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HomeMy WebLinkAboutAQ_F_1300005_20220623_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Atrium Health Cabarrus NC Facility ID 1300005 Inspection Report County/FIPS: Cabarrus/025 Date: 06/21/2022 Facility Data Permit Data Atrium Health Cabarrus Permit 03570/R22 920 Church Street North Issued 7/20/2020 Concord,NC 28025 Expires 1/31/2023 Lat: 35d 26.3582m Long: 80d 35.9749m Class/Status Synthetic Minor SIC: 8062/General Medical& Surgical Hospitals Permit Status Active NAILS: 62211 /General Medical and Surgical Hospitals Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Greg Mackin Gene Monago Greg Mackin MACT Part 63: Subpart ZZZZ Plant Operations VP of Facilities Mgmt Plant Operations NSPS: Subpart Dc, Subpart IIII Support Services (704) 667-9461 Support Services 704 996-4740 704 996-4740 Compliance Data Comments: Inspection Date 06/21/2022 Inspector's Name Joe Foutz O eratin Status O eratin Inspector's Signature: . E. FO l L 1� Compliance Status Compliance-inspection Action Code FCE Inspection Result Compliance Date of Signature: 06/23/2022 Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 * HAP 2013 0.7500 0.0600 13.52 0.5600 7.50 0.7500 259.00 2009 0.7100 1.33 14.05 0.6700 7.13 0.7100 231.00 * Highest HAP Emitted in ounds Five Year Violation History:None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested Atrium Health Cabarrus June 21,2022 Page-2— Type Action: X Full Compliance _Partial Compliance _Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Date submitted for initial review 06/23/2022 _IBEAM WARNING/OB,NOD,NOV,NRE Tracking: X IBEAM Document X IBEAM Inspection,list date inspected X IBEAM LAT/LONG,Facility Locked X IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates checked X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint X IBEAM Planning,Next Inspection Date 06/01/2023 Directions: Travel to Highway 73 and take I-85 North to Exit 58 for Kannapolis/Concord and US 601 South. Follow US 601 South for approximately'/2 mile. Turn left onto Mall Dr NE. After a short distance(approx 100 feet)the road forks,bear right onto Medical Park Dr NE. The Energy Center is located at the corner of Medical Park Dr.NE and Lake Concord Rd NE. All the permitted equipment is located in the hospital's Energy Center. The Facility Contact is located in Charlotte so it is recommended to make contact with the Facility Contact prior to arriving at the facility. Safety Equipment: No specific requirements for safety equipment. Safety Issues: No safety issues were noted by me during the inspection. Lat/Long: A review of the facility's coordinates on"Maps of DAQ Regulated Facilities" indicates the facility's latitude and longitude coordinates are accurate and are locked in IBEAM. Email Contacts: Email contacts found in IBEAM were verified.No changes to email address are needed at this time. However,the mailing address has changed. See Section 2.below for changes. 1. The purpose of this site visit was to conduct a routine air quality inspection of Atrium Health Cabarrus. I arrived at the facility on June 21,2022 at approximately 10:00 am. Atrium Health Cabarrus is a hospital that utilizes four steam boilers for heating, food processing, and sterilization(non ethylene oxide) purposes; and five emergency generators. Mr. Greg Mackin,Plant Operations Support Services, and Mr. David Rhodes,Energy Plant Operator, accompanied me during this inspection. 2. Facility Contact Information: During the inspection I verified the facility contact information in IBEAM. The address for the Facility Contact and Technical Contact,Mr. Greg Mackin,has changed to 9401 Arrowpoint Blvd, Charlotte,NC 28273. 1 made the change in IBeam. 3. Compliance history file review: MRO issued a NOD to this facility on August 18,2017 for late reporting. Atrium Health Cabarrus June 21,2022 Page- 3- 4. Observations of permitted air emission sources and control devices: Emission Emission Source 6W Source ID Description B I (NSPS), four(4)natural gas/No. 2 fuel oil-fired boilers B2 (NSPS), (14.6 mmBtu/hr maximum heat input, each) B3 (NSPS), B4 (NSPS) Observed. Mr. Rhodes stated the typical operating procedure is to have one boiler operating while one boiler is on standby. The standby boiler fluctuates between 100°F and 300°F. The 2 remaining boilers are not operated and the facility refers to the boilers as"in wet layup". Boiler B3 was operating during the inspection and was combusting natural gas. Boiler B4 was in standby mode. Boilers B 1 and B2 were not operating(ie, in wet layup). The exhaust for all four boilers are connected to a single stack. I observed no visible emissions from the stack. Below is information regarding each boiler's National Board number. Boiler B 1 -National Board#44089 Boiler B2 -National Board#44110 Boiler B3 -National Board#44094 Boiler B4-National Board#48755 Emission Emission Source Source ID Description 11 diesel-fired emergency generator(2,500 kilowatts rated capacity) (NSPS,NESHAP) Observed.Mr.Mackin stated the generator is for emergency use only. The generator typically operates 30 minutes per month for maintenance purposes. This generator was not in operation during the inspection. The facility refers to this generator as Generator No. 3. The hour meter readings are shown below. August 30,2021 —460.8 hours June 21,2022—475.7 hours Total since the last air quality inspection is 14.9 hours. Atrium Health Cabarrus June 21,2022 Page-4— Emission Emission Source Source ID Description 12 diesel-fired emergency generator(2,500 kilowatts rated capacity) (NSPS,NESHAP) Observed.Mr.Mackin stated the generator is for emergency use only. The generator typically operates 30 minutes per month for maintenance purposes. This generator was not in operation during the inspection. The facility refers to this generator as Generator No. 4. The hour meter readings are shown below. August 30,2021 —398.3 hours June 21,2022—414.7 hours Total since the last air quality inspection is 16.4 hours Emission Emission Source Source ID Description 13 diesel-fired emergency generator(3,000 kilowatts rated capacity) (NSPS,NESHAP) Observed.Mr.Mackin stated the generator is for emergency use only. The generator typically operates 30 minutes per month for maintenance purposes. This generator was not in operation during the inspection. The facility refers to this generator as Generator No. 5. The hour meter readings are shown below. August 30,2021 —534.3 hours June 21,2022—556.7 hours Total since the last air quality inspection is 22.4 hours Emission Emission Source Source ID Description 14 diesel-fired emergency generator(3,000 kilowatts rated capacity) (NSPS,NESHAP) Observed.Mr. Mackin stated the generator is for emergency use only. The generator typically operates 30 minutes per month for maintenance purposes. This generator was not in operation during the inspection. The facility refers to this generator as Generator No. 6. The hour meter readings are shown below. August 30,2021 —512.0 hours June 21,2022—526.4 hours Total since the last air quality inspection is 14.4 hours Atrium Health Cabarrus June 21,2022 Page- 5— Emission Emission Source Source ID Description 15 (NSPS,NESHAP) diesel-fired emergency generator(3,000 kilowatts rated capacity) Observed.Mr.Mackin stated the generator is for emergency use only. The generator typically operates 30 minutes per month for maintenance purposes. This generator was not in operation during the inspection. The facility refers to this generator as Generator No. 7. The hour meter readings are shown below. August 30,2021 —205.5 hours June 21,2022—227.2 hours Total since the last air quality inspection is 21.7 hours 5. Observations of insignificant air emission sources and control devices listed on the current permit: Source ID I Source I Observations I14 Diesel-fired fire pump engine Did not observe. The fire pump is not subject to NESHAP Subpart (251 hp rated capacity) ZZZZ because it is an existing emergency unit located at institutional facility. IES-25 Diesel fuel aboveground storage This tank stores the diesel fuel for the boilers and emergency tank(30,000 gallons capacity) generators. The tank is located outside of the Energy Center. IES-26 Diesel fuel aboveground storage This tank stores the diesel fuel for the boilers and emergency tank(30,000 gallons capacity) Igenerators. The tank is located outside of the Energy Center. IES-30 Diesel fuel aboveground day tank (150 gallons capacity) This tank is the day tank for the boilers. IES-38 Diesel fuel aboveground storage This tank is the day tank for generators 11 and 12. tank(200 gallon capacity) IES-39 Diesel fuel aboveground storage This tank is the day tank for generators 11 and 12. tank(200 gallon capacity) IES-40 Diesel fuel aboveground storage This tank is the day tank for generators 13, 14, and 15. tank(275 gallons capacity) IES-41 Diesel fuel aboveground storage This tank is the day tank for generators 13, 14, and 15. tank(275 gallons capacity) IES-42 Diesel fuel aboveground storage This tank stores the diesel fuel for the boilers and emergency tank(30,000 gallons capacity) Igenerators. The tank is located outside of the Energy Center. IES-43 Diesel fuel aboveground storage This tank is the day tank for generators 13, 14, and 15. tank(275 gallons capacity) IES-44 Diesel fuel aboveground storage This tank stores the diesel fuel for the boilers and emergency tank(30,000 gallons capacity) Igenerators. The tank is located outside of the Energy Center. 6. Observations of air emission sources and control devices not listed on the current permit: None noted. Atrium Health Cabarrus June 21,2022 Page- 6— 7. Compliance with specific permit conditions and limitations: a. Condition A.2. 15A NCAC 2D .0202 "Permit Renewal and Emission Inventory Requirement"The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter. The report shall be submitted to the Regional Supervisor,DAQ and shall document air pollutants emitted for the 2021 calendar year. Observed. The current permit expires 01/31/2023. 1 discussed the renewal process with Mr. Mackin. Compliance is indicated. b. Condition A.3. 15A NCAC 2D .0503 "Particulates from Fuel Burning Indirect Heat Exchangers". Particulate matter emissions from the fuel burning indirect heat exchangers shall not exceed the allowable emission rates listed below: Source Source Description Emission Limit ID No. (lbs/million Btu) B1 natural gas/No. 2 fuel oil-fired boiler 0.38 14.6 mmBtu/hr maximum heat input) 132 natural gas/No. 2 fuel oil-fired boiler 0.38 14.6 mmBtu/hr maximum heat input) 133 natural gas/No. 2 fuel oil-fired boiler 0.38 14.6 mmBtu/hr maximum heat in ut B4 natural gas/No. 2 fuel oil-fired boiler 0.38 14.6 mmBtu/hr maximum heat inputt))t Observed. The particulate matter emissions from the four boilers are not exceeding the allowable emission rates. Compliance with this stipulation was indicated during the permit application process. c. Condition A.4. 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources". Sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input. Observed. Per MRO memo"21) .0516 analysis"dated 04/10/97, compliance is indicated for No. 1 fuel oil,No. 2 fuel oil,natural gas,butane,propane, and wood dust. d. Condition A.5. 15A NCAC 2D .0521 "Control of Visible Emissions". Visible emissions from the emission sources, shall not be more than 20 percent opacity. Observed.I observed no visible emissions from the sources that were operating during the inspection. Compliance is indicated. e. Condition A.6. 15A NCAC 2D .0524"New Source Performance Standards." For natural gas/No. 2 fuel oil-fired boilers(ID Nos. B1,B2,B3, and B4),the Permittee shall comply with all applicable provisions, including the notification,testing,reporting,recordkeeping, and monitoring requirements contained in 15A NCAC 2D .0524 -NSPS Subpart Dc. NSPS Reporting Requirements -In addition to any other notification requirements to the EPA, the Permittee is required to NOTIFY the Regional Supervisor,DAQ, in WRITING, of the following: Atrium Health Cabarrus June 21,2022 Page- 7— i. The sulfur content of the distillate oil combusted in an affected source shall not exceed 0.5 percent by weight. Within 30 days after each six-month period of the calendar year,the Permittee must submit in writing to the Regional Supervisor,DAQ,the sulfur content of the distillate oil combusted in an affected source. NSPS Recordkeeping Requirements -In addition to any other recordkeeping requirements of the EPA,the Permittee is required to maintain records as follows: i. The amounts of each fuel combusted during each month; and ii. All records required under this section shall be maintained for a period of two years following the date of such record. NSPS Emissions Limitations -As required by 15A NCAC 2D .0524,the following permit limits shall not be exceeded: Affected ollutant Emission Limit natural gas/No. 2 fuel oil-fired boiler(14.6 mmBtu/hr)(BI)ISulfur content 10.5%by weight natural gas/No. 2 fuel oil-fired boiler(14.6 mmBtu/hr)(132) Sulfur content 0.5%by weight natural gas/No. 2 fuel oil-fired boiler(14.6 mmBtu/hr)(133)JSulfur content 10.5%by weight natural gas/No. 2 fuel oil-fired boiler(14.6 mmBtu/hr)(134) Sulfur content 0.5%by weight Observed. Records of the natural gas and No.2 fuel oil combusted in the four boilers are being kept. The boilers generally combust natural gas. The boilers combust fuel oil primarily for testing and maintenance purposes and typically combust less than 100 gallons of fuel oil in each boiler. Mr. Mackin stated the facility has not been curtailed off natural gas since 2015. From January 1,2022 through May 2022 the boilers have combusted a combined total of 58 gallons of fuel oil. Mr. Mackin stated since they have large storage tanks for fuel oil then they have not purchased any fuel oil in over 2 years. The facility submitted reports on July 19,2021 and January 30,2022. Compliance is indicated. f. Condition A.7. 15A NCAC 2D .0524 "New Source Performance Standards". For the following equipment, The Permittee shall comply with all applicable provisions, including the notification, testing,reporting,recordkeeping,and monitoring requirements contained in Environmental Management Commission Standard NSPS Subpart IIII. gulatio. Diesel-fired emergency generators 40 CFR 60, Subpart IIII (ID Nos. 11' 12 13 14 and 15) "Standards of Performance for Stationary FC mpression Ignition Internal Combustion Engines(CI ICE)" 1. Emission Standards: i. The Permittee shall operate and maintain stationary CI ICE that achieves the emission standards as required in 60.4205 over the entire life of the engine. ii. For the 2007 model year and later emergency stationary Cl ICE with a displacement of less than 30 liters per cylinder that are not fire pump engines,the Permittee shall Atrium Health Cabarrus June 21,2022 Page- 8— comply with the emission standards for new nonroad Cl engines in 40 CFR 60.4202, for all pollutants, for the same model year and maximum engine power. [60.4205(b)] 2. Fuel Requirements: i. Engines subject to this subpart with a displacement of less than 30 liters per cylinder that use diesel fuel shall use diesel fuel that meets the requirements of 40 CFR 80.510(b) for nonroad diesel fuel, as listed below: A. Has a maximum sulfur content of 15 ppm [40 CFR 80.510(b)]; and B. Has a minimum cetane index of 40 or a maximum aromatic content of 35 volume percent. [40 CFR 80.510(b)] 3. Monitoring Requirements: For the emergency stationary CI ICE that does not meet the standards applicable to non-emergency engines,the Permittee shall install a non-resettable hour meter prior to startup of the engine. [60.4209(a)] 4. Compliance Requirements: i. The Permittee shall comply by purchasing an engine certified to the emission standards in 40 CFR 60.4204(b),or 4205(b)or(c),as applicable, for the same model year and maximum(or in the case of fire pumps,NFPA nameplate)engine power. The engine shall be installed and configured according to the manufacturer's emission-related specifications, except as permitted in 40 CFR 60.421 l(g). If the Permittee changes emission-related settings in a way that is not permitted by the manufacturer,the Permittee shall demonstrate compliance per the requirements of 40 CFR 60.4211(g). [60.4211(g)] ii. The Permittee shall operate the emergency stationary ICE according to the requirements NSPS Subpart IIII. In order for the engine to be considered an emergency stationary ICE under NSPS Subpart 1111, any operation other than emergency operation,maintenance and testing,and operation in non-emergency situations for 50 hours per year, as described in NSPS Subpart 111I, is prohibited. If the Permittee does not operate the engine according to the requirements in NSPS Subpart IIII,the engine will not be considered an emergency engine under this subpart and shall meet all requirements for non-emergency engines. 5. Recordkeeping Requirements: i. If the stationary Cl ICE is equipped with a diesel particulate filter,the Permittee shall keep records of any corrective action taken after the backpressure monitor has notified the Permittee that the high backpressure limit of the engine is approached. [60.4214(c)] ii. All records required under this section shall be maintained for a period of two(2)years following the date of such record. All records shall be kept on-site and made available to DAQ personnel upon request. [40 CFR 60.7(f)] iii. Starting with the model years in Table 5 to 40 CFR 60, Subpart IIII, if the emergency engine does not meet the standards applicable to non-emergency engines in the applicable model year,the Permittee shall keep records of the operation of the engine in emergency and non-emergency service that are recorded through the non-resettable hour meter. The Permittee shall record the time of operation of the engine and the reason the engine was in operation during that time. [60.4214(b)] Atrium Health Cabarrus June 21,2022 Page- 9— 6. Notification and Reporting Requirements: i. No initial notifications under 40 CFR 60.7(a)(1) and(a)(3)are required for emergency use engines. [60.4214(b)] Observed. The generators are used for emergency purposes only. The facility does not have a contract and does not participate in a peak shaving or demand response program. Generators 11 and 12 were manufactured in 2010; Generators 13 and 14 were manufactured in 2016; and Generator 15 was manufactured in 2017. Each generator has a cylinder displacement less than 30 liters/cylinder. The diesel fuel for the boilers and generators come from the same bulk storage tanks and has a maximum sulfur content of 15 ppm according to the fuel certification records. The generators do not have diesel oxidation catalysts. Each generator has a non-resettable hour meter and the hour meter reading are shown below. Since the previous air quality inspection, each generator has operated for testing and maintenance purposes only. A report is not required. The EPA certification for each engine can be found on the following website. Annual Certification Data for Vehicles,Engines,and Equipment I US EPA. Compliance is indicated. ID No. Facility Previous Hr Current Hr Total Engine Family Code EPA Certification From ID. No. Meter Reading Meter Reading Hours No. Permit 11 3 460.8 475.7 14.9 ACPXL78.1T2E CPX-BRCI-10-24 12 4 398.3 414.7 16.4 ACPXL78.1T2E CPX-NRCI-10-24 13 5 534.3 556.7 22.4 GCPXL106.NZS.7NSF-020 GCPXL106.NZS-009 14 6 512 526.4 14.4 GCPXL106.NZS.7NSF-020 GCPXL106.NZS-009 15 7 205.5 227.2 21.7 HCPXL106.NZS HCPXL106.NZS-009 g. Condition A.B. 15A NCAC 2D .0535 "Notification Requirement".the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time of the Division's next business day of becoming aware of the occurrence. Observed. No excess emissions have been reported since the last inspection. Compliance is indicated. h. Condition A.9. 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources". the Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. If substantive complaints are received or excessive fugitive dust emissions from the facility are observed the owner or operator may be required to submit a fugitive dust plan. Observed. No fugitive dust emissions were observed during the inspection. Compliance is indicated. i. Condition A.10. 15A NCAC 2D .I I I I "Maximum Achievable Control Technology"For the diesel- fired emergency generators(ID Nos. 11, 12, 13, 14, 15), classified as new stationary RICE located at an area source of HAP emissions,the Permittee shall comply with all applicable provisions, including the notification,testing,reporting,recordkeeping, and monitoring requirements contained in Atrium Health Cabarrus June 21,2022 Page- 10— Environmental Management Commission Standard 15A NCAC 2D .1111, as promulgated in NESHAP Subpart ZZZZ. Observed. The emergency diesel-fired generators are in compliance with NESHAP Subpart ZZZZ by being in compliance with NSPS IIII. Compliance is indicated. j. Condition A.11. 15A NCAC 2D .1806"Control and Prohibition of Odorous Emissions"the Permitee shall not operate the facility without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. Observed.No odors were detected during the inspection. Compliance is indicated. k. Condition A.12. 15A NCAC 2Q .0315 "Synthetic Minor Facilities". To avoid the applicability of 15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit,"as requested by the Permittee, facility-wide emissions shall be less than the following: �oll.utant�( mission Limit Tons per consecutive 12-mon h period) S02 100 NOx 100 1. Recordkeeping Requirements i. The Permittee shall record monthly and total annually the following: A. The gallons of No. 2 fuel oil combusted in the boilers(ID Nos. B1,B2,B3, and B4). B. The hours of operation for the engines associated with emergency generators (ID Nos. 11, 12, 13, 14, 15, and 114). C. The facility-wide S02 and NOx emissions. ii. Fuel supplier certification shall be kept on-site and made available to DAQ personnel upon request. 2. Reporting Requirements -Within 30 days after each calendar year,regardless of the actual emissions,the Permittee shall submit the following: i. emissions and/or operational data listed below. The data should include monthly and 12 month totals for the previous 12 month period. A. The gallons of No. 2 fuel oil combusted in the boilers(ID Nos. B 1,B2,B3, and B4). B. The hours of operation for the engines associated with emergency generators(ID Nos. 11, 12, 13, 14, 15, and 114). C. The facility-wide S02 and NOx emissions. Observed. The monthly and annual records are being kept as required by this condition. Copies of the fuel supplier certifications from Nisbet Oil are also being kept. The facility used 3,958 gallons of No. 2 fuel oil in the boilers in 2021 and 152 gallons so far in 2022. The facility operated the generators a total of 125 hours in 2021 and approximately 18 hours to date in 2022. The facility is also tracking facility-wide S02 and NOx emissions. The facility submitted the annual report on Atrium Health Cabarrus June 21,2022 Page- 11 — 1/31/22 showing the facility-wide S02 emissions were 0.029 tons, and the NOx emissions were 2.82 tons. Compliance is indicated. 1. Condition A.13. 15A NCAC 2Q .0317 "Avoidance Condition for Area Sources Subject To 40 CFR 63 Subpart JJJJJJ(0)". The Permittee is avoiding applicability of NESHAP Subpart JJJJJJ(6J) "Industrial, Commercial, and Institutional Boilers Area Sources". The Permittee is permitted to operate natural gas/No. 2 fuel oil-fired boilers(ID Nos. B 1,B2,B3 and B4). Per 40 CFR 63.11195(e), these sources are exempt from NESHAP Subpart 6J because they are defined as gas-fired boilers in 40 CFR 63.11237. In order to maintain this exemption,the Permittee is allowed to fire liquid fuel only during periods of gas curtailment, gas supply interruptions, startups, or for periodic testing on liquid fuel (periodic testing not to exceed a combined total of 48 hours during any calendar year). The Permittee shall maintain records that document the time periods when liquid fuel is fired and the reasons the liquid fuel is fired. Observed. The facility is maintaining records of the time periods when liquid fuel is fired. Boilers have used approximately 152 gallons of fuel oil so far in 2022 and approximately 380 gallons over the past 12 months. There have been no instances of curtailment since the last inspection. Compliance is indicated. in. Condition A.14. 15A NCAC 2Q .0317 Limitation to avoid 15A NCAC 2D .0530"Prevention of Significant Deterioration". To comply with this permit and avoid the applicability of 15A NCAC 2D .0530 "Prevention of Significant Deterioration," as requested by the Permittee, emissions shall be limited as follows: Affected Source(s) Pollutant lEmission Limit(Tons Per Consecutive 12-month Period) Facility Wide S02 250 Observed. The facility is in compliance with the Synthetic Minor Limitations identified in Condition A.12 -2Q .0315 and,as a result,is in compliance with this condition. n. Condition A.15. 15A NCAC 2Q .0317 Limitation to avoid 15A NCAC 2D .0531 "New Source Review".to comply with this permit and avoid the applicability of 15A NCAC 2D .0531 "New Source Review," as requested by the Permittee, emissions shall be limited as follows: Affected Sources) Pollutant Emission Limit (Tons Per Consecutive 12-month Period) Facility Wide I NOx J 100 Observed. The facility is in compliance with the Synthetic Minor Limitations identified in Condition A.12 -2Q .0315 and,as a result, is in compliance with this condition. o. Condition A.16. 15A NCAC 2Q .0317 Limitation to AVOID 15A NCAC 2D .1402 "Applicability". To comply with this permit, as requested by the Permittee,emissions shall be limited as follows: Affected pollutant Emission Limit Source(s) Facility Wid I 100 tons per consecutive 12-month period Atrium Health Cabarrus June 21,2022 Page- 12— Facility Wide NOx 560 pounds per calendar day from May 1 through September 30 of any year Observed. The facility is in compliance with the Synthetic Minor Limitations identified in Condition A.12 -2Q .0315 and, as a result,the facility emits less than 100 tons per year of NOx. The facility's actual emissions of NOx are typically less than 3 tons per year and, as a result,the facility emits less than 560 lbs per day of NOx. Compliance in indicated. 8. NSPS/NESHAP Review The emergency engines(ID Nos. 11,12,13,14,and 15)are considered new with regard to NESHAP Subpart 4Z and comply with NESHAP 4Z by complying with NSPS 4I. Four existing natural gas/No. 2 fuel oil-fired boilers(ID Nos. B1,B2,B3, and B4) are not subject to the NESHAP Subpart JJJJJJ because the facility stated the four boilers(ID Nos. B 1,B2,B3, and B4)will combust No. 2 fuel oil only during times of curtailment, emergencies and periodic testing. Records are being kept to demonstrate that the limit of 48 hours per calendar year on fuel oil is not being exceeded. The facility does not have any gasoline storage tanks. Therefore,the facility is not subject to NESHAP Subpart 6C. The facility does not sterilize equipment with ethylene oxide. Therefore,the facility is not subject to NESHAP Subpart 5W. 9. Summary of changes needed to the current permit: None 10. Compliance assistance offered duringtpection: I discussed the permit renewal process with Mr. Mackin. 11. Section 112(r)applicability: This facility does not appear to be subject to the requirements of the Chemical Accident Release Prevention Program, Section 112(r)of the Clean Air Act. 12. Compliance determination: Based on my observations,this facility appeared to be in compliance with the applicable air quality regulations at the time of the inspection. JEF: c: MRO File https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/CABARRUS/00005/INSPECT_20220621.docx Atrium Health Cabarrus June 21,2022 Page- 13—