SUNY Westchester Community College Air Emissions Permit Program Latest Revision Date January 2, 2016 Previous Revision Date June 12, 2015.

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1 SUNY Westchester Community College Air Emissions Permit Program Latest Revision Date January 2, 2016 Previous Revision Date June 12, 2015 Air Emissions Permit Program Contents I. Air Permitting Introduction II. State Facility Air Registration III. Westchester County Combustion Certificates to Operate IV. Federal Boiler MACT V. RICE MACT / NSPS VI. Spray Booths VII. Laboratory Ventilation I. AIR PERMITTING INTRODUCTION: Air pollutant emissions, pollution control equipment, and associated operations and maintenance are regulated in accordance with various local state and federal statutes. These include the federal Clean Air Act Amendments of 1990 (CAAA), New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAPs), Prevention of Significant Deterioration (PSD), New Source Review (NSR), Protection of Stratospheric Ozone, New York State Department of Environmental Conservation (NYSDEC), and Westchester County, NY Department of Health (WCDOH). Within New York State, the (NYSDEC) administers the federally enforceable air permitting program. In particular, under 6 NYCRR Part 201, owners and/or operators of air contamination sources are required to obtain a Title V Permit, State Facility Permit, or Minor Facility Registration based on the type of emission sources and the facility s total potential and actual emissions. Each of the permit types are described below. Title V Permitting 1

2 Any source meeting the Title V Threshold criteria found in Table 1 must apply for and obtain a Title V Permit. Westchester County is in a nonattainment zone for Particulate Matter (PM) and moderate nonattainment for ozone, which is regulated by NOx and VOC precursors. Areas designated as nonattainment zones have lower emission thresholds for PM, NOx, and VOC than areas in attainment. The lower limits are expressed in Table 1. Table 1: Westchester County Permitting Emission Thresholds Westchester County Permitting Emission Thresholds Pollutant Title V Threshold (tons/year) State Permit Threshold (tons/year) Registration (Cap by Rule) Threshold (tons/year) Oxides of Nitrogen (NOx) > 100 < Sulfur Dioxide (SO2) > 100 < Carbon Monoxide (CO) > 100 < Volatile Organic Compounds (VOC) > 50 < Hazardous Air Pollutants (HAPs)* > 10 / 25 < 10 / Particulates (PM) > 50 < Carbon Dioxide Equivalents (CO2e) > < 100,000 50,000 *Single HAP / Combination of HAPs State Facility Permit Any facility that is not subject to Title V permitting requirements, and whose potential emissions meets the State Permit Thresholds in Table 1 above, is eligible for a State Facility Permit. If it is determined that a facility's potential emissions exceed the Title V Threshold, but actual emissions meet the State Permit Thresholds, the facility may opt to avoid obtaining a Title V Permit by implementing federally enforceable permit conditions to "cap" emissions below Title V Thresholds. Examples of federally enforceable permit conditions include but are not limited to enforcing a limitation of fuel usage, hours of operation, or production. Minor Facility Registration 2

3 Any facility whose annual potential emissions are less than the Registration Threshold in Table 1 is eligible for a Minor Facility Registration. If the facility s potential emissions are above the Minor Facility Registration, but the actual emissions are less than the Registration Threshold, the facility may cap the emissions at the Registration Threshold and obtain a Minor Facility Registration. Exempt and Trivial In addition, 6 NYCRR Part and 3.3 list exempt sources and trivial activates. The exempt / trivial sources do not require permits, but they must be considered in the calculation of total emissions from a facility when determining Title V applicability and total emissions from a facility for State WCC Status: A review of the emission sources on-site was conducted in September, 2012, potential and actual emissions were calculated to determine the facility s permitting requirements. AP-42 emission factors were used to calculate the criteria pollutant emission sources from the various combustion sources on-site. Actual emissions were based on energy tracking information provided by the facility for Potential emissions were calculated assuming each combustion unit operates 8,760 hours per year at the maximum rated capacity (e.g. horsepower, MMBtu/hr). Total facility-wide actual and potential emissions are summarized in the table below, along with the Title V emission thresholds for Westchester County and Minor Facility Registration emission thresholds: Table 2: Facility Wide Emissions Summary Facility Wide Emissions Pollutant Title V Threshold Cap By Rule Limit Potential Actual tons/year tons/year tons/year tons/year NOx SO CO VOC HAP PM CO2e 100,000 50,000 84,041 3,755 II. STATE FACILITY AIR REGISTRATION 3

4 Since the facility s annual potential to emit NOx and SO2 is greater than the Title V threshold but the actual emissions are less than the Cap by Rule limits, Westchester Community College is eligible for a Facility Registration. The facility maintains a Facility Registration which was initially issued on May 5, 2005, and it is located in the EHS Office files. An application to update the Registration to more accurately represent current conditions at the College was submitted to NYSDEC Region 3 on April 16, The facility is responsible for the following: Operating Requirements: Emission Limits Facility-Wide emissions must be below the Registration Threshold stated in Table 1 above. Opacity Limit Combustion units may not emit smoke with an opacity greater than 20% (six minute average). Fuel Oil Sulfur Limit Fuel oil may not contain more than 0.37 % sulfur by weight. Recordkeeping Requirements: Emission Tracking Emissions must be tracked on a 12 month rolling basis to ensure that the emissions remain below the Cap by Rule threshold. A special facility wide emission tracking spread sheet entitled 12 Months Rolling Average Tracking Sheet is used by the EHS Manager to track emissions on a twelve month rolling average through inputting monthly fuel purchase records, supplied by the accounting office (Carolyn Lancaster), into the spreadsheet which uses standard combustion units emission factors to calculate the emissions. Fuel Oil Certification A copy of each fuel oil certification which includes the sulfur content (below 0.37 wt. %) of the fuel for each delivery must be maintained on-site for at least five (5) years. Reporting Requirements: None Note: If any new sources are added, or existing sources are modified an evaluation of those sources must be performed to ensure compliance. III. WESTCHESTER COUNTY COMBUSTION CERTIFICATES TO OPERATE: The Westchester County Department of Health (WCDOH) requires a certificate to operate fuel oil fired stationary combustion installations with a rated capacity of 1.0 MMBtu/hr or greater according to Section of the Westchester County Sanitary Code. 4

5 Fourteen (14) of the boilers which exhaust to eight (8) emission points (shared stacks) throughout the facility. The boilers have a heat input greater than 1,000,000 Btus, and have the capability to fire number 2 fuel oil, and therefore require a certificate to operate from the WCDOH. Please note that while the boilers have the capacity to fire number 2 fuel oil, they typically fire only on natural gas. The eight (8) emissions points require a WCDOH certificate to operate. These permits are on file in the EHS Office. Operating Requirements: A combustion installation must not discharge smoke having opacity greater than or equal to 20 percent for any time period, as determined by a trained certified observer using USEPA Method Nine, except during startup or emergencies. Recordkeeping Requirements: Signed copies of the certificates to operate must be maintained on-site for at least five (5) years. Reporting Requirements: None Exemptions: Emergency generators and fire pumps are exempt from permitting according to Westchester Community College maintains thirteen (13) generators, and three (3) electric fire pumps which are exempt and therefore do not require a WCDOH certificate to operate. IV. FEDERAL BOILER MACT: Fuel oil fired boilers are subject to federal National Emission Standards for Hazardous Air Pollutants (NESHAPS). These requirements are set forth in 40 CFR Part 63 Subpart JJJJJJ and are known as Boiler MACT. Fuel oil fired boilers that have a maximum input rating between 1.0 and 10 MMBtu/hr are subject to less stringent requirements than those with an input rating greater than 10 MMBtu/hr. Initial notifications for applicable boilers were required to be submitted to the EPA by September, Westchester Community College maintains six (6) fuel oil fired boilers, fifteen (15) dual fuel fired boilers, six (6) natural gas fired boilers, one (1) propane fired boiler and twelve (12) hot water heaters. Fifteen (15) of the fuel oil and dual fuel fired boilers, reviewed have a heat input rating between 1.0 and 10 MMBtu/hr and therefore are subject to the requirements listed below. Operating Requirements: 5

6 Startup / Shutdown The facility must minimize the boiler s startup and shutdown periods following the manufacturer s recommended procedures. Biennial Tune-up The facility must conduct a tune-up of each affected boiler at least every two (2) years. The first tune-up is due by March 21, Recordkeeping Requirements: Tune-up records and the initial notifications should be maintained on-site for at least five (5) years. Reporting Requirements: An initial notification stating the boilers that are affected by the regulation must be submitted to the EPA. The WCC Boiler MACT Notifications were submitted to USEPA Region 2 and NYDEC Region 3 on April 16, Copies are in EHS files. Exemptions: The natural gas and propane boilers are exempt from Boiler MACT. Additionally, any small boiler that has a capacity of less than 120 US gallons, 160 psig, and 210 F are considered to be hot water heaters and are exempt from this regulation. This includes the twelve hot water heaters observed during the inventory. Note: If any new sources are added, or existing sources are modified an evaluation of those sources must be performed to ensure compliance. V. RICE MACT/ NSPS: Reciprocating Internal Combustion Engines (RICE), which include generators and non-electric fire pumps, are subject to either 40 CFR 63 Subpart ZZZZ (RICE MACT) or 40 CFR 63 Subparts IIII or JJJJ (NSPS). Depending on the size and the rating of each unit, various requirements (emission limits, maintenance and testing requirements, etc.) apply. If a RICE unit is used only for emergency purposes (as defined by the regulations) in an institutional setting it is exempt from most requirements. WCC Status: Westchester Community College maintains thirteen (13) RICE units on-site. The units, all generators are all considered institutional emergency generators and therefore exempt, provided that they do not exceed the following operation limits listed below. Operating Requirements: Each generator must not exceed the following operating limits: 50 hours per year for maintenance and testing 50 hours per year for non-emergency use 6

7 Unlimited hours for emergency purposes Non-resettable hour meters must be installed on each unit In addition, the 50 hours per year for non-emergency use cannot be used for peak shaving, as part of an Emergency Demand Response Program (EDRP), or to generate income for a facility to supply power to an electric grid. Recordkeeping Requirements: The run times for each generator and the reason for use (Emergency, Non-Emergency, EDRP, Maintenance and Testing) must be logged to ensure that it does not exceed the operating limits listed above. The logs must be maintained on-site for at least five (5) years. Reporting Requirements: None Note: If any new sources are added, or existing sources are modified an evaluation of those sources must be performed to ensure compliance. VI. SPRAY BOOTHS: The WCDOH requires a certificate to construct and operate a spray booth, if the source is in operation. Please note that there is no emission threshold, so any amount of material released will require a certificate to construct and operate. Pursuant to 6 NYCRR 228-1, spray paint booths utilizing aerosol spray cans are exempt from permitting, if the facility s total VOC emissions are below 25 tons per year. Findings: The facility has a spray paint booth which is not currently in operation. Since the booth is not in operation, it is not considered an emission source according to the WCDOH. If the booth is used at any point, it will become an emission point, and will require a WCDOH permit to construct and operate if anything more than spray paint cans are use in the booth. To avoid state requirements, the facility should cap its VOC emissions to below 25 tons per year as stated in 6 NYCRR Operating Requirements: The facility must cap its VOC use to below 25 tons per year. 7

8 Recordkeeping Requirements: The facility must track its VOC use on a 12-month rolling basis. Reporting Requirements: If the spray booth is used, the facility must submit a certificate to construct and operate to the WCDOH for the emission source. VI. LABORATORY VENTILATION: WCC also operates nineteen (19) laboratory hoods. Based on telephone conversation with Natasha Court of the WCDOH it is understood that these laboratory hoods are exempt from Westchester County permitting, due to their use in an academic institution. The NYSDEC exempts laboratory ventilation operations from permitting pursuant to 6 NYCRR Exemptions: The laboratory hoods and ventilation systems are exempt from state and county permitting. 8