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

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

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This webinar by James A Westbrook at BlueScape describes requirements of 40 CFR 63 Subpart DDDDD to boilers and process heaters located at industrial facilities, including major and area sources of ...

This webinar by James A Westbrook at BlueScape describes requirements of 40 CFR 63 Subpart DDDDD to boilers and process heaters located at industrial facilities, including major and area sources of hazardous air pollutants. Mr. Westbrook can be reached at 858-774-2009 for more information. Also see www.bluescapeinc.com.

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  • Hi everyone this is ….. …. I’m James Westbrook, the President of BlueScape Thank you very much for attending today. EPA has recently finalized national emission standards for hazardous air pollutants that applies to new and existing industrial, commercial and institutional boilers and process heaters located at major sources; and two area source categories: industrial boilers and commercial/institutional boilers.These rules cover potentially thousands of units in the US, and it’s important to understand how they will impact your operations.My goal today is to have you think about a process to determine rule applicability and introduce certain requirements you should be aware of.
  • Today I am going to talk about …. The purpose of this rule. who applies to this rule and how it applies. Discuss the new emission standards … and strategies. Startup, shutdown and malfunction requirements Notification, recordkeeping and reporting requirements I will also provide two case study examples, a refinery and a biomass plant, in order to go through the procedure and identify the standards I encourage you to use the webinar panel to send in questions, I’ll address questions as Ihave time, or I will follow-up with you after the webinar. There is far too much information in the rules to cover everyone’s specific situation in a short time, in addition to asking questions, please feel free to call me and I’ll be happy to review your specific situation.
  • - First some information about BlueScape Lots of experience Solve tough problems
  • Rule requires new and existing industrial, commercial and institutional boilers and process heaters at major and area sources to meet air toxics standards. Applies to units that burn coal, oil, biomass and non-waste solid materials, and in addition to gas for units located at major sources. Define boilers and process heatersEmission limits are established for new and existing boilers and process heaters located at major source facilities in 15 subcategories, which are based on unit design.Emission limits are established for new and existing boilers located at area sources in 4 subcategories, which are also based on unit design.
  • First, need to determine if your boiler or process heater is located at a major or area source. Major source facility emits or has the potential to emit 10 tpy or more of any single Hazardous Air Pollutant or 25 tpy or more of any combination of Hazardous Air Pollutants. An area source is a Hazardous Air Pollutant emitting stationary source that is not a major source. Further, how do I categorize multiple boilers at an area source facility? The affected area source is collection of all existing boilers within a subcategory located at area source facility or each new boiler located at area source facility. Next, how do I define my fuel subcategory?For boilers and process heaters located at major sources, follow the 10% rule. If your new or existing unit combusts at least 10% of solid fuel on an annual basis, the unit is subject to emission limits based on data from all of solid fuel-fired combustor designs. Same for biomass on an annual average heat input basis. If your new or existing unit combusts at least 10% liquid fuel and less than 10% solid fuel, the unit is subject to liquid fuel emission limits for fuel-based pollutants. Same for coal (at least 10% coal and less than 10% biomass) on an annual average heat input basis.For boilers located at area sources. If your boiler burns any solid fossil fuel and no more than 15% biomass on a total fuel annual heat input basis, your boiler is in the coal subcategory. If your boiler burns at least 15% biomass on total fuel annual heat input basis, your unit is in the biomass subcategory. If your boiler burns any liquid fuel and is not in the coal or biomass subcategory, your unit is in oil subcategory.LAUNCH THE FIRST POLL, how many of you have affected boilers and/or process heaters in your facility?
  • All units less than 10 MMBtu/hr and new and existing “limited use” boilers, which are units that operate less than 10% of the year as emergency and backup boilers to supplement process power needs, do not have numeric emission limits but are required to establish work practice standards and perform tune-ups for each unit every two years.Numeric emission limits are established for existing and new boilers and process heaters located at major sources, including those that burn coal and biomass.All existing boilers and process heaters are required to conduct an energy assessment, by a qualified personnel, to identify cost-effective energy conservation measures.
  • Area source does not include process heaters, only applicable to boilers. Boilers at area sources are further divided into new and existing boilers. We will first cover new boilers located at area sources.Air toxics standards for new boilers at area sources are divided into three subcategories based on unit design.The first pertains to coal boilers 10 MMBtu/hr or greater are required to meet mercury, PM and carbon monoxide emission limits.Biomass and oil-fired boilers 10 MMBtu/hr or greater are required to meet PM emission limitsBoilers less than 10 MMBtu/hr do not have numeric emission limits, but are required to perform tune-ups every 2 yearsGaseous boilers are not covered in the area source final rule.
  • When emission limits don’t apply?Work practice standards is an alternative to meeting emission limits and it requires the implementation of a tune-up program. For boilers and process heaters located at a major source, work practice standards are established for four cases: new and existing units less than 10 MMBtu/hr, new and existing units in Gas 1 subcategory (which are units that combusts only natural gas or refinery gas, units combusting gaseous fuels other than NG or refinery gas, in order to qualify for Gas 1 subcategory work practice standard, must meet contaminant levels specified for mercury and hydrogen sulfide (H2S)), and metal process furnaces subcategory. Boilers located at area source that are subject to work practice standards are new boilers less than 10 MMBtu/hr and existing biomass, oil-fired and small coal boilers. Note: Heat input means heat derived from combustion of fuel in boiler or process heater and doesn’t include heat derived from preheated combustion air, recirculation flue gases or exhaust gases from other sources (such as stationary turbines, internal combustion engines, and kilns)
  • Startup, shutdown, and malfunctions requirements apply to both boiler and process heaters at major sources and boilers at area sourcesFacilities must follow work practice standards for periods of startup and shutdown which include following manufacturer’s recommended procedures for minimizing periods of startup and shutdown. In the event of a malfunction, the owner or operator must correct and minimize emissions, and take preventative and corrective actions to prevent future malfunctions.
  • The final rule includes notification, recordkeeping and reporting requirements. Semiannual compliance reports are required only for semiannual reporting periods when deviation form any of the requirements, or any process changes occurred and compliance certifications were reevaluated The owner or operator is required to submit notification of compliance status report, which includes notification of compliance status report certifications of compliance with rule requirements. The owner or operator is also required to keep records to demonstrate compliance with each emission limit and work practice standard. Units are required to perform tune-ups, and keep records of dates and results of each tune-up. If continuously monitored parameter data are used for the control device, you must keep records of the device used or Continuous Emission Monitoring data. New and existing boilers and process heaters are required to perform initial compliance tests to demonstrate compliance with all applicable emission limits. The owner or operator is required to submit to EPA, an electronic copy of the reports. Electronic Reporting Tool (ERT) will be used and available on December 31, 2011, this will reduce data collection requests.
  • I will continue by presenting two case studies, the first is a refinery.What standards are applicable?Identify standards that to apply to unit. Because the unit is a Gas 1 subcategory, work practice standards that require annual tune-ups are enforced instead of numeric emission limits, and a one-time energy assessmentPeriods of startup, shutdown and malfunction do not have numeric emission limits, but work standards in place to follow. Follow manufacturer’s recommended procedures for minimizing periods of startup and shutdownYou must correct and minimize emissions during malfunction periods, including preventative and corrective actions to prevent any future malfunctionsAny deviations from requirements, must submit semiannual compliance reports, also required to submit records to demonstrate compliance with work practice standards. The owner or operator is required to keep records of dates and results of each annual tune-up.
  • The second case study involves the biomass boiler located at a power plant.What standards are applicable?New affected biomass major source emission limitsPeriods of startup, shutdown and malfunction do not have numeric emission limits, but work standards in place to follow. Follow manufacturer’s recommended procedures for minimizing periods of startup and shutdownYou must correct and minimize emissions during malfunction periods, including preventative and corrective actions to prevent any future malfunctionsContinuous compliance requirements, require PM CEMS be installed and operated and must monitor all other control devices.Must keep records of all continuous monitoring dataRequired to submit a notification of compliance status report in order to certify compliance with rule requirements.Semiannual compliance reports, required when deviation from the emission limits occurred, or process change or compliance certifications were reevaluated.
  • You need to decide soon if standards are applicable to your facility boiler or process heater unit. You need to determine if your boiler or process heater is located at a major or area source, because major source requirements are more stringent. Rule requires notification, recordkeeping and reporting I’ve presented two case studies, the gas boiler located at the refinery and the biomass boiler located at the power plant, in order to walk through the steps in order to identify applicability and apply the standardsThank you….
  • Take questions.Conclude webinar.

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

  • 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)