Healthcare and Air Quality

1. Healthcare and Air Quality H2E Conference - Dec 6, 2007 K-State Pollution Prevention Institute Ryan Hamel

2. K-State SBEAP • K-State University • Engineering Extension • Pollution 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

3. 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

4. Presentation Overview • Potential-to-emit (PTE) • Air regulations (healthcare-related) • Boilers • Emergency generators • Ethylene oxide sterilizers • Changes to emission sources

5. 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

6. Calculating PTE Calculation methods • Emission factors • Material balances • Other approved methods • Computer programs • Industry-specific emission factors • Approved by KDHE on an individual basis

7. 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

8. 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

9. 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)

10. 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)

11. Construction Approval If 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

12. 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

13. 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

14. 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)

15. 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

16. 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

17. 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 Complete the KDHE boiler form Yes Yes No The heat input capacity is less than 10 MMBtu/hr The boiler is not subject to NSPS requirements Yes Heat input capacity is greater than 100 MMBtu/hr, subject to large boiler NSPS requirements No

18. 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

19. 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.

20. 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

21. 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

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

23. 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)

24. 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

25. 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

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

27. Ethylene oxide sterilizers • Does anyone have one? • Used to sterilize heat- and moisture-sensitive products • Increase regulatory requirements (NESHAP) • Contact SBEAP for further assistance

28. 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

29. Questions or Comments? Contact Information Ryan Hamel K-State Pollution Prevention Institute 800.578.8898 or 785.532.4994 rhamel@ksu.edu www.sbeap.org