Managing Environmental Issues with Hospital Expansion Projects

Tank, Generator, and Boiler Installations from an Environmental Permitting Perspective

Chris C. Maye, P.E.Manager, Environmental Services

Case Study – CUP Expansion Plan

• Generator Installation: 4 months– 2 1,500-kW Generators (Diesel)– 1 2,000-kW Generator (Diesel)

• Boiler Installation: 5 months– 4 Dual Fuel, ~29 MMBTU/Hr (700 bhp) each

• Fuel Oil Tanks Installation: 4 months– 1 30,000-gallon Diesel Tank (EGENS)– 1 20,000-gallon #2 Fuel Oil Tank (Boilers)

Generators• Typical diesel-fired, 300-2,000 kW

• Equipment: Engine and Tank

• Applicable Regulatory Considerations: – Air Permitting– Tank Permitting– Spill Prevention

Generators - Air Requirements

• Federal Requirements (MACT/NSPS)– Need Manufacturer Specifications (EPA Certified Engine,

Emission Rates, Horsepower rating, fuel source, etc.)– Emission standards and hour limitations depend on use of

unit (emergency, peak shaving, demand response, etc.)

• State Requirements – Air Emission Limitations

• Only applies to engines rated at greater than 1,000 horsepower and located in Bucks, Chester, Delaware, Montgomery or Philadelphia County

– Tank Requirements

Generators – PA Air Permitting

• Permit Exemption/Request for Determination: Allows installation without a permit– Time to Decision: ~10-14 days– Applicable if site wide actual NOx emissions below exemption

thresholds

• General Permit (GP-9)– Time to Approval: ~30 days– Stack Testing required for engines of certain size

• Plan Approval– Time to Issuance: ~3-6 months– No real limitations; Emission standards apply, other

requirements negotiable

Tanks

• Tank Permitting: Depending on size (>1,100 gallons), “belly” tanks or standalone may require tank registration under DEP’s Storage Tank Program.– Registration – Site-Specific Installation Permit

(larger tanks)

• Spill Planning– Site likely needs to update existing Oil Spill Prevention, Control,

and Countermeasure (SPCC) Plan– If Site has >21,000 gallons of registered storage, Spill

Prevention and Response (SPR) Plan Required prior to submission of application.

Generators and Tanks – Case Study

• In order to meet the construction deadline:– RFD filed for new generators (approved in 15 days)– SSIP for 30,000-gallon Diesel Tank

• Application: 4 weeks to prepare

• Approval: 3 months from submittal

– SPCC/SPR (includes existing and boiler tank installation) updated as well.

Boiler Installations

• Typical Unit: dual-fuel (natural gas with (fuel oil backup) 10-50 MMBTU/Hr

• Equipment: Burner and Tank

• Applicable Regulatory Considerations – Air Permitting– Tank Permitting– Spill Prevention

Boiler Regulations

• Federal– New Source Performance

Standards– National Emissions Standards for

Hazardous Air Pollutants– Oil Spill Prevention

• State– Emission Limitations– Tank Requirements

Boiler Air Issues

• Need Manufacturer Data (Emission Rates, etc.)

• Air Permitting (PA): 2 options– General Permit (GP-1)

• Time to Issuance: ~30 days• Potential to Emit must below major source thresholds

– Plan Approval• Time to Issuance: ~3-6 months• No real limitations; can be used only for the operation

of a boiler on fuel oil.

Boilers – Case Study• To meet construction timeline, Air Permitting

performed included:– Obtain Coverage under General Permit (GP-1)

for natural gas only: Approval allowed construction to begin 3 weeks after submittal

– Simultaneously file Plan Approval for firing #2 fuel oil: Approval received 5 months after filing

• After units installed, need to:– Stack Test (GP-1 Condition)– Consolidate into an Operating Permit– Prepare regulatory notifications under applicable rules

• No Tank Permitting Required• SPCC Plan required updating

Boiler Tank Issues

• Tank Permitting:– For aboveground tanks:

Not applicable for #2 Fuel Oil ASTs based on exemption for on-site consumptive use of non-motor fuel in tanks <30,000 gallons.

– For underground tanks: Not applicable for #2 Fuel Oil USTs based on exemption for on-site consumptive use of “heating oil.”

Case Study - Results• ON-TIME: Each authorization was obtained on-time,

causing no construction delays for environmental issues

• RIGHT EQUIPMENT: Proper instrumentation for fuel consumption communicated and verified early in design.

• RIGHT SETTING: Tank construction and fuel unloading area design reviewed and confirmed compliant prior to start of project

• STILL WORK TO DO: Additional Follow-up still pending (stack testing, air permit consolidation, etc.)

• COMMUNICATION! Frequent and clear communication of when the facility could install/use equipment critical to maintaining compliance

Case Study - Conundrum

• Why Communication on Approval Status is essential!

– Month 2 after applications were filed, approval status was such that:

• Generators could be run, but no fuel could be added to supply tank

• On #2 Fuel Oil, the boilers could not be run, but fuel could be added to supply tank

Lessons Learned/Key Points Pre-Construction

• PLAN AHEAD: Get detailed equipment and installation information as early as possible

• MONITORING = INSTRUMENTATION: Know what monitoring/recordkeeping will be required to ensure proper instrumentation (fuel consumption, etc.) are part of the project design.

• GET THE RIGHT SUBS: If tanks require registrations, ensure certified tank installers are part of the construction team.

• COMMUNICATION: Ensure timing is communicated so that environmental permitting does not slow you down and compliance is maintained.

Lessons Learned/Key Points Post-Construction

• NEW EQUIPMENT = NEW RECORDS: New Air Quality Emissions, Fuel, and Hours of Operation Recordkeeping must be addressed.

• NEW RULES = NEW RECORDS & REPORTS: New Standards (Boiler Area Source MACT, RICE MACT/NSPS) may require additional recordkeeping, notifications, and reporting.

• UPDATE EXISTING INSPECTIONS: Spill Planning Document Updates will include additional inspection requirements once units are installed.

References

• DEP Generator Tank Registration:– http://files.dep.state.pa.us/

EnvironmentalCleanupBrownfields/StorageTanks/StorageTanksPortalFiles/Emergency%20Generator%20Tanks.ppt

• DEP Air Quality General Permits:– http://www.dep.state.pa.us/dep/deputate/AIRWASTE/

AQ/permits/gp.htm

• EPA Generator MACT Air Standard:– http://www.epa.gov/ttn/atw/rice/ricepg.html

• EPA Area Source Boiler NESHAP Standard:– http://www.epa.gov/boilercompliance/