PA DEP SOUTHWEST REGIONAL OFFICE MEMO - GASPgasp-pgh.org/wp-content/uploads/SCI-Laurel-Highlands-review-memo.pdf · coal-fired, Riley Stoker boilers, which were installed in 1950

TO

FROM

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Background:

PA DEP SOUTHWEST REGIONAL OFFICE MEMO

Air Quality Permit File: TVOP-56-00257 Pennsylvania Department of Corrections/SCI Laurel Highlands

Martin L. Hochhauser, P .E. 1-.... '2-~ f.£. Air Quality Eng. Specialist Air Quality Program

Thomas J. Josephffujf Mark R. Gorog, P .E. ./')1/1/(/ !Jf---Facilities Engineerin anager Air Quality Progr

November 30, 2015

Environmental Program Manager Air Quality Program

Review of Application for Title V Operating Permit Renewal Pennsylvania Department of Corrections/SCI Laurel Highlands Somerset Township, Somerset County APS#762921; AUTH #899421 ; PF#261482

On October 11 , 1995, the Department received an application for the initial facility-wide permit for the boiler house at SCI Laurel Highlands. TVOP-56-00257 was issued on January 26, 2000. It incorporated the applicable requirements ofRACT Operating Permit #56-000-257, including a facility limit on coal consumption, which also assured that the facility would be a minor source ofNOx. TVOP-56-00257 was renewed on March 23, 2007.

The primary sources at the powerhouse at SCI Laurel Highlands were three, 27.1 MMBtulhr coal-fired, Riley Stoker boilers, which were installed in 1950. The facility also contained three, 2,235-bhp, 2,235-bhp, and 268-bhp, emergency, diesel generator engines.

On September 15, 2009, the Department received an application to replace this boiler house by constructing a cogeneration powerhouse in a new building. The three emergency generators were the only processes from the old boiler house that would remain in service. Plan Approval (PA) PA-56-002578 for the new powerhouse was issued on July 27, 2010, to authorize construction and temporary operation of one, 44.4 MMBtulhr, landfill gas (LFG)-fueled turbine driving an electrical generator, two 2,233-bhp, SI, LFG-fueled, generator engines, one, 20.3 MMBtu/hr, dual fuel , LFG and NG-fired boiler, and ancillary equipment.

Initial startup of the dual fuel boiler took place on August 22, 2011. The initial stack compliance testing ofthe dual fuel boiler took place on February 21 , 2012. The LFG-fueled engines were

Pennsylvania Department of Corrections SCI Laurel Highlands Operating Permit #TVOP-56-00257

tested on February 22, 2012, and the LFG-fueled turbine was tested on February 23 , 2012. Emissions from the sources, whose construction was authorized under the Plan Approval, were found to be within the limits set by PA-56-00257B, with the exception of formaldehyde emissions from the two LFG-fired engines. Through a second Best Available Technology (BAT) analysis, it was found that each of the two LFG-fueled engines could not operate in compliance with an hourly formaldehyde emission limit of0.79 pounds per hour. It was determined that the emission limit was incorrectly low and no enforcement action was taken. On June 24, 2014, this limit was changed to 1. 70 pounds per engine per hour as a result of a new Best Available Technology (BAT) analysis. Also, an annual time operating limit of 8,400 hours was added for the sum of the time of operation for each of the two LFG-fueled engines. In addition, the annual formaldehyde emission limit from the facility was changed 7.5 tpy to 7.8 tpy.

Plan Approval PA-56-00257B has been extended several times. The current extension expires February 8, 2016. The proposed TVOP contains the ongoing requirements ofPA-56-00257B and will replace it.

The application for renewal ofthe current TVOP was received on September 23 , 2011 . Also, on September 28, 2015, the Department received a request for a GPAJGPl , to authorize the installation of a 27.7-MMBtu/hr, natural gas (NG)-fired, with distillate fuel oil (FO) backup, trailer mounted boiler at SCI Laurel Highlands. This boiler was previously in operation at SCI Mahanoy. Installation and temporary operation of the boiler was authorized by a GP1 on November 23 ,2015, and these requirements are included in the proposed TVOP renewal. Review of the application for TVOP renewal is the subject of this document.

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Emissions and Control:

This proposed permit is for operation of a prison with a powerhouse producing electrical power and steam at a correctional institution known as SCI laurel Highlands, located in Somerset Township, Somerset County. The main sources at this facility are one (1), 44.4 MMBtulhr, Solar Centaur Landfill Gas Turbine, which powers an electrical generator, two (2), 2,233-bhp, SI, Caterpillar Landfill Gas-fueled, Generator Engines, and one (1), 20.3 MMBtu/hr, Dual Fuel (LFG & NG) Boiler.

Supporting equipment at this site includes one siloxane removal system with purge gas and an enclosed flare, two, 9.85 MMBtu/hr, Miura, NO-fired boilers, one, 27.7 MMBtulhr, trailer mounted boiler, and three, 2,23 5-bhp, 2,235-bhp, and 268-bhp, emergency, diesel driven, generator engines.

Sources at SCI Laurel Highlands are shown in Table 1:

ID

034

035

036

037

105

107

108

109

110

Ill

11 2

Table 1 Pa. Department of Corrections - SCI Laurel Highlands (TVOP-56-00257)

Emission Processes and Controls Installation or

Source Name Emission Control Startup, or P A Issue Date

Johnston Dual Fuel Boiler (20.3 07/27/2010

MMBtu!Hr,(LFG/NG)

Miura Natural Gas Boiler 1 (9 .85 MMBtu!Hr) 07/27/20 10

Miura Natural Gas Boiler 2 (9.85 MMBtu!Hr) 07/27/2010

Low NOx Burner and Flue Gas Trailer Mounted Boiler (27.7 MMBtu!Hr, NG/FO) Recirculation, FO use limited to 3/20 12

emergencies . Onan Genset Emergency Diesel Generator Limited to a maximum operation of 400

Pre-1995 (268-bhp, Diesel) hours per year. # 1 Kohler Emergency Generator (2,235-bhp, Limited to a maximum operation of 400

02/ 19/ 1999 Diesel) hours per year. #2 Kohler Emergency Generator (2,235-bhp, Limited to a maximum operation of 400

02/19/1999 Diesel) hours per year. Solar Centaur Landfill Gas Turbine ( 44.4

07/27/20 10 MMBtu!Hr)

Caterp illar, SI, Landfi ll Gas Engine 1 (2,233 bhp) Limited to a maximum operation of 8,400 07/27/20 10

Caterp illar, SI, Landfi ll Gas Engine 2 (2,233 bhp) hours per year for the sum of each of the

07/27/2010 two engines.

Siloxane Removal System Purge Gas Enclosed Flare 07/27/2010

3


Actual air emissions from SCI Laurel Highlands during 2014 are shown in Table 2:


2014 Facility Emissions Criteria Pollutants Carbon Monoxide Nitrogen Oxides

Particulate Matter < 1 0 Microns

Particulate Matter < 2.5 Microns

Sulfur Oxides

Volatile Organic Compounds

Hazardous Air Pollutants (112b HAPs) Acetaldehyde

Formaldehyde

TPY

92.53 21.12

4.69

4.69 9.32

19.90

TPY

0.58 7.60

_fiy~~o~!~}9!ic_ ~~i~ __ __________________________ Q_.?J ____ _ Sum of All HAPs Combined 8.97

Greenhouse Gases TPY

Carbon Dioxide 40,779 Methane 16.44

-~t_r~u_s _O_xJ.d5!~LQ) ______________________________ 0_:_1~ __

Total C02e 41 ,226

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Table 3 shows projected emissions from the sources at the facility:


Projected Facility Emissions Emission Rate (tpy)

Source PM2.s PM IO so2 co NO, voc

Johnston Dual Fuel Boiler 0.09 0.09 5.68 3.26 3. 18 0.35

(20.3 MMBtu/Hr,(LFG/NG) Miura Natural Gas Boiler I

0.33 0.33 0.03 3.61 4.30 0.24 (9 .85 MMBtu!Hr)5

Miura Natural Gas Boiler 2 0.33 0.33 0.03 3.6 1 4.30 0.24

(9.85 MMBtu!Hd Trailer Mo unted Boiler

1.313 1.31 3 0.423 26.9i 4.961 0.503

(27.7 MMBtu/Hr, NG/FO) Onan Genset Emergency Diesel Generator

0.153 0.153 0.11 0.36 2.083 0.1i (268-bhp, Diesel) # 1 Kohler Emergency Generator (2,235-bhp, Diesel)5 0.393 0.393 3.61 2.463 13.41 3 0.393

#2 Kohler Emergency Generator 0.393 0.393 3.61 2.463 13.4 13 0.393

(2,235-bhp, Diesel)5

Solar Centaur Landfill Gas Turbine 5.081 5.081 16.201 57.901 36.791 3.07

( 44.4 MMBtu/Hr)4

Caterpillar, SI, Landfill Gas Engine 1 1.45 1.45 1.98

(2,233 bhp/ 75.4i 10.7i 18.9i

Caterpillar, SI, Landfill Gas Engine 2 (2,233 bhp)4 1.45 1.45 1.98

Siloxane Removal System Purge Gas 0.39 0.39 1.51 4.73 1.42 0.05 Total 15.30 15.30 48.13 242.06 94.62 24.37

I, EmiSSIOns based on permit hm1ts. 2Projected non-FORM HAP emissions are from Source IDs 110 - 0.04 tpy, Ill- 0.15 tpy, & 112-0.15 tpy. 3Emissions are based on AP-42. 4Emissions are based on modified PA-56-00257B (Modified June 24, 20 14.) and splitting of sources. 5Sources were split.

HCHO

0.01

0.00

0.00

0.01 3

0.00

0.00

0.00

7.801

0.00 7.82

All emission values not based on AP-42, were taken from PA-56-00257B TRD (Issued: July 27, 2010, TRD Dated: May 25, 2010 (revised July 26, 20 10)) Values were rounded in spreadsheet shown in Attachment I .

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HAPs

0.17

0.08

0.08

0.223

0.00

0.01

0.01

8.141' 2

0.01 8.72


I. Emission Increases

Plan Approval PA-56-002578 was issued on July 27,2010. Changes were made to the PA under BAT on June 14,2014, because the LFG-fueled Engines could not operate in compliance with the initial formaldehyde emission limit. While the hourly formaldehyde emission limit from each engine was increased, restrictions on their annual hours of operation reduced emissions of other pollutants.

Installation of a boiler (Source 10 037) was authorized by GPA/GPl-56-00257 A, on November 23, 2015. No other changes have made at Laurel Highlands since that time . Therefore, the total increase of each pollutant emission is less than that necessary to be a significant increase in criteria or greenhouse gas emissions under New Source Review. Changes to the emission baseline of SCI Laurel Highlands are shown below:


Ch . th E . . P . f . I f PA 56 00257B J I 27 2010 ange m e miSSIOnS ro ec Ion smce ssuance o - - on UIY ' PMzs PM IO SOz co NOx voc C02e

Source Ton/ Ton/ Ton/ Toni Ton/ Ton/ Ton/ Year Year Yr Yr Yr Yr Yr

6/24/20 14 - Change in the hourly formaldehyde emission limit and addition of

-3 .02 -3.02 -4. 12 -78.60 -11.20 -19.80 -7,522 the hours of operation limit for the LFG-fueled Engines (Source IDs 110 & 111)1

11 /23/20 15- Addition of the Trailer Mounted 1.31 1.31 0.42 26.97 4.96 0.50 14,594

Boiler. (27.7-MMBtu/hr, Source ID 037)2

Total Change -1.71 -1.71 -3.70 -51.63 -6.24 -19.3 7,072 Em1ss1ons based on est1mates m PA-56-002578 TRD.

2 CO & NOx based on limits in GP-1. PM2.s, PM 10, & VOC based on vender estimates. S02 based on 500 PPM sulfur in fuel oil and AP-42 factor for natural gas. Values shown in this table were rounded.

Also, the annual fac ility PTE of formaldehyde was increased by 0.3 1 tons since July 27, 2010, while the annual PTE of all HAPs combined was increased by 0.222 tons.

1 Formaldehyde emission estimate is based on the increase in the LFG Engines emission limit. 2 Emission of all HAPS, other than formaldehyde is based on EPA 's AP-42.

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Regulatory Analysis:

This facility is a major source of air emissions for CO, but is a minor source of all other ~ollutants .

Therefore, SCI Laurel Highlands is a Title V facility and an area source of J:IA-Ps. A review of potentially applicable federal and Pennsylvania air pollution control regulatiOns was made and the results are shown in Table 5:


egu atory natysts R I A I .

Federal Regulations

NSPS

40 CFR Part 60 Subpart D - Standards of Performance No boiler at the facility is larger than 250 MMBtu/hr. for Fossil-Fuel-Fired Steam Generators. Subpart is not applicable .

40 CFR Part 60 Subpart Da - Standards of No boiler at the facility is larger than 250 MMBtu/hr. Performance for Electric Utility Steam Generating

Subpart is not applicable . Units. 40 CFR Part 60 Subpart Db - Standards of No boiler at the facility is larger than 100 MMBtu/hr. Performance for Industrial-Commercial-Institutional

Subpart is not applicable. Steam Generating Units.

Subpart applies to ICI boilers 10- 100 MMBtu/hr constructed after June 9, 1989. Only the Johnson Dual

40 CFR Part 60 Subpart De - Standards of Fuel (~10 & :::;30 MMBTU/hr, gas fueled only, Source ID Performance for Small Industrial-Commercial-

034) and Trailer Mounted (~10 & ::::;30 MMBTU/hr, Institutional Steam Generating Units.

capable of burning natural gas & distillate oil with ::::;0 .5% s, Source ID 037) Boilers have applicable requirements.

40 CFR Part 60 Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage

No tank at the facility stores liquids with a vapor Vessels (Including Petroleum Liquid Storage Vessels)

pressure greater than 0.51 psi. Subpart is not applicable . for Which Construction, Reconstruction, or Modification Commenced After July 23 , 1984.

40 CFR Part 60 Subpart IIII - Standards of No Cl engine at the facility is new enough to be Performance for Stationary Compression Ignition

applicable for this subpart. Subpart is not applicable. Internal Combustion Engines.

40 CFR Part 60 Subpart JJJJ - Standards of This subpart applies to the Sl, landfill gas engines (NSPS engine, >100-bhp, non-gasoline & non-LPG fueled,

Performance for Stationary Spark Ignition Internal Source IDs 110 & 111, each 2,233-bhp) . These engines

Combustion Engines. have applicable requirements under the subpart.

40 CFR Part 60 Subpart KKKK - Standards of This subpart applies to the landfill gas turbine (~10 MMBTU/hr, NSPS turbine, Source ID 109). This turbine

Performance for Stationary Combustion Turbines. has applicable requirements under the subpart.

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NESHAPs 40 CFR Part 63 Subpart YYYY -National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines .

40 CFR Part 63 Subpart ZZZZ -National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines. (RICE)

40 CFR Part 63 Subpart DDDDD- National Emission Standards for Industrial, Commercial, Institutional (ICI) Boilers and Process Heaters. 40 CFR Part 63 Subpart UUUUU- National Emission Standards for Hazardous Air Pollutants (NESHAP) for electric utilities.

40 CFR Part 63 Subpart JJJJJJ -National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial, and Institutional Boilers.

Air Programs

NOx Allowance Program/CAIR/PA CAIR/CSAPR

40 CFR Part 64, Compliance Assurance Monitoring. (CAM)

40 CFR Parts 72, 73 , 75 , 77- Acid Rain Program

40 CFR Part 98 , Mandatory Greenhouse Gas Reporting

The facility is an area source not a major source of HAPs. The subpart is not applicable.

The landfill gas engines (Source IDs 110 & 111} have requirements under Part 60 Subpart JJJJ and therefore, no requirements under this subpart. Under 40 CFR § 63.6585(f}(3}, institutional emergency RICE at area sources that are not obligated to operate for more than 15 hours annually for peak shaving, or load balancing, have no requirements under the subpart. Therefore, the three emergency generator engines (existing, emergency, no peak shaving, Source IDs 105, 107, & 108} have no requirements under this subpart.

The facility is not a major source of HAP emissions. This subpart is not applicable to any source.

No source is an EGU. This subpart is not applicable to any source.

The dual gas-fueled boiler (gas fired boiler, Source ID 034} and two NG-fired boilers (gas fired boiler, Source IDs 035 & 036} have no requirements under this subpart. The Trailer Mounted Boiler (gas fired boiler, Source ID 037} is operated as to meet the definition of a gas-fired boi ler and also has no requirements under the subpart.

These parts are not applicable to any source because no source is an EGU or a large non-EGU. No source at the facility is major for uncontrolled emissions.

No source at the facility can emit sufficient quantities to have applicable requirements under these parts. While the facility's emissions of GHGs require the facility to report these emissions to the federal government, this reporting is not considered an applicable requirement for a TVOP.

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Pennsylvania Air Pollution Control Regulations

25 Pa Code § 123. 1 (Prohibition of Certain Fugitive Emissions)

25 Pa Code § 123.2 (Fugitive Particulate Matter)

25 Pa Code§ 123. 11 (Combustion Units)

25 Pa Code § 123.13 (Processes)

25 Pa Code § 123.21 (General)

25 Pa Code§ 123.22 (Combustion Units)

25 Pa Code § 123.25 (Monitoring Requirements)

25 Pa Code § 123.31 (Odor Emissions)

25 Pa Code § 123.41 (Limitations- Visible Emissions)

25 Pa Code § 123.42 (Exceptions- Visible Emissions)

25 Pa Code § 123.43 (Measuring Techniques)

25 Pa Code Chapter § 127.44 1 (Operating permit terms and conditions)

25 Pa Code Chapter§ 129.14 (Open Burning Operations)

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Section is applicable.


Section is applicable to boilers. (Source IDs 034 -037} Each un it is limited to maximum particulate emission of 0.41b/MMBtu.

Section is applicable to processes that generate particulate that can be measured and do not burn fuel for direct heat transfer. (Source IDs 105 and 107 - 112} Each unit is limited to maximum particulate emission of 0.04 grain/SDCF.

Section is applicable to processes that emit oxides of sulfur and do not meet the definition of combustion process. (Source IDs 105 and 107 -112} Each unit is limited to a maximum emission of 500 PPM, expressed as S02.

Section is applicable to combustion units that emit oxides of sulfur. (Source IDs 034 - 037} Each unit is limited to a maximum emission of 4.0 lb/MMBtu, expressed as S02 .

Section is not applicable.





Section is applicable. Emission restrictions for the facility (Section C, Condition #006, Section D, Source ID 109 - LFG Turbine, Conditions #003,

#004, & #005, Section E, Source Group G02- LFG Engines, Conditions #003 & #004} were developed under BAT, in PA-56-002578.

Section is applicable. Facility is not in an air basin and open burning, with limitations, is allowed.

Pennsylvania Department of Corrections SCI Laurel Highlands Operating Pennit #TVOP-56-00257

Existing Permit Requirements

I. Existing Title V Operating Permit

Conditions from the existing Operating Permit were carried forward into this operating permit with some deletions, changes and additions. The emergency engines (Source IDs 105, 107, and 108) are the only emission sources that have been carried forward from this permit. The applicability of specific NSPS and MACT standards that have become effective since the issuance of this TVOP have been evaluated and the applicable requirements of Part 63 , Subpart ZZZZ (National Emission Standards for Hazardous Pollutants for Stationary Reciprocating Internal Combustion Engines) are included in the proposed operating permit.

Requirements for a daily walk-around inspection of the facility have also been added. Source ID numbers were changed to reflect the current identification numbers of the sources. Also, the sources comprising the Source Groups were changed to properly include the requirements for the individual sources. The coal-fired boilers (Source IDs 031 , 032, & 033) were removed from the permit, since they are permanently out of service. Conditions in Section C pertaining to the coal-fired boilers (Conditions #008 & #0 11 , old) were not carried forward .

II. Plan Approval PA-56-002578

Source IDs 034-036 and 109- 112 from PA-56-002578 were added to the proposed permit, along with their ongoing requirements. This PA will be inactivated upon issuance of the proposed TVOP.

Applicable requirements for 40 CFR Part 60, Subpart De (Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, Source IDs 034- 036), Subpart JJJJ (Standards of Performance for Stationary Spark Ignition Internal Combustion Engines, Source IDs 110 and 111 ), Subpart KKKK (Standards of Performance for Stationary Combustion Turbines, Source ID 1 09), and 40 CFR Part 63 , Subpart JJJJJJ (National Emission Standards for Hazardous Air Pollutants for Industrial , Commercial, and Institutional Boilers at Area Sources, Source IDs 034-036) were added to the permit.

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Even though the Plan Approval does not encompass all emission sources at SCI Laurel Highlands, it contains annual facility emission limits for NOx, CO, VOC, and formaldehyde . (Section C, Condition #005) These limits are based on the PTE for the facility. With the exception of formaldehyde emissions from the Solar Centaur Landfill Gas Turbine (Source ID 1 09), the PA already contains all necessary emission limits at the process level for the authorized project. Therefore, imposition of these facility emission limits was not necessary at the time of evaluation of the app lication for PA-56-00257B. It has been, and would be, necessary to change these limits to authorize any changes at the fac ility and maintain the basis of these changes. Because the facility emission limits were unnecessary, these emission limits were not carried forward into the proposed Title V Operating Permit. A new annual formaldehyde emission limit for the sum of emissions from the LFG-fired engines and turbine was added to the proposed TVOP, to limit emissions from the turbine.

III. General Permit GPA/GP1-56-00257A

This General Permit authorized the construction of a 27.7 MMBtu/hr boi ler at the facility . (Source ID 037) Because this boiler is designed to bum distillate oil as its backup fuel , it is subject to 40 CFR Part 60, Subpart De (Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units) . Also, the boiler will be operated as a gas-fired boiler, meeting this definition in 40 CFR Part 63 , Subpart JJJJJJ (National Emission Standards for Hazardous Air Pollutants for Industrial , Commercial, and Institutional Boilers at Area Sources). This operation exempts the boiler from any other requirements of the NESHAP.

The app licable requirements of this NSPS, the definition of gas-fired boiler in the NESHAP, and ongoing requirements of the GP are contained proposed TVOP. This GP will be inactivated upon issuance ofthe proposed TVOP.

11


Conclusions and Recommendations:

The Pennsylvania Department of Corrections has proposed in this application to operate a boiler and electrical powerhouse in Somerset Township, Somerset County. The landfill gas-fired turbine (Source ID 1 09) was last tested on November 24, 2014, and its emissions were found to be in compliance with limits in Plan Approval PA-56-00257B. The landfill gas-fired engines (Source IDs 110 & 111) were last tested on November 25, 2014, and their emissions were also found to be in compliance with the limitations in the PA-56-00257B. The facility was last inspected for a Full Compliance Evaluation, on September 29, 2014, by Tom Norris, Air Quality Supervisor for DEP, and no vio lations were found.

I recommend the issuance of an Operating Permit, subject to the attached permit conditions, for this application.

Permit Authorized by this Authorization Quantity Fac ility Name l PF ID: 261482

1 Pennsylvania Department of Corrections/SCI Laurel Highlands (TVOP-56-00257) I APS ID: 762921 I Auth. ID: 899421

Short Descr. I Prison with a Steam & Electric Prison Powerhouse

Permits Inactivated by this Authorization Permit# l

PA-56-00257B Pennsylvania Department of Corrections/SCI Laurel H~hlands I APS ID: 876567 1 Auth. ID : 1083372

GP1-56-00257 A Pennsylvania Department of Corrections/SCI Laurel Highlands J APS ID: 882061 1 Auth. ID: 1092531

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Documents

PA DEP SOUTHWEST REGIONAL OFFICE MEMO - GASPgasp-pgh.org/wp-content/uploads/SCI-Laurel-Highlands-review-memo.pdf · coal-fired, Riley Stoker boilers, which were installed in 1950