Miami Valley Hospital

8/13/2009

JIM HARTKE

Miami Valley Hospital

ONE WYOMING STREET

DAYTON, OH 45409-2793

RE:DRAFT AIR POLLUTION PERMIT-TO-INSTALL

Facility ID: 0857040180

Permit Number: P0104850

Permit Type:Initial Installation

County: Montgomery

Dear Permit Holder:

A draft of the Ohio Administrative Code (OAC) Chapter 3745-31 Air Pollution Permit-to-Install for the referenced facility has been issued for the emissions unit(s) listed in the Authorization section of the enclosed draft permit. This draft action is not an authorization to begin construction or modification of your emissions unit(s). The purpose of this draft is to solicit public comments on the permit. A public notice will appear in the Ohio EPA Weekly Review and the local newspaper, Dayton Daily News. A copy of the public notice and the draft permit are enclosed. This permit has been posted to the Division of Air Pollution Control (DAPC) Web page in Microsoft Word and Adobe Acrobat format. Comments will be accepted as a marked-up copy of the draft permit or in narrative format. Any comments must be sent to the following:

Andrew Hall
Permit Review/Development Section
Ohio EPA, DAPC
122 South Front Street
Columbus, Ohio 43215 / and / Regional Air Pollution Control Agency
117 South Main Street
Dayton, OH 45422-1280

Comments and/or a request for a public hearing will be accepted within 30 days of the date the notice is published in the newspaper. You will be notified in writing if a public hearing is scheduled. A decision on issuing a final permit-to-install will be made after consideration of comments received and oral testimony if a public hearing is conducted. Any permit fee that will be due upon issuance of a final Permit-to-Install is indicated in the Authorization section. Please do not submit any payment now. If you have any questions, please contact Regional Air Pollution Control Agency at (937)225-4435.

Sincerely,

Michael W. Ahern, Manager

Permit Issuance and Data Management Section, DAPC

Cc:U.S. EPA

RAPCA; Indiana; Kentucky

Montgomery County

PUBLIC NOTICE

Issuance Of Draft Air Pollution Permit-To-Install

Miami Valley Hospital

Issue Date: 8/13/2009

Permit Number: P0104850

Permit Type: Initial Installation

Permit Description: PTI for installation of three diesel-fired emergency generators, two natural gas/oil-fired boilers, and two diesel storage tanks.

Facility ID: 0857040180

Facility Location:Miami Valley Hospital

ONE WYOMING STREET,

DAYTON, OH 45409-2793

Facility Description: General Medical and Surgical Hospitals

Chris Korleski, Director of the Ohio Environmental Protection Agency, 50 West Town Street, Columbus Ohio, has issued a draft action of an air pollution control permit-to-install (PTI) for an air contaminant source at the location identified above on the date indicated. Installation of the air contaminant source may proceed upon final issuance of the PTI. Comments concerning this draft action, or a request for a public meeting, must be sent in writing no later than thirty (30) days from the date this notice is published. All comments, questions, requests for permit applications or other pertinent documentation, and correspondence concerning this action must be directed to Dale Davidson at Regional Air Pollution Control Agency, 117 South Main Street or (937)225-4435. The permit can be downloaded from the Web page:

Permit Strategy Write-Up

Permit Number: P0104850

Facility ID: 0857040180

Permit Strategy Write-Up

1. Check all that apply:

X Synthetic Minor Determination

Netting Determination

1. Source Description:

The emission units in this permit are for the new installation of 3 diesel-fired standby generators, 2 natural gas/oil-fired boilers, and 2 underground diesel fuel storage tanks at Miami Valley Hospital. They will be added to 8 generators (B001-B006, B014 and B017), 10 boilers (B007-B013, B015, B016 and B018), and 4 fuel storage tanks (T001-T004) that are already permitted and operated at the facility. The generators are used for back up electricity power in the event power outages or disruptions, and the boilers are used throughout the facility for heating. Both the existing units and new units are included in the combined emissions limitations and combined fuel oil usage restrictions cited in this permit for the generators and boilers.

1. Facility Emissions and Attainment Status:

Miami Valley Hospital is a Title V facility major for SO2 and NOx. The cumulative potential to emit of SO2 and NOx emissions from the standby generators and small boilers located throughout the facility exceeds Title V thresholds. With this PTI, the current facility PTE for SO2 and NOx will be 119.46 tons/year and 130.03 tons/year, respectively. Miami Valley Hospital is located in Dayton, Ohio which is in Montgomery County. Montgomery County is currently designated as non attainment for PM2.5, and attainment for all other criteria pollutants.

1. Source Emissions:

Miami Valley Hospital has previous issued PTIs for the generators and boilers that contain emissions limitations and fuel usage restrictions for the purpose of avoiding earlier Title V permit requirementsor to avoid PSD review.

Federally enforceable diesel fuel oil usage restriction and corresponding PE, SO2, NOx, CO and OC emissions limitations, combined, for generator emissions units B001-B006, B014, and B017 were established in earlier PTI #P0105030. With issuance of this PTI new generator emissions units B021 - B023 will be included under the same combined operating restriction and combined emissions limitations. This PTI establishes federally enforceable diesel fuel oil usage restriction and corresponding PE, SO2, NOx, CO and OC emissions limitations, combined, for emissions units B001-B006, B014, B017, and B021-B023. With a restriction of an annual fuel oil usage of 330,000 gallons/year, based upon a rolling 12-month summation , combined for all the generator units, the resulting enforceable PTE for the generator units will be: SO2 = 6.46 tons/year; NOx = 98.23 tons/year; CO = 21.16 tons/year; OC = 8.02 tons/year; and PE = 6.9 tons/year.

Federally enforceable diesel fuel oil usage restriction and corresponding PE, SO2, NOx, CO and OC emissions limitations, combined, for the boiler emissions units B007-B013, B015, B016, and B018 were established in PTI 08-04392 issued 7/23/2002. With issuance of this PTI new boiler emissions units B019 and B020 will be included under the same combined operating restriction and combined emissions limitations. This PTI establishes federally enforceable diesel fuel oil usage restriction and corresponding PE, SO2, NOx, CO and OC emissions limitations, combined, for emissions units B007-B013, B015, B016, and B018 – B020. With a restriction of an annual fuel oil usage of 3,182,400 gallons/year, based upon a rolling 12-month summation , combined for all the boiler units, the resulting enforceable PTE for the boiler units will be: SO2 = 113.0 tons/year; NOx = 31.8 tons/year; CO = 29.4 tons/year; OC = 3.8 tons/year; and PE = 3.2 tons/year.

Emissions from the tanks are deminimus, conservatively determined to be 4 lb/day and 0.73 tons/year VOC for each tank, for a total of 1.46 tons/year VOC for per both tanks together. However, they are subject to the NSPS 40 CFR Part 60, Subpart KB, Standards of Performance for Volatile Organic Storage Vessels. The emissions from these tanks will be the only increase of emissions occurring with this PTI.

1. Conclusion:

With the federally enforceable fuel oil usage rates, based on a rolling 12-month summation, contained in this permit, one for the generator units and one for the boiler units, the facility SO2 and NOx emissions will remain below PSD threshold. In addition, this permit establishes federally enforceable PTEfor CO, OC, and PE for the generator and boiler units. Monitoring, record keeping and reporting requirementswill ensure compliance with these federally enforceable restrictionson the fuel oil usages rates and the facility emissions will remain below major NSR thresholds.

1. Please provide additional notes or comments as necessary:

None

1. Total Permit Allowable Emissions Summary(for informational purposes only):

Pollutant / Tons Per Year
SO2 / 119.46
NOx / 130.03
CO / 50.06
OC / 13.06
PE / 10.01

State of Ohio Environmental Protection Agency

Division of Air Pollution Control

DRAFT

Air Pollution Permit-to-Install

for

Miami Valley Hospital

Facility ID: 0857040180

Permit Number: P0104850

Permit Type: Initial Installation

Issued: 8/13/2009

Effective: To be entered upon final issuance

Air Pollution Permit-to-Install

for

Miami Valley Hospital

Table of Contents

Authorization

A.Standard Terms and Conditions

1.Federally Enforceable Standard Terms and Conditions

2.Severability Clause

3.General Requirements

4.Monitoring and Related Record Keeping and Reporting Requirements

5.Scheduled Maintenance/Malfunction Reporting

6.Compliance Requirements

7.Best Available Technology

8.Air Pollution Nuisance

9.Reporting Requirements

10.Applicability

11.Construction of New Sources(s) and Authorization to Install

12.Permit-To-Operate Application

13.Construction Compliance Certification

14.Public Disclosure

15.Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations

16.Fees

17.Permit Transfers

18.Risk Management Plans

19.Title IV Provisions

B.Facility-Wide Terms and Conditions

C.Emissions Unit Terms and Conditions

1.Emissions Unit Group - diesel storage tanks: T005, T006,

2.Emissions Unit Group - natural gas/oil-fired boilers: B019, B020

3.Emissions Unit Group - standby generators: B021, B022, B023,

Permit Strategy Write-Up

Permit Number: P0104850

Facility ID: 0857040180

Authorization

Facility ID: 0857040180

Facility Description: general medical and surgical hospital

Application Number(s): A0037036

Permit Number: P0104850

Permit Description: PTI for installation of three diesel-fired emergency generators, two natural gas/oil-fired boilers, and two diesel storage tanks.

Permit Type: Initial Installation

Permit Fee: $1,900.00 DO NOT send payment at this time, subject to change before final issuance

Issue Date: 8/13/2009

Effective Date: To be entered upon final issuance

This document constitutes issuance to:

Miami Valley Hospital

ONE WYOMING STREET

DAYTON, OH 45409-2793

of a Permit-to-Install for the emissions unit(s) identified on the following page.

Ohio EPA District Office or local air agency responsible for processing and administering your permit:

Regional Air Pollution Control Agency

117 South Main Street

Dayton, OH 45422-1280

(937)225-4435

The above named entity is hereby granted a Permit-to-Install for the emissions unit(s) listed in this section pursuant to Chapter 3745-31 of the Ohio Administrative Code. Issuance of this permit does not constitute expressed or implied approval or agreement that, if constructed or modified in accordance with the plans included in the application, the emissions unit(s) of environmental pollutants will operate in compliance with applicable State and Federal laws and regulations, and does not constitute expressed or implied assurance that if constructed or modified in accordance with those plans and specifications, the above described emissions unit(s) of pollutants will be granted the necessary permits to operate (air) or NPDES permits as applicable.

This permit is granted subject to the conditions attached hereto.

Ohio Environmental Protection Agency

Chris Korleski

Director

Authorization (continued)

Permit Number:P0104850

Permit Description:PTI for installation of three diesel-fired emergency generators, two natural gas/oil-fired boilers, and two diesel storage tanks.

Permits for the following Emissions Unit(s) or groups of Emissions Units are in this document as indicated below:

Group Name:diesel storage tanks

Emissions Unit ID: / T005
Company Equipment ID: / T009
Superseded Permit Number:
General Permit Category and Type: / Not Applicable
Emissions Unit ID: / T006
Company Equipment ID: / T010
Superseded Permit Number:
General Permit Category and Type: / Not Applicable

Group Name:natural gas/oil-fired boilers

Emissions Unit ID: / B019
Company Equipment ID: / B019
Superseded Permit Number:
General Permit Category and Type: / Not Applicable
Emissions Unit ID: / B020
Company Equipment ID: / B020
Superseded Permit Number:
General Permit Category and Type: / Not Applicable

Group Name:standby generators

Emissions Unit ID: / B021
Company Equipment ID: / B021
Superseded Permit Number:
General Permit Category and Type: / Not Applicable
Emissions Unit ID: / B022
Company Equipment ID: / B022
Superseded Permit Number:
General Permit Category and Type: / Not Applicable
Emissions Unit ID: / B023
Company Equipment ID: / B023
Superseded Permit Number:
General Permit Category and Type: / Not Applicable

A.Standard Terms and Conditions

1.Federally Enforceable Standard Terms and Conditions

a)All Standard Terms and Conditions are federally enforceable, with the exception of those listed below which are enforceable under State law only:

(1)Standard Term and Condition A. 2.a), Severability Clause

(2)Standard Term and Condition A. 3.c) through A. 3.e)General Requirements

(3)Standard Term and Condition A. 6.c) and A. 6.d), Compliance Requirements

(4)Standard Term and Condition A. 9., Reporting Requirements

(5)Standard Term and Condition A. 10., Applicability

(6)Standard Term and Condition A. 11.b) through A. 11.e), Construction of New Source(s) and Authorization to Install

(7)Standard Term and Condition A. 14., Public Disclosure

(8)Standard Term and Condition A. 15., Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations

(9)Standard Term and Condition A. 16., Fees

(10)Standard Term and Condition A. 17., Permit Transfers

2.Severability Clause

a)A determination that any term or condition of this permit is invalid shall not invalidate the force or effect of any other term or condition thereof, except to the extent that any other term or condition depends in whole or in part for its operation or implementation upon the term or condition declared invalid.

b)All terms and conditions designated in parts B and C of this permit are federally enforceable as a practical matter, if they are required under the Act, or any its applicable requirements, including relevant provisions designed to limit the potential to emit of a source, are enforceable by the Administrator of the U.S. EPA and the State and by citizens (to the extent allowed by section 304 of the Act) under the Act. Terms and conditions in parts B and C of this permit shall not be federally enforceable and shall be enforceable under State law only, only if specifically identified in this permit as such.

3.General Requirements

a)The permittee must comply with all terms and conditions of this permit. Any noncompliance with the federally enforceable terms and conditions of this permit constitutes a violation of the Act, and is grounds for enforcement action or for permit revocation, revocation and re-issuance, or modification.

b)It shall not be a defense for the permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the federally enforceable terms and conditions of this permit.

c)This permit may be modified, revoked, or revoked and reissued, for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or revocation, or of a notification of planned changes or anticipated noncompliance does not stay any term and condition of this permit.

d)This permit does not convey any property rights of any sort, or any exclusive privilege.

e)The permittee shall furnish to the Director of the Ohio EPA, or an authorized representative of the Director, upon receipt of a written request and within a reasonable time, any information that may be requested to determine whether cause exists for modifying or revoking this permit or to determine compliance with this permit. Upon request, the permittee shall also furnish to the Director or an authorized representative of the Director, copies of records required to be kept by this permit. For information claimed to be confidential in the submittal to the Director, if the Administrator of the U.S. EPA requests such information, the permittee may furnish such records directly to the Administrator along with a claim of confidentiality.

4.Monitoring and Related Record Keeping and Reporting Requirements

a)Except as may otherwise be provided in the terms and conditions for a specific emissions unit, the permittee shall maintain records that include the following, where applicable, for any required monitoring under this permit:

(1)The date, place (as defined in the permit), and time of sampling or measurements.

(2)The date(s) analyses were performed.

(3) The company or entity that performed the analyses.

(4)The analytical techniques or methods used.

(5)The results of such analyses.

(6)The operating conditions existing at the time of sampling or measurement.

b)Each record of any monitoring data, testing data, and support information required pursuant to this permit shall be retained for a period of five years from the date the record was created. Support information shall include, but not be limited toall calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Such records may be maintained in computerized form.

c)Except as may otherwise be provided in the terms and conditions for a specific emissions unit, the permittee shall submit required reports in the following manner:

(1)Reports of any required monitoring and/or recordkeeping of federally enforceable information shall be submitted to the Regional Air Pollution Control Agency.

(2)Quarterly written reports of (i) any deviations from federally enforceable emissionlimitations, operationalrestrictions, andcontroldeviceoperatingparameterlimitations, excluding deviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06, that have been detected by the testing, monitoring and recordkeeping requirements specified in this permit, (ii) the probable cause of such deviations, and (iii) any corrective actions or preventive measures taken, shall be made to the Regional Air Pollution Control Agency. The written reports shall be submitted (i.e., postmarked) quarterly, by January 31, April 30, July 31, and October 31 of each year and shall cover the previous calendar quarters. See A.15. below if no deviations occurred during the quarter.

(3)Written reports, which identify any deviations from the federally enforceable monitoring, recordkeeping, andreportingrequirements contained in this permit shall be submitted (i.e., postmarked) to the Regional Air Pollution Control Agency every six months, by January 31 and July 31 of each year for the previous six calendar months. If no deviations occurred during a six-month period, the permittee shall submit a semi-annual report, which states that no deviations occurred during that period.