COMMONWEALTH OF PENNSYLVANIA Department of Environmental Protection Southwest Regional Office

TO: Air Quality Case File OP-26-00032

FROM: Nicholas J. Waryanka, P. Air Quality Engineer Air Quality

THROUGH: Barbara Hatch, P.E.

DATE:

RE:

Environmental Engin Air Quality

March 5, 2013

SOOP Renewal Application OP-26-00032 Uniontown Hospital Uniontown, Fayette County APS 778975 AUTH 923977 PF 511875

BACKGROUND

OffiCiAl ALE COPY

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

MEMO

The Department received a natural minor renewal Operating Permit application on April 18, 2012 from the Uniontown Hospital Association for the Uniontown Hospital (UH) in Uniontown, Fayette County. The hospital is located on West Berkeley St. about Y4 mile south of the intersection of State Routes 119 and 40 (West Main St.) on the west side of Uniontown. 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 three combustion units which are capable of firing either natural gas or No. 2 fuel oil. Source 031 is a 41 .0 mmbtu/hr Cleaver Brooks model #D-52 boiler that was installed in September 1973. Formerly the main boiler for the hospital, it now functions strictly as a back-up unit and is used mainly when the weather gets particularly cold. Two Burnham combustion units were installed in January 2002 and are now the primary boilers providing heat and steam at UH. The larger of the two units, Source #032, is a model #LN3P-350 boiler rated at 14.6 mmbtu/hr. The smaller unit is a model #LN3P-150 boiler rated at 6.2 mmbtu!hr. This source was originally listed in Section G, Miscellaneous as a minor source but is now Source #035 in the renewal operating permit. These three combustion units fire mostly on natural gas but have the capability to burn No. 2 fuel oil as well which generally happens only when the hospital nears its gas allotment according to Department inspection reports.

The hospital has two AMSCO Eagle Ethylene Oxide Sterilizers/Aerators, model #3017, listed as Sources #033 and #034 which are subject to recently promulgated National Emissions Standards for Hazardous Air Pollutants (NESHAPs) Subpart WWWWW. These units are processes and should have been assigned "100" series numbers but the source numbers will not be changed so as to avoid confusion.

The hospital also has three small, diesel-fired emergency generators. There are two 350 kW units and one 275 kW unit which are listed in Section Gas minor sources. These units are test fired weekly and a log book of these tests is maintained. I recommend adding an annual 500 hours operating restriction to the renewal permit for all three generators.

The original operating permit was issued on May 16, 2016. An administrative amendment application was submitted on July 27, 2009 requesting a change of the responsible official. The permit was amended on November 20, 2009. The renewal application was deemed administratively complete on July 27, 2012. The original operating permit expired on May 16, 2011.

SOURCES, CONTROL DEVICES AND EMISSIONS

The following potential to emit estimates are based upon each source' s fuel usage at its rated heat input capacity and AP-42 emission factors and 8,760 hours of operation except for S02 emissions. S02 emissions were calculated based upon a facility wide annual fuel oil consumption limit of 500,000 gallons in any consecutive 12 month period. Without this limit, the hospital would be a Title V facility based on its potential to emit S02 according to AP-42 emission factors and a sulfur content of0.5%. Emissions of other pollutants besides S02 for fuel burning sources were based upon burning natural gas. The emergency generator emissions were considered to be negligible based upon the 500 hours of operation in any consecutive 12 month period limitation.

Emissions from the Ethylene Oxide Sterilizers/ Aerators were taken directly from the UH' s Subpart WWWWW Initial Notification of Compliance Status from November 2009. We do not have any reason to believe that these reported emissions do not represent the typical annual usage of ethylene oxide at the hospital. The emissions calculations are presented in Table 1 below:

Table 1 - UH Potential To Emit

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

Cleaver Brooks Boiler - Source #031 17.3 14.5 1.3 0.9 -Burnham 14.6 mmbtu/hr Boiler - Source

6.1 5.2 17.8 0.5 0.3 -

#032 combined

Burnham 6.2 mmbtu/hr Boiler - Source all 3 units -#035

2.6 2.2 0.2 0.1

EO Sterlizer/Aerator - Source #033 - - - - - 27.8 EO Sterilizer/ Aerator - Source #034 - - - - - 27.8 TOTALS 26.3 21.9 17.8 2.0 1.3 55.6

* EO = Ethylene Oxide, in Pounds Per Year

REGULATORY ANALYSIS

There are no new regulatory requirements which apply to the combustion 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.

There are no applicable New Source Performance Standards. 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 mmbtu/hr but only those that commenced construction after June 9, 1989. Therefore, the applicable requirements from Subpart De apply only to the Burnham 14.6 mmbtu/hr boiler, Source #032. These requirements have already been included in the previous version of the operating permit.

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, promulgated on December 28, 2007, 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 were incorporated into the permit during the November 2009 administrative amendment.

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 ofUH's operating permit renewal application. UH 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.