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HomeMy WebLinkAboutAQ_F_1300005_20210831_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: 08/30/2021 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 NAICS: 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 Support VP of Facilities Mgmt Plant Operations Support NSPS: Subpart Dc,Subpart IIII Services (704)667-9461 Services (704)996-4740 (704)996-4740 Compliance Data Comments: Inspection Date 08/30/2021 Inspector's Name Alejandra Cruz Inspector's Signature: CZCZk6(ZG = 1. auz 9)jm Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: 8/31/2021 Inspection Result Compliance 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 pounds) 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 August 30,2021 Page -2— Type Action: X Full Compliance _Partial Compliance _Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Date submitted for initial review 8/31/2021 _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 8/01/2022 Directions: Travel on Highway 3 South for 10 miles and turn right onto Rankin Road. Continue onto Stirewalt Road and take right onto Drakestone Road. Continue onto Trinity Church Road for three miles and continue straight onto Orphanage Road for two miles. Turn left onto Winecoff School Road for approximately one mile and turn right onto US-29A/Kannapolis Hwy. Travel approximately one mile and continue straight onto Mall Drive NE. Turn right onto Memorial Blvd and turn right onto Medical Park Drive NE. Turn into the first drive to the left past the energy facility to park. Contact Mr. Greg Mackin, Senior Specialist Facilities Manager before the inspection since he will have to travel from Charlotte,NC to be at the inspection. Safety Equipment: Ear protection is required to be worn by the inspector in the Energy Center. 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 are needed at this time. 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 August 30,2021 around 10:30 am. Atrium Health Cabarrus is a hospital that utilizes four steam boilers for heating, food processing, and sterilization purposes; and five emergency generators for electrical outages.Mr. Thomas Grosso,Plant Manager 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.No changes are needed at this time. 3. Compliance history file review: MRO issued a NOD to this facility on August 18,2017 for late reporting. Atrium Health Cabarrus August 30,2021 Page -3— 4. Observations of permitted air emission sources and control devices: Emission Emission Source Source ID Description B1 (NSPS), four(4)natural gas/No.2 fuel oil-fired boilers(ID Nos. B1,B2,B3, B2 (NSPS), and B4, 14.6 million Btu per hour maximum heat input, each) B3 (NSPS), B4 (NSPS) Observed.Boilers B2 and B4 were not operating. B3 was operating(steam pressure 73.9 psi)and B 1 was on standby. All boilers were observed without visible emissions. The exhausts of all four boilers are manifold into a single stack. The boilers' national board numbers are 44089 (B1),44110(B2),44094 (B3), and 48755 (B4). Emission Emission Source Source ID Description I I (NSPS,NESHAP) diesel-fired emergency generator(2,500 kilowatts rated capacity) Observed.This generator was not in operation during the inspection.Hour meter read 460.8 hrs. Emission Emission Source Source ID Description 12 (NSPS,NESHAP) diesel-fired emergency generator(2,500 kilowatts rated capacity) Observed.This generator was not in operation during the inspection.Hour meter read 398.3 hrs. Emission Emission Source Source ID Description 13 (NSPS,NESHAP) diesel-fired emergency generator(3,000 kilowatts rated capacity) Observed.This generator was not in operation during the inspection.Hour meter read 534.3 hrs. Emission Emission Source Source ID Description 14(NSPS,NESHAP) diesel-fired emergency generator(3,000 kilowatts rated capacity) Observed.This generator was not in operation during the inspection.Hour meter read 512 hrs. Emission Emission Source Source ID Description 15 (NSPS,NESHAP) diesel-fired emergency generator(3,000 kilowatts rated capacity) Observed.This generator was not in operation during the inspection.Hour meter read 205.5 hrs. 5. Observations of insignificant air emission sources and control devices listed on the current permit: Source I Source ID I Observations Diesel-fired fire pump I14 Did not observe. The fire pump is not subject to NESHAP engine (251 hp rated Subpart ZZZZ because it is an existing emergency unit located at capacity) institutional facility. Diesel fuel aboveground IES-25 This tank stores the diesel fuel for the boilers and four storage tank(30,000 emergency generators. The tank is located outside of the Energy gallons capacity) Center. Atrium Health Cabarrus August 30,2021 Page -4— Diesel fuel aboveground IES-26 This tank stores the diesel fuel for the boilers and four storage tank(30,000 emergency generators. The tank is located outside of the Energy gallons capacity) Center. Diesel fuel aboveground IES-30 This tank is the day tank for the boilers. It pulls diesel from the day tank (150 gallons big tanks. capacity) Diesel fuel aboveground 7 8 storage tank(200 gallon This tank is the day tank for generators 11 and 12. capacity) Diesel fuel aboveground IES-39 storage tank(200 gallon This tank is the day tank for generators 1 l and 12. capacity) Diesel fuel aboveground IES-40 storage tank(275 gallons This tank is the day tank for generators 13, 14, and 15. capacity) Diesel fuel aboveground IES-41 storage tank(275 gallons This tank is the day tank for generators 13, 14, and 15. capacity) Diesel fuel aboveground IES-42 This tank stores the diesel fuel for the boilers and four storage tank(30,000 emergency generators. The tank is located outside of the Energy gallons capacity) Center. Diesel fuel aboveground IES-43 storage tank(275 gallons This tank is the day tank for generators 13, 14, and 15. capacity) Diesel fuel aboveground IES-44 This tank stores the diesel fuel for the boilers and four storage tank(30,000 emergency generators. The tank is located outside of the Energy gallons capacity) Center. 6. Observations of air emission sources and control devices not listed on the current permit: a. None noted. 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 does not expire until 01/31/2023. 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 in the permit. 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. Atrium Health Cabarrus August 30,2021 Page - 5— 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. The four boilers are not exceeding the limitation for sulfur dioxide. 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. No visible emissions were observed 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 boiler(ID No. B1), natural gas/No. 2 fuel oil-fired boiler(ID No. B2),natural gas/No. 2 fuel oil-fired boiler(ID No. B3)and natural gas/No. 2 fuel oil-fired boiler (ID No. 134), the Permittee shall comply with all applicable provisions, including the notification,testing,reporting,recordkeeping,and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D.0524"New Source Performance Standards" (NSPS) as promulgated in 40 CFR 60, Subpart Dc, including Subpart A"General Provisions." NSPS Reporting Requirements -In addition to any other notification requirements to the Environmental Protection Agency(EPA),the Permittee is required to NOTIFY the Regional Supervisor,DAQ,in WRITING,of the following: 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(by January 30 for the previous six-month period between July and December and by July 30 for the previous six-month period between January and June),the Permittee must submit in writing to the Regional Supervisor,DAQ,the sulfur content of the distillate oil combusted in an affected source. Observed.The last reports were received 1/27/2021 and 7/19/2021. Compliance is indicated. NSPS Recordkeeping Requirements -hi 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. Observed.Records of the natural gas and No. 2 fuel oil combusted in the four boilers are being kept by this company. The facility generally uses natural gas,but 201 Atrium Health Cabarrus August 30,2021 Page -6— gallons of No. 2 fuel oil were combusted in the boilers in 2020, and 3,866 gallons so far in 2021. Compliance is indicated. NSPS Emissions Limitations-As required by 15A NCAC 2D .0524,the following permit limits shall not be exceeded: Affected Source(s) I Pollutant lEmission Limit natural gas/No. 2 fuel oil-fired boiler(14.6 mmBtu/hr)(Bl)ISulfur content 10.5%by weight natural gas/No. 2 fuel oil-fired boiler(14.6 mmBtu/hr)(132)jSulftir content 10.5%by weight natural gas/No. 2 fuel oil-fired boiler(14.6 mmBtu/hr)(B3)ISulfur content 10.5%by weight natural gas/No. 2 fuel oil-fired boiler(14.6 mmBtu/hr)(B4) Sulfur content 0.5%by weight Observed. The facility submitted the fuel supplier certification indicating that all the No. 2 fuel oil received from Nisbet Oil Company did not exceed 0.5 percent by weight of sulfur. Tune ups for the boilers are conducted. The last tune up is shown below. Compliance is indicated. Boiler Last tune up B1 8/26/2020 B2 12/23/2020 B3 1/5/2021 B4 1/8/2021 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) as promulgated in 40 CFR 60, Subpart indicated below,and including Subpart A"General Provisions." Emission Source(s) MEW Regulation 40 CFR 60, Subpart II11 emergency generator(ID No. 11), emergency generator(ID No. 12), "Standards of Performance emergency generator(ID No. 13),diesel-fired emergency generator(ID for Stationary No. 14) and emergency generator(ID No. 15) Compression Ignition Internal Combustion Engines(Cl ICE)" 1. Emission Standards: i. The Permittee shall operate and maintain stationary Cl ICE that achieve 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 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)] Atrium Health Cabarrus August 30,2021 Page -7— iii. For the fire pump engines with a displacement of less than 30 liters per cylinder, the Permittee shall comply with the emission standards in Table 4 of 40 CFR 60 Subpart IIII,for all pollutants. [60.4205(c)] 2. Fuel Requirements: i. For the stationary Cl ICE with a displacement of greater than or equal to 30 liters per cylinder,the Permittee shall use fuel that meets a maximum per-gallon sulfur content of 1,000 parts per million(ppm). Observed. Generators(ID Nos. 11 and 12)were manufactured in 2010 and have a total displacement of 78.1 liters. Generators(ID Nos. 13 and 14)were manufactured in 2016 and have a total displacement of 84.7 liters. Generator(ID No. 15)was manufactured in 2017 and has a total displacement of 84.7 liters. Therefore,for all 5 generators, each cylinder is less than 30 liters. The four diesel-fired emergency generators are subject to 40 CFR Part 60,NSPS Subpart 1111(41), since these engines were constructed(ordered) after July 11,2005 and manufactured after the applicability date of April 1,2006 in 60.4200(a)(2)(i). According to the fuel supplier certification,manufacturer's specifications, and maintenance logs,the four diesel-fired emergency generators appear to be in compliance with the fuel limitations(15 ppm)in 60.4207(b) and 40 CFR 80.510(b)for non-road diesel fuel; limit NOx and PM emissions in 60.4205 based on (d)(2) and(d)(3);hour meter requirements(installed non-resettable meter)in 60.4209(a). 3. Compliance Requirements: i. The Permittee shall do all the following, except as permitted under 40 CFR 60.4211(g): a. Operate and maintain the stationary Cl ICE and control device according to the manufacturer's written emission-related instructions or procedures developed by the Permittee that are approved by the engine manufacturer; b. Change only those emission-related settings that are permitted by the manufacturer and c. Meet the requirements of 40 CFR parts 89, 94 and/or 1068, as applicable. ii. For the 2007 model year and later stationary Cl ICE that must comply with the emission standards specified in 40 CFR 60.4204(b)or 4205(b),or for the Cl fire pump engine that is manufactured during or after the model year that applies to the fire pump engine power rating in Table 3 to 40 CFR 60 Subpart IIII that must comply with the emission standards specified in 40 CFR 60.4205(c),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). Atrium Health Cabarrus August 30,2021 Page - 8— iii. If the Permittee does not install,configure, operate, and maintain the engine and control device according to the manufacturer's emission-related written instructions, or 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)] iv. The Permittee shall operate the emergency stationary ICE according to the requirements in paragraphs A through C below. In order for the engine to be considered an emergency stationary ICE under this subpart, any operation other than emergency operation,maintenance and testing, and operation in non- emergency situations for 50 hours per year, as described in paragraphs A through C below, is prohibited. If the Permittee does not operate the engine according to the requirements in paragraphs A through C below,the engine will not be considered an emergency engine under this subpart and shall meet all requirements for non-emergency engines. a. There is no limit on the use of emergency stationary ICE in emergency situations. b. The Permittee may operate the emergency stationary ICE for any combination of the purposes specified in paragraph I below for a maximum of 100 hours per calendar year. Any operation for non- emergency situations as allowed by paragraph C below counts as part of the 100 hours per calendar year allowed by this paragraph B. 1. Emergency stationary ICE may be operated for maintenance checks and readiness testing,provided that the tests are recommended by federal, state or local government,the manufacturer,the vendor,the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The Permittee may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing,but a petition is not required if the Permittee maintains records indicating that federal, state, or local standards require maintenance and testing of emergency ICE beyond 100 hours per calendar year. c. Emergency stationary ICE may be operated for up to 50 hours per calendar year in non-emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing provided in paragraph B above. Except as provided in paragraph I below,the 50 hours per calendar year for non-emergency situations cannot be used for peak shaving, or to generate income for a facility to an electric grid or otherwise supply power as part of a financial arrangement with another entity. 1. The 50 hours per year for non-emergency situations can be used to supply power as part of a financial arrangement with another entity if all of the following conditions are met: Atrium Health Cabarrus August 30,2021 Page -9— (a) The engine is dispatched by the local balancing authority or local transmission and distribution system operator; (b) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region; (c) The dispatch follows reliability, emergency operation or similar protocols that follow specific NERC,regional, state, public utility commission or local standards or guidelines; (d) The power is provided only to the facility itself or to support the local transmission and distribution system; and (e) The Permittee identifies and records the entity that dispatches the engine and the specific NERC,regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the Permittee. Observed.No initial performance test is required if the engines are certified. These are EPA certified Tier II engines: EPA family code ACPXL78.1T2E for generators(ID Nos. 11 and 12), EPA family code GCPXL106.NZs.7NSF-020 for generators(ID Nos. 13 and 14), and EPA family code HCPXL106.NZS for generator No. 15. The facility does not have a contract and does not participate in a peak shaving or demand response program. These are emergency use engines only. The facility has an agreement with the hospital accreditation authority, The Joint Commission(TJC)to provide communications,resources and assets, security, and safety, staff, utilities, or patient care for at least 96 hours. According to 40 CFR 60.4211 (f)(2)(i),the emergency stationary ICE may be operated for maintenance and checks for more than 100 hours if recommended by federal, state or local government,the manufacturer,the vendor,the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The facility is required to run the engines for 96 hours to show they are available for that amount of time. CAT conducted equipment change out on engines 11, 12, 13 and 14 during 2017 that caused these engines to exceed 100 hours. Compliance is indicated 4. 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)] Atrium Health Cabarrus August 30,2021 Page - 10— 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)] Observed: The facility is keeping all operational and maintenance records as required. Compliance is indicated 5. 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)] ii. For the emergency stationary Cl ICE with a maximum engine power more than 100 HP that operates for non-emergency situations as described above,the Permittee shall submit an annual report according to the following requirements: [60.4214(d)] a. The report shall contain the following information: 1. Company name and address where the engine is located. II. Date of the report and beginning and ending dates of the reporting period. IIl. Engine site rating and model year. IV. Latitude and longitude of the engine in decimal degrees reported to the fifth decimal place. V. Hours spent for operation for non-emergency situations as described above,including the date, start time, and end time for these non-emergency situations. The report shall also identify the entity that dispatched the engine and the situation that necessitated the dispatch of the engine. b. The first annual report shall cover the calendar year 2015 and shall be submitted no later than March 31,2016. Subsequent annual reports for each calendar year shall be submitted no later than March 31 of the following calendar year. c. The annual report shall be submitted electronically using the subpart specific reporting form in the Compliance and Emissions Data Reporting Interface(CEDRI)that is accessed through EPA's Central Data Exchange(CDX)(www.epa.gov/cdx). However, if the reporting form specific to this subpart is not available in CEDRI at the time that the report is due,the written report shall be submitted to the Administrator at the appropriate address listed in 40 CFR 60.4. Atrium Health Cabarrus August 30,2021 Page - 11 — Observed. The facility does not have a contract and does not participate in a peak shaving or demand response program. These are emergency only generators. A report is not required,compliance is indicated. g. Condition A.8. 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 .1111 "Maximum Achievable Control Technology"For the emergency generator (ID No. 11), emergency generator (ID No. 12), emergency generator (ID No. 13), diesel-fired emergency generator (ID No. 14) and emergency generator(ID No. 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 Environmental Management Commission Standard 15A NCAC 2D .1111, as promulgated in 40 CFR 63,Subpart ZZZZ-"National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines," including Subpart A"General Provisions." Observed.The emergency diesel-fired generators are in compliance with NESHAP 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: Atrium Health Cabarrus August 30,2021 Page - 12— ollutant Emission Limit (Tons per consecutive 12-month period) S02 1 100 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. Bl, B2, B3, and 134). B. The hours of operation for the engines associated with emergency generators(ID Nos. 11, 12, 13, 14, 15, and I14). 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. Observed.The monthly and annual records are being kept by this hospital as required by this condition. Copies of the fuel supplier certifications from Nisbet Oil are also being kept by this hospital. The facility used 201 gallons of No. 2 fuel oil in 2020. The facility is also tracking facility-wide S02 and NOx emissions. Compliance with this stipulation is indicated. 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. B1, B2, B3, and 134). B. The hours of operation for the engines associated with emergency generators(ID Nos. 11, 12, 13, 14, 15, and I14). C. The facility-wide S02 and NOx emissions. Observed. The facility submitted the report on 1/27/2021. The boilers used a total of 201 gallons during 2020.The total hours of operation during 2020 for all 5 generators were 231 hours.The S02 emissions were 1.93E-02 tons,and the NOx emissions were 1.02 tons.Mr. Mackin indicated that they are trying to decrease the emissions to eventually become small. Compliance is indicated. 1. Condition A.13. 15A NCAC 2Q .0317"Avoidance Condition for Area Sources Subject To 40 CFR 63 Subpart JJJJJJ(6J)". The Permittee is avoiding applicability of 40 CFR 63 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. B1,B2, Atrium Health Cabarrus August 30,2021 Page - 13— B3 and B4). Per 40 CFR 63.11195(e),these sources are exempt from this Subpart 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 3,866.8 gallons of fuel oil so far in 2021. 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.All recordkeeping and reporting requirements are identified in synthetic minor condition, 15A NCAC 2Q .0315 "Synthetic Minor Facilities"; therefore,no further restrictions are required. Compliance is indicated. 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 NOx 100 Observed.All recordkeeping and reporting requirements are identified in synthetic minor condition, 15A NCAC 2Q .0315 "Synthetic Minor Facilities";therefore,no further restrictions are required. Compliance is indicated. 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 Wide NOx 100 tons per consecutive 12-month period Facility Wide NOx 560 pounds per calendar day from May 1 through September 30 of any year Atrium Health Cabarrus August 30,2021 Page - 14— Observed.All recordkeeping and reporting requirements are identified in synthetic minor condition, 15A NCAC 2Q .0315 "Synthetic Minor Facilities"; therefore,no further restrictions are required. Compliance is indicated. 8. NSPS/NESHAP Review The emergency engines(ID Nos. 11,12,13,14, and 15) are new emergency engines subject to 40 CFR Part 63 Subpart ZZZZ(4Z) and 40 CFR Part 60 NSPS Subpart IIII(4I). The new engines comply with NESHAP 4Z by complying with NSPS 4I. Four existing natural gas/No. 2 fuel oil-fired boilers (ID Nos. Bl,B2,B3, and 134) are not subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ or 6J). This hospital submitted the initial notification form received by NCDAQ on September 15,2011,stating that four boilers (ID Nos. Bl, B2, B3, and 134) would use 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. 9. Summary of changes needed to the current permit: None. 10. Compliance assistance offered duringtpection: None. 11. Section 112(r) gpplicabilitX: 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. AFC:Ims c: MRO File https://neconnect.sharepoint.com/sites/DAQ-MRO/Counties/CABARRUS/00005/INSPECT 20210830.docx