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EPA Air Toxics Standards for Boilers <br />and Process Heaters<br />James A. Westbrook<br />March 15, 2011<br />
Agenda<br />Rule Introduction – Standards for Boilers and Process Heaters<br />NOT cover Incinerators<br />Applicability (...
About BlueScape<br />20 years experience, air quality compliance <br />Permits, air modeling, compliance for boilers and h...
Introduction to the Boiler Air Toxics Rules   <br />40 CFR 63 Subpart DDDDD, NESHAP<br />Finalized February 21, 2011<br />...
Applicability<br />Major or area source?<br />Major Source = 10 tpy or more of any single HAP or 25 tpy or more of any com...
Not Applicable, Major Sources<br />Electric utility steam generating unit<br />Recovery boiler or furnace under Subpart MM...
Major Source RequirementsLarge Boilers & Heaters  (>= 10 MMBtu/hr)<br />7<br />
Major Source RequirementsSmall Boilers & Heaters  (< 10 MMBtu/hr)<br />8<br />
Area Source RequirementsLarge Boilers & Heaters  (>= 10 MMBtu/hr)<br />9<br />
Area Source RequirementsSmall Boilers & Heaters  (< 10 MMBtu/hr)<br />10<br />
Tune-Up Program, Major Sources<br />Inspect burner, clean replace components<br />Inspect flame pattern, adjust<br />Inspe...
12<br />Emission Limits, Major Sources<br />Reference: USEPA<br />
13<br />Emission Limits, Area Sources<br />Reference: USEPA<br />
Emission Limit Comparisons<br />14<br />CO, ppm<br />PM, lb/MMBtu<br />
Startup, Shutdown & Malfunctions<br />Applies to both boiler and process heaters at major sources and boilers at area sour...
Notification, Recordkeeping & Reporting<br />Semiannual compliance reports<br />Notification of compliance status report<b...
Compliance Schedule<br />Boilers and process heaters, major sources<br />	- New, comply 60 days from rule date, or startup...
Case Study: Refinery<br /><ul><li>3 boilers and 10 process heaters, existing
Major Source of HAPs
Combust refinery gas, Gas 1 Subcategory
One affected facility, all 13 units
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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 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 …..&lt;read the webinar title&gt; …. 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.
  • Transcript of "BlueScape EPA Air Toxics Standards for Boilers and Process Heaters 03-15-11"

    1. 1. EPA Air Toxics Standards for Boilers <br />and Process Heaters<br />James A. Westbrook<br />March 15, 2011<br />
    2. 2. Agenda<br />Rule Introduction – Standards for Boilers and Process Heaters<br />NOT cover Incinerators<br />Applicability (and not applicable)<br />Major and Area Sources<br />Affected and Non-Affected, New & Existing Units<br />Large and small units, by unit and fuel type<br />Requirements – notification, limits, work practice requirements, testing, records and reporting<br />Case Studies – Refinery and Biomass Plant<br />
    3. 3. About BlueScape<br />20 years experience, air quality compliance <br />Permits, air modeling, compliance for boilers and heaters, various fuels<br />National Experience<br />Solve tough air quality compliance issues:<br />- Determining rule applicability<br />- Assess how to reduce impacts, change status<br />- Develop monitoring, recordkeeping and reporting protocols<br />- Agency negotiations <br />
    4. 4. Introduction to the Boiler Air Toxics Rules <br />40 CFR 63 Subpart DDDDD, NESHAP<br />Finalized February 21, 2011<br />Effective 60 days from publish in Federal Register<br />New and existing industrial, commercial and institutional boilers and process heaters<br />Regulate HCl, Hg, PM, dioxins/furans, and CO<br />Major Source Rule, 15 unit-based subcategories<br />Area Source Rule, 4 general subcategories<br />Parts will be reconsidered<br />
    5. 5. Applicability<br />Major or area source?<br />Major Source = 10 tpy or more of any single HAP or 25 tpy or more of any combination of HAP<br />Only boilers at area sources, not process heaters<br />Affected source, New or Existing<br />Collection of boilers and heaters at a source within a subcategory<br />New or reconstructed, commence construction or reconstruction after June 4, 2010<br />Existing affected source, June 4, 2010<br />Fuel subcategory?<br />Major source, 10% rule to determine source category and emission limits<br />Area source, 15% rule to determine source category and emission limits<br />
    6. 6. Not Applicable, Major Sources<br />Electric utility steam generating unit<br />Recovery boiler or furnace under Subpart MM<br />Boiler or heater for research and development<br />Hot water heater<br />Refining kettle under Subpart X<br />Ethylene cracking furnace<br />Blast furnace stoves<br />Boiler or process heater part of the affected source subject to another NESHAP<br />Boiler of process heater used as a control device<br />Temporary boilers<br />Blast furnace gas fuel-fired boilers and process heaters<br />Clean Air Act Section 129 and Solid Waste Disposal Act boilers<br />
    7. 7. Major Source RequirementsLarge Boilers & Heaters (>= 10 MMBtu/hr)<br />7<br />
    8. 8. Major Source RequirementsSmall Boilers & Heaters (< 10 MMBtu/hr)<br />8<br />
    9. 9. Area Source RequirementsLarge Boilers & Heaters (>= 10 MMBtu/hr)<br />9<br />
    10. 10. Area Source RequirementsSmall Boilers & Heaters (< 10 MMBtu/hr)<br />10<br />
    11. 11. Tune-Up Program, Major Sources<br />Inspect burner, clean replace components<br />Inspect flame pattern, adjust<br />Inspect system controlling air-to-fuel ratio, calibrate<br />Optimize CO emissions per manufacturer<br />Measure CO before and after adjustments<br />Submit annual reports, CO ppm and fuel data<br />
    12. 12. 12<br />Emission Limits, Major Sources<br />Reference: USEPA<br />
    13. 13. 13<br />Emission Limits, Area Sources<br />Reference: USEPA<br />
    14. 14. Emission Limit Comparisons<br />14<br />CO, ppm<br />PM, lb/MMBtu<br />
    15. 15. Startup, Shutdown & Malfunctions<br />Applies to both boiler and process heaters at major sources and boilers at area sources<br />Work practice standards<br />Manufacturer’s recommended procedures<br />Minimize emissions and prevent future malfunctions<br />
    16. 16. Notification, Recordkeeping & Reporting<br />Semiannual compliance reports<br />Notification of compliance status report<br />Records of compliance and tune-ups<br />Records of continuously monitored data<br />Electronic Reporting Tool (ERT) - Submission of test results <br />
    17. 17. Compliance Schedule<br />Boilers and process heaters, major sources<br /> - New, comply 60 days from rule date, or startup<br /> - Existing, 3 years from rule date <br />Boilers located at an area source<br /> - New, comply 60 days from rule date, or startup<br /> - Existing, tune-up compliance no later than 1 year from rule date<br /> - Existing, emission limits no later than 3 years after rule date<br />
    18. 18. Case Study: Refinery<br /><ul><li>3 boilers and 10 process heaters, existing
    19. 19. Major Source of HAPs
    20. 20. Combust refinery gas, Gas 1 Subcategory
    21. 21. One affected facility, all 13 units
    22. 22. Analysis:</li></ul>- Annual Tune-Up, 1-Time Energy Assessment (more extensive)<br />- Minimizing Periods of Startup and Shutdown<br />- Minimize and Correct Malfunctions<br /><ul><li>Recordkeeping and Reporting</li></li></ul><li>Case Study: Biomass Power Plant<br /><ul><li>250 MMBtu/hr FBC boiler
    23. 23. Built 1984, lignite Coal / biomass / tires
    24. 24. Idled 10 years
    25. 25. New Source Review permit in 2011, biomass only
    26. 26. Major source of HCL
    27. 27. Analysis:
    28. 28. New affected major source, new subcategory
    29. 29. Emission limits for 5 compounds apply, energy assessment
    30. 30. Startup, shutdown, malfunction requirements
    31. 31. Notification, testing/monitoring, records & reports
    32. 32. Option to control HCL, become area source</li></li></ul><li>Summary<br />Clean Gas boilers and heaters – mainly tune-up requirements, or not applicable<br />Extensive requirements for solid fuel process gas and oil boilers at major sources<br />Consider for new projects:<br />Emission controls to get area source status<br />Clean gas fuel to avoid emission limits<br />Time for existing boilers for compliance<br />Stay tuned to reconsideration details<br />
    33. 33. Contact with Questions<br />James A. Westbrook, President<br />BlueScape, Inc.<br />858-774-2009 (cell)<br />jwestbrook@bluescapeinc.com<br />www.bluescapeinc.com<br />The Webinar presentation will be posted on <br />Slideshare and Scribd (search for BlueScape)<br />
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