Opacity of Visible Emissions Ontario Regulation 419/05 Section 34 (Amended)

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Opacity of Visible Emissions Ontario Regulation 419/05 Section 34 (Amended)

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Opacity of Visible Emissions Ontario Regulation 419/05 Section 34 (Amended)

  1. 1. Opacity of Visible Emissions Ontario Regulation 419/05 Section 34 (Amended) Tina Sanderson, B.Sc. Environmental Scientist and Hank Van Bakel, P.Eng. Manager, Compliance and Permitting Sarnia-Lambton Environmental Association May 13, 2008
  2. 2. Opacity is currently legislated through Ontario Regulation 419/05 Section 34. Note: O. Reg. 419/05 has been amended by O. Reg. 516/07 which includes changes to Section 34 effective April 1, 2008. MOE Technical Bulletin (Draft) released in November 2007.
  3. 3. Current Opacity Limits <ul><li>Section 34(1) states: </li></ul><ul><li>No person shall cause or permit an emission into the air that, during a period of six minutes , obstructs the passage of light at any point by an average of more than 20%. </li></ul><ul><li>Limit applies to “out-of-stack” discharges. </li></ul><ul><li>C of A opacity limits take precedence over Section 34 as long as they are more stringent than the 20% opacity limit. </li></ul>
  4. 4. Current Opacity Limits <ul><li>Section 34(2) states: </li></ul><ul><li>Subsection (1) does not apply to an emission from a source of combustion that uses fuel with high ash content , if, </li></ul><ul><li>(a) during the six minute period referred to in subsection (1), the passage of light was not obstructed by an average of 40% or more at any point; and </li></ul><ul><li>(b) the six minute period referred to in subsection (1) was part of a period of 30 consecutive minutes in which there were four periods of six consecutive minutes during which the person complied with subsection (1); and </li></ul><ul><li>(c) the four periods referred to in clause (b) did not overlap with each other and did not overlap with the six minute period referred to in subsection (1) </li></ul>
  5. 5. Current Opacity Limits <ul><li>What does Section 34(2) mean? </li></ul><ul><li>If you operate combustion equipment that burns high ash fuels (coal, oil, wood, black liquor) periodic soot blowing may be required which can increase opacity for short periods. </li></ul><ul><li>In these situations there is an exception to the 20% opacity limit. Your opacity can increase up to 40% for a period of no more than 6 consecutive minutes in any 30 minute period. </li></ul>
  6. 6. Exemption from the Opacity Limits <ul><li>20% opacity limit may not apply to a facility if; </li></ul><ul><li>- The facility is using equipment designed for the purpose of minimizing opacity. </li></ul><ul><li>- The equipment is required by a C of A. </li></ul><ul><li>- The Director is satisfied that the equipment effectively minimizes opacity. </li></ul>
  7. 7. Current Alternate Methods for Minimizing Opacity <ul><li>Fabric filters with a bag leak detection system. </li></ul><ul><li>Fabric filters with a bag leak detection system in combination with wet scrubbers with monitoring of pH, pressure drop and liquid flow rate. </li></ul><ul><li>ESPs with monitoring of voltage and secondary current in combination with wet scrubbers with monitoring of pH, pressure drop and liquid flow rate. </li></ul><ul><li>Other alternate methods must be approved via CofA, notice or some other formal approval. </li></ul>
  8. 8. Notifying the MOE of Exceedences <ul><li>A person who contravenes the opacity limit shall notify a provincial officer in writing as soon as practicable after the contravention occurs. </li></ul><ul><li>Unless; </li></ul><ul><li>A person contravenes the opacity limit more than once in a 24 hour period, the person may notify a provincial officer after the end of the 24 hour period of the number of contraventions. </li></ul><ul><li>Note: Confirm notification procedures with the Local District Office. </li></ul>
  9. 9. Start-Up, Shut-Down and Maintenance <ul><li>Opacity exceedences due to start-up, shut-down and maintenance do not have to be reported if the facility has a plan on-site to minimize conditions that lead to high opacity. </li></ul><ul><li>Note: Does not absolve the facility from meeting opacity limits. </li></ul>
  10. 10. Plan to Minimize Opacity <ul><li>What should be included in the Plan? </li></ul><ul><li>Sources that may exceed opacity </li></ul><ul><li>Opacity data if available </li></ul><ul><li>- Operation of each source (soot-blowing schedule) </li></ul><ul><li>- Maintenance schedule and records </li></ul><ul><li>Start-up and shut-down duration and records </li></ul><ul><li>How high opacity will be determined </li></ul><ul><li>How opacity will be minimized </li></ul>
  11. 11. Potential Sources of Opacity to Consider for a Plan <ul><li>Boilers and Heaters </li></ul><ul><li>Emergency Generators and Fire Pumps </li></ul><ul><li>Welding Operations </li></ul><ul><li>Cooling Towers </li></ul><ul><li>Flares </li></ul><ul><li>Burn Pits </li></ul><ul><li>Note: Section 34 does not specify or exempt any types of sources (e.g. fugitive, mobile) </li></ul>
  12. 12. Summary Opacity Requirements <ul><li>Note: All limits based on 6-minute block average </li></ul>Equipment detailed in CofA Opacity Plan None Other Requirements Exempt Exempt After exceedence or once every 24h Reporting Exceedences Exempt 40% (6 min every ½ h) 40% (6 min every ½ h) High Ash Fuel Opacity Limit Exempt 20% 20% Opacity Limit Sources with Alternate Methods Start-Up, Shut-Down and Maintenance Normal Operations
  13. 13. Questions? ORTECH Environmental 2395 Speakman Drive Mississauga, ON L5K 1B3 Tel: 905-822-4120 Fax: 905-855-0406 Web: www.ortech.ca

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