EPA Air Toxics Standards for Boilers and Process Heaters 03-15-11

EPA Air Toxics Standards for Boilers
and Process Heaters
James A. Westbrook
March 15, 2011

Agenda
Rule Introduction – Standards for Boilers and Process Heaters
NOT cover Incinerators
Applicability (and not applicable)
Major and Area Sources
Affected and Non-Affected, New & Existing Units
Large and small units, by unit and fuel type
Requirements – notification, limits, work practice requirements, testing, records and reporting
Case Studies – Refinery and Biomass Plant

About BlueScape
20 years experience, air quality compliance
Permits, air modeling, compliance for boilers and heaters, various fuels
National Experience
Solve tough air quality compliance issues:
- Determining rule applicability
- Assess how to reduce impacts, change status
- Develop monitoring, recordkeeping and reporting protocols
- Agency negotiations

Introduction to the Boiler Air Toxics Rules
40 CFR 63 Subpart DDDDD, NESHAP
Finalized February 21, 2011
Effective 60 days from publish in Federal Register
New and existing industrial, commercial and institutional boilers and process heaters
Regulate HCl, Hg, PM, dioxins/furans, and CO
Major Source Rule, 15 unit-based subcategories
Area Source Rule, 4 general subcategories
Parts will be reconsidered

Applicability
Major or area source?
Major Source = 10 tpy or more of any single HAP or 25 tpy or more of any combination of HAP
Only boilers at area sources, not process heaters
Affected source, New or Existing
Collection of boilers and heaters at a source within a subcategory
New or reconstructed, commence construction or reconstruction after June 4, 2010
Existing affected source, June 4, 2010
Fuel subcategory?
Major source, 10% rule to determine source category and emission limits
Area source, 15% rule to determine source category and emission limits

Not Applicable, Major Sources
Electric utility steam generating unit
Recovery boiler or furnace under Subpart MM
Boiler or heater for research and development
Hot water heater
Refining kettle under Subpart X
Ethylene cracking furnace
Blast furnace stoves
Boiler or process heater part of the affected source subject to another NESHAP
Boiler of process heater used as a control device
Temporary boilers
Blast furnace gas fuel-fired boilers and process heaters
Clean Air Act Section 129 and Solid Waste Disposal Act boilers

Major Source RequirementsLarge Boilers & Heaters (>= 10 MMBtu/hr)
7

Major Source RequirementsSmall Boilers & Heaters (< 10 MMBtu/hr)
8

Area Source RequirementsLarge Boilers & Heaters (>= 10 MMBtu/hr)
9

Area Source RequirementsSmall Boilers & Heaters (< 10 MMBtu/hr)
10

Tune-Up Program, Major Sources
Inspect burner, clean replace components
Inspect flame pattern, adjust
Inspect system controlling air-to-fuel ratio, calibrate
Optimize CO emissions per manufacturer
Measure CO before and after adjustments
Submit annual reports, CO ppm and fuel data

12
Emission Limits, Major Sources
Reference: USEPA

13
Emission Limits, Area Sources
Reference: USEPA

Emission Limit Comparisons
14
CO, ppm
PM, lb/MMBtu

Startup, Shutdown & Malfunctions
Applies to both boiler and process heaters at major sources and boilers at area sources
Work practice standards
Manufacturer’s recommended procedures
Minimize emissions and prevent future malfunctions

Notification, Recordkeeping & Reporting
Semiannual compliance reports
Notification of compliance status report
Records of compliance and tune-ups
Records of continuously monitored data
Electronic Reporting Tool (ERT) - Submission of test results

Compliance Schedule
Boilers and process heaters, major sources
- New, comply 60 days from rule date, or startup
- Existing, 3 years from rule date
Boilers located at an area source
- New, comply 60 days from rule date, or startup
- Existing, tune-up compliance no later than 1 year from rule date
- Existing, emission limits no later than 3 years after rule date

Case Study: Refinery
3 boilers and 10 process heaters, existing
Major Source of HAPs
Combust refinery gas, Gas 1 Subcategory
One affected facility, all 13 units
Analysis:
- Annual Tune-Up, 1-Time Energy Assessment (more extensive)
- Minimizing Periods of Startup and Shutdown
- Minimize and Correct Malfunctions
Recordkeeping and Reporting

Case Study: Biomass Power Plant
250 MMBtu/hr FBC boiler
Built 1984, lignite Coal / biomass / tires
Idled 10 years
New Source Review permit in 2011, biomass only
Major source of HCL
Analysis:
New affected major source, new subcategory
Emission limits for 5 compounds apply, energy assessment
Startup, shutdown, malfunction requirements
Notification, testing/monitoring, records & reports
Option to control HCL, become area source

Summary
Clean Gas boilers and heaters – mainly tune-up requirements, or not applicable
Extensive requirements for solid fuel process gas and oil boilers at major sources
Consider for new projects:
Emission controls to get area source status
Clean gas fuel to avoid emission limits
Time for existing boilers for compliance
Stay tuned to reconsideration details

Contact with Questions
James A. Westbrook, President
BlueScape, Inc.
858-774-2009 (cell)
jwestbrook@bluescapeinc.com
www.bluescapeinc.com
The Webinar presentation will be posted on
Slideshare and Scribd (search for BlueScape)

EPA Air Toxics Standards for Boilers and Process Heaters 03-15-11

by James Westbrook on Mar 15, 2011

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EPA Air Toxics Standards for Boilers and Process Heaters 03-15-11 — Presentation Transcript