HomeMy WebLinkAboutAQ_F_1800194_20190214_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Frye Regional Medical Center
NC Facility ID 1800194
Inspection Report County/FIPS: Catawba/035
Date: 0211412019
Facility Data Permit Data
Frye Regional Medical Center Permit 02790/R15
420 North Center Street Issued 12/31/2015
Hickory,NC 28601 Expires 5/31/2022
Lat:35d 44.2794m Long: 81d 20.2392m Class/Status Small
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
Todd Cook Chris Fensterle Eddie Braswell MACT Part 63: Subpart WWWWW, Subpart
Admin.Director,Facility Chief Operating Officer Plant Operations ZZZZ
Services (828)315-3410 Manager NSPS: Subpart Dc, Subpart IIII
(828)315-3825 (828)315-3825
Compliance Data
Comments:
Inspection Date 02/14/2019
Inspector's Name Donna Cook
Inspector's Signature: o a Cook/ Operating Status Operating
f �r Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: �� 7 f On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PM10 *HAP
2013 0.2800 0.2500 4.20 0.2700 2.93 0.2800 134.00
2008 0.9000 0.2500 12.87 0.6500 10.22 0.9000 427.43
*Highest HAP Emitted inpounds)
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
Frye Regional Medical Center
February 14, 2019
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Tracking: X Date submitted for initial review 2/22/2019 _IBEAM WARNING/OB,NOD,NOV,NRE
/ 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 2/01/2021
Directions: From Mooresville Regional Office to Hickory,travel W. Statesville Avenue;North Broad
Street and the name changes to Statesville Highway(Highway 115 North)and then to Charlotte Highway
(Highway 21 North and Highway 115 North); Interstate 77 North;Exit 51 (Hickory/Winston-Salem)-
Interstate 40 West toward Asheville; off Interstate 40 West take Exit 125 Hickory,turn right off exit ramp
onto Lenoir Rhyne Blvd. SE; 1.3 miles turn left at the stop light onto Ist Ave. SE; 0.4 mile turn right onto
NC 127 N.; 0.4 mile turn left on 3`d Ave.NE; 0.1 turn right onto North Center Street; and 0.1 mile on the
right is the hospital. The visitor parking for the hospital is on the left. The street address for the hospital
is 420 North Center Street. It is recommended that the facility contact be phoned prior to leaving the
office. The facility contact will meet the inspector in the lobby area of the hospital.
Safety Equipment: Inspector is required to wear hearing protection when the generators and boilers are
operating. This hospital will provide a sterile gown(overalls, shoe covers and hair net)for the inspector
to wear prior to entering the sterile processing department where the ethylene oxide sterilizers/aerators are
located.
Safety Issues: This hospital will provide a sterile gown(overalls, shoe covers and hair net)that must be
worn by the inspector prior to entering the sterile processing department where the ethylene oxide
sterilizers are located.
Lat/Long Coordinates: The facility's coordinates on "Maps of DAQ Regulated Facilities" are not
accessible on the DAQ web site. The latitude and longitude coordinates of this facility are accurate and
locked in IBEAM.
Email Contacts: The emails for the facility, authorized and technical contacts were verified by
Mr. Todd Cook, administrative director of facility services. I updated the email addresses of the
facility, authorized and technical contacts in IBEAM.
1. The purpose of this site visit was to conduct a routine air quality inspection. Frye Regional
Medical Center is a hospital that utilizes two permitted boilers for food preparation,
domestic hot water, sterilization purposes and heating/humidification of this facility; two
permitted and one exempt diesel-fired emergency generators for electrical outages; and four
ethylene oxide sterilizers/aerators for sterilization and fumigation of surgical instruments.
Mr. Todd Cook, administrative director of facility services, and Mr. Eddie Braswell,plant
operations manager, accompanied me during this inspection.
Frye Regional Medical Center
February 14, 2019
Page 3
2. Facility Contact Information:
During the inspection, I verified the facility contact information in IBEAM with Mr. Cook. I
changed the technical contact to Mr. Eddie Braswell, plant operations manager, in IBEAM.
3. Compliance history file review:
No problems have been noted in the last five years by DAQ prior to this inspection. The current
compliance status is discussed in the following sections.
4. Observations of permitted air emission sources and control devices:
Emission Emission Source Control Control System
Source ID Description System ID Description
�B 1 (NSPS) ;natural gas/No. 2 fuel oil-
jfired boiler(14.29 million
Btu per hour maximum N/A N/A
(heat input)
B2(NSPS) natural gas/No. 2 fuel oil-
jfired boiler(14.29 million N/A N/A
Btu per hour maximum
,heat input)
'The two boilers (ID Nos. B l and B2)are used for food preparation, domestic hot water,
sterilization purposes and heating/humidification at this hospital. Natural gas is the primary fuel
source for each boiler. No. 2 fuel oil is the backup fuel source for each boiler if natural gas is
curtailed to this hospital. According to the records provided by this hospital,the amount of
natural gas combusted in the two boilers was 43,754.2 mcf in 2018 and 45,068.0 mcf in 2017.
No. 2 fuel oil was not combusted in the two boilers for curtailment purposes in 2017 and 2018.
Fhe amount of No. 2 fuel oil combusted for the once a year boiler tune-up inspection was not
recorded by this hospital since it is conducted by an outside contractor. I advised Mr. Cook and
Mr. Braswell to include the amount combusted during periodic testing in the total No. 2 fuel oil
consumption and operational hours of the boiler on No. 2 fuel oil.
The boilers are considered an existing area source per NESHAP area boiler GACT Subpart JJJJJJ
(6J), since it commenced construction before June 4, 2010. This company chose to avoid
NESHAP Subpart 6J boiler GACT by only burning No. 2 fuel oil during times of curtailment,
,emergencies and periodic testing as specified in Specific Condition and Limitation A. 11. This
,Ifacility is required to maintain records that document the time periods when liquid fuel is fired and
(reasons the liquid fuel is fired. No curtailment or emergency situation of each boiler occurred
from calendar year 2017 to present date. The periodic testing for the tune-up of each boiler on No.
12 fuel oil is conducted for eight hours once a year. The periodic testing is not exceeding 48 hours
!per boiler during any calendar year.
The fuel oil for the two boilers(ID Nos. B 1 and B2) is stored in two underground storage tanks
with capacities of 10,000 and 15,000 gallons, each. The boilers share the two fuel oil storage
hanks with the three diesel-fired generators (ID Nos. EG1,EG4 and I-EG5).
1I observed the following information on the plates of the two boilers:
Frye Regional Medical Center
February 14,2019
Page 4
Boiler(ID No. B1 or#1): manufacturer, Cleaver Brooks; model#CB 1200-350-150; serial#
OL096346; date, 1997; input rating, 14,288,100 Btu/hr; and 102.1 gph oil. The boiler stack
exhausts through the roof to the outdoor atmosphere. The stack of the boiler is vertical with a rain
cap. A ladder has to be climbed to observe the stack of the boiler. A photograph of the stack was
taken by Mr. Cook instead of climbing the ladder.
Boiler(ID No. B2 or#2): manufacturer, Cleaver Brooks; model# CB 1200-350-150; serial#
OL102671; date, 2003; input rating, 14,288,000 Btu/hr; and 102.1 gph oil. The boiler stack
exhausts through the roof to the outdoor atmosphere. The stack of the boiler is vertical with a rain
cap. A ladder has to be climbed to observe the stack of the boiler. A photograph of the stack was
taken by Mr. Cook instead of climbing the ladder.
Observed. The Cleaver Brooks model boiler(ID No. B 1 or#1)was in standby mode. The
Cleaver Brooks model boiler(ID No. B2 or#2)was firing on natural gas and operating at 75 psi.
No visible emissions were observed by me from the roof line of this facility or from the photos
taken of the boiler stacks by Mr. Cook.
EG1 diesel fired emergency
generator(800 kW rated N/A N/A
capacity)
The diesel-fired generator(ID No. EG1)provides emergency power to critical areas and
equipment essential for life safety at the hospital. The generator is not being used as a peak shaver
or for demand response. The toxic air pollutant permit condition A. 9. requires that the hours
operated for the two diesel-fired generators(ID Nos. EG1 and EG4)be recorded monthly and
totaled annually by this hospital. The operating hours for generator(ID No. EG1)was 15.44 in
2017 and 23.66 in 2018. The generator was not used for emergency purposes in 2017. and 2018.
The diesel fuel for three emergency generators (ID Nos. EG1,EG4 and IEG5) is stored in two
underground storage tanks with capacities of 10,000 and 15,000 gallons, each. The diesel-fired
generators also share the two fuel oil storage tanks with the two boilers (ID Nos.B 1 and B2). The
generator(ID No.EG1) has an aboveground day tank with a capacity of 100 gallon to store the
i
diesel fuel.
I observed the following information on the engine/generator plate:
Emergency generator(ID No. EG1; 800 kW)—engine plate: manufacturer, Caterpillar; model#
3412; serial#2W501393 and rating, 1180 hp@1800 rpm; and generator plate: manufacturer,
Caterpillar; model#3412; stator#40927034;rating, 800 kW; year,1997 and run hours on digital
readout 551. The previous run hours on digital readout were 510 hours during an inspection on
November 16, 2016. I was unable to view the generator stack. Mr. Cook provided a photo of this
stack. The stack of the generator(ID No. EG1) is horizontal and uncapped.
I
The engine was manufactured in 1997. The engine is considered an existing area source if
construction commenced before June 12,2006 at this institutional facility and used only in case of
emergencies. According to 40 CFR 63.6585, existing emergency engines at institution facilities
are not subject to NESHAP Subpart ZZZZ(4Z). The generator is also not subject to 40 CFR Part ;
60,NSPS, Subpart IIII(4I), since the applicability dates of the NSPS Subpart 4I is constructed
(ordered) after July 11, 2005 and manufactured after April 1, 2006.
Frye Regional Medical Center
February 14, 2019
Page 5
Observed. The Caterpillar model diesel-fired emergency generator(ID No. EG1)was not in
loperation at the time of the inspection.
EG4 diesel-fired emergency
generator(1500 kW rated N/A N/A
capacity)
The diesel-fired generator(ID No. EG4)provides emergency power to critical areas and
jequipment essential for life safety at the hospital. The generator is not being used as a peak shaver
for for demand response. The toxic air pollutant permit condition A. 9. requires that the hours
+operated for the two diesel-fired generators (ID Nos. EG1 and EG4) be recorded monthly and
(totaled annually by this hospital. The operating hours for generator(ID No. EG4)was 18.76 in
,2017 and 24.68 in 2018. The generator was not used for emergency purposes in 2017 and 2018.
The diesel fuel for three emergency generators is stored in two underground storage tanks with
capacities of 10,000 and 15,000 gallons, each. The diesel-fired generators also share the two fuel
oil storage tanks with the two boilers (ID Nos. B 1 and B2). The generator(ID No. EG4)has an
laboveground day tank with a capacity of 100 gallon to store the diesel fuel.
I observed the following information on the engine/generator plate:
Emergency generator(ID No:EG4; 1500 kW)—engine plate: manufacturer, Caterpillar; model#
3512; serial# 1GZ01395, rating 1620 kw@1800 rpm; no horsepower rating listed but calculated
at 2011 hp by Mr. Cook and generator plate: manufacturer, Caterpillar; model#3512; serial#
7GM01010; rating, 1500 kW; standby; year, 2003 and run hours on digital readout 408. The
previous run hours on digital readout were 362 hours during an inspection on November_16, 2016.
1 was unable to view the generator stack. Mr. Cook provided a photo of this stack. The stack of
the generator(ID No. EG2) is horizontal and uncapped.
The engine was manufactured in 2003. The engine is considered an existing area source if
construction commenced before June 12,2006 at this institutional facility and used only in case of
;emergencies. According to 40 CFR 63.6585, existing emergency engines at institution facilities
are not subject to NESHAP Subpart ZZZZ(4Z). The generator is also not subject to 40 CFR Part
NSPS, Subpart 11II (4I), since the applicability dates of the NSPS Subpart 4I is constructed
(ordered) after July 11, 2005 and manufactured after April 1, 2006.
Observed. The Caterpillar model diesel-fired emergency generator(ID No. EG2)was not in
loperation at the time of the inspection.
5. Observations of insignificant air emission sources and control devices listed on the current permit:
Source Exemption Source of Source of Title V
Regulation TAPs? Pollutants?
I-EOS—four(4) ethylene oxide sterilizers 2Q .0102
(4.95 cubic feet capacity each) subject to Yes Yes
NESHAP 40 CFR Part 63 Subpart WWWWW I(c)(2)(E)(i)
The four ethylene oxide sterilizers/aerators are located inside an enclosed room of the sterile
{processing department..The four ethylene oxide sterilizers/aerators (ID No. I-EOS)are used for
Frye Regional Medical Center
February 14, 2019
Page 6
the sterilization and fumigation of the surgical instruments. No controls have been installed on the:
four ethylene oxide sterilizers and aerators. The ductwork of the four ethylene oxide sterilizers/
aerators exhaust through a fan and stack to the outdoor atmosphere. The vertical and uncapped
stack is located on the roof of this hospital.
The four ethylene oxide sterilizers/aerators use ethylene oxide cartridges. Each cartridge contains
100 grams (3.52 ounces) of ethylene oxide(100%). The ethylene oxide is injected into the
sterilizer chamber for one hour to three hours and then aerated in the same chamber from six to
twelve hours per load. The total sterilization process in each of the four sterilizers/aerators is
fifteen hours from 3 p.m. to 6 a.m. Ms. Tiffany Phillips, sterile processing supervisor, stated that
the sterilization loads are four per day or less if sterilization and fumigation of the surgical
instruments is needed by medical staff.
Ethylene oxide is a hazardous air pollutant(HAP),toxic air pollutant(TAP), and volatile organic
compound (VOC). The four ethylene oxide sterilizers/aerators are subject to 40 CFR 63
(NESHAP, Subpart WWWWW or 5W). The four ethylene oxide sterilizers (ID No.IEOS)are
subject to 40 CFR 63 NESHAP, Subpart WWWWW or 5W "National Emission Standards for
Hospital Ethylene Oxide Sterilizers. The requirements of the NESHAP Subpart WWWWW
(5W)to the ethylene oxide sterilizers are discussed in Specific Condition and Limitation No.A.
10.
Observed. The four ethylene oxide sterilizers/aeration units were not in operation.
I-EG5—diesel-fired emergency generator
(500 kW rated capacity) subject to NSPS 40 2Q .0102 No Yes
CFR Part 60 Subpart IIII and NESHAP 40 0(2)(B)(v)(III)
CFR Part 63 Subpart ZZZZ
The exempt diesel-fired generator(ID No. I-EG5)provides emergency power to critical areas and
equipment essential for life safety at the hospital. The generator is not being used as a peak shaver,
or for demand response.
The diesel fuel for the three emergency generators(ID Nos. EG1, EG2 and I-EG5) is stored in two
underground storage tanks with capacities of 10,000 and 15,000 gallons, each. The three diesel-
fired generators also share the two fuel oil storage tanks with the two boilers (ID Nos.B I and B2).
The generator(ID No. I-EG5)has a day tank with a capacity of 100 gallon to store the diesel fuel.
I observed the following information on the engine/generator plate:
Emergency generator(ID No. I-EG5; kW)- engine plate: manufacturer, Caterpillar; model#C15;
serial#FSE 02357, rating 762 hp and 568 kW; and generator plate: manufacturer, Caterpillar;
model#LC6; serial#G813 15174; rating, 500 kW; standby; year, 2008 and run hours on digital
readout 85.8. The previous run hours on digital readout were not noted in the inspection report
dated November 16, 2016. The stack of the generator is located on the top right side. The stack is,
vertical and capped.
I
(The generator has a 2008 model year engine. The emergency generator(ID I-EG5) is subject to
.140 CFR Part 63,NESHAP, Subpart ZZZZ(4Z) as a new source, since applicability date of the
NESHAP Subpart 4Z rule is commenced construction of the engine on or after June 12, 2006.
This generator is also subject to 40 CFR Part 60,NSPS Subpart IIII(4I), since the applicability
Frye Regional Medical Center
February 14, 2019
Page 7
!dates of the NSPS Subpart II11 (4I) rule is constructed(ordered) after July 11, 2005 and
!manufactured after April 1,2006 of the engine. According to 40 CFR 63.6590(c),the new engine
1complies with 4Z RICE NESHAP by complying with NSPS Subpart 41. The requirements of
!NESHAP 4Z and NSPS Subpart 41 are discussed in Specific Condition and Limitation No. A. 10.
lObserved. The Caterpillar model diesel-fired emergency generator(ID No. I-EG5)was not in
operation at the time of the inspection.
6. Observations of air emission sources and control devices not listed on the current permit:
a. The fuel oil for the two boilers (ID Nos. B 1 and 132) and three emergency generators(ID
Nos. EG1, EG4 and I-EG5) is stored in two underground storage tanks with capacities of
10,000 and 15,000 gallons. The tanks are exempted from permitting per 15A NCAC 2Q
.0102 (g)(4).
b. Each emergency generator(ID Nos. EG1, EG4 and I-EG5) has an aboveground day tank.
Each day tank contains 100 gallons of diesel fuel. The three diesel fuel aboveground day
tanks (100 gallon capacity, each) are exempt from permitting per 15A NCAC 2Q .0102
(g)(4)•
C. This hospital has an electric fire pump that is not subject to NESHAP Subpart 4Z, since it
is electrically powered.
d. This hospital also has two cooling towers, three chillers, two bulk liquid oxygen tanks
and three steam sterilizers.
7. Compliance with specific permit conditions and limitations:
a. Condition A. 2. 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 with application form and submit the air pollution emission inventory report
with certification sheet for 2020 calendar year to MRO DAQ.
Observed. I informed Mr. Cook and Mr. Braswell that the current air permit would
expire on May 31, 2022. 'Compliance with this stipulation is indicated.
b. Condition A. 3. Particulate Control Requirement - As required by 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 Emission Limit
(lbs/million Btu)
]natural gas/No. 2 fuel oil-fired boiler(14.29 million Btu per
hour maximum heat input)(B 1) 0.46
natural gas/No. 2 fuel oil-fired boiler(14.29 million Btu per 0.42
(hour maximum heat input) (132) :�
Frye Regional Medical Center
February 14,2019
Page 8
Observed. The particulate matter emissions from the two boilers (ID Nos. B1 and B2)
while combusting natural gas and No.2 fuel oil are not exceeding the allowable emission
rates as indicated in the permit review. Compliance with this stipulation was indicated
during the permit application process.
C. Condition A. 4. Sulfur Dioxide Control Requirement-As required by 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"2D .0516 analysis"dated 04/10/97, compliance is indicated
for No. 1 fuel oil,No. 2 fuel oil, natural gas, butane, propane,and wood fuel.
Compliance with this stipulation was indicated during the permit application process.
d. Condition A. 5.Visible Emissions Control Requirement-As required by 15A NCAC 2D
.0521 "Control of Visible Emissions",visible emissions from the emission sources,
manufactured after July 1, 1971, shall not be more than 20 percent opacity when
averaged over a six-minute period.
Observed. No visible emissions were observed by me from this facility. Compliance
with this stipulation is indicated.
e. Condition A. 6. 15A NCAC 2D .0524 "New Source Performance Standards" -For the
boiler(ID No.B 1)and boiler(ID No. 132),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."
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 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. If fuel supplier
certification is used to demonstrate compliance, fuel supplier
certification shall include the following information:
A. The name of the oil supplier;
B. A statement from the oil supplier that the oil complies with the
specification under the definition of distillate oil in 40 CFR 60.41(c); and
C. A certified statement signed by the owner or operator of an affected
source that the records of fuel supplier certification submitted represent
all of the fuel combusted during the reporting period.
Observed. This office received the fuel supplier certification semi-annual
reports on January 8, 2019;July 9,2018; January 8, 2018; July 13,2017;
and January 6, 2017 within the allotted time frame. The fuel supplier
certification submitted by this company indicated that all the No. 2 fuel oil
i
Frye Regional Medical Center
February 14, 2019
Page 9
received from Bumgarner Oil Company had a maximum sulfur content of 15
ppm or 0.0015 percent by weight; and then combusted in boilers(ID Nos.B 1 and
B2) did not exceed the 0.5 percent by weight of sulfur as specified by this
condition. Compliance with this stipulation is indicated.
ii. NSPS Recordkeeping Requirements-1n addition to any other recordkeeping
requirements of the EPA,the permittee is required to maintain records as
follows:
A. the amounts of each fuel combusted during each month; and
B. All records required under this section shall be maintained for a period
of two years following the date of such record.
Observed. The records of the natural gas and No.2 fuel oil combusted in the
two boilers(ID Nos. B 1 and B2) are tracked monthly and annually by this
company. The natural gas combusted in the two boilers was 45068.0 mcf in
2017 and 43754.2 mcf in 2018. No. 2 fuel oil was not combusted in the two
boilers for curtailment purposes in 2017 and 2018. The amount of No. 2 fuel oil
combusted for the once a year boiler tune-up inspection was not recorded by this
hospital since it is conducted by an outside contractor. 1 advised Mr. Cook and
Mr. Braswell to include the amount combusted during periodic testing in the total
No. 2 fuel oil consumption. Compliance with this stipulation is indicated.
iii. NSPS Emissions Limitations -As required by 15A NCAC 2D .0524,the
following permit limits shall not be exceeded:
Affected Source(s) i Pollutant Emission
Limit
Inatural gas/No. 2 fuel oil-fired boiler(20.4 million Btu Sulfur 10.5% by
per hour maximum heat input)(ES-B3) Icontent ;weight
Inatural gas/No. 2 fuel oil-fired boiler(20.4 million Btu [content
ulfur �0.5% by
Iper hour maximum heat input)(ES-B4) ;weight
natural gas/No. 2 fuel oil-fired boiler(21.0 million Btu ;Sulfur i0.5°/by
per hour maximum heat input) (ES-B5) jcontent Iweight
Observed. This company submitted the fuel supplier certification on January 8,
2019; July 9, 2018; January 8, 2018; July 13, 2017; and January 6, 2017 to this
office indicating that all the No. 2 fuel oil (ultra low sulfur diesel-ulsd)received
from Bumgarner Oil Company contained 15 ppm or 0.0015 percent by weight of
sulfur and was less than 0.5 percent by weight of sulfur as required by this
condition. Compliance with this stipulation is indicated.
f. Condition A. 7. Notification Requirement - As required by 15A NCAC 2D .0535, 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
Frye Regional Medical Center
February 14, 2019
Page 10
9:00 a.m. Eastern time of the Division's next business day of becoming aware of the
occurrence.
Observed. Based on a records review and conversation with Mr. Cook and Mr.
Braswell,no excess emissions have occurred at the facility. Compliance with this
stipulation is indicated.
g. Condition A. 8. Fugitive Dust Control Requirement-As required by 15A NCAC 2D
.0540 "Particulates from Fugitive Dust Emissions Sources",the permittee shall not cause
or allow fugitive dust emissions to'cause or contribute to the substantive complaints or
excess visible emissions beyond the property boundary. If substantive complaints or
excessive fugitive dust emissions from the facility are observed beyond the property
boundaries for six minutes in any one hour(using Reference Method 22 in 40 CFR,
Appendix A),the owner or operator may be required to submit a fugitive dust plan as
described in 2D .0540(f).
Observed. MRO DAQ has-not received any fugitive dust emissions complaints
regarding this facility. This company has paved roads at this facility. During the
inspection, I observed no fugitive dust or visible emissions from this facility.
Compliance with this stipulation is indicated.
h. Condition A. 9. Toxic Air Pollutant Emission Limitation and Reporting Requirement-
Pursuant to 15A NCAC 2D .1100 "Control of Toxic Air Pollutants," and in accordance
with the approved application for an air toxic compliance demonstration,the following
permit limits shall'not be exceeded:
Affected Source(s) Toxic Air Pollutant Eti
ion
it
natural gas/No. 2 fuel oil-fired boiler Arsenic& Compounds (total
(14.29 million Btu per hour maximum mass of elemental AS, arsine 0.482 lbs/yr
heat input)(B 1) and all inorganic compounds)
(ASC (7778394))
natural gas/No. 2 fuel oil-fired boiler Arsenic&Compounds(total
(14.29 million Btu per hour maximum mass of elemental AS, arsine 0.4821bs/yr
heat input) (B2) and all inorganic compounds)
(ASC (7778394))
Arsenic&Compounds (total
diesel-fired emergency generator(800 mass of elemental AS, arsine 0.017 lbs/yr
kW rated capacity)(EGI) and all inorganic compounds)
(ASC (7778394))
Arsenic& Compounds (total -
diesel-fired emergency generator(1500 mass of elemental AS, arsine 0.0321bs/yr
kW rated capacity) (EG4) and all inorganic compounds)
(ASC (7778394))
natural gas/No. 2 fuel oil-fired boiler
(14.29 million Btu per hour maximum Benzene(71-43-2) [245 lbs/yr
cheat input) (B1)
Frye Regional Medical Center
February 14, 2019
Page 11
1natural gas/No. 2 fuel oil-fired boiler F
(14.29 million Btu per hour maximum Benzene(71-43-2) 12.45 lbs/yr
heat input) (B2)
;diesel-fired emergency generator(800
jkW rated capacity) (EG1) Benzene (71-43-2) 13.3 lbs/yr
�diesel-fired emergency generator(1500 — ---__ f—
kW rated capacity)(EG4) [Benzene(71-43-2) 6.2 lbs/yr
ntura _
l
gas/No. 2 fuel oil-fired boiler _Cadmium Metal, elemental, —
4.29 million Btu per hour maximum unreacted (Component of CDC) 10.375 lbs/yr
heat input)(B 1) (7440-43-9)
natural gas/No. 2 fuel oil-fired boiler Cadmium Metal, elemental,
(14.29 million Btu per hour maximum unreacted(Component of CDC) , 0.375 lbs/yr
heat input) (B2) (7440-43-9) s
diesel-fired emergency generator(800 Cadmium Metal, elemental,unreacted
unreacted(Component of CDC) 0.01� 3 lbs/yr
�kW rated capacity) (EG 1) I
(7440-43-9)
Cadmium Metal, elemental,
diesel-fired emergency generator(1500 unreacted (Component of CDC) �0.024 lbs/yr
kW rated capacity)(EG4) (7440-43-9)
i. Recordkeeping_Requirements-The permittee shall record monthly and total
annually the following:
A. The hours operated for the emergency generators(ID Nos. EG1 and
EG4).
Observed. Arsenic, benzene and cadmium have the potential to emit above the annual
TPER limits. This facility has triggered air toxics for arsenic, benzene and cadmium.
The air toxics were triggered by a Director's call in 2Q .0712. This facility is tracking
the natural gas usage and fuel oil usage from the two boilers and two emergency
generators(ID Nos. EG1 and EG4). The natural gas combusted by the boilers was
45.068 million scf in 2017 and 43.7542 million scf in 2018. The No. 2 fuel oil burned
by the boilers was 0 gallons in 2017 and 2018. The hours of operation for generator(ID
No. EG1)were 15.44 in 2017 and 23.66 in 2018. The hours of operation for generator
(ID No. EG4)were 18.76 in 2017 and 24.68 in 2018. Based on the actual fuel usage
from the two boilers and actual hours of operation from the two emergency generators,
the emission limits for 2Q .0711 are not being exceeded. Compliance with this
stipulation is indicated.
i. Condition A. 10. Federal and State Rules Applicable to Sources Exempted from Air
Permitting Requirements -Your facility is subject to the following federal and state rules:
40 CFR 60 -NSPS - Subpart IIII - Standards of Performance for Stationary
jCompression Ignition Internal Combustion Engines
40 CFR 63 -NESHAP/MALT- Subpart WWWWW-Hospital Ethylene Oxide
Sterilizers Area Sources
Frye Regional Medical Center
February 14,2019
Page 12
40 CFR 63 -NESHAP/MALT- Subpart ZZZZ-Reciprocating Internal Combustion
Engines
which are applicable to some of the emission sources at your facility listed on the
"Insignificant/Exempt Activities" list attached to this permit. The purpose of this permit
condition is to inform you of your compliance obligations to these applicable_ rules as
they are enforceable.
Observed: The exempt diesel-fired generator(ID No. I-EG5) at this institutional facility
provides emergency power to critical areas and equipment essential for life safety at the
hospital. The generator is not being used as a peak shaver or for demand response.
The exempt diesel-fired emergency generator(ID No. I-EG5)has a 2008 model year
engine. This emergency generator is subject to 40 CFR Part 63,NESHAP, Subpart
ZZZZ(4Z) as a new source, since applicability date of the NESHAP Subpart 4Z rule is
commenced construction of the engine on or after June 12,2006. It is also subject to 40
CFR Part 60,NSPS Subpart 1111 (41), since the applicability dates of the NSPS Subpart
IIII(41) rule is constructed(ordered) after July 11,2005 and manufactured after April 1,
2006 of the engine. According to 40 CFR 63.6590(c),the new engine complies with 4Z
RICE NESHAP by complying with NSPS Subpart 4I.
The NSPS Subpart IIII(41)requirements for this engine are to purchase a certified engine
to the appropriate tier standard for the model year engine per 60.4205(b)&40 CFR 1039;
using diesel fuel with a maximum sulfur content of 15 ppm (0.0015)per 60.4207(b)and
80.510(b); and non-resettable hour meter per 60.4209(a).
This hospital purchased a certified engine. The EPA certificate of conformity(CPX-
NRCI-08-10 and EPA engine family 8CPXL15.2ESV)for a 2008 model year Caterpillar
engine was provided by Mr. Cook during an inspection on October 7, 2015. This
information indicates that the engine meets the EPA tier emission levels for model year
2008.
The maximum sulfur content of the nonroad diesel fuel has to be 15 ppm per 60.4207(b)
and 80.510(b). The fuel oil certification records submitted semiannual indicted that the
sulfur content of the non-road diesel fuel received from the fuel oil supplier, Bumgarner
Oil Company, and combusted by the generator is 15 ppm. The maximum sulfur content
of 15 ppm is not being exceeded.
The engine has a non-resettable hour meter and meets the monitoring requirement in
60.4209(a). The engine meets the requirements in 60.411(f) by limiting the non-
emergency usage to 50 hours per calendar year and the maintenance checks and readiness
testing to 100 hours per calendar year. This hospital appeared to be complying with the
NSPS 41 and NESHAP 4Z.
This hospital uses ethylene oxide in the four exempt sterilizers/aerators(ID No. I-EOS)
for the sterilization and fumigation of surgical instruments. No controls have been
installed on the four ethylene oxide sterilizers/aerators. Ethylene oxide is classified as a
hazardous air pollutant(HAP),toxic air pollutant(TAP) and volatile organic compound
(VOC). The four sterilizers/aerators are subject to 40 CFR 63 NESHAP, Subpart
Frye Regional Medical Center
February 14,2019
Page 13
WWWWW or 5W "National Emission Standards for Hospital Ethylene Oxide
Sterilizers" (also known as Generally Achievable Control Technology or GACT Subpart
WWWWW or 5W).
NC DAQ sent a letter dated September 17,2008 identifying this hospital as being
potentially subject to the NESHAP 5W and requested an initial notification form be
submitted by October 15, 2008, and initial notification of compliance status form is
submitted by June 27, 2009 both to NCDAQ and USEPA. This office received the
initial notification form on October 14, 2008 and the initial notification of compliance
form required by NESHAP 5W'on January 16, 2009. This hospital has copies of these
notification forms.
This hospital is required by NESHAP 5W to implement a management practice to
sterilize full loads of items having a common aeration time, except under medically
necessary circumstances; keep copies of sterilization cycle records (date and time of each
sterilization cycle; run full or not; and note if not run full that it was medically
necessary); keep records for five years following the date of each record(onsite for at
least two years and offsite for remaining three years); and keep a copy of the initial
notification of compliance status.
The sterilization cycle records for the four sterilizers/aerators (ID No. I-EOS)were
provided by Ms. Tiffany Phillips, sterile processing supervisor(828 315-5896). I
observed that sterilization cycle records for four sterilizers/aerators (ID No. 1, 2, 3 and 4)
contained the date and time of each sterilization cycle, and whether the cycle was run full
or not. The partial loads are documented in these records as being medically necessary.
These records also contained the equipment being sterilized and paper strip charts of each
sterilization cycle. These records are kept by this hospital for five years. The ethylene
oxide sterilizers/aerators appeared to be in compliance with NESHAP Subpart 5W.
j. Condition A. 11. Avoidance Condition for Area Sources Subject to 40 CFR 63 Subpart
JJJJJJ(611-In accordance with 15A NCAC 2Q .0317,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. B 1 and 132). Per 40 CFR 63.11195(e),these/this source(s)
is/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).
i. The permittee shall maintain records that document the time periods when liquid
fuel is fired and reasons the liquid fuel is fired.
ii. If the permittee fires liquid fuel for reasons other than gas curtailment, gas supply
interruptions, startups, or for periodic testing on liquid fuel,the Permittee is no
longer exempt from Subpart JJJJJJ(6J). As required by 40 CFR 62.11225(g),the
Permittee must provide notice within 30 days of the fuel switch. The notification
must identify:
Frye Regional Medical Center
February 14, 2019
Page 14
A. The name of the owner or operator of the affected source,the location of
the source,the boiler(s)that have switched fuels, and the date of the
notice.
B. The date upon which the fuel switch occurred.
C. As required by 40 CFR 63.11210(h),the permittee must demonstrate
compliance within 180 days of the effective date of the fuel switch.
Observed. This hospital will only burn No. 2 fuel oil in times of curtailment, gas supply
interruptions, startups, or for periodic testing. No curtailment of the two boilers(ID Nos.
B 1 and 132)occurred from January 1, 2017 to present date. The periodic testing for the
tune-up of each boiler on No. 2 fuel oil is conducted for eight hours once a year. The
periodic testing is not exceeding 48 hours per boiler during any calendar year.
Therefore,the two natural gas/No. 2 fuel oil-fired boilers(ID Nos. B 1 and B2) 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). Compliance with this stipulation is indicated.
k. Condition A. 12. Toxic Air Pollutant Emissions Limitation Requirement-Pursuant to
15A NCAC 2Q .0711 "Emission Rates Requiring a Permit" for each of the below listed
toxic air pollutants (TAPs),the permittee has made a demonstration that facility-wide
actual emissions,where one or more emission release points are obstructed or non-
vertically oriented, do not exceed the Toxic Permit Emission Rates (TPERs) listed in 15A
NCAC 2Q .0711(a). The facility shall be operated and maintained in such a manner that
emissions of any listed TAPs from the facility, including fugitive emissions,will not
exceed TPERs listed in 15A NCAC 2Q .0711(a).
Carcinogens [Chro
nic Acute Systemic Acute
Pollutant (lb/yr) Toxicants Toxicants Irritants
(lb/day) (lb/hr) (lb/hr)
Acetaldehyde(75-07-0) �_ �- � 6.8
Acrolein(107-02-8) F0.02
F F
Benzo(a)pyrene (Component
of 83329/POMTV& 2.2
56553/7PAH) (50-32-8)
Beryllium Metal(unreacted)
(Component of BEC)(7440- 0.28
41-7)
Chromium (VI) Soluble
Chromate Compounds 0.013
(Component of CRC)
(So1CR6)
Fluorides (sum of all fluoride
compounds as mass of F ion) FO.34 0.064
(16984-48-8)
Frye Regional Medical Center
February 14, 2019
Page 15
!Formaldehyde (50-00-0) j f I 1 0.04
Hexachlorodibenzo-p-dioxin
1,2,3,6,7,8 (57653-85-7) 0.0051 ' 1
Hexane, n-(110-54-3)~w `�y —�- 23
Hydrogen chloride
l
!(hydrochloric acid) (7647- 0.18
101-0)
Manganese &compounds F_ {
I(MNC) 0.63
'Mercury, vapor(Component F0.013 1 '
_
of HGC) (7439-97-6)
!Methyl chloroform(71-55-6) �� 250 64
Nickel metal(Component of 0.13 ! �^
INIC) (7440-02-0)
Tetrachlorodibenzo-p-dioxin,
l2,3,7,8- (Component of 0.0002
1CLDC & 83329/POMTV)
1(1746-01-6) , !
!Toluene (108-88-3) 98 I 1 4
1Xylene(mixed isomers) 57 16.4
(1330-20-7)
1
Observed. In the past,this hospital operated a medical waste incinerator,which emitted
TAP emissions above its TPERs limits. The medical waste incinerator was removed in
July 2000. Historically, once a facility is triggered into the toxics program for specific
toxic air pollutants(TAPs)then the TAPs remain on the permit regardless of the emission
rates. The combustion of natural gas and fuel oil does emit specific TAPs listed in the
above table.
The last air permit review for 2Q .0711 indicated that this facility combusted 63.67
million scf of natural gas and 408 gallons per year of No. 2 fuel oil in the boilers (ID Nos.
B 1 and 132)and 24 hours per year of operation for each emergency generator(ID No.
EGl and EG4) in 2013. The two boilers combusted less natural gas and fuel oil in 2017
and 2018 than in 2013. The hours of operations for each emergency generator(ID Nos.
EGl and EG4)were less in 2017 and 2018 than in 2013. The emission limits for 2Q
.0711 are not being exceeded. Compliance with this stipulation is indicated.
8. NSPS/NESHAP Review:
a. The two diesel-fired engines(ID Nos. EG 1 and EG4) at this institutional facility are only
used in case of emergencies. The two diesel-fired engines meet the definition of an
emergency RICE in 40 CFR 63.6675. The two engines are considered existing area
sources in 40 CFR Part 63,NESHAP, Subpart ZZZZ(4Z) because these engines
commenced construction before the rule applicability date of June 12, 2006. According
to 40 CFR 63.6585, existing emergency engines at institutional facilities are not subject
to NESHAP Subpart ZZZZ(4Z). Therefore,the two diesel-fired engines (ID Nos. EG 1
Frye Regional Medical Center
February 14, 2019
Page 16
and EG4)are not subject to 40 CFR Part 63,NESHAP, Subpart ZZZZ(4Z).
b. The exempt emergency diesel-fired generator(ID No. I-EG5) is subject to 40 CFR Part
63,NESHAP, Subpart ZZZZ(4Z) as a new-source, since applicability date of the
NESHAP Subpart 4Z rule is commenced construction of the engine on or after June 12,
2006.
C. The exempt emergency diesel-fired generator(ID No. I-EG5) is also subject to 40 CFR
Part 60,NSPS Subpart IIII (41), since the applicability dates of the NSPS Subpart IIII
(4I)rule is constructed (ordered) after July 11, 2005 and manufactured after April 1, 2006
of the engine. According to 40 CFR 63.6590(c),the new engine complies with 4Z RICE
NESHAP by complying with NSPS Subpart 41.
d. The four ethylene oxide sterilizers(ID No. IEOS) are subject to 40 CFR 63 NESHAP,
Subpart WWWWW or 5W "National Emission Standards for Hospital Ethylene
Oxide Sterilizers."
e. . The two boilers (ID Nos. B 1 and 132)are subject to 40 CFR Part 60, Subpart Dc—
"Standards of Performance for Small-Industrial- Commercial-Institutional Steam
Generating Units," since these boilers were constructed after June 9, 1989 with a
maximum heat input capacity greater than 10 million Btu per hour.
f. The two boilers(ID Nos. B i and 132)are not subject to 40 CFR Part 63,National
Emission Standards for Hazardous Air Pollutants(NESHAP)for Industrial, Commercial,
and Institutional Boilers Area Sources Subpart JJJJJJ or 6J, since the two boilers are only
burning natural gas. This hospital will only burn No. 2 fuel oil in the two boilers (ID
Nos. B 1 and 132)during times of gas curtailment, gas supply interruptions, startups, or for
periodic testing(not to exceed combined total of 48 hours per boiler during any calendar
year).
g. The fire pump engine at this hospital is not subject to NESHAP Subpart 4Z, since it is
electrically powered.
9. Summary of changes needed to the current permit:
a. The underground fuel oil storage tanks (10,000 and 15,000 gallons) for the boilers (ID
Nos. B1 and 132) and emergency generators (ID Nos. EG1, EG4 and I-EG5) should be
listed in the insignificant/exempt activities during the next permit revision.
b. The three aboveground day tanks(100 gallons capacity, each) store diesel fuel for each of
the emergency generators (ID Nos. EG1,EG4 and I-EG5). The three diesel fuel
aboveground day tanks should be listed in the insignificant/exempt activities during the
next permit revision.
C. The electronic yellowsheet for permit changes needed has been completed and placed in
the facility's electronic file.
10. Compliance assistance offered duringthe he inspection:
None.
Frye Regional Medical Center
February 14, 2019
Page 17
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.
DLC:Ihe
c: MRO File
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Personal/DLC/Joe Foutz/1800194_Frye Regional Medical Center/INSPECT_20190214.docx