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 PointsPost-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/