AQ_F_1000117_20190227_CMPL_InspRpt

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NORTH CAROLINA DIVISION OF Wilmington Regional Office
AIR QUALITY Novant Health Brunswick Medical Center
NC Facility ID 1000117
Inspection Report County/FIPS: Brunswick/019
Date: 02/27/2019
Facility Data Permit Data
Novant Health Brunswick Medical Center Permit 10031 /RO1
240 Hospital Drive North East Issued 10/15/2014
Bolivia,NC 28422 Expires 9/30/2022
Lot: 34d 1.8390m Long: 78d 15.6670m Classification Small
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
John Melcher Shelbourn Stevens John Melcher NSPS: Subpart Dc, Subpart IIII
Facility Supervisor President Facility Supervisor
[phone] [phone]
910 279-4056 cell 910 2794056 cell
Compliance Data
Comments: Inspect facility as scheduled.
Inspection Date 02/21/2019
Inspector's Name Scott Sanders
Inspector's Signature: Scott Sanders C— — Operating Status Operating
Compliance Code Compliance-inspection
' I Action Code FCE
Date of Signature: 2/27/19 '1I�q On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR: YYYY 1
TSP SO2 NOX VOC CO PM10 * HAP
2013 0.3750 0.0350 4.90 0.2750 4.12 0.2800 ---
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
*** Directions to the facility are as follows:From Wilmington,take the US-17/Shallotte/Myrtle Beach exit onto Ocean
Highway East(US-17 South). Go 21.5 miles. Turn right onto Brunswick Medical Center Drive. Park in the parking
lot behind the facility and enter the premises through the shipping/receiving area.

Novant Health Brunswick Medical Center
February 27,2019
1. Contact was made with John Melcher, Supervisor Plant Engineering Services.
2. Applicable regulations for Novant Health Brunswick Medical Center are as follows:
2D .0202 "Permit Renewal and Emission Inventory Requirement"
2D .0503 "Particulates from Fuel Burning Indirect Heat Exchangers"
2D .0515 "Particulates from Miscellaneous Industrial Processes"
2D .0516 "Sulfur Dioxide Emissions from Combustion Sources"
2D .0521 "Control of Visible Emissions"
2D .0524 1140 CFR 60, Subpart Dc and Subpart IIII (4I)"
2D .0535 "Excess Emissions Reporting and Malfunctions"
2D .0540 "Fugitive Dust Control Requirement"
2D .1111 1140 CFR 63 Subpart ZZZZ (4Z)—Reciprocating Internal
Combustion Engines"
2Q .0317 1140 CFR Part 63 Subpart JJJJJJ (6J) Avoidance"
3. The following equipment is contained in Permit No. 10031R01:
Emission Emission Source Control Control System
Source ID Description ISystem ID Description
ES-1 (NSPS) one boiler(2009 model,
natural gas/No. 2 fuel N/A N/A
oil fired, 400 hp/16.8
j MM Btu/hr heat input)
ES-2 (NSPS) one boiler (2009 model,
natural gas/No. 2 fuel N/A N/A
oil fired, 400 hp/16.8
MM Btu/hr heat input)
ES-3 (NESHAP, one emergency back-up
NSPS) generator(2009 model,
No. 2 diesel fueled, N/A N/A
rated at 1,500 kw/2,328
hp)
ES-4 (NESHAP, one emergency back-up
NSPS) generator(2009 model,
No. 2 diesel fueled, N/A N/A
rated at 1,500 kw/2,328
hp)
4. This facility opened and started receiving patients on July 31, 2011. The boilers were
manufactured in December 2008 and delivered to the facility in September 2009.
Testing for the boilers began on May I, 2010 with the ultra-low sulfur No. 2 fuel oil <
15 ppm (.0015%). Conversion and startup of the boilers to natural gas occurred on
November 8, 2010. Compliance was achieved with the NSPS startup notifications for
the boilers.
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Novant Health Brunswick Medical Center
February 27,2019
5. The first-time air permit renewal was done on October 15, 2014. The emissions
inventory report was completed on time. The facility requested a name change from
Brunswick Novant Medical Center to Novant Health Brunswick Medical Center.
Specific Condition a. 9 was added to the permit—40 CFR Part 60, NSPS Subpart IIII
for the two existing 2009 model generators. The previous permit version (R00)
included the adhoc 4I language, which explained the requirements of 41 very
thoroughly with the 4Z header. In this permit, the regulations pertaining to 41 from
permit writer were added as the new A.9 condition. Also, Specific Condition A.11 was
added to include 40 CFR Part 63 Subpart JJJJJJ(6J)Boiler GACT avoidance condition
(2Q .0317) for the two existing boilers. The previous permit (R00) included the 41
requirements, but when that permit was initially drafted the permit writer did not have
any specific language for the 41 requirements and an adhoc condition explaining the 41
requirements was added in the permit — under the 4Z NESHAP heading (former
condition A.8.). Specific Condition A.8 in the previous permit revision for the
NESHAP Subpart ZZZZ will remain as a header and will explain that compliance with
the 4Z NESHAP will be demonstrated by meeting the 41 NSPS rule. This revision
(RO1)will use the language already existing in the permit writer(see Specific Condition
A. 9. for 4I). The 2Q .0317 Avoidance Condition for Area Sources subject to 40 CFR
Part 63 Subpart JJJJJJ (6J) is added in this permit (see Specific Condition A.11) since
the two boilers burn natural gas. If the boilers are switched to No. 2 fuel, they will be
subject to the Boiler GACT Subpart JJJJJJ (6J) requirements.
6. On April 5, 2017, the facility began operating a newer and smaller 150 hp boiler. The
400 hp boilers are too large for a facility that is sized this small. This new 150 hp boiler
runs as lead and one of the 400 hp boilers serves as backup. Boiler No. 2 (ES-2) was
dry stored in September of 2017. All the fluids were drained out and dried at that time.
Dean Carroll (DAQ WiRO Permit Coordinator) was notified about the addition of the
new 150 hp boiler before it began operating. It was determined that this new boiler
would be allowed to operate without a permit modification per the 2Q .0318 rule —
"Changes Not Requiring a Permit Revision". Refer to a previously attached email
between John Melcher and Dean Carroll. The following info was obtained from the
new boiler's nameplate: 150 hp, date 2015, 150 psi, 5,175 Ib/hr, natural gas/# 2 oil,
Model WB-A2-3P, Serial No. 15150P-WBLGL-08. A new and efficient Limpsfield
burner is installed on the unit. This boiler was operating during the during the
inspection. It was being fired with natural gas and was operating at 0% opacity. The
400 hp boiler (ES-1) was not operating during the inspection. This facility only runs
one boiler at a time (mainly the new 150 hp) and will rotate the usage to the 400 hp
boiler once every two weeks for 3 hours. The boilers use natural gas as a primary fuel
unless curtailment occurs. Brady Boiler Services does quarterly inspections and annual
maintenance on the boilers.
7. The facility is in compliance with their semi-annual NSPS recordkeeping and reporting
requirements pertaining to the boilers. The first semi-annual report was due by January
30, 2012 and was received on time. Subsequent reports have been received on time
and have indicated compliance. A copy of the last semi-annual report is attached(time
period July 1, 2018 —December 31, 2018). The facility last got curtailed for 72 hours
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Novant Health Brunswick Medical Center
February 27,2019
during very cold weather from January 7, 2017 @ 10 am to January 10,2017 @ 10 am.
2,160 gallons of ultra low sulfur No. 2 fuel oil were burned in each boiler (4,320 total
gallons) during that time. Each boiler burns approximately 120 gallons of ultra low
sulfur No. 2 fuel oil (4 hours)during each semi-annual period due to required quarterly
periodic testing.
8. The facility is subject to the NSPS I1II rule since the generators were constructed after
June 12, 2006. Compliance with the rule has been achieved. By complying with the
NSPS 4I Cl RICE regulations, the facility will also be in compliance with the
requirements of the NESHAP ZZZZ (4Z) regulations. The last load of No. 2 fuel oil
was received on September 12, 2018 from INA Oil in Southport ahead of impending
Hurricane Florence. 1,000 gallons of No. 2 fuel oil were received at that time. The
facility typically receives one delivery every two years just to top off their tanks or if
there is an impending hurricane. Certifications of the No. 2 fuel oil indicate that the
sulfur PPM < 15 and the cetane index is > 40 and are attached to the semi-annual
reports. This ultra low sulfur No. 2 fuel oil is used in the generators and is also used
for boiler backup fuel. There are two (2) 10,000-gallon storage tanks at the facility that
store the No. 2 fuel oil. The No. 2 fuel oil is sampled two times per year (refer to
attachments). The generators were equipped with a non-resettable hour meter prior to
startup of the engines to comply with NSPS IIIt. The generators are each limited to
100 hours per year for maintenance checks and readiness testing per NSPS 1III. Each
generator only runs about thirty (30) minutes per month for maintenance checks and
readiness testing. This is done on the last Thursday of every month. On one day every
third year(36 months), each generator must run four(4) hours continuously under load
at 30%of the nameplate rating for maintenance checks and readiness testing. This was
done on a day in March 2018, so this won't occur again until 2021. The 100-hour limit
on each generator for maintenance checks and readiness testing per NSPS I111 is easily
being obtained. Generator No. 1 has operated 269.71 total hours since startup of the
unit. Generator No. 2 has operated 275.82 total hours since startup of the unit. 180
gallons of ultra low sulfur No. 2 fuel oil are typically used in each generator during
each semi-annual period (30 gallons per month X 6 months). The generators were not
operating during this inspection. The generators operated for 48 hours during
Hurricane Florence. Gregory Poole performs quarterly maintenance on the generators.
9. The facility is not subject to the Boiler GACT (6J) because it burns natural gas as a
primary fuel unless it is curtailed. It will become subject to 6J if it switches to burning
No. 2 fuel oil as the primary fuel. It would then have 180 days to do a one-time energy
assessment. An initial boiler tune up will be required soon thereafter. The facility does
not think the fuel switch will ever happen unless the price of No. 2 fuel oil becomes
much lower.
10. 5-year compliance history — Compliance has been achieved during this time period.
No NOD's, NOV's, or NRE's have been issued to this facility.
11. Novant Health Brunswick Medical Center is in compliance with Air Quality
regulations.
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