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) 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: – wnfields/StorageTanks/StorageTanksPortalFiles/Eme rgency%20Generator%20Tanks.ppthttp://files.dep.state.pa.us/EnvironmentalCleanupBro wnfields/StorageTanks/StorageTanksPortalFiles/Eme rgency%20Generator%20Tanks.ppt DEP Air Quality General Permits: – AQ/permits/gp.htmhttp:// AQ/permits/gp.htm EPA Generator MACT Air Standard: – EPA Area Source Boiler NESHAP Standard: –