions calculated ll'ith a combined throughput or 10.000 tons per year.

"Emission laclor for sulfur is !he 1tcighl ')o sulfur contenl of the recci\Cd coal (ll.5"o) multiplied b) 35.

TU:ble 2: Boilei'ifl and Boil Cr #2 Baghouse PM, PM1(l and PMo.sEDJissio.ns 1

PM PM10 PM2.s Source MMBtu/hr -- ------ --lb/hr lpy lb/hr lp)' lb/hr lpy Boiler fl I 9.4➔

0.53 2.37 0.32 1.42 0.1-1 0.62 Boiler#,., 9.44 1 F11!erabk portion of PM. f'il,Ji,. nnd l'tvb ,.

T.tble 3: Jlactmp Steam ·Generator Emissions 1

NO, co voe Source lb/MMscf lb/hr tpy lb/MMscf lb/hr lpy lb/MMscf lb/hr tpy

29.3 MMBtuthr

backup steam ., ,_ 0.9 4.0 S•l 2.-l 10.6 5.5 0.2 generator (Boiler #3) 1 l:m1ss1ons factors m lb 1hr arc based on a fuel gas hcatmg value ol 1.0:w Blu•sci.

TablC 4: llaekup Stt.am Ceucrntoi- Emissions 1 .

SO, PM/PMrn/PM2.s Source lb/l\1Mscf lb/hr tpy lb/MMscf lb/h,·

29.3 MMI3lu1hr backup steam

0.6 "0.1 0.1 7.6 0.2 generator (Boiler 113) -1 Emission !actors 111 lbtl1r arc ha5cd ,,n a !ucl gas hcm111g \aluc- oi 1.020 BlLt ~cl.

'fable S: Boiler ·E.niission Factors --

Source MM Btu/hr Emission Rate (lb/MMBtu)

NO, co voe Boiler /fl and Boiler#?. 1 18.9 0.535 0.302 -backup steam generator

29.3 0.031 0.082 0.005 (Boiler f/3)"

1 l:mtsswn fa cl ors based on comb med sub-b1tum111ous nml throughput o! ](},()(){) tons pc1 )Ca!.

"Emission lac1ors in llv:-.1:vtn1u arc hasctl on a lt!cl gas h..::ating 1·aluc or 1.020 Blu'scr.

SO,

l.059

0.001 tpy

1.0

PMio

0.017

0.008

0.7

PM2.s

0.0074

0.008

Table 6~ Sheridan-YA_ Medical Center Emissions·

Source NO, co voe lb/hr tpy lb/hr tpy lb/hr

Boiler 4-1 and Boiler#? 1 10.1 44.0 10.' 25.0 - Boiler Baghousc - - - - - Backup steam generator {Boiler lt-3) 1.0 4.0 2.4 10.6 0.2 Cummins QSX!5-G9 NR2 diesel

8.0 0.4 4.3 0.2 -. ' generator engme -

Combustion ash handling - I - - - - Total Facility Emissions 19.1 48.4 16.9 35.8 0.2 : l.1ni~~iom li1r LI wmhincd ~ub-hitwninou:-; w;1] throughput (11" HUIOO tons pcl' ~car.

: l·.mi~~ion~ in lp) ;tr('. h,1,cJ mi 100 hour., oi"n(>n-crncq_lc1K~ an11ual opcrntion.

tpy

0.7

0.7

SO, PM PM111 I Pi\h~ lb/hr tpy lb/hr tpy lb/hr lpy I lb/hr tpy

20.0 87.5 Controlled with Boiler Baghouse

- - 0.3 1.4 0.3 1.4 0.1 0.6

<0.1 0.1 0.2 1.0 0.2 1.0 0.2 1.0

- - 0.3 <O.l 0.3 <0.1 - -

- - insignificant

20.0 87,6 0.8 I 2.4 0.8 2A 0.3 1.6

HAP

lb/hr tpy

!.55 6.81

0.05 0.24 l.60 7.05