1. Healthcare and Air Quality H2E Conference - Dec 6, 2007 K-State Pollution Prevention Institute Ryan Hamel

2. K-State SBEAP K-State University Engineering Extension Pollution Prevention Institute (PPI) Small Business Environmental Assistance Program (SBEAP) Similar program in every state - reqd by Clean Air Act Provides air-focused technical assistance to small- and medium-sized businesses –Permitting and reporting requirements –Regulatory compliance –Emissions/waste reduction

3. K-State SBEAP Services Environmental hotline (800.578.8898) On-site visits Targeted regulatory or industry-specific workshops Publications (hard copy or electronic) Fact sheets, manuals, E-tips Web-based resources and training: www.sbeap.org www.sbeap.org Funded by KDHE

4. Potential-to-emit (PTE) Air regulations (healthcare-related) Boilers Emergency generators Ethylene oxide sterilizers Changes to emission sources Presentation Overview

5. Potential to Emit (PTE) Represents the sources maximum capacity or worst case scenario emissions The maximum amount of air pollution your facility can emit if: –Each process operated at 100% of its capacity –All equipment is operating 24/7 (8,760 hrs/yr) –Materials that emit the most air pollution are processed 100% of the time –No pollution control equipment is used

6. Calculating PTE Calculation methods –Emission factors –Material balances –Other approved methods Computer programs Industry-specific emission factors Approved by KDHE on an individual basis

7. PTE Emission factors –Manufacturers emission factors are best –AP-42 is a compilation of factors for specific processes accepted by EPA www.epa.gov/ttn/chief/ap42/index.html –Emission factors software and tools www.epa.gov/ttn/chief/efpac/efsoftware.html

8. PTE Material balance –Product in = product out (assumes constant inventory) –Product in can be the purchased material –Product out can be the emissions –Material balance can be applied to individual units or the whole process

9. Air regulations KAQA Standards –Air construction approval/permit –Operating permit NSPS (New Source Performance Standards) PSD (Prevention of Significant Deterioration) NESHAP (National emission standard for hazardous air pollutants) / MACT (Maximum achievable control technology)

10. Permitting Web site www.kdheks.gov/air-permit/download.html Includes forms for: Construction approvals Construction permits Operating permits (Class I and II) Emergency generators Boilers (available Feb. 20)

11. Construction Approval If your PTE exceeds these thresholds, then youll need a construction approval: Source: What is the Kansas Air Quality Act? - www.sbeap.org/publications/airqual.pdf

12. Construction Permit If your PTE exceeds these thresholds, then youll need a construction permit: Source: What is the Kansas Air Quality Act? - www.sbeap.org/publications/airqual.pdf

13. Operating Permit (Class I) Required if PTE exceeds these thresholds: –100 tons per year NOx, SOx, PM10, VOC, CO –10 tons per year of any single hazardous air pollutant (HAP) –25 tons per year of combined HAPs

14. Operating Permit (Class II) If actual emissions are below the Class I thresholds but PTE is above – then limit PTE and apply for a Class II operating permit A Class II permit requires minimal record keeping and is simpler (and cheaper) than maintaining a Class I permit Class II permit-by-rule (KAR 28-19-561-564)

15. Operating Permit (Class II) Limit PTE by –Implementing pollution prevention Change the material Change the process Change the technology –Limiting process rate –Limiting hours of operation –Limiting amount of material processes –Installation of a pollution control device

16. Small Boiler NSPS NSPS = New Source Performance Standards –40 CFR 60.42 subpart Dc –Installed or modified after June 9, 1989 –Heat input capacity is between 10 and 100 MMBTU/hr

17. Subject to NSPS? The heat input capacity of the boiler is between 10 and 100 MMBtu/hr The boiler was constructed, modified, or reconstructed after June 9, 1989 The boiler is not subject to NSPS requirements Yes No Complete the KDHE boiler form Yes The heat input capacity is less than 10 MMBtu/hr Heat input capacity is greater than 100 MMBtu/hr, subject to large boiler NSPS requirements No

18. NSPS (continued) Regulates NOx, SOx, and PM (for boilers firing coal, distillate and residual oil, and wood). Dictates recordkeeping requirements for all fuels, including natural gas. One way to comply: limit the weight percent sulfur of the fuel to 0.5% or less KDHE will have application form for small boilers

19. PSD PSD = Prevention of Significant Deterioration K.A.R. 28-19-350 or 40 CFR 52.21 PSD affects: –New major sources or major modifications –Those located in an attainment or unclassified area Requirements include installation of best available control technology (BACT), analyses, etc.

20. NESHAP and MACT Apply to sources of HAPs (hazardous air pollutants) Approximately 188 HAPs Known or suspected to cause cancer or other serious health affects NESHAP (National Emission Standards for Hazardous Air Pollutants) are health-based standards MACT (Maximum Achievable Control Technology) are technology-based standards

21. NESHAP and MACT Examples: –Medical waste incinerators –Perchloroethylene from dry cleaners –Halogenated solvent vapor degreasers Not currently aware of future MACT rules applicable to hospitals, this could change

22. Penalty Violations Source: www.kdheks.gov/air-permit/forms/Air_Enforcement_Policy_7_20_05.pdf

23. Evaluating permit need (boilers) Identify for all boilers: –Date of installation or modification –Heat input capacity (typically in MMBTU/hour) –Type of fuel (natural gas, fuel oil, etc) –Low NO X burner (for natural gas-fired boilers)

24. Evaluating permit need (boilers) Use information (from previous slide) Use AP-42 emission factors –http://www.epa.gov/ttn/chief/ap42/ch03/index.htmlhttp://www.epa.gov/ttn/chief/ap42/ch03/index.html Emissions can be estimated with this info Affected facilities must submit form by June 30, 2008 If assistance is needed, contact SBEAP

25. Emergency generators Emergency generator definition –Used only for back-up power (not to offset peak energy usage) –For PTE calculations, assume 500 hours/year All emergency generators should be registered with KDHE Expedited form available

26. Expedited form Source: www.kdheks.gov/air-permit/forms/Emergency_Gen_App.pdf

27. Ethylene oxide sterilizers Does anyone have one? Used to sterilize heat- and moisture- sensitive products Increase regulatory requirements (NESHAP) Contact SBEAP for further assistance

28. Future Additions or Modifications Evaluate PTE for new or modified eqpmt. If PTE exceeds construction approval or permit thresholds, contact KDHE –Thresholds: www.sbeap.org/publications/airqual.pdf –Forms: www.kdheks.gov/air-permit/download.html Boiler between 10 and 100 MMBTU/hr, complete the KDHE NSPS Boiler form

29. Questions or Comments? Contact Information Ryan Hamel K-State Pollution Prevention Institute 800.578.8898 or 785.532.4994 rhamel@ksu.edu www.sbeap.org