WDEQ Permit P0022530 Boiler 3 testing req.pdf

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

Matthew H. Mead, Governor

Mr. Sean Saltzman Chief, Facilities Management Service Department of Veterans Affairs Veterans Affairs Medical Center Sheridan, WY 8200 I

Dear Mr. Saltzman:

April 11, 2017

Permit No. P0022530

Todd Parfitt, Director

The Division of Air Quality of the Wyoming Department of Environmental Quality has completed final review of the Department of Veterans Affairs' application to revise the PM10 and PM2.s emission limits for Boiler #1 and Boiler #2, revise the PM/PM10/PM2.s testing requirements for Boiler #1 and Boiler #2, and revise the CO emission limit for Boiler #1 and Boiler #2. The Sheridan VA Medical Center is located at 1898 Fort Road, in Sheridan, Sheridan County, Wyoming.

Following this agency's proposed approval of the request as published March 10, 2017 and in accordance with Chapter 6, Section 2(m) of the Wyoming Air Quality Standards and Regulations, the public was afforded a 30-day period in which to submit comments concerning the proposed modification, and an opportunity for a public hearing. No comments have been received. Therefore, on the basis of the information provided to us, approval to modify the Sheridan VA Medical Center as described in the application is hereby granted pursuant to Chapter 6, Section 2 of the regulations with the following conditions:

1. That authorized representatives of the Division of Air Quality be given permission to enter and inspect any property, premise or place on or at which an air 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, permits or orders.

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 That all substantive commitments and descriptions set forth in the application for this permit, unless superseded by a specific condition of this permit, are incorporated herein by this reference and are enforceable as conditions of this permit.

3. That a permit to operate, in accordance with Chapter 6, Section 2(a)(iii) of the WAQSR, is required after a 120 day start-up period in order to operate this facility.

4. That all notifications, reports and correspondences associated with this permit shall be submitted to the Stationary Source Compliance Program Manager. Submissions may be done electronically through https://airimpact.wyo.gov to satisfy requirements of this permit.

5. The.owner or operator shall furnish the Administrator written notification of: (i) the anticipated date of initial startup not more than sixty (60) days or less than thirty (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) of the W AQSR.

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 P0022530

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 W AQSR, 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 construction 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. Initial performance tests, as required by Condition 7 of Air Quality Permit P0020542, shall be conducted on the following sources:

1. Boiler # 1 and #2 Baghouse:

NOx and CO Emissions:

SO2 Emissions:

PM/PM10/PM2.s Emissions:

Opacity:

Compliance testing shall consist of three (3) I-hour tests following EPA Reference Methods 1-4, 7E and I 0.

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

Compliance tests shall consist of EPA Reference Test Methods 1-4, 5 or a Division approved test method.

Opacity testing shall consist of three (3) 6-minute averages of the opacity as determined by of 40 CFR part 60, appendix A, Method 9.

A test protocol shall be submitted for review and approval prior to testing. Other operating conditions shall be recorded during each test run and submitted with the test report. Results shall be submitted to this Division within forty-five ( 45) days of completion.

8. That emissions from the following boilers shall be limited as follows:

Pollutant Boiler #1 and Boiler #2 1 Backup steam generator (Boiler #3) lb/ton coal tpy lb/MMBtu lb/hr tpy

NOx 8.8 44.0 0.031 0.9 4.0 co 15.0 75 .0 0.082 2.4 10.6

SO2 17.5 87.5 - - -

1 Emissions in tpy are based on a total throughput of I 0,000 tons per year for Boiler# I and Boiler #2 combined.

9. That emissions from the Boiler# I and Boiler #2 baghouse shall be limited as follows:

PM10 PM2.s Source gr/dscf lb/hr tpy lb/hr tpy

Boiler #I and Boiler #2 Baghouse 0.01 Q8 3.4 0.33 1.46

10. Effective upon permit issuance, the conditions of this permit shall supersede Conditions 8(i), 9, and 10 from Air Quality Permit P0020542 for the Sheridan VA Medical Center.

11 . Unless specifically superseded by a condition of this permit, the conditions of Air Quality Permit P0020542 shall remain in effect.

It must be noted that this approval does not relieve you of your obligation to comply with all applicable county, state, and federal standards, regulations or ordinances. Special attention must be given to Chapter 6, Section 2 of the Wyoming Air Quality Standards and Regulations, which details the requirements for compliance with Conditions 3, 5 and 6. Any appeal of this permit as a final action of the Department must be made to the Environmental Quality Council within sixty (60) days of permit issuance per Section 16, Chapter I, General Rules of Practice and Procedure, Department of Environmental Quality.

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

Sincerely, ~ft<· I)( g~ tiJ. fie!/ Nancy E. Vehr Administrator Air Quality Division

Todd Parfitt Director Dept. of Environmental Quality

Table 1: Coal Fired Boiler NO,, CO, and SO2 Emissions 1

NO, CO 2

Source MMBtu/hr lb/ton coal tpy lb/ton coal tpy

Boiler #I 9.44

8.8 44.0 15.0 75 .0

Boiler #2 9.44

SO2 3

lb/ton coal tpy

17.5 87.5

1 Emission factors for NO, and SO2 in terms of pounds per ton of coal feed taken from AP-42, Chapter I.I, Table 1.1-3 for sub bituminous coal, and tpy emissions calculated with a combined throughput of I 0,000 tons per year.

2 Emission factor for CO is based on most recent performance test data.

3 Emission factor for sulfur is the weight% sulfur content of the received coal (0.5%) multiplied by 35.

Table 2: Boiler #1 and Boiler #2 Baghouse PM, PM10 and PM2.s Emissions 1

PM

Source MMBtu/hr

PM10 PM2.s lb/hr tpy lb/hr tpy lb/hr tpy Boiler #I 9.44

0.77 3.38 0.77 3.38 0.33 1.46 Boiler #2 9.44

1 Filterable portion of PM, PM to, and PM2.s.

Table 3: Sheridan VA Medical Center Emissions

Source NOx co voe SO2 lb/hr tpy lb/hr tpy lb/hr tpy lb/hr tpy

Permitted Emissions (P0020542)

Boiler #1 and Boiler #2 1 10.1 44.0 10.2 25 .0 - - 20.0 87.5

Boiler Baghouse - - - - - - - - Backup steam generator (Boiler #3) 1.0 4.0 2.4 10.6 0.2 0.7 <0.1 0.1

Cummins QSX l 5-G9 NR2 diesel

8.0 0.4 4.3 0.2 - - - -generator engine 2

Combustion ash handling - - - - - - - - Total Permitted Emissions 19.1 48.4 16.9 35.8 0.2 0.7 20.0 87.6

Proposed Emissions After Modification

Boiler #1 and Boiler #2 1 10.1 44.0 17.1 75.0 - Boiler Baghouse - - - - - Backup steam generator (Boiler #3) 1.0 4.0 2.4 10.6 0.2 Cummins QSX15-G9 NR2 diesel

8.0 0.4 4.3 0.2 -generator engine 3

Combustion ash handling - - - - -

Change in Emissions 0.0 0.0 6.9 50.0 0.0

Total Proposed Emissions 19.1 48.4 23.8 85.8 0.2 1 Emissions for a combined sub-bituminous coal throughput of I 0,000 tons per year.

2 Emissions in tpy are based on 500 hours of annual operation.

3 Emissions in tpy are based on I 00 hours of non-emergency annual operation.

- 20.0 87.5

0.7 <0.1 0.1

0.0 0.0 0.0

0.7 20.0 87.6

PM PM10 PM2.s lb/hr tpy lb/hr tpy lb/hr tpy

Controlled with Boiler Baghouse

0.3 1.4 0.3 1.4 0.1 0.4

0.2 1.0 0.2 1.0 0.2 1.0

0.3 <0.1 0.3 <0.1 - -insignificant

0.8 2.4 0.8 2.4 0.3 1.6

Controlled with Boiler Baghouse

0.8 3.4 0.8 3.4 0.3 1.5

0.2 1.0 0.2 1.0 0.2 1.0

0.3 <0.1 0.3 <0.1 - -insignificant

0.5 2.0 0.5 2.0 0.2 0.9

1.3 4.4 1.3 4.4 0.5 2.5

HAP

lb/hr tpy

1.55 6.81

0.05 0.24

1.60 7.05

1.55 6.81

0.05 0.24

0.0 0.0

1.60 7.05