Healthcare and Air QualityH2E Conference - Dec 6, 2007

K-State Pollution Prevention InstituteRyan Hamel

K-State SBEAP

K-State UniversityEngineering ExtensionPollution Prevention Institute (PPI)Small Business Environmental Assistance Program (SBEAP)

• Similar program in every state - req’d by Clean Air Act

• Provides air-focused technical assistance to small- and medium-sized businesses

– Permitting and reporting requirements– Regulatory compliance– Emissions/waste reduction

K-State SBEAP Services

• Environmental hotline (800.578.8898)

• On-site visits

• Targeted regulatory or industry-specific workshops

• Publications (hard copy or electronic)Fact sheets, manuals, E-tips

• Web-based resources and training: www.sbeap.org

• Funded by KDHE

• Potential-to-emit (PTE)

• Air regulations (healthcare-related)

• Boilers

• Emergency generators

• Ethylene oxide sterilizers

• Changes to emission sources

Presentation Overview

Potential to Emit (PTE)

Represents the source’s maximum capacity or worst case scenario emissions

The maximum amount of air pollution your facility can emit if:– Each process operated at 100% of its capacity– All equipment is operating 24/7 (8,760 hrs/yr)– Materials that emit the most air pollution are processed

100% of the time– No pollution control equipment is used

Calculating PTE

Calculation methods– Emission factors– Material balances– Other approved methods

• Computer programs• Industry-specific emission factors• Approved by KDHE on an individual basis

PTE

Emission factors– Manufacturer’s emission factors are best– AP-42 is a compilation of factors for specific

processes accepted by EPA• www.epa.gov/ttn/chief/ap42/index.html

– Emission factors software and tools• www.epa.gov/ttn/chief/efpac/efsoftware.html

PTE

Material balance– Product in = product out (assumes constant

inventory)– Product in can be the purchased material– Product out can be the emissions– Material balance can be applied to individual

units or the whole process

Air regulations

• KAQA Standards– Air construction approval/permit – Operating permit

• NSPS (New Source Performance Standards)

• PSD (Prevention of Significant Deterioration)

• NESHAP (National emission standard for hazardous air pollutants) / MACT (Maximum achievable control technology)

Permitting Web site

www.kdheks.gov/air-permit/download.html

Includes forms for:• Construction approvals• Construction permits• Operating permits (Class I and II)• Emergency generators• Boilers (available Feb. 20)

Construction ApprovalIf your PTE exceeds these thresholds, then you’ll need a construction approval:

Source: What is the Kansas Air Quality Act? - www.sbeap.org/publications/airqual.pdf

Construction Permit

If your PTE exceeds these thresholds, then you’ll need a construction permit:

Source: What is the Kansas Air Quality Act? - www.sbeap.org/publications/airqual.pdf

Operating Permit (Class I)

Required if PTE exceeds these thresholds:– 100 tons per year NOx, SOx, PM10, VOC, CO– 10 tons per year of any single hazardous air

pollutant (HAP)– 25 tons per year of combined HAPs

Operating Permit (Class II)

• If actual emissions are below the Class I thresholds but PTE is above – then limit PTE and apply for a Class II operating permit

• A Class II permit requires minimal record keeping and is simpler (and cheaper) than maintaining a Class I permit

• Class II permit-by-rule (KAR 28-19-561-564)

Operating Permit (Class II)

Limit PTE by– Implementing pollution prevention

• Change the material• Change the process• Change the technology

– Limiting process rate– Limiting hours of operation– Limiting amount of material processes– Installation of a pollution control device

Small Boiler NSPS

NSPS = New Source Performance Standards– 40 CFR 60.42 subpart Dc– Installed or modified after June 9, 1989– Heat input capacity is between 10 and 100

MMBTU/hr

Subject to NSPS?

The heat input capacity of the boiler

is between 10 and 100 MMBtu/hr

The boiler was constructed, modified, or reconstructed after June 9, 1989

The boiler is not subject to NSPS requirements

Yes

No

Complete the KDHE boiler form

Yes

YesThe heat input capacity is less than 10 MMBtu/hr

Heat input capacity is greater than 100 MMBtu/hr, subject to large boiler NSPS requirements

No

NSPS (continued)

• Regulates NOx, SOx, and PM (for boilers firing coal, distillate and residual oil, and wood).

• Dictates recordkeeping requirements for all fuels, including natural gas.

• One way to comply: limit the weight percent sulfur of the fuel to 0.5% or less

• KDHE will have application form for small boilers

PSD

• PSD = Prevention of Significant Deterioration• K.A.R. 28-19-350 or 40 CFR 52.21 • PSD affects:

– New major sources or major modifications – Those located in an attainment or unclassified area

• Requirements include installation of best available control technology (BACT), analyses, etc.

NESHAP and MACT

• Apply to sources of HAPs (hazardous air pollutants)• Approximately 188 HAPs• Known or suspected to cause cancer or other

serious health affects• NESHAP (National Emission Standards for

Hazardous Air Pollutants) are health-based standards

• MACT (Maximum Achievable Control Technology) are technology-based standards

NESHAP and MACT

• Examples: – Medical waste incinerators– Perchloroethylene from dry cleaners– Halogenated solvent vapor degreasers

• Not currently aware of future MACT rules applicable to hospitals, this could change

Penalty Violations

Source: www.kdheks.gov/air-permit/forms/Air_Enforcement_Policy_7_20_05.pdf

Evaluating permit need (boilers)

Identify for all boilers:– Date of installation or modification– Heat input capacity (typically in MMBTU/hour)– Type of fuel (natural gas, fuel oil, etc)

– Low NOX burner (for natural gas-fired boilers)

Evaluating permit need (boilers)

• Use information (from previous slide)

• Use AP-42 emission factors– http://www.epa.gov/ttn/chief/ap42/ch03/index.html

• Emissions can be estimated with this info

• Affected facilities must submit form by June 30, 2008

• If assistance is needed, contact SBEAP

Emergency generators

• Emergency generator definition– Used only for back-up power (not to offset

peak energy usage)– For PTE calculations, assume 500 hours/year

• All emergency generators should be registered with KDHE

• Expedited form available

Expedited form

Source: www.kdheks.gov/air-permit/forms/Emergency_Gen_App.pdf

Ethylene oxide sterilizers

• Does anyone have one?

• Used to sterilize heat- and moisture-sensitive products

• Increase regulatory requirements (NESHAP)

• Contact SBEAP for further assistance

Future Additions or Modifications

• Evaluate PTE for new or modified eqpmt.

• If PTE exceeds construction approval or permit thresholds, contact KDHE– Thresholds: www.sbeap.org/publications/airqual.pdf

– Forms: www.kdheks.gov/air-permit/download.html

• Boiler between 10 and 100 MMBTU/hr, complete the KDHE NSPS Boiler form

Questions or Comments?

Contact InformationRyan Hamel

K-State Pollution Prevention Institute

800.578.8898 or 785.532.4994

rhamel@ksu.edu

www.sbeap.org