COMMONWEALTH OF PENNSYLVANIA Department of Environmental Protection Southwest Regional Office

TO:

FROM:

Air Quality File OP-32-00197 (\ }

Nicholas J. Waryanka, P.E. ~ ~ tW

OFFIOlAL FilE COPY

MEMO

THROUGH:

Air Quality Engineer 1

/ V v Air Quality

Barbara Hatch, P.E. /J () « Environmental Engin~n~ger Air Quality

M~~r, PE

DATE:

RE:

January 23, 2014

Regional Manager Air Quality

Synthetic Minor OP Renewal Application OP-32-00 197 Purchase Line School District Purchase Line Junior/Senior High Schools Greene Township, Indiana County APS 707265 AUTH 813941 PF 516181

BACKGROUND

The Department received a synthetic minor renewal Operating Permit application on November 16, 2009 Purchase Line School District (PLSD) for the Purchase Line Junior/Senior High Schools (PLJSHS) in Greene Township, Indiana County. The school is located on rural Route 286 approximately 10 miles northeast of Indiana, Pa. and about halfway between Route 119 north and Route 219 north. The SIC and NAICS Codes for elementary and secondary schools are 8211 and 611110, respectively .

The school operates two (2) Kewanee coal-fired boilers for heating purposes. Source #031 is designated Boiler #2 at the school and is a model #NB 7L90 unit installed in 1954. Source #032 is Boiler# 1 and the same vintage as Source #031. The boilers are rated at 12.0 mmbtu/hr and are never fired simultaneously such that one is always serving in a backup capacity. The boilers are tri­fuel units but are only set up to bum coal.

Both units are equipped with fly ash separator particulate matter control devices manufactured by Auburn Corp. , model #29-IDS-HR, which were installed in July 2009 and are alleged to provide 84% capture efficiency. Additional equipment installed in 2009 include induced draft fans , opacity monitors, furnace draft controls, separate boiler stacks for each unit, overfire air interlock controls based on opacity, and fly ash collector differential pressure gauges.

There is also an emergency generator, Source # 101 , at the school for providing emergency electric power. This unit is a diesel-fired, Kohler model #400 Redzb unit with a rated power output of 400 Kilo Volt Amperes (kVA) or 320 Kilo Watts (kW). The generator was constructed in June 2003 and is rated at 602 horsepower (HP) at 1,800 revolutions per minute (RPM) according to Department inspection reports.

The application was originally found to be administratively deficient on January 13, 2010 for not being signed by a legitimate responsible official, failure to provide potential emissions estimates, and additional shortcomings. The application was revised and the missing information submitted on February 2, 2010. The application was then deemed administratively complete on March 4, 2010. The previous operating permit was issued on May 31 , 2005 and expired on May 31 , 2010.

SOURCES, CONTROL DEVICES AND EMISSIONS

The boilers are limited to 2,150 tons of coal usage per year as a means of maintaining this facility as a synthetic minor although the district generally only burns about 500 tons per year. The operating permit also restricts the coal sulfur content to 2.3% by weight and the ash content to 10%. The maximum theoretical amount of coal that can be consumed by both boilers operating simultaneously for 8, 760 hours per year is 8,410 tons which would make the school a Title V facility for S02. Using AP-42 Section 1.1 Bituminous and Subbituminous Coal Combustion in External Combustion Sources emission factors for underfeed stokers, the potential to emit (PTE) S02 for the boilers is only 76.6 tons per year when limiting annual coal usage to 2,150 tons. Emissions of the other criteria pollutants are less than 10 tons per year. The fly ash separators on the boilers reduce particulate emissions by 84% according to PLSD ' s consultant, The Boyer Partnership, Inc. PTE for the boilers based on burning 2,150 tons of coal per year is presented below in Table 1 :

Table 1- Potential To Emit for Sources #031 & #032 Based on Annual Coal Usage of 2,150 tpy

Pollutant PTE in tpy

NOx 10.2 co 11.8

TNMOC* 1.4 so2 76.6 PM 2.8®

* TNMOC ="Total Non-Methane Organtc Compounds" @ Based on 84% control efficiency by fly ash separators

Considering that the emergency generator will be limited to 500 operating hours per calendar year, emissions are considered negligible. The unit is test-fired for one half hour each week to ensure proper operation.

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REGULATORY ANALYSIS

There are several new regulatory requirements which were evaluated for applicability to this facility. There is a recently promulgated National Emission Standards for Hazardous Air Pollutants (NESHAPs) standard which potentially could apply to PLJSHS. 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 1 0 mmbtu/hr but only those that commenced construction after June 9, 1989. Both of the units at this facility have heat input ratings less than 1 0 mmbtu/hr.

40 CFR 63 , Subpart JJJJJJ, NESHAPs for Industrial, Commercial, and Institutional Boilers Area Sources applies to almost any area source boiler that is not defined in this subpart as a "gas-fired boiler" in accordance with 40 CFR §63.11195(e). "Gas-fired boiler" is defined in 40 CFR §63.11237 as including "any boiler that burns gaseous fuels not combined with any solid fuels and burns liquid fuel only during periods of gas curtailment, gas supply interruption, startups, or periodic testing on liquid fuel. Periodic testing of liquid fuel shall not exceed a combined total of 48 hours during any calendar year." Although these are tri-fuel boilers, they burn coal exclusively and thus are subject to Subpart JJJJJJ.

Notification of Subpart JJJJJJ applicability was due to the US EPA as well as the Department on January 20, 2014. The PLSD permit contact has been informed of this notification requirement. Because these are coal-fired boilers with heat input capacities of greater than 10 mmbtu/hr, there are quite a few requirements for these affected units under Subpart JJJJJJ . Some of the more notable requirements include the following:

• Mercury emission limit of 2.2E-05 lb per mmbtu of heat input • Carbon monoxide (CO) emission limit of 420 parts per million by volume on a dry basis

corrected to 3 percent oxygen • Minimization of boiler startup and shutdown periods according to manufacturer' s recommended

procedures • Performance of a tune-ups biennially or every 5 years for boilers with oxygen trim systems that

maintain optimum air-to-fuel ratio • Performance of a one-time energy assessment on boilers performed by a qualified energy

assessor • Maintain boiler stack opacity to less than or equal to 10 percent (daily block average) • Install, operate, certify and maintain a continuous opacity monitoring system • Install, calibrate, operate, and maintain an oxygen analyzer system as defined in §63 .11237 and

operate it at or above the minimum oxygen level established as the operating limit during the most recent CO performance stack test

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• Performance of periodic stack testing for carbon monoxide and fuel analysis requirements for mercury content

• Maintain fuel type or fuel mixture (annual average) such that the mercury emission rate calculated in accordance with Subpart JJJJJJ is less than the applicable emission limit for mercury

There are also associated recordkeeping, reporting, and additional notification requirements as well and these have been incorporated into the renewal operating permit.

Table 2 of Subpart JJJJJJ requires tune-ups every five (5) years for existing coal-fired boilers with an oxygen trim system that maintains an optimum air-to-fuel ration that would otherwise be subject to a biennial tune-up. §63.11237 defines oxygen trim system as "a system of monitors that is used to maintain excess air at the desired level in a combustion device. A typical system consists of a flue gas oxygen and/or carbon monoxide monitor that automatically provides a feedback signal to the combustion air controller." Since this definition describes a typical oxygen trim system as having oxygen and/or carbon monoxide monitors, it does not exclude systems that use opacity monitor feedback as a means of controlling the amount of excess air delivered to the boiler' s combustion chamber. Therefore, we believe these units are subject to tune-ups every five years as opposed to biennially.

Notable SIP standards which apply include 25 Pa. Code §123.11 - 0.4 lb PM/mmbtu, § 123.22-4 lb S02/mmbtu, and the malodor provisions of§ 123.31. 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.

The emergency generator is subject to the particulate matter and S02 emission standards of 25 Pa. Code § 123 .13( c) and § 123.21 , respectively, as well as the malodor and § 123.41 opacity standards. Annual fuel usage records are required to be kept. Records of hours of operation for the emergency generator must also be maintained.

CONCLUSIONS AND RECOMMENDATIONS

I have completed my review ofPLSD' s Synthetic Minor renewal application for the PLJSHS. PLSD 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 facility for a five (5) year permit term.

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