Document pB1pr4Bq8Vx4d33opNypBow9D

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1 5 POST OFFICE SQUARE, SUITE 100 BOSTON, MASSACHUSETTS 02109-3912 Clean Air Act Inspection Report Drafted: August 7, 2024 Finalized: August 20, 2024 EPA Inspector: Grace Perry, Environmental Engineer, Air Compliance Section EPA Reviewer: John Melcher, Senior Enforcement Coordinator, Air Compliance Section Date of Inspection: July 31, 2024 Facility Name: Bates College ICISAir ID#: ME0000002300100010 Facility Location: 5 Andrews Road, Lewiston, ME 04240 Mailing Address: 5 Andrews Road, Lewiston, ME 04240 Disclaimer: Unless otherwise noted, this report describes conditions at the facility/property as observed by EPA inspector(s), and/or through records provided to and/or information reported to EPA inspector(s) by facility representatives and as understood by the inspector(s). This report may not capture all operations or activities ongoing at the time of the inspection. This report does not make final determinations on potential areas of concern. Nothing in this report affects EPA's authorities under federal statutes and regulations to pursue further investigation or action. Inspection Attendees Name Grace Perry Darren Fortescue Tim Smith Jim Morrison Andi Lasselle Timothy Pratt Alan Kelley Karen Morrison Title Environmental Engineer Manager, Air Compliance Section Compliance Inspector Director of Environmental Health & Safety Environmental Health & Safety Coordinator Director of Facility Services & Operations Mechanical Services Manager Environmental Consultant Organization EPA Region 1 EPA Region 1 Maine DEP Bates College Bates College Bates College Bates College Morrison Environmental Engineering Facility/Process Description Facility Bates College ("Bates") is a private college located at 5 Andrews Road, Lewiston, Maine. It was founded in 1855. Bates provides academic services and laboratory facilities, athletic fields and facilities, and dormitories to provide education, athletics, and housing to students. Generators For the purpose of this inspection, EPA focused on the generators located at the facility. Bates owns and operates eight licensed stationary reciprocating internal combustion engines ("RICE"). See Attachment A for engine details. Three of the engines participate in a demand response program, and five of the engines are for emergency use only. Bates also owns and operates two additional RICE that are exempt from licensing due to their small size (Not inspected). Number of Employees and Working Hours Bates College employs roughly 2,000 employees. The facility primarily operates from 7:45 a.m. to 4:30 p.m. on business days, but the facility is open 24 hours per day, 7 days a week. Potentially Applicable Clean Air Act Requirements 40 CFR Part 60, Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines ("Subpart 4I") 2  40 CFR Part 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engine ("Subpart 4J") 40 CFR Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines ("Subpart 4Z") Maine DEP Air Emissions License and Renewal A-373-71-O-R/M Previous Enforcement Actions A "Detailed Facility Report" from EPA's Enforcement and Compliance History Online database indicates that there have been no informal or formal Clean Air Act enforcement actions taken against Bates College in the past five years. Entry and Opening Conference On July 31, 2024, at 10:05 a.m., EPA Region 1 representatives Grace Perry and Darren Fortescue, and Maine Department of Environmental Protection (Maine DEP) Representative Tim Smith arrived at the facility at Dana Hall, located at 5 Andrews Road, Lewiston, Maine. EPA and Maine DEP representatives entered the facility and met with Jim Morrison, Andi Lasselle, Karen Morrison, and Timothy Pratt. Mr. Fortescue presented his credentials, and the EPA Region 1 Representatives initiated an opening conference. Ms. Perry asked Mr. Morrison for the physical and mailing address for the facility. Mr. Morrison said that the physical address is 5 Andrews Road, Lewiston, ME 04240. Mr. Morrison said that address is also the mailing address for the Environmental Health and Safety Department, but that the physical address for the Bates College Power plant is 147 Russel Street, Lewiston, ME 04240. Ms. Perry asked how many stationary reciprocating internal combustion engines Bates College owns and operates. Mr. Morrison said that there are eight licensed generators at Bates College. Ms. Morrison added that there are two generators, one located in the security building and one located in the Russel Building, that are exempt from licensing because that have a maximum capacity below 45 kW. Ms. Morrison showed the EPA representatives the most recent copy of the Bates College Air Emissions License and Renewal, filed January 18, 2024. Ms. Morrison provided the license number A-373-71-O-R/M. Alan Kelley, Bates College Mechanical Services Manager, entered the room and joined the opening conference. Ms. Perry asked what the purpose of each engine was. Mr. Morrison said that of the eight licensed engines, Generators #2, #4, and #5 participate in a demand response program, and that Generators #1, #3, #6, #7 and #8 are emergency use only. Mr. Fortescue asked the facility representatives if they could provide a description of the demand response program. Mr. 3 Morrison said that the demand response program they participate in is with Independent System Operator (ISO) New England. ISO New England gives the facility a 30-minute warning when there is an event that requires reducing power loads in an emergency setting. Mr. Morrison said that in such an event the generators in the demand response program provide power to the facility and do not provide electricity back to the grid. Mr. Morrison said that there have been fewer than five demand response events over the last two years. Mr. Morrison said that ISO New England runs two tests annually to ensure proper function of the program. Mr. Morrison said that the demand response program that the facility participates in also includes demand reduction, which requires the facility to reduce electricity usage during peak periods for a financial incentive. Mr. Morrison said the facility is typically notified the day before they are expected to reduce demand, and that this type of curtailment occurs frequently, especially during periods of hot weather. Mr. Fortescue asked if the facility has a contract with ISO New England, and if they have a broker. Mr. Morrison said that a company called C-Power is the broker between ISO New England and Bates College. The facility representatives provided the inspectors with copies of the contract with C-Power, "Maine Demand Management Program Addendum" and the Active Demand Capacity Reduction Program Standard Operating Procedure. Ms. Perry asked what type of fuel the demand response generators utilize. Mr. Morrison said Generators #2, #4, and #5 are the only engines owned and operated by Bates that are EPA certified, and that they run on diesel fuel. Mr. Fortescue asked if the diesel fuel that is used by Bates is ultra-low sulfur, and Mr. Morrison said yes. The facility representatives provided the inspectors with a copy of a recent fuel invoice that states the sulfur content of the fuel. Ms. Perry asked what the load of each generator was. Mr. Morrison and Ms. Morrison said they did not know because the load of each generator is tracked by the energy manager, and that they would provide the record to the EPA representatives following the inspection. Mrs. Morrison said that the Demand Response SOP says that the program expects to reduce the overall facility load by 500 kW. Mr. Morrison said that none of the generators have had emissions or stack testing, that none of the generators have had significant modification or reconstruction, and that the facility had not submitted any initial or annual compliance reports to EPA. Ms. Perry asked if the natural gas generators ever burn landfill gas. Mr. Morrison said that the natural gas generators do not burn landfill gas, and that the facility's natural gas is supplied by Unitil. Ms. Perry asked if the generators were equipped with non-resettable hour meters, and what the hours of operation were for each engine for the most recent calender year. Mr. Morrison said that each generator was equipped with a non-resettable hour meter, and the facility representatives provided the inspectors with a monthly compiled hour log for each generator. Ms. Morrison said that all of the hours recorded on the log are for the purpose of preventative maintenance service unless stated otherwise. 4 Ms. Perry asked how much fuel the facility burned in each engine over the previous calendar year. Ms. Morrison said that the facility annual reports track percent load, and do not track the quantity of fuel burned. Mr. Fortescue asked if the facility's emission calculation is based on worst case scenario, and Ms. Morrison said yes. Ms. Perry asked if any of the engines had Certificates of Conformity. Mr. Morrison said that Generators #4, #5, #7 and #8 had Certificates of Conformity. Generators #1, #2, and #3 were not required to have Certificates of Conformity based on their year of manufacture. Mr. Morrison said that Generators #6, #7 and #8 were certified by manufacturer for use with natural gas. Facility representatives provided the EPA inspectors with copies of the Generator #4 Certificate of Conformity for a Perkins Engines Co. Ltd. Engine with EPA Engine Family Number 7PKLXL06.6PJ1, and copies of the Generator #5 Certificate of Conformity with EPA Engine Family Number HCEXL0661.AAH issued on November 21, 2016. Ms. Perry asked if the facility follows the manufacture's requirements for their operations and maintenance plans. Mr. Morrison said that operations and maintenance is tracked by a facility preventative maintenance system. The generator contractor comes annually in May to perform maintenance and make replacements as needed to spark plugs, belts, coolants and oil filters. Mr. Morrison said that each generator has its oil filters are replaced annually. Mr. Morrison said that Generators #4, #5, #6, #7, and #8 were located outside, so the facility personnel needed to retrieve the keys to the generator doors before the facility walk through could commence. Facility Walk-Through At 11:07 am, Mr. Morrison, Ms. Lasselle, Mr. Pratt, Mr. Kelley, and Ms. Morrison led Ms. Perry, Mr. Fortescue and Mr. Smith on a tour of the facility. During the tour Mr. Fortescue took photographs of each generator, available nameplate, and available emissions label. All photo documentation is included in the inspection file. The group toured the facility to inspect the generators in the following order: Generator #4: Gillespie Hall Generator #8: Bonney Science Complex Generator #6: Carnegie Hall Generator #7: Kalperis Hall Generator #5: Dining Commons Generator #1: Cutten Generator #2: Mays Generator #3: Pettengill 5 Documented generator information can be found in Attachment 1. The EPA representatives did not inspect the two generators that are exempt from the Bates College Air Emissions License, located in the security building and the Russel building. Closing Conference The group returned to the original meeting place in Dana Hall at 1:02 p.m. Ms. Perry confirmed with facility representatives that post inspection they would provide the EPA representatives with copies of the generator operations and maintenance logs, and the Certificate of Conformity for Generator #6. Mr. Fortescue told the facility that EPA inspectors do not make compliance determination in the field, however the only potential area of concern identified was that they were unable to review the Certificate of Conformity for Generator #6. Mr. Fortescue said that due to the voluntary nature of certification by manufacturer of natural gas fired stationary Spark Ignition Internal Combustion Engine under Subpart 4J, it is an important document for EPA representatives to examine in order to make an appropriate compliance determination. Ms. Perry told the facility representatives that she would send them a draft of the inspection report within 70 days of the inspection, and the EPA representatives thanked everyone for their time. The EPA and Maine DEP representatives departed the facility at 1:10 p.m. Post Inspection Following the inspection, on August 6, 2024, Jim Morrison sent EPA representatives copies of the Preventative Maintenance Report for each generator via email. 6 Attachment A: Generator Information Generator No. #1 #2 #3 #4 #5 #6 Building Name Manufacturer Cutten Caterpillar Mays Cummins Pettengill Hall Kohler Gillespe Caterpillar Dining Commons Cummins Carnegie Hall Olympian/Caterpillar Model # 3306 6BTS.9-G2 Not available C6.6 QSM11-G4 NR3 G100F31 Serial # Manufacture Date Installation Date Capacity 2TM00161 1995 1995 335 bhp Hour Meter (hrs) 769 Fuel Type Diesel Purpose Emergency Use DemandResponse Emergency Y N Maintenance Oil filter replaced 5/2023 44778545 Not available E6M00551 8/11/1992 1993 166 hp Not available 1999 415 bhp 2007 Sept. 2007 217 bhp 414.9 Diesel Demand Response N 957.6 Diesel Emergency Y 594.9 Diesel Demand Response N Y Radiator, hoses, and ELC replaced 8/17 Belt replaced 8/12 N ELC and alt. belts replaced 3/09 Oil filters replaced 05/24 Y Fuel oil filters replaced 5/14/2024 Not available 6/19/2007 Feb. 2008 470 bhp no reading available Diesel Demand Response N Y OLY00000LNGD011521 3/20/2008 2012 163 bhp 260.2 Natural Gas Emergency Y N Oil filters replaced Fuel oil filters replaced 05/24 5/14/2024 EPA Engine Family Number N/A N/A N/A 6PXL06.6PJ1 7CEXL0661AAH not available Notes: 1. Model Number and Serial Number sourced from the Generator Set Label instead of from the engine emissions label. #7 Kalparus Hall Caterpillar G250LG41 GXJ039141 11/12/2015 2015 453 bhp 166.5 Natural Gas Emergency Y N G6NXB14.22C1 #8 Bonney Science Complex Cummins GTA38E 99800531 Feb. 2020 2020 850 hp 90.3 Natural Gas Emergency Y N LCEXB38.0AAA 7