State Registration
Number
K1271
Michigan Department of Environmental Quality
Air Quality Division
RENEWABLE OPERATING PERMIT
STAFF REPORT
ROP Number
MI-ROP-K1271-2012
Henry Ford Hospital
SRN: K1271
Located at
2799 W. Grand Boulevard, Detroit, Michigan 48202
Permit Number:
MI-ROP-K1271-2012
Staff Report Date:
March 26, 2012
This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air
Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as
amended (Act 451). Specifically, Rule 214(1) requires that the Michigan Department of
Environmental Quality (MDEQ), Air Quality Division (AQD), prepare a report that sets forth the
factual basis for the terms and conditions of the Renewable Operating Permit (ROP).
Page: 1
TABLE OF CONTENTS
MARCH 26, 2012 STAFF REPORT
3
SEPTEMBER 5, 2012 STAFF REPORT ADDENDUM
7
NOVEMBER 20, 2012 STAFF REPORT ADDENDUM
13
Page 2
State Registration
Number
Michigan Department of Environmental Quality
Air Quality Division
RENEWABLE OPERATING PERMIT
K1271
ROP Number
MI-ROP-K1271-2012
MARCH 26, 2012 STAFF REPORT
Purpose
Major stationary sources of air pollutants, and some non-major sources, are required to obtain
and operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990
and Michigan’s Administrative Rules for air pollution control pursuant to Section 5506(1) of Act
451. Sources subject to the ROP program are defined by criteria in Rule 211(1). The ROP is
intended to simplify and clarify a stationary source’s applicable requirements and compliance
with them by consolidating all state and federal air quality requirements into one document.
This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis
for the draft permit terms and conditions including citations of the underlying applicable
requirements, an explanation of any equivalent requirements included in the draft permit
pursuant to Rule 212(5), and any determination made pursuant to Rule 213(6)(a)(ii) regarding
requirements that are not applicable to the stationary source.
General Information
Stationary Source Mailing Address:
Source Registration Number (SRN):
North American Industry Classification
System (NAICS) Code:
Number of Stationary Source Sections:
Is Application for a Renewal or Initial
Issuance?
Application Number:
Responsible Official:
AQD Contact:
Date Permit Application Received:
Date Application Was Administratively
Complete:
Is Application Shield In Effect?
Date Public Comment Begins:
Deadline for Public Comment:
Henry Ford Hospital
2799 W. Grand Boulevard
Detroit, Michigan 48202
K1271
622110
1
Initial Issuance
200900082
Dan Murakami, Plant Operations Manager
313-916-2202
Terseer Hemben, Environmental Engineer
313-456-4677
05/27/2009
05/27/2009
Yes
March 26, 2012
April 25, 2012
Page 3
Source Description
The Henry Ford Hospital is located at 2799 West Grand Boulevard in the City of Detroit,
Michigan. The facility operates diesel generators as emergency electrical power supply backup,
4 boilers and an ethylene oxide sterilizer for the hospital. The electric generators are
reciprocating internal combustion engines with series of generators rated 300 KW to 2000 KW.
The generators were initially exempt and limited to operate for 4 hours per month for testing and
maintenance. The engines were subsequently permitted to operate in excess of the limited 4
hours per month, for emergencies only. The Hospital requested that the generators should be
changed from emergency use only to include occasional power production during high demand
periods to assist the power utility to meet their load obligations. In this respect, the Hospital
applied for a Renewable Operating Permit to cover the emissions at the facility.
The following table lists stationary source emission information as reported to the Michigan Air
Emissions Reporting System in the 2010 submittal.
TOTAL STATIONARY SOURCE EMISSIONS
Pollutant
Tons per Year
Carbon Monoxide (CO)
Lead (Pb)
Nitrogen Oxides (NOx)
Particulate Matter (PM)
Sulfur Dioxide (SO2)
Volatile Organic Compounds (VOCs)
15.85
0.00008
25.85
3.81
0.71
0.90
In addition to the pollutants listed above that have been reported in MAERS, the potential to
emit of Greenhouse Gases in tons per year of CO2e is < 100,000. CO2e is a calculation of
combined global warming potentials of six greenhouse gases (carbon dioxide, methane, nitrous
oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride.
See Parts C and D in the draft ROP for summary tables of all processes at the stationary source
that are subject to process-specific emission limits or standards.
Regulatory Analysis
The following is a general description and history of the source. Any determinations of
regulatory non-applicability for this source are explained below in the Non-Applicable
Requirement part of the Staff Report and identified in Part E of the ROP.
The stationary source is located in Wayne County, which is currently designated by the U.S.
Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants.
The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR), Part 70,
because
the potential to emit all criteria pollutants exceeds 100 tons per year. The potential to emit
Greenhouse Gases is 100,000 tons per year or more calculated as carbon dioxide equivalents
(CO2e) and 100 tons per year or more on mass basis. No emissions units at the stationary
source are currently subject to the Prevention of Significant Deterioration (PSD) regulations of
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Part 18, Prevention of Significant Deterioration of Air Quality of Act 451, because at the time of
New Source Review permitting the potential to emit of carbon monoxide was less than 100 tons
per year
At this time, there are no GHG applicable requirements to include in the ROP. The mandatory
Greenhouse Gas reporting Rule under CFR 98 is not an ROP applicable requirement and is not
included in the ROP.
No emission units are subject to the federal Compliance Assurance Monitoring rule under 40
CFR, Part 64, because all emission units at the stationary source either do not have a control
device or those with a control device do not have potential pre-control emissions over the major
source thresholds.
Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the
stationary source. Part A contains regulatory citations for general conditions.
Source-wide Permit to Install (PTI)
Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established
pursuant to Rule 201. All terms and conditions that were initially established in a PTI are
identified with a footnote designation in the integrated ROP/PTI document.
Streamlined/Subsumed Requirements
This permit does not include any streamlined/subsumed requirements pursuant to Rules 213(2)
and 213(6).
Non-applicable Requirements
Part E of the draft ROP lists requirements that are not applicable to this source as determined
by the AQD, if any were proposed in the application. These determinations are incorporated
into the permit shield provision set forth in Part A (General Conditions 26 through 29) of the draft
ROP pursuant to
Rule 213(6)(a)(ii).
Processes in Application Not Identified in Draft ROP
The following table lists processes that were included in the ROP application as exempt devices
under Rule 212(4). These processes are not subject to any process-specific emission limits or
standards in any applicable requirement.
Exempt
Emission Unit ID
EUE&RGEN5
EUWCLINICGEN6
EUWCLINCGEN7
Description of
Exempt Emission Unit
150 KW outside Emergency
generator for E & R, aka Engine 8
620 KW emergency generator in
West Clinic, east side, aka engine
6
620 KW emergency generator in
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Rule 212(4)
Exemption
R 336.1212(f)
Rule 201
Exemption
Rule 285(g)
R 336.1212(f)
Rule 285(g)
R 336.1212(f)
Rule 285(g)
Exempt
Emission Unit ID
EUSOLVDIST
Description of
Exempt Emission Unit
West Clinic, west side, aka engine
7
Solvent distillation unit with batch
capacity much less than 20
gallons
Rule 212(4)
Exemption
Rule 201
Exemption
R 336.1212(f)
Rule 285(g)
Draft ROP Terms/Conditions Not Agreed to by Applicant
This permit does not contain any terms and/or conditions that the AQD and the applicant did not
agree upon pursuant to Rule 214(2
Compliance Status
The AQD finds that the stationary source is expected to be in compliance with all applicable
requirements as of the effective date of this ROP.
Action taken by the DEQ
The AQD proposes to approve this permit. A final decision on the ROP will not be made until
the public and affected states have had an opportunity to comment on the AQD’s proposed
action and draft permit. In addition, the U.S. Environmental Protection Agency (USEPA) is
allowed up to 45 days to review the draft permit and related material. The AQD is not required
to accept recommendations that are not based on applicable requirements. The delegated
decision maker for the AQD is Teresa Seidel, Field Operations Supervisor. The final
determination for ROP approval/disapproval will be based on the contents of the permit
application, a judgment that the stationary source will be able to comply with applicable
emission limits and other terms and conditions, and resolution of any objections by the USEPA.
Page 6
State Registration
Number
K1271
Michigan Department of Environmental Quality
Air Quality Division
RENEWABLE OPERATING PERMIT
SEPTEMBER 5, 2012 STAFF REPORT
ADDENDUM
ROP Number
MI-ROP-K1271-2012
Purpose
A Staff Report dated March 26, 2012, was developed in order to set forth the applicable
requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and
conditions as required by R 336.1214(1). The purpose of this Staff Report Addendum is to
summarize any significant comments received on the draft ROP during the 30-day public
comment period as described in R 336.1214(3). In addition, this addendum describes any
changes to the draft ROP resulting from these pertinent comments.
General Information
Responsible Official:
AQD Contact:
Dan Murakami, Plant Operations Manager
313-916-2202
Terseer Hemben, Environmental Engineer
313-456-4677
Summary of Pertinent Comments
The Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD)
received the following comments from the Environmental Protection Agency during the public
comment period from March 26, 2012 to April 25, 2012.
EPA Comment 1:
Conditions 1.1, 1.2, and 1.3 for Emission Unit EUENGINE 12a, located on page 14 of the draft
permit, establish the emission limits required for a 2,000 kW, 20 MMBtu/hr. diesel-fired
generator. These conditions come from PTI 186-06B via Subpart IIII of 40 CFR 60 Condition
IX.l of PTI 186-06B for EUENGINE12a, included in this draft permit as Condition IX.l for
EUENGINE12a on page 16, states that "the permittee shall comply with all applicable
requirements of [40 CFR 60 Subpart IIII]". 40 CFR §
60.4205 refer to Table 1 to Subpart IIII of 40 C.F.R. 60 which contains the applicable emission
limits for this engine, including an emission limit for hydrocarbons (HC) of 1.3 g/kW-hr. However,
the limit for HC emissions is not included in this permit. Please either add the HC limit of 1.3
g/kW-hr to this permit or provide an explanation why this limit is not applicable to
EUENGINE12a.
AQD Response 1:
AQD agrees and has added the HC limit in Condition I.4 on page 14.
Page: 7
EPA Comment 2:
Conditions 1.1, 1.2, and 1.3 for EUENGINE12a refer to conditions IL3 and II.4 for monitoring
and testing. However, these conditions do not seem to exist in this draft permit. If conditions II.3
or II.4 are included as conditions within another part of the permit, such as a flexible group that
includes EUENGINE12a as a member unit, then the permit should reflect that location in the
permit when the reference is established. However, if the reference to conditions II.3 and IL4 is
to a requirement for another unit or flexible group for which EUENGINE12a is not a member
then the requirements should
Be repeated for EUENGINE12a specifically. Please either update both references to existing
conditions that provides for sufficient monitoring, reporting, and recordkeeping of the emission
limits or add conditions for monitoring and testing sufficient to ensure compliance with the limits
in Conditions I.1, I.2, and I.3.
AQD Response 2:
AQD agrees and has updated the references listed on page 14.
EPA Comment 3:
Condition II.2 for EUWPAVGEN8, located on page 20 of the draft permit, limits the amount of
distillate oil used in the West Pavilion Emergency Generator to 58,000 gallons of distillate oil per
rolling 12-month period. Special Condition (SC) 5 of PTI 355-97 establishes the limit at 58,500
gallons of distillate oil per rolling 12-month period. Please either update the permit to read
58,500 gallons as opposed to 58,000 gallons or provide an explanation why the limit changed.
AQD Response 3:
AQD agrees and has revised Condition II.2 to reflect this change.
EPA Comment 4:
Condition I for EUBUNITGEN, located on page 22 of the draft permit, establishes emission limits
for the B unit-HFHS No. 9 emergency generator. The permit refers to General Condition (GC)
12 of the permit as the method for testing and monitoring compliance with these limits. GC 12
says that the permittee shall not emit air contaminants in quantities that impact human health,
safety, and enjoyment of life and property. As written, GC 12 does not seem to provide for
sufficient monitoring or testing to show compliance with the emission limits. Please either add
sufficient monitoring, testing, and recordkeeping so that compliance with the emission limits can
be enforced practically, provide a reference to an appropriate specific permit condition that can
be used to ensure continuous compliance with the emission limits, or provide an explanation
why the current monitoring, testing, and recordkeeping requirements in the draft permit are
sufficient to ensure continuous compliance with these limits.
AQD Response 4:
AQD agrees and has replaced GC 12 with GC 13 on page 22. In addition, references to
monitoring/recordkeeping conditions were added.
EPA Comment 5:
Condition II.2 for EUBUNITGEN, located on page 22 of the draft permit, states that the sulfur
content of the fuel used in this emergency generator shall not exceed 15 ppm. The permit does
not contain monitoring, testing, or recordkeeping to ensure compliance with the sulfur content
limit. The permit should at least include keeping records of the sulfur content in the fuel as per
SC 3 of PTI 307-99. Please either add sufficient monitoring, testing, and recordkeeping
requirements to ensure compliance with the sulfur content limit in the fuel or explain why the
Page 8
current monitoring, testing, and recordkeeping requirements in the draft permit are sufficient to
ensure compliance with this limit.
AQD Response 5:
AQD agrees and has added Condition VI.1 on page 23.
EPA Comment 6:
PTI 287-01 establishes emission and material usage limits for EUCLVBOILER of 7.15 tpy and
143 MMCF of natural gas, both calculated as a 12-month rolling sum, respectively. Neither limit
is included on page 24 of the draft permit. Additionally, page 13 of the draft permit states that
EUCLVBOILER meets current exemption requirements. Please clarify the exemption for which
EUCLVBOILER qualifies. If necessary, the conditions for EUCLVBOILER to qualify for the
exemption should also be included in the permit. Also, please either add the emission and
material usage limits as listed in PTI 287-01 along with sufficient monitoring and testing to
ensure compliance or explain why these limits are no longer required.
AQD Response 6:
AQD agrees and included the limits from PTI-287-01 on pages 24 and 25. In addition, the
exemption reference was deleted from the Emission Unit Summary Table on page 13.
EPA Comment 7:
Condition I.I for FGPEAKSHAVERS, located on page 28 of the draft permit, establishes a
Nitrogen Oxides emission limit of 13.5 tpy for member units of this flexible group. Condition III.1
for FGPEAKSHAVERS establishes an operational restriction of 1,500 hours per 12-month
rolling time period as established at the end of each calendar month. Currently, the draft permit
does not require the permittee to track the number of hours the units are operated. Please either
add sufficient monitoring and testing to ensure continuous compliance with these limits or
explain why the monitoring and testing is sufficient to ensure continuous compliance with the
operating limit.
AQD Response 7:
AQD agrees and has added Condition VI.1 on page 29.
EPA Comment 8:
PTI 279-07 is included in the permit record for Henry Ford Hospital. However, this PTI is not
listed in the table under Appendix 6 on page 43 of the draft permit. Please ensure that the
requirements from PTI 279-07 are added to the draft permit or explain why the conditions
established in PTI 279-07 no longer apply to the source.
AQD Response 8:
PTI 279-07 was not included in Appendix 6 or in the draft permit because the equipment has
been removed from the facility.
EPA Comment 9:
The following minor typographical errors were found while reviewing the permit:
a. Condition III.2 of EUTOSTER1, located on page 18 of the draft permit, should begin
as "The permittee shall not operate [...]".
b. The word "e" should be "be" in the second sentence of Condition VII.3 for
EUTOSTER1, EUWPAVGEN8, EUBUNITGEN, and FGENGINES.
Page 9
c. Condition I.1 for FGENGINES, located on page 30 of the draft permit, refers to SC 1.2
for monitoring/testing method. This condition does not exist within this permit.
d. Conditions III.4, III.5, and III.6 for FGENGINES9-10-11, located on page 32 of the
draft permit, should refer to EUENGINE9, EUENGINE10, and EUENGINE11,
respectively.
e. Condition VI.l for FGENGINES9-10-11, located on page 33 of the draft permit, the
hour meter should be "with a non-resettable" as opposed to "with-resettable".
f. Condition II.3 for FGBOILERS, located on page 38 of the draft permit, should limit
natural gas usage to 1,515,480,000 cubic feet per year as opposed to 1,515,480,000
gallons per year of fuel oil per PTI 186-06B.
g. The third line of the table on page 43 of the draft permit should refer to PTI 355- 97
instead of 355-98.
AQD Response 9:
AQD agrees and has corrected the typographical errors.
The Michigan Department of Environmental Quality received the following comments from
Henry Ford Hospital (HFH) during the company’s review of the proposed changes to the ROP:
HFH Company Comment #1: The facility operates diesel generators as emergency electrical
power supply backup, 3 boilers (Change to “4” boilers) and an ethylene oxide sanitary system
(change “sanitary system” to “sterilizer”) for the hospital.
AQD Response 1:
AQD agrees and has changed the number and verbiage.
HFH Company Comment #2
In the remainder of that paragraph, we would not suggest replacing the original language in the
Staff report:
“The generators were initially exempt and limited to operate for 4 hours per month for testing
and maintenance. The engines were subsequently permitted to operate in excess of the limited
4 hours per month, for emergencies only. The Hospital requested that the generators should be
changed from emergency use only to include occasional power production during high demand
periods to assist the power utility to meet their load obligations. In this respect, the Hospital
applied for a Renewable Operating Permit to cover the emissions at the facility.”
with the following:
“All of the generators are "emergency generators" installed to provide backup power in case the
electrical grid is down. In addition, generators have been permitted to include occasional power
production during high demand periods to assist the power utility to meet their load obligations.”
AQD Response 2:
AQD held a phone meeting with HFH representative seeking clarification on the comment. HFH
representative rescinded the recommendation stating the comment was an oversight, and was
withdrawn.
HFH Company Comment #3 to the ROP:
In the attached Draft ROP, on page 27, boilers 4, 5 and 6 are listed under FGENGINES; they
should be removed from this list.
Page 10
AQD Response 3:
AQD agrees and the correction was made to the boilers FG classification list.
HFH Company Comment #4
Just above this, under FGENGINES9-10-11, the description should be three outside generators
(not necessarily the IPD generator, the two other generators have different names.)
AQD Response 4:
AQD agrees and the correction was made to the generators’ description.
HFH Company Comment #5
On page 44, the B unit generator is in the ROP, and is not NA. NA should be replaced with
EUBUNITGEN
AQD Response 5
AQD agrees and the correction was made to the Emission Unit assignment status.
Changes to the March 26, 2012 Draft ROP
During the AQD review, the following changes were made to the draft ROP. Throughout the
document, the AQD corrected typographical errors in Emission Unit and Flexible Group IDs
related to the proposed ROP.
Changes to draft ROP based on EPA comments:
On page 14, added the limit of HC emissions 1.3 kg/kW-hr as Condition I.4 and added
references to monitoring/recordkeeping conditions.
On page 14, removed conditions II.3 and II.4, and added conditions II.1 and II.2. The references
were updated.
On page 18, corrected typographic error by deleting “change” from the Condition III.2 of
EUTOSTER1.
On page 19, corrected typographic error by inserting letter “b” to read “be” in Condition VII.3.
On page 20, corrected the typographic error in Condition II.2 by replacing 58,000 gallons with
58,500 gallons.
On page 22, II.1, II.2, III.1, III.2, VI.1 as testing/monitoring/recordkeeping requirements in
support of GC 13 in Condition I.
On page 23, added a monitoring/recordkeeping requirement, Condition VI.1, for compliance
assurance.
On page 24, added the emission and material usage limits along with sufficient monitoring and
testing to ensure compliance.
On page 29, added a monitoring/recordkeeping requirement, Condition VI.1, pertaining to the
hours of operation to ensure compliance with limits.
Page 11
On page 30, the reference to SC I.2 was deleted.
On page 33, corrected conditions III.4, III.5, and III.6 by removing the extra spaces and letters in
the emission unit names.
On page 34, corrected phrase “with resettable” to “with a non-resettable”.
On page 39, corrected limits units to 1,515,480,000 cubic feet per year of natural gas.
On page 44, corrected permit listing to PTI 355-97 in Appendix 6.
Changes to draft ROP based on HFH Company’s Comments:
During the AQD review, the following changes were made to the proposed ROP:
Within the Source Description text, (a) corrected the number of boilers from “3” to “4” boilers,
and (b) corrected verbiage from “sanitary system” to “sterilizer”. The language in the remainder
of the paragraph remained unchanged consistent with the HFH’s request.
On page 27 of the ROP, corrected boilers 4, 5, and 6 listing under FGENGINES by removing
them from the FGENGINES list.
On page 27, of the ROP, corrected the description of the FGENGINES9-10-11 to “three outside
emergency generators”.
On page 44 of the ROP, corrected the B unit generator emission unit from “NA” to
EUBUNITGEN.
Page 12
Michigan Department of Environmental Quality
Air Quality Division
State Registration Number
RENEWABLE OPERATING PERMIT
ROP Number
K1271
NOVEMBER 20, 2012 STAFF REPORT
ADDENDUM
MI-ROP-K1271-2012
Purpose
A Staff Report dated March 26, 2012, was developed in order to set forth the applicable requirements
and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by
R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments
received on the draft ROP during the 45-day EPA comment period as described in R 336.1214(3). In
addition, this addendum describes any changes to the proposed ROP resulting from these pertinent
comments.
General Information
Responsible Official:
AQD Contact:
Dan Murakami, Plant Operations Manager
313-916-2202
Terseer Hemben, Environmental Engineer
313-456-4677
Summary of Pertinent Comments
No pertinent comments were received during the 45-day EPA comment period.
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