Document DGxGEZgqnYraQeEV0rL1ygja5

SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 CLEAN AIR ACT INSPECTION REPORT Corix Cleveland Thermal Generating LP, Cleveland, Ohio Charles Hall, Environmental Engineer AECAB (MN-OH) Brian Dickens, Section Chief AECAB (MN-OH) File, Corix Cleveland Thermal Generating LP, Cleveland, Ohio BASIC INFORMATION Facility Name: Corix Cleveland Thermal Generating LP Facility Location: 1921 Hamilton Avenue, Cleveland, Ohio Date of Inspection: April 23, 2024 EPA Inspectors: 1. Charlie Hall, Region 5 Air Enforcement and Compliance Assurance Branch 2. Briana Fenzl, Region 5 Air Enforcement and Compliance Assurance Branch Other Attendees: 1. William Adams, Health, Safety, and Environmental Manager 2. Joel Bolanos, Senior Manager, Production and Capital Projects 3. Lisa Sparrow, CEO, Corix Group of Companies1 4. Masen Sudduth, Plant Engineer 5. Seth Whitney, President, Corix Cleveland Thermal Contact Email Address: Joel.Bolanos@clevelandthermal.com Purpose of Inspection: To determine Cleveland Thermal's compliance with its Title V permit. Facility Type: three natural gas boilers 1 Sparrow and Whitney greeted the inspectors briefly but did not otherwise participate in the inspection. Regulations Central to Inspection: The Standards of Performance for Industrial-CommercialInstitutional Steam Generating Units (ICI SGU NSPS), 40 C.F.R. Part 60, Subpart Db, and the Title V permit. Arrival Time: 13:00 hrs EDT Departure Time: 15:15 hrs EDT Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet. Small Business Resource Information Sheet not provided. Reason: If this box is checked, you must enter a reason such as "Not a Small Business," here. Provided CBI warning to facility The following information was obtained verbally from Adams, Bolanos, and Sudduth unless otherwise noted. Process Description: Corix Cleveland Thermal (CCT) operates three natural gas fired boilers that meets the definition of a heat release natural gas-fired steam generating unit in ICI SGU NSPS. Each boiler is rated at 150,000 pounds steam per hour and 182.0 million British Thermal Unit per hour heat input (mmBTU/hour). As required by the Title V permit, each boiler is equipped with an oxygen trim system, low oxides of nitrogen (NOx) burners (LNBs), and flue gas recirculation. The boilers supply steam for heating for numerous buildings in downtown Cleveland and for one steam chiller. From late spring to early fall, CCT operates only one boiler at a time. CCT also operates two 500-kilowatt generators for on-site electrical use. The two generators do not supply all electricity required at the facility. Staff Interview: CCT's Title V permit includes visible emissions standards which pertained to six oil-fired boilers. CCT has decommissioned the oil-fired boilers by cutting and capping the fuel supply lines. Thus, CCT has rendered the visible emission standards moot. The Title V permit requires CCT to maintain records of all maintenance performed on the boiler that follows the manufacturer's recommendations to ensure that the boiler will operate as designed. The weekly inspections of the boilers include a visual inspection of each boiler and its NOx CEM. CCT conducts a calibration gas audit of each NOx CEM during three calendar quarters and a relative accuracy test audit during the other calendar quarter. Annual maintenance includes cleaning the mud and upper steam drums of each boiler, repairing refractory as Page 2 of 4 needed, and rebuilding the site glasses and blow down valves. The LNBs do not need annual maintenance. CCT does tune the boilers biannually. The oxygen trim system, the components of which are not visible from each boiler's exterior, maintains the oxygen concentration at 3 percent, which maximizes combustion efficiency across each boiler's natural gas firing range. The Cleveland Department of Air Quality has not asked CCT to conduct stack tests for carbon monoxide, particulate matter, or visible emissions. TOUR INFORMATION EPA Tour of the Facility: Yes. Data Collected and Observations: At the time of the inspection, only Boiler 7 was operating. Boiler 8 and Boiler 9 were shut down. The lead inspector took a picture of the screens with the monitored parameters for Boiler 7. However, either the camera did not record the picture with the data for the time of the inspection or the inspector unintentionally deleted the pictures. At the inspector's request, CCT provided the following data for Boiler 8 on May 1, 2024. Parameter Low Range NOx concentration, ppmV High Range NOx concentration, ppmV NOx concentration, ppmV Oxygen concentration, percent by volume NOx concentration corrected to 3% oxygen, ppmV Natural Gas Flow Rate, thousand cubic feet per hour Natural Gas Heat Input, mmBTU/hour NOx Emissions, pounds per hour NOx Emissions, pounds per million British Thermal Unit 30-day rolling average Value 24.2 24.2 24.2 03.4 24.75 94.6 95.5 02.87 00.032 Because CCT commenced construction on each boiler in 2016, each boiler is subject to the oxides of nitrogen (NOx) emission standard for a high heat release natural gas-fired ICI EGU of 0.20 pounds of NOx per million British Thermal Unit heat input as 30-day rolling average. See 40 C.F.R. 60.44b(a)(1)(ii) and 60.44b(i). On May 1, 2024, the 30-day rolling average NOx emissions from Boiler 8 was 0.032 lbs/mmBTU. CCT was not operating the other two boilers. The ICI SGU NSPS does not include an emission standard for carbon monoxide, particulate matter, or sulfur dioxide. Therefore, CCT does not have a compliance obligation for carbon monoxide, particulate matter, or sulfur dioxide under the ICI SGU NSPS. The ICI SGU NSPS requires each ICI SGU subject to an NOx emission standard to install, calibrate, operate, and maintain a NOx continuous emission monitor (NOx CEM) and conduct an annual Relative Accuracy Test Audit. CCT has installed, operates, calibrates, and maintains a NOx CEM. Page 3 of 4 As requested during the inspection, CCT provided the reports for the most recent Relative Accuracy Test Audit on each NOx CEM. Photos were taken during the inspection. Field Measurements were not taken during the inspection. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility. Requested documents: A copy of the report from the most recent RATA for each NOx CEM; and A copy of the written quality assurance/quality control plan designed to ensure continuous valid and representative readings of NOx emissions from the continuous monitors, in units of the applicable standards. DIGITAL SIGNATURES CHARLES HALL Report Author: BRIAN DICKENS Section Chief: Digitally signed by CHARLES HALL Date: 2024.05.23 07:36:51 -05'00' Digitally signed by BRIAN DICKENS Date: 2024.05.24 09:22:08 -05'00' Page 4 of 4 Facility Name: Corix Cleveland Thermal Generating LP Facility Location: 1921 Hamilton Avenue, Cleveland, Ohio Date of Inspection: April 23, 2024 APPENDICES AND ATTACHMENTS 1. Digital Image Log Page 5 of 5 Facility Name: Corix Cleveland Thermal Generating LP Facility Location: 1921 Hamilton Avenue, Cleveland, Ohio Date of Inspection: April 23, 2024 APPENDIX A: DIGITAL IMAGE LOG Photographer: Charles Hall Image File Name Number 1 P4230238.jpg Camera: Olympus Tough TG-6 Date and Time EPA Bar Code: SZ4061 Description of Image 04/23/2024 14:23 EDT Flue gas recirculation duct (horizontal) from exhaust stack (vertical) on Boiler 7 2 P4230239.jpg 04/23/2024 14:23 EDT Combustion Air Inlet on Boiler 7 Appendix Page 1 of 4 Facility Name: Corix Cleveland Thermal Generating LP Facility Location: 1921 Hamilton Avenue, Cleveland, Ohio Date of Inspection: April 23, 2024 Image Number 3 File Name P4230240.jpg Date and Time Description of Image 04/23/2024 14:28 EDT NOx CEM Cabinet for Boiler 7 4 P4230241.jpg 04/23/2024 14:28 EDT Back of NOx CEM Cabinet and calibration gas cylinders for Boiler 7 Appendix Page 2 of 4 Facility Name: Corix Cleveland Thermal Generating LP Facility Location: 1921 Hamilton Avenue, Cleveland, Ohio Date of Inspection: April 23, 2024 Image Number File Name 5 P4230242.jpg Date and Time Description of Image 04/23/2024 14:32 EDT Boiler Control Cabinet 6 P4230243.jpg 04/23/2024 14:32 EDT Detail of Boiler Control Cabinet Panel Appendix Page 3 of 4 Facility Name: Corix Cleveland Thermal Generating LP Facility Location: 1921 Hamilton Avenue, Cleveland, Ohio Date of Inspection: April 23, 2024 Image Number 7 File Name P4230244.jpg Date and Time Description of Image 04/23/2024 14:39 EDT Flue gas recirculation duct (largest horizontal) from exhaust stack (largest vertical) on Boiler 8 Appendix Page 4 of 4