WDEQ Permit P0025873 B4 with 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.

Mark Gordon. Governor Todd ParfiM, Director

Mr. Shain Wright GEMS Program Manager Depaitment of Veterans Affairs 1898 Foil Road

Sheridan, WY 82801

Issuance Date

SEP 2 6 2019

Permit No. P0025873

Dear Mr. Wright:

The Division of Air Quality of the Wyoming Department of Environmental Quality has completed final review of Department of Veterans Affairs's (CMP001703) application to add a temporaiy 27.3 MMBtu/hr dual fired boiler (BOL005) capable of operating on nalural gas and fuel oil at the Sheridan VA Medical Center (F00075Q).

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 August 19, 2019, 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 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 That all substantive commitments and descriptions set forth in the application for this permit, unless superseded by a specific condition of this permit, are incorporated herein by this reference and are enforceable as conditions of this permit.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 stai1-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 also be done electronically through https://airimpact.wvo.tiov 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 dale in accordance with Chapter 6, Section 2(i) of the WAQSR.

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

ADMIN/OUTREACH ABANDONED MINES

(307) 777-7937 (307) 777-6145

AIR QUALITY

(307) 777-7391

INDUSTRIAL SITING

(307) 777-7369

LAND QUALITY

(307) 777-7756

SOLID & HA2. WASTE

(307) 777-7752

WATER QUALITY

(307) 777-7781

Department of Veterans Affairs Air Quality Permit P0025873

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 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. That performance tests be conducted, in accordance with Chapter 6, Section 2(j) 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 of the 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, shall be conducted on the following source:

i. Fuel Oil Fired - Boiler #4 (BOL005):

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

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

PM/PMio/PM? s Emissions (filterable): Compliance tests shall consist of EPA Reference Test Methods 1-4, 5 or a Division approved test method.

Opacitv: 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.

ii. Natural Gas Fired - Boiler #4 (BOL005):

NOx Emissions: Testing shall consist of three (3) 1-hour tests following EPA Reference Methods 1-4, 7E.

Opacitv: 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. 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.

9. That emissions from the following boiler shall be limited as follows:

Boiler #4 (BOL005) - Fuel OH

Unit NOx CO SO2

PM/PM10/PM2.5

(filterable)

Ib/MMBtu Ib/hr tpy Ib/MMBtu Ib/hr tpy lb/10^ Gal Ib/hr tpy lb/10^ Gal Ib/hr tpy

Boiler #4

(Fuel Oil)

0.13 3.4 15.5 0.036 1.0 4.3 0.21 <0.1 0.2 2.00 0.4 1.7

Boiler #4 (BOL005) - Natural Gas

Unit

NOx

Ib/MMBtu Ib/hr tpy

Boiler #4

(Natural Gas)

0.04 1.1 4.8

10.

12.

13.

14.

That the Department of Veterans Affairs shall follow the testing requirements as follows for the dual fired boiler U (BOL005):

i. For fuel oil fired, BOL005 shall be tested every twelve (12) calendar months, or as otherwise specified by the Administrator, to verify compliance with the NOx, CO, SO2 and PM (filterable) limits set forth in this permit. Periodic testing for the boiler is required one (1) year after completion of the initial performance test or the last periodic test. Testing shall be conducted following EPA reference methods. A test protocol shall be submitted for review and approval prior to testing. Notification of the test date shall be provided to the Division fifteen (15) days prior to testing. Results shall be submitted to this Division within forty-five (45) days of completion.

ii. For natural gas fired, BOL005 shall be tested every twelve (12) calendar months, or as otherwise specified by the Administrator, to verify compliance with the NOx limit set forth in this permit.

Periodic testing for the boiler is required one (1) year after completion of the initial performance test or the last periodic test. Testing shall be conducted following EPA reference methods. A test protocol shall be submitted for review and approval prior to testing. Notification of the test date shall be provided to the Division fifteen (15) days prior to testing. Results shall be submitted to this Division within forty-five (45) days of completion.

The Sheridan VA Medical Center shall track the annual fuel oil usage for the 27.3 MMBtu/hr boiler (BOL005). Documentation of the amount of fuel oil burned each year shall be maintained and made available upon request.

The Sheridan VA Medical Center shall comply with all applicable requirements of 40 CFR part 60, subpart Dc for Boiler #4 (BOL005).

The Sheridan VA Medical Center shall comply with all applicable requirements of 40 CFR part 63, subpart JJJJJJ.

All records required under this permit shall be kept for a period of at least five (5) years and shall be made available to the Division upon request.

It must be noted that this approval does not relieve you of your obligation to comply with ail 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, 6 and 7. Any appeal of this permit as a final action of the Department must be made to the Environmental Quality Council within thirty (30) days of permit issuance per Section 8, 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, E. ̂eiir Todd Parfitt istrator Director

Air Quality Division Dept. of Environmental Quality

Table 1: Sheridan VA Medical Center Emissions

IMPACT

AQD ID Source NOx CO VOC SO2 PM PMio PM2.5 HAP

Ib/hr tpy Ib/hr tpy Ib/hr tpy Ib/hr tpy Ib/hr tpy Ib/hr tpy Ib/hr tpy Ib/hr tpy

BOLOOI-

BOL002

Boiler # I and Boiler

#2 ' lO.I 44.0 10.2 25.0 - - 20.0 87.5 Controlled with Boiler Baghouse 1.55 6.81

— Boiler Baghouse - - - - - - - - 0.3 1.4 0.3 1.4 O.I 0.6 - -

BOL003

Backup steam generator (Boiler #3)

I.O 4.0 2.4 10.6 0.2 0.7 <0.1 O.I 0.2 1.0 0.2 1.0 0.2 1.0 0.05 0.24

ENGOOI

Cummins QSXI5- G9 NR2 diesel generator engine -

8.0 0.4 4.3 0.2 - - - - 0.3 <0.1 0.3 <0.1 - - - -

Combustion ash handling

- - - insignificant - -

ENGOl l-

ENG016

Five (5) emergency diesel-fired generator engines and one (I) propane-fired generator engine'

1.0 4.4 0.3 1.3 <0.1 0.2 O.I 0.6 <0.1 0.2 <0.1 0.2 - - - -

BOL005 Boiler #4'' 3.5 15.5 1.0 4.3 - - 0.04 0.2 0.4 1.7 0.4 1.7 0.4 1.7 - -

Total Facility Emissions 23.6 68.3 18.2 41.4 0.2 0.9 20.14 88.4 1.2 4.3 1.2 4.3 0.7 3.3 1.60 7.05

' Emissions for a combined sub-bituminous coal throughput of 10,000 tons per year.

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

^ Emissions in tpy are based on 100 hours of annual operation for each of the six (6) engines.

Emissions based on worst case scenario of operating 8,760 hours of operation on lliel oil.