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ENB Region 7 Completed Applications 08/24/2011

Tompkins County

Applicant:

Cornell University
300 Day Hall
Ithaca, NY 14853 -2801

Facility:

Cornell University Main Campus
College Ave
Ithaca, NY 14853

Application ID:

7-5007-00030/00031

Permit(s) Applied for:

Article 19 Air Title V Facility

Project is Located:

Ithaca, Tompkins County


Project Description:

The Department has prepared a draft permit and has made a tentative decision to issue (1) a modification to the Air Title V operating permit to Cornell University for operation of its stationary gas turbines and (2) a modification to the federal Prevention of Significant Deterioration permit. Cornell currently holds three Title V operating permits, one of which (the Utilities Department) authorizes the operation of six boilers: Boilers 1 and 8, which burn coal; Boilers 6 and 7, which burn oil or gas; Boiler 5, which burns gas and Boiler 2 which burns oil. Cornell has publicly committed to not combusting coal in Boilers 1 or 8.

In addition to the Utilities Department Title V operating permit, Cornell also holds a DEC-issued State Facility Permit and an EPA-issued Prevention of Significant Deterioration permit which together authorized the construction and operation of two 15 MW stationary gas turbines and two emergency diesel generators, referred to as the Cornell Combined Heat and Power Project (CCHPP).

Emission testing of the gas turbines in the spring of 2010 showed noncompliance with the H2SO4 limits in the PSD permit while firing oil. Cornell, in a letter dated October 26, 2010 to the EPA, explained that the emission limits were based on assumptions that did not hold and requested a permit modification to raise the H2SO4 emission limits. The EPA agreed that the emission limits should be raised, and requested the DEC to provide public notice of such change. BACT remains the combustion of ultra low sulfur diesel fuel oil.

Pursuant to 6 NYCRR 201-6.3(a)(2), Cornell submitted to the DEC an application to incorporate the conditions of the gas turbine permits (both the DEC State Facility Permit and the EPA PSD permit) into the Utilities Department Title V permit, and also requested a cap on emissions of hazardous air pollutants (HAPs).

Cornell also operates two large emergency diesel generators that were installed as part of the CCHPP. A federal regulation exists that governs emissions of HAPs, called the RICE rule (reciprocating internal combustion engines). At the time of permitting, Cornell was a major source of HAPs and, interestingly, exempt from the RICE rule. See 40 CFR 63.6590(b)(1)(i). Now, Cornell is an area source of HAPs, and this subjects the emergency diesel generators to a RICE requirement, namely, to comply with 40 CFR Part 60, Subpart IIII. The permit is being revised to recognize this change.

This permit action (1) incorporates the conditions of the CCHPP State Facility Permit and PSD permit into the Utilities Department Title V permit; (2) modifies the PSD permit emission limits for H2SO4 while firing fuel oil, (3) establishes a cap on emissions of hazardous air pollutants, and (4) changes the status of the emergency diesel generators from major source applicability to the RICE NESHAPs to the area source RICE NESHAPs.

In accordance with 6NYCRR Parts 621.7(d) (9) and 201-6.4(c), the Administrator of the U.S. Environmental Protection Agency has the authority to bar issuance of any Title V Facility Permit if it is determined not to be in compliance with applicable requirements of the Clean Air Act or 6NYCRR Part 201.

Persons wishing to inspect the subject Title V files, including the applicaton with all relevant supporting materials, the draft permit, and all other materials available to the DEC (the "permitting authority") that are relevant to this permitting decision should contact the DEC representative listed below. The Draft Permit and Permit Review Report may be viewed and printed from the DEC website at: http://www.dec.ny.gov/chemical/32249.html.

DEC will evaluate the application and the comments received on it to determine whether to hold a public hearing. Comments and requests for a public hearing should be in writing and addressed to the Department rep listed below. A copy of the DEC's permit hearing procedures is available upon request or on the DEC website at: http://www.dec.ny.gov/permits/6234.html.

Availability of Application Documents:

Filed application documents, and Department draft permits where applicable, are available for inspection during normal business hours at the address of the contact person. To ensure timely service at the time of inspection, it is recommended that an appointment be made with the contact person.

State Environmental Quality Review (SEQR) Determination:

Project is not subject to SEQR because it is a Type II action.

SEQR Lead Agency: None Designated

State Historic Preservation Act (SHPA) Determination:

The proposed activity is not subject to review in accordance with SHPA. The permit type is exempt or the activity is being reviewed in accordance with federal historic preservation regulations.

Coastal Management:

This project is not located in a Coastal Management area and is not subject to the Waterfront Revitalization and Coastal Resources Act.

Opportunity for Public Comment:

Comments on this project must be submitted in writing to the Contact Person no later than Sep 23, 2011.

Contact:

Joseph M Dlugolenski
NYSDEC Region 7 Cortland Sub-Office
1285 Fisher Ave
Cortland, NY 13045
(607)753-3095
dep.r7@dec.ny.gov


Applicant:

Cornell University
300 Day Hall
Ithaca, NY 14853 -2801

Facility:

Cornell University Main Campus
College Ave
Ithaca, NY 14853

Application ID:

7-5007-00030/00049

Permit(s) Applied for:

Article 19 Air State Facility

Project is Located:

Ithaca, Tompkins County


Project Description:

The Department has prepared a draft permit pursuant to Article 19 (Air Pollution Control) of the NYS Environmental Conservation Law and has made a tentative determination to issue to Cornell University a permit authorizing the temporary installation of two rental boilers and the permanent installation of a oil/gas dual fuel fired package boiler.

Cornell has discontinued use of its coal fired boilers. Two rental boilers are being installed to make up for the lost steam capacity for the next heating season, and possibly the following heating season, too. A package boiler will be installed permanently to replace the rental boilers.

The rental boilers have a heat input capacity of 96 mmBtu/hr, will fire distillate oil and be equipped with flue gas recirculation. The package boiler will have a heat input capacity of 200 mmBtu/hr on natural gas and 190 mmBtu/hr on oil. The package boiler will be equipped with flue gas recirculation and will be new.

The rental boilers are subject to the Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units, found at 40 CFR Part 60, Subpart Dc. The package boilers are subject to the Standards for Industrial-Commercial-Institutional Steam Generating Units, found at 40 CFR Part 60, Subpart Db. All three boilers are subject to the National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources, found at 40 CFR Part 63, Subpart JJJ JJJ. Emissions from the three boilers will be capped below new source review significance thresholds. The boilers are also subject to the Department's NOx RACT rule.

The draft permit and application are available for review in the DEC Cortland Office.

Availability of Application Documents:

Filed application documents, and Department draft permits where applicable, are available for inspection during normal business hours at the address of the contact person. To ensure timely service at the time of inspection, it is recommended that an appointment be made with the contact person.

State Environmental Quality Review (SEQR) Determination:

Project is not subject to SEQR because it is a Type II action.

SEQR Lead Agency: None Designated

State Historic Preservation Act (SHPA) Determination:

The proposed activity is not subject to review in accordance with SHPA. The permit type is exempt or the activity is being reviewed in accordance with federal historic preservation regulations.

Coastal Management:

This project is not located in a Coastal Management area and is not subject to the Waterfront Revitalization and Coastal Resources Act.

Opportunity for Public Comment:

Comments on this project must be submitted in writing to the Contact Person no later than Sep 23, 2011.

Contact:

Joseph M Dlugolenski
NYSDEC Region 7 Cortland Sub-Office
1285 Fisher Ave
Cortland, NY 13045
(607)753-3095
dep.r7@dec.ny.gov


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